Privacy policy

Operator: CLAYTON DIVIDE VALLEY CORPORATION

Address in Japan: 愛知県清須市土器野315 (c/o U-Right)

Head office: 1487 W 178th St Suite 310, Gardena, CA 90248, U.S.A.

Contact: info@esim.co.jp

We collect the following information in order to provide this service.

(1) What you enter at checkout: name, email address, phone number

(2) Order details: plan, amount, order number, date and time

(3) Payment: payment method type and the identifier issued by our payment provider (we do not hold card numbers)

(4) Information needed to issue the eSIM, such as device identifiers (EID) where you provide them

(5) Access logs and interaction records: IP address, browser, pages viewed, cookies and similar identifiers, and a record of what you do on screen (clicks, scrolling and similar)

(6) If you link your LINE account: the user identifier (userId) issued by LINE. We do not obtain your LINE name, profile picture or email address from LINE. If you unfriend the account, we stop sending to that identifier.

(1) Issuing eSIMs, sending QR codes (by email, SMS, and LINE where you have linked your account), checking activation

(2) Confirming orders and issuing receipts

(3) Answering enquiries and contacting you about faults

(4) Refunds and other after-sales service

(5) Preventing misuse

(6) Improving the service and analysing usage

(7) Complying with law

We obtain your consent before using your data beyond these purposes.

[AI auto-reply in LINE chat]

Enquiries sent in LINE chat, including any images you send, may be answered by an AI auto-reply. This uses the generative AI service of Google LLC (the paid tier of the Gemini API), under contractual terms in which the content sent is not used to train their models. We do not store the text of your enquiry in our database. AI replies are marked as such. When the AI cannot answer, a ‘Talk to a person’ button appears below the reply and puts you through to our team.

We do not share personal data without your consent except:

(1) with carriers and suppliers, to the extent needed to issue your eSIM;

(2) with our payment provider, to process payment;

(3) where required by law or to protect life, body or property;

(4) with Google LLC, to measure advertising (see section 7[2]; your name and email address are hashed on your device or on our servers before being sent. We do not send your mobile phone number).

(5) No mobile information — including mobile phone numbers and SMS opt-in or consent data — will be shared with any third parties or affiliates for marketing or promotional purposes. This information is handled only by the subcontractors we engage to deliver the messages you asked for (our SMS delivery provider), solely to the extent needed for that delivery, and never for their own purposes.

Our eSIMs are provided by overseas carriers, so issuing an eSIM involves transferring the information needed for your order to third parties outside Japan.

Principal destinations: the People's Republic of China (including Hong Kong SAR) and the country of the carrier serving your destination.

What is transferred: order number, product code, plan duration, and the device identifier needed to issue the eSIM (where you have entered one).

We do not transfer your name, email address, phone number or payment details to these carriers and suppliers. We do not collect passport details. Where real-name registration is required by law, you register directly with the carrier yourself.

Separately, to measure advertising, we transfer your name and email address to Google LLC in the United States as hashed strings — hashed either on your device or on our own servers (see section 7[2]). We do not transfer your mobile phone number, not even in hashed form.

Data protection regimes in those countries differ from Japan's. Under Article 28(2) of the Act, we tell you the destination country, its regime and the measures the recipient takes, and obtain your consent at checkout.

See "Transfers of personal data outside Japan" for details.

We may engage processors as needed (hosting, email and SMS delivery, payment processing).

We require security measures by contract and supervise them appropriately.

When you use this service, information stored on your device (cookies and similar identifiers) is sent to the following third parties. How to stop each one is given below.

[1] Google Analytics 4 — recipient: Google LLC (United States)

What is sent: the identifiers stored in cookies (_ga and those beginning with _ga_), your IP address, the URL of the page viewed, the referring page, and your browser and device type

Purpose: understanding and improving how the service is used, and measuring advertising

How to stop: install Google's Analytics opt-out add-on (https://tools.google.com/dlpage/gaoptout).

Google privacy policy: https://policies.google.com/privacy

[2] Google Ads — recipient: Google LLC (United States)

What is sent: the identifiers collected under [1] above, together with records of pages viewed and purchases (sent through the link with Google Analytics)

We also send the name and email address you enter at checkout, hashed (SHA-256) on your own device, for Google's enhanced conversions feature. In addition, so that ad clicks can be matched to orders afterwards (offline conversion import), we send your email address hashed (SHA-256) on our own servers, together with the order number, amount and order time. We do not send your mobile phone number, not even in hashed form. The values themselves are never sent. The hashed strings are used only to measure advertising results, and Google does not share them with other advertisers.

Purpose: measuring advertising and serving ads based on interests

How to stop: turn off personalised ads in Google Ad Settings (https://myadcenter.google.com/). If you would like us to stop sending the hashed information, email info@esim.co.jp and we will stop from then on.

[3] Stripe — recipient: Stripe, Inc. (United States)

What is sent: the identifiers stored in cookies (__stripe_mid and others), your IP address, and information about how you use the payment screen

Purpose: processing card payments and detecting fraud

How to stop: this cannot be stopped separately, as it is required to take payment.

Stripe privacy policy: https://stripe.com/privacy

[4] LINE — recipient: LY Corporation (Japan)

What is sent: only where you have linked your LINE account, the user identifier (userId) issued by LINE

Purpose: sending QR codes, notifying you about activation, and answering enquiries

How to stop: unfriend our LINE account. We then stop sending to that identifier.

[5] TrustedSite - recipient: TrustedSite (United States)

What is sent: the identifiers stored in cookies, your IP address, the URL of the page viewed, and your browser and device type

Purpose: displaying the site security trustmark, and counting how often it is shown

How to stop: block this provider's cookies in your browser. The mark simply stops appearing; ordering and payment are unaffected.

TrustedSite privacy policy: https://www.trustedsite.com/privacy

[6] Microsoft Clarity - recipient: Microsoft Corporation (United States)

What is sent: the identifiers stored in cookies, your IP address, the URL of the page viewed, your browser and device type, and a recording of what you do on screen (clicks, scrolling, pointer and touch movement) together with what the page displays

Purpose: finding where visitors get stuck or find the site hard to use, so that we can improve it

Text you type into form fields - your name, email address, phone number and card details - is configured not to be recorded.

We do not record our own administration or support screens.

How to stop: block this provider's cookies in your browser. Recording simply stops; ordering and payment are unaffected. You may also email info@esim.co.jp and we will stop recording from then on.

Microsoft privacy statement: https://privacy.microsoft.com/privacystatement

We also use cookies of our own that the service needs in order to work, such as remembering your language. Those are not sent to any third party.

You may disable cookies in your browser, but some features may then stop working.

Order records are kept for the period required by law (generally seven years for accounting records).

We delete personal data without delay once it is no longer needed.

We limit access rights, encrypt communications, keep access logs and take other measures to prevent loss or leakage.

Staff receive training on handling personal data.

[Handling of personal data outside Japan]

We are a corporation headquartered in the United States. Personal data collected by our Japanese office is also handled by our head office in the United States. This is handling by us, within one legal entity — not a transfer to a third party.

The United States has no comprehensive federal data protection law; protection is provided by state laws and sector-specific statutes. There are also regimes permitting government access to information.

Having assessed that external environment, we apply access controls, encryption in transit and access logging.

You or your representative may ask us to notify the purpose of use, or to disclose, correct, add to, delete, suspend the use of, erase, or stop sharing your personal data.

Write to info@esim.co.jp. We may ask for identification.

We do not charge a fee for disclosure requests.

If you are under 18, please use the service with the consent of a parent or guardian.

CLAYTON DIVIDE VALLEY CORPORATION — personal data enquiries

Email: info@esim.co.jp

Phone: 050-1730-9585 (9:00–16:00 JST, every day)

We may revise this policy to reflect changes in law or in the service.

We will announce material changes on the site.

Adopted 25 August 2026

Revised 1 September 2026 (added LINE identifier)

Revised 3 September 2026 (AI auto-reply in LINE chat)

Revised 17 September 2026 (fuller disclosure of cookies sent to third parties)

Revised 1 October 2026 (added TrustedSite as a recipient)

Revised 2 October 2026 (added Google Ads enhanced conversions)

Revised 7 October 2026 (added Microsoft Clarity as a recipient; session recording)

Revised 9 October 2026 (stated that SMS opt-in data is not shared with third parties; stopped sending mobile phone numbers for advertising measurement)

Revised 15 October 2026 (stated that an email address hashed on our servers is sent for offline conversion import)