Privacy Policy

Last Updated: July 18, 2026

1. Introduction

This Privacy Policy explains how APPCODIX LTD, a company registered in Cyprus, located at Spyrou Kyprianou & Agias Fylaxeos, 182, KOFTEROS BUSINESS CENTRE, 2nd floor, Flat/Office 201, 3083 Limassol, Cyprus (“AppCodix”, “Company”, “we”, “us”, “our”), collects, uses, and protects your personal data when you use our mobile applications, including eSIM, Hilibre, and Homind (each an “App”, collectively the “Apps”), and our website.

We are committed to protecting your privacy and processing your personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Cyprus data-protection law.

2. Data Controller

The data controller responsible for your personal data is APPCODIX LTD, at the address above. For any privacy-related request, contact us at services@appcodix.com.

3. Information We Collect

3.1 Information you provide

  • Content you upload — for example, photos of rooms or spaces you submit to Homind for AI processing.
  • Account and contact details — such as email address or name, where an App requires an account or you contact support.
  • Purchase information — records of subscriptions and purchases. Payment card details are handled by the app stores and payment processors, not stored by us.

3.2 Information collected automatically

  • Device and technical data — device type, operating system, app version, language, and a device or advertising identifier.
  • Usage and diagnostic data — features used, interactions, crash reports, and performance data.
  • Approximate location — derived from your IP address or, for connectivity Apps, the region of the data plan you select. We do not collect precise GPS location unless you explicitly grant permission.

Some Apps use anonymous, device-based accounts and collect no name or email. The data we process depends on the specific App you use.

4. How We Use Your Information

  • To provide, operate, and maintain the Apps and their features;
  • To process your uploaded content and generate AI results (Homind);
  • To provision and manage eSIM data plans and connectivity;
  • To process purchases, subscriptions, and refunds;
  • To provide customer support and respond to your requests;
  • To analyze usage, fix bugs, and improve the quality and performance of the Apps;
  • To detect, prevent, and address fraud, abuse, and security issues;
  • To comply with legal obligations.

5. Legal Bases for Processing

Under the GDPR, we rely on the following legal bases:

  • Performance of a contract — to deliver the Apps and features you request;
  • Consent — for optional processing such as certain analytics or precise location; you may withdraw consent at any time;
  • Legitimate interests — to secure, maintain, and improve the Apps, where not overridden by your rights;
  • Legal obligation — to comply with applicable law.

6. AI Processing and Sub-processors

For AI-powered Apps such as Homind, content you upload is processed by third-party AI providers to generate results. We share only the content necessary to perform the requested processing and require our providers to protect your data. We do not sell your personal data or use your uploaded photos to identify you.

7. How We Share Information

We do not sell your personal data. We share it only with:

  • Service providers — cloud hosting, AI providers, analytics, and customer-support tools acting on our instructions;
  • Connectivity partners — mobile network operators required to provision eSIM plans;
  • App stores and payment processors — to complete purchases and subscriptions;
  • Legal and safety recipients — where required by law, or to protect our rights, users, or the public;
  • Business transfers — in connection with a merger, acquisition, or sale of assets.

8. Data Retention

We retain personal data only for as long as necessary to provide the Apps, comply with legal obligations, resolve disputes, and enforce our agreements. Uploaded content is retained for the period needed to deliver and improve the service and is then deleted or anonymized. You may request deletion of your data as described below.

9. Data Security

We implement appropriate technical and organizational measures — including encryption in transit and access controls — to protect your personal data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. International Transfers

Your data may be processed outside the European Economic Area by our service providers. Where this occurs, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, to ensure your data receives an adequate level of protection.

11. Your Rights

Subject to applicable law, you have the right to:

  • Access the personal data we hold about you;
  • Request correction of inaccurate data;
  • Request deletion of your data (“right to be forgotten”);
  • Restrict or object to certain processing;
  • Request portability of your data;
  • Withdraw consent at any time, without affecting prior processing;
  • Lodge a complaint with your local supervisory authority — in Cyprus, the Office of the Commissioner for Personal Data Protection.

To exercise any of these rights, contact us at services@appcodix.com.

12. Children’s Privacy

The Apps are intended for users aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

13. Cookies and Analytics

Our website and Apps may use cookies, SDKs, and similar technologies to operate the service, remember preferences, and measure usage. You can control cookies through your browser or device settings; disabling them may affect functionality.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be posted within the relevant App or on our website, with an updated “Last Updated” date. Your continued use of the Apps after changes take effect constitutes acceptance of the revised policy.

15. Contact

For any questions or requests regarding this Privacy Policy or your personal data, contact APPCODIX LTD, Spyrou Kyprianou & Agias Fylaxeos, 182, KOFTEROS BUSINESS CENTRE, 2nd floor, Flat/Office 201, 3083 Limassol, Cyprus, or email services@appcodix.com.

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