Privacy Policy

This Privacy Policy describes policies and practices of China Mobile International Limited (“CMI”) in the collection, use, disclosure and transmission of your personal information in relation to the products and services available on our website/mobile applications.

CMI  (“we”, “us” or “our”) strive to comply with applicable data protection and privacy legislation and regulations (“Applicable Laws”), that may include, without limitation, the Personal Data (Privacy) Ordinance (Cap.486) of the Laws of Hong Kong Special Administrative Region (the “PDPO”), the Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”) , the Personal Information Protection Law of the People's Republic of China (PIPL) and the Personal Data Protection Act of the laws of Singapore (“PDPA”).

When we post changes to this Privacy Policy, we will update the "last revised" date at the bottom of the Privacy Policy. This website/mobile application is operated by CMI. To the maximum extent permitted by Applicable Laws, and subject to your valid consent where required by Applicable Laws, your continued use of this website/mobile application and/or goods and services after notice shall constitute your acceptance of this Privacy Policy. We may occasionally update this Privacy Policy to reflect changes in our software, mobile applications and/or products and customer feedback, or changes of Applicable Laws. When we post changes to this Privacy Policy, we will update the "last revised" date at the bottom of the Privacy Policy. Please read this Privacy Policy through and come back regularly. We encourage you to periodically review this Privacy Policy to be informed of how CMI is collecting, using, and protecting your information.

This Privacy Policy may be translated into other languages for reference purpose. If there is any inconsistency or conflict between the English version and other versions of this Privacy Policy, the English version shall always prevail.

Personal information we collect

1. In order to provide products or services, we may collect information about you from time to time, including  information in the following categories:

(a) For registration or login: [mobile number, email address, nickname, third-party login accounts, preferred currency, preferred usage scenarios, preferred destinations, IP address, cookies]
(b) For product purchase and payment: [mobile number, email address, nickname, third-party login accounts, bank card number, expiration date, cardholder name, card verification code (CVC)]
(c) For product usage: [order information, purchased product information]
(d) For message notifications: [mobile device type (Android, iOS), device identification code from push notification platforms]
(e) For customer service: [mobile number, email address, nickname, third-party login accounts, order information, purchased product information]

For a detailed list of the personal information we collect, you may refer to the "Detailed List of Personal Information Collected".

You are not obliged to supply to us your personal data, however, we may be unable to provide you with the required goods and services if we do not have certain types of personal data from you.
In addition, your online session data may also be collected indirectly on an aggregated and anonymous basis.

Use of your personal information

2. Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience. Subject to your valid consent, we collect and use, or have third party service providers acting on behalf of us collecting and using, personal data relating to you, as permitted or necessary to:

• provide you with phone, internet communication, and/or other products ;
• take, process or deliver orders made via our websites, invoice you or notify you of the status of your order;
• provide other services for you (as described when we collect the information);
• administer, operate and manage loyalty programs;
• communicate with you by email, phone, mail or other means;
• process payment instructions, billing and refund;
• provide you with customer support and troubleshoot problems;
• compare information for accuracy;
• inform you about service updates and faults;
• request feedback or participation in on-line surveys;
• handle enquiries, complaints and feedbacks;
• resolve disputes;
• verify your identity;
• conduct internal research;
• design and improve CMI’s products, software, mobile applications and websites;
• plan and carry out CMI’s marketing or promotional operations/offers and similar events;
• offer certain free of charge CMI’s software, mobile applications, features and websites, through the support of advertising;
• process debt recovery and credit checking;
• obtain legal advice and establish legal claims or defences and in legal proceedings;
• protect your, CMI’s interests, including in particular to enforce our Terms and Conditions and prevent and fight against fraud, (together, the Purposes).

Disclosure and transfer of your personal information

3.  Except as provided below, we will not sell, rent, trade or otherwise transfer any personal and/or traffic data or communications without your explicit permission, unless it is obliged to do so under applicable laws or by order of the competent authorities.
In order to facilitate the purposes set out in paragraph 2, we may disclose personal information to:

• Our partners (including affiliated companies, suppliers, partners, and other third parties) are authorized to work with us in providing certain services to you. For detailed information about how your personal information is shared with third parties, you may refer to the "Third-Party Information Sharing List" and the "Detailed List of Personal Information Collected".
• respond to legal requirements, exercise our legal rights or defend against legal claims;
• protect CMI's interests, fight against fraud and to enforce our policies or to protect anyone's rights, property, or safety.

CMI, CMI's partner,  or the operator or company facilitating your communication may provide personal data, communications content and/or traffic data to an appropriate judicial, law enforcement or government authority or other organizations lawfully requesting such information. CMI will provide reasonable assistance and information to fulfill this request and you hereby consent to such disclosure.
Subject to your valid consent, CMI may give your information to other company located outside Hong Kong, which may be a supplier or CMI’s affiliate company, for the provision of CMI's and/or CMI's affiliate company’s services.

This website/mobile application may contain links that could cause you to leave this website/mobile application and/or be redirected to other third-party websites. Please note that any personal information you provide to these third-party websites is not governed by the ​​CMLink eSIM Privacy Policy​​. Therefore, CMI shall not be held liable for any losses, damages, costs, or expenses you may incur as a result of providing or making your personal information or other data accessible to such third-party websites.

Security and retention of your personal information

4.  We keep your personal information while you are our customer or after you have stopped to use the service, but only when necessary or as required by Applicable Laws. We will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. Your personal and traffic data can only be accessed by authorized employees or third parties, and will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the personal and traffic data is also retained to satisfy any Applicable Laws or contractual obligations. We will only retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and within the time limits stipulated by applicable laws, regulations, and supervisory requirements. After the expiration of the storage period, we will delete or anonymize the collected information.

5.    To allow the provision of goods and services to you, we require your approval of the transfer of your certain personal data to us:

Direct marketing

6.    Subject to your valid consent and in strict accordance with the Applicable Laws, CMI intends to use your personal data to deliver to you information about any goods and services, loyalty programs, activities (including joint collaboration with third parties), newsletters, contests, lucky draws and etc of us and our business partners. The said information may include various classes of marketing subjects including but not limited to mobile devices and accessories, network services such as TV, mobile voice, SMS and data communications, IDD/roaming, Internet connectivity, mobile applications, entertainment and data communications on Internet, other value-added services, as well as computer peripheral, accessories and software (including notebooks, handsets, keyboards, security installations and mobile applications), secretarial services, personal assistance services and information services, gaming, sports, music, beauty products, electronics, technology, ecommerce, mobile payment, travelling, banking, investment, entertainment, transportation, household, fashion, food and beverages, insurance, education, health and wellness, social networking, charity activities, media and high-end consumer products and services. The said information may be delivered to you by mail, phone, email, fax or other means.

CMI may not use your personal data for direct marketing unless CMI received your valid consent in accordance with Applicable Laws. If you wish to stop receiving direct marketing materials from us, you may write to us any time. In any such request, please state clearly your personal information and contact details for identification purposes.

Use of cookies and location data

7.    If you visit any of our websites, CMI may use cookie files to store and track information about you and your preferences. A cookie is a small text file that our website transfers to your device. It allows us to better serve you and/or maintain your information across multiple pages within or across one or more sessions. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. Cookies contain information about you and your preferences. For example, if you inquire about rates and availability, the site might create a cookie that contains the details you entered. Or it might only contain a record of which pages within the site you visited to help the site customize the view for you the next time you visit. Only the information that you provide or the choices you make while visiting a website can be stored in a cookie. For example, the site cannot determine your email address unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your device, and only the site that created the cookie can read it.

CMI may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information CMI receives from third parties to provide you with better service and, where you have consented to receive direct marketing, CMI may provide you with targeted advertisements, content, features, deals and offers.

Data access or correction

8.  You have the right to access and, where relevant, to correct your personal information held by us. CMI will respond to requests to access, correct or remove your personal information within a reasonable period of time and upon verification of your identity.

• You can access and update your personal information, such as your mobile number, email address, nickname, preferred currency, preferred usage scenarios, and preferred destinations, by visiting  "Personal Profile - Profile" .
•  You can submit a request to delete your personal information by visiting  "Personal Profile - Profile - Delete Account" . After submission, your personal information will be deleted within  7 business days .

We will use all reasonable endeavours to accommodate requests to delete personal information unless it is required to be retained by law or for lawful business purposes. If the statutory retention period required by laws and administrative regulations has not yet expired, or if the deletion of personal information is technically infeasible, we will cease processing your personal information beyond storage and necessary security protection measures. If we decide to comply with your deletion request, we will also notify the entities that have obtained your personal information from us, requiring them to delete it in a timely manner, unless otherwise stipulated by laws and regulations or unless these entities have obtained your separate authorization.

In accordance with the Applicable Laws, we reserve the right to charge a reasonable fee for the processing of any data access request.

Access by phone

9.    When you use goods and services on your phone, CMI may use notification services available for that phone to let you know of any information when you are not actively running or using the CMI application. These services may be provided by a third party. For example, messages sent to an Apple device will use Apple’s Push Notification Services.

Notification services may receive information about the caller, sender of the message and the content of the message as part of providing the service and may use the information in accordance with the terms and conditions and privacy policy for the service provider. CMI is not responsible for the data collected by third party notification services.

(Apple is a trademark of Apple Inc., registered in U.S. and other countries.)

Age, Parental and Guardian Consent.

10.    If you are under the age of 13, you are required to ask your parent(s) or guardian(s) before providing any personal data to us. 

If you are below 13 years old or under guardianship, you must obtain approval from your parent(s) or legal guardian(s); and your parent(s) or legal guardian(s) are responsible for:

• all your actions in connection with your access to and use of the website/mobile applications;
• your compliance with this policy;
• and ensuring that any of your participation in the website/mobile applications will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the website/mobile applications.

For the personal data collected with the consent of parent(s) or guardian(s), we will only use, share or disclose it when permitted by laws, explicitly consented by the parent(s) or guardian(s) or required for protecting the child. If we discover collecting personal data of a minor who is under the age of 13 without the prior consent of parent(s) or legal guardian(s), we will delete it as soon as possible.

Contact us

11.    Should you have any question about the Privacy Policy above, please write to our Data Protection Team at the following address: Level 30, Tower 1, Kowloon Commerce Centre, No. 51 Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong.  Email: esim_support@cmlink.com

© China Mobile International Limited – Last revised: 3rd October 2025