Transfers of personal data outside Japan

This notice is provided in advance under Article 28(2) of Japan's Act on the Protection of Personal Information, before we transfer your personal data to third parties outside Japan.

You consent to this transfer when you place an order. Without your consent we cannot issue an eSIM and therefore cannot accept the order.

We are not a carrier. We sell capacity prepared by overseas operators.

Issuing a single eSIM requires us to send an issuance request to that operator, which cannot be fulfilled without the information relating to your order.

The People's Republic of China (including the Hong Kong SAR).

The country of the carrier serving your destination (listed under "Coverage" on each product page).

Our supplier, an eSIM platform operator, and the carrier at your destination.

Your information passes from our office in Japan, via our head office in the United States, to the recipients above.

We are a United States corporation with an office in Japan, so the movement between Japan and the United States is handling within one legal entity. It is not a transfer to a third party, and no consent is required for that step.

For how data is handled in the United States, see section 9 of our privacy policy.

The consent we ask for under Article 28 covers the onward transfer to the People's Republic of China (including the Hong Kong SAR) and to the carrier at your destination.

· Order number, product code, number of days

· Device identifiers needed to issue the eSIM, where you provide them

We do not transfer your name, email address, phone number or payment information.

Nor do we transfer passport details. Where local law requires real-name registration (Taiwan and similar), you register directly with the carrier at https://kyc.esim.exchange. We never hold your passport details.

China has a Personal Information Protection Law, in force since 1 November 2021, covering both the private and public sectors.

However, no independent supervisory authority equivalent to Japan's Personal Information Protection Commission has been identified.

Under the Cybersecurity Law, the Data Security Law and the National Intelligence Law, state security organs may require businesses to provide information and cooperation, and the limits and transparency of such access are not clearly defined.

This summary is based on the survey of that country's regime published by Japan's Personal Information Protection Commission. Please refer to its website for the latest information.

We require recipients not to use the transferred information for any purpose other than issuing the eSIM and providing the line, not to pass it on to further parties, and to take the security measures necessary to protect it.

To withdraw your consent, contact info@esim.co.jp. Information already sent for an eSIM that has been issued cannot be recalled.

After withdrawal we are unable to accept further orders from you.

Questions about this notice, and requests for further information about the destination country's regime:

CLAYTON DIVIDE VALLEY CORPORATION — personal data enquiries

Email: info@esim.co.jp Phone: +81-50-1730-9585 (9:00–16:00 JST)

25 August 2026