Effective Date: 01/01/2025

Cookies Policy

1. Scope of This Policy

Flash Connect Limited (trading as Flash eSim – “we”, “us” or “our”), located at Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong, uses cookies and similar technologies on the Flash eSim website (https://flashconnect.hk) (the “Website”). This Cookies Policy explains how and why we use cookies on our Website. We may update this policy from time to time to reflect changes in technology or legal requirements regarding cookies. Any updates will be posted on this page, so we encourage you to review it periodically to stay informed about how we use cookies and how you can manage your preferences.

2. Summary of This Policy

When you first visit our Website, we will set only cookies that are strictly necessary for the site to function on your device (e.g. your computer or mobile). Non-essential cookies (such as those for preferences, analytics, or advertising) will be used only with the appropriate consent, as detailed below. In practice, this means that users in Europe must give us permission (opt-in) before we deploy optional cookies, whereas for users in other regions, these optional cookies are enabled by default upon your first visit. In all cases, you have control over which cookies are used: you can adjust your choices at any time through our Cookies Settings pop-up (described in Section 6).

Please note that some cookies (even certain optional ones) may collect personal data about you, such as your IP address or device information. We handle any personal data collected via cookies in accordance with our Privacy Policy. For more details on how we process personal data and protect your privacy, please refer to our Privacy Policy available on our Website.

3. What Are Cookies?

Cookies are small text files that are placed on your web browser or device when you visit a website. They serve as a memory for the website, allowing it to remember information about your visit (such as your preferences or login status) and recognize you upon subsequent visits. Cookies can also collect information related to your device and your usage of a site. In some cases, this information can be considered personal data (for example, cookies might collect your IP address or infer your location).

Cookies can be categorized by who sets them: “first-party” cookies are those placed by the website you are visiting (in this case, by Flash eSim on the flashconnect.hk domain), whereas “third-party” cookies are set by other parties via that website. For example, if our Website uses an analytics service or a social media plugin, those third parties may set their own cookies when you visit our site. We use both first-party and third-party cookies on Flash eSim for the purposes explained below.

4. Why Do We Use Cookies?

We use cookies to distinguish you from other users and to improve your experience on our Website. In practical terms, cookies help us to:

• Provide Core Functions: Certain cookies are essential for the Website to operate correctly. They enable basic features like page navigation and secure access to areas of the site. Without these cookies, the Website may not function properly.
• Remember Preferences: Cookies allow us to remember your preferences and settings over time, so you don’t have to re-enter them each time you visit. For example, they can recall your chosen language, currency, or other customization options, making your browsing more convenient.
• Improve Performance: We use cookies to understand how visitors use our Website, which pages are popular, or if any errors occur. This information (often aggregated and anonymous) helps us improve the Website’s design, content, and functionality.
• Marketing and Personalization: If we (or our advertising partners) use advertising or targeting cookies, these help tailor the ads or content you see, so they are more relevant to you. They also help measure the effectiveness of advertising campaigns.

Overall, cookies enable us to provide you with a smoother, more personalized, and more efficient online experience, while also allowing us to continually enhance our services.

5. Types of Cookies We Use

On the Flash eSim Website, we use several categories of cookies. Some are strictly necessary for the site to work, while others are optional and used for additional purposes. Below are the types of cookies you may encounter on our site:

• Strictly Necessary Cookies: These cookies are essential for the operation of our Website and cannot be switched off in our systems. They are usually set only in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms. For example, they might remember your session ID so you stay logged in as you navigate the site, or help load pages faster. Without these cookies, certain services or functionalities you request may be impaired. These cookies do not require your consent because they are necessary for the Website to function.

• Functional (Preference) Cookies: These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. Functional cookies remember choices you make on our site — for instance, your language selection, region, or other customizable elements — to provide a more tailored experience. While they greatly improve convenience, they are not strictly necessary, so we will only use them with your consent (in regions where consent is required). If you choose to disable these cookies, some of these preferences may not be saved for your next visit.

• Analytics (Performance/Statistics) Cookies: These cookies help us understand how visitors interact with our Website. They collect information about how you use our site, such as which pages you visit, how long you stay, and any issues you encounter (like error messages). This data is collected in an anonymous or aggregated form and is used to improve the usability and performance of our Website. For example, using analytics cookies, we can identify trends in usage and make informed decisions on how to enhance our content or navigation. These cookies are optional – we only deploy analytics cookies with your consent if you are in a jurisdiction that requires it. If you opt out of these, it will not affect your ability to use our site, but it makes it harder for us to improve our services based on your feedback.

• Advertising (Marketing) Cookies: Advertising cookies may be used to track your browsing habits and activity across our site (and potentially other sites) to deliver advertisements that are more relevant to you and your interests. They can also limit the number of times you see an ad and help measure the effectiveness of advertising campaigns. These cookies might be set through our site by our advertising partners (third parties) to build a profile of your interests and show you relevant ads on other sites. Advertising cookies are also optional, and will be used only with your consent where required. If you disable these cookies, you will receive less targeted advertising, but you may still see generic ads.

Note: In practice, “Functional,” “Analytics,” and “Advertising” cookies are all considered non-essential (optional) cookies. We group these as optional cookies that you can choose to allow or disable. Only Strictly Necessary cookies operate all the time by default, since the site cannot run properly without them.

6. Your Cookie Choices and Consent (Cookiebot CMP)

We want to give you clear control over the cookies used on our Website. To manage cookie consents and ensure compliance with privacy regulations, Flash eSim uses Cookiebot, a Consent Management Platform (CMP). Cookiebot helps us present a cookie consent banner or pop-up to users in certain regions and remembers your preferences going forward.

Regional Consent Differences: Cookiebot allows us to tailor our cookie consent approach based on your location:

• Users in Europe: If you are visiting our site from the European Economic Area (EEA) or other regions with similar cookie consent laws, you will be presented with our cookie consent banner when you first visit the Website. This banner will inform you about our use of cookies and ask for your preferences for optional cookies. We will not deploy functional, analytics, or advertising cookies until you make a choice and give consent. In other words, European users must actively opt in to enable optional cookies on their device. You have the option to accept all cookies, reject all non-essential cookies, or pick and choose which categories of cookies you want to allow. (See “Cookie Consent Banner Options” below for details.)

• Users in Other Regions (Rest of the World): If you are visiting from a region that does not legally require prior consent for non-essential cookies, our Website may enable optional cookies by default when you first visit. In these cases, you might not see a detailed cookie consent banner at the top of the site. Instead, by continuing to use our Website, it is assumed that you consent to the use of cookies as described in this policy. However, this does NOT mean you lack control – all users, regardless of location, can still manage their cookie settings and opt out of any optional cookies if desired (see “Managing Your Cookie Preferences” below). We believe in being transparent and giving you a choice, even if your region’s laws don’t mandate an explicit banner.

Cookie Consent Banner Options (for users who see the banner): Our cookie banner (powered by Cookiebot) gives you a clear set of choices when you first visit:

• “Accept All” – Selecting this means you consent to all cookies we use, including both strictly necessary and all optional cookies (functional, analytics, and advertising). This is a quick way to enable full functionality and personalized experience on our site.
• “Reject All” – Selecting this means you decline any non-essential cookies. We will not set any functional, analytics, or advertising cookies on your device. Only the strictly necessary cookies (which don’t require consent) will remain active. This may limit some features or personalization, but our core services will still work.
• “Manage Preferences” (or “Customize Settings”) – This option allows you to choose specifically which cookie categories you want to allow. You can toggle individual categories (Functional, Analytics, Advertising) on or off according to your comfort level. No optional cookies will be set until you save your preferences. If you choose to allow some and not others, we will respect that choice.

Once you have made your selection on the banner, Cookiebot will remember your preferences by storing a cookie consent record. If you are in Europe and choose not to interact with the banner (i.e., neither accept nor reject), we will treat that as no consent for optional cookies, and only necessary cookies will run. You can always change your mind later.

Managing Your Cookie Preferences (Cookie Settings Pop-up): Regardless of where you are located, you can modify your cookie choices at any time after your initial decision. We provide a “Cookies Settings” link/pop-up on our Website (for example, this may appear as a widget or link in the footer saying “Cookie Settings” or a small icon). By clicking this at any time, you can reopen the Cookiebot preferences dialog. This allows you to review your current consent status and adjust which categories of cookies are active. For instance, if you previously accepted all cookies but later decide you want to disable analytics or advertising cookies, you can do so through the Cookies Settings pop-up. Conversely, if you initially rejected or skipped optional cookies and later decide you want to enable certain features that use them, you can use the settings pop-up to grant consent for those categories.

Cookiebot ensures that when you withdraw consent or disable a category via the settings, the Website will stop using those cookies (and where applicable, those cookies will be removed or no longer collect data). Your updated preferences will be honored immediately. Keep in mind that if you clear your browser cookies entirely, you may lose our record of your consent preferences – in that case, the cookie banner may appear again on your next visit (for EU users), or optional cookies will load with default settings (for non-EU users), until you adjust the settings again.

Our use of Cookiebot and the above measures are in place to comply with privacy regulations (such as the EU’s GDPR) and to be transparent about user choices. We want you to have confidence that you can control your data. We do not override your selections, and we will not deploy optional cookies without consent when the law requires consent. For users outside regions with strict cookie laws, we still provide the same transparency and ability to opt out, reflecting our commitment to user privacy and choice.

7. How to Disable or Delete Cookies (Browser Settings)

In addition to the on-site tools (like our Cookies Settings pop-up), you have the ability to control and manage cookies through your web browser settings. Most web browsers allow you to view the cookies stored on your device and delete them, and also to block or restrict cookies from certain sites or all sites. Here are general ways to manage cookies in common browsers:

• Browser Cookie Settings: Check your browser’s Privacy or Security settings section. You will typically find options to clear browsing data (which includes deleting cookies) and settings to block or allow cookies. For example, in Chrome you can go to Settings > Privacy and Security > Cookies and other site data to adjust preferences; in Safari (on a Mac) you can go to Preferences > Privacy to manage cookies; in Firefox, go to Options > Privacy & Security and look for the Cookies section.
• Blocking All or Some Cookies: You may choose to block third-party cookies (cookies from domains other than the one you are visiting) or even all cookies. Most browsers let you set up rules to block cookies from specific websites or block third-party cookies generally. Keep in mind that if you block all cookies, our Website (and other sites) may not function optimally since even necessary cookies would be blocked.
• Deleting Cookies: You can delete cookies that have already been set on your device. This is usually done through the browser’s history or privacy settings (often labeled as “Clear browsing data” or “Clear history” with an option to include cookies). Deleting cookies will remove the information they stored, which means settings or preferences they enabled will be lost (for example, you may be logged out of websites or your site preferences may reset).

For more detailed information on managing cookies for your specific browser, you can refer to the official support pages of the browser vendor. Below are helpful links for major browsers:

• Google Chrome: Google Chrome – Clear, enable, and manage cookies
• Mozilla Firefox: Firefox – Delete cookies to remove the information websites have stored on your computer
• Microsoft Edge (Chromium): Microsoft Edge – View and delete browser history (including cookies)
• Apple Safari: Safari – Manage cookies and website data

Please note that the process for managing cookies may vary over time as browsers are updated, so it’s a good idea to consult the latest instructions from your browser’s support site if you are unsure.

Warning: If you disable or delete certain cookies (especially the strictly necessary ones), parts of our Website may not work properly. For example, you might not be able to log in, use the shopping cart, or the site might not remember your language or other preferences. We recommend keeping the necessary cookies enabled to ensure our services function correctly. You always have the option to disable optional cookies through either our site tools or your browser if you prefer, and our site should remain usable, though possibly with reduced functionality or personalization.

8. Additional Information and Contact Details

Privacy Policy: For more information about how we handle personal data (including data that may be collected by cookies) and to understand your rights regarding your personal information, please see our Privacy Policy. Our Privacy Policy details our data protection practices and how you can contact us to exercise your rights or ask questions about your privacy.

Policy Updates: This Cookies Policy may be updated by Flash eSim from time to time. If we make significant changes, we may provide a prominent notice (such as a banner or pop-up notification) on our Website in addition to updating the text of this policy. However, it’s ultimately your responsibility to review this policy periodically. The “last updated” date (or effective date) at the top of the policy indicates when it was most recently revised.

Language: This Cookies Policy is written in English. If we provide translations in other languages, those are for convenience. In the event of any inconsistency or ambiguity between the English version and a translated version, the English version will prevail to the extent permitted by law.

Contact Us: If you have any questions or concerns about this Cookies Policy or about how Flash eSim uses cookies and similar technologies, please feel free to contact us. You can reach out via email at contact@flashconnect.hk. Alternatively, you may write to us at: Flash Connect Limited, Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong. We are committed to addressing any inquiries about privacy and cookies promptly and transparently.

By using our Website, you acknowledge that you have read and understood this Cookies Policy. Thank you for taking the time to learn about our cookie practices. We value your privacy and strive to ensure that your personal data is handled safely and responsibly when you use Flash eSim.