Eterna Privacy Notice

Jetpac Eterna (“Eterna”) is a lifetime-free travel eSIM from Jetpac. Once installed, it stays on your phone and switches on when you travel abroad. It gives you free access to selected essential apps (currently WhatsApp, Google Maps, Apple Maps, Uber, Grab) and a free data allowance for every eligible trip, with paid top-ups available at any time.

This Eterna Privacy Notice explains how Jetpac (Circles Global) Pte. Ltd. (“Jetpac”, “we”, “us” or “our”) collects, uses, shares and retains your personal data when you view, redeem, install or use Eterna, contact us about Eterna, or purchase a related service such as a data top-up.

This Privacy Notice applies specifically to Eterna and supplements the Jetpac Global Privacy Policy which continues to apply to our broader relationship with you and provides additional information about how Jetpac and its group companies process personal data.

The company responsible for your personal data in connection with Eterna (the “data controller”) is Jetpac (Circles Global) Pte. Ltd., a company registered in Singapore (UEN 202402905C) with its registered address at 63 Alexandra Terrace, #06-18 Harbourlink Innohub, Singapore 119937 (“Jetpac”, “we”, “us”, “our”). Jetpac is part of the Circles group of companies.

The information we collect depends on how you access and use Eterna. We may collect and process the following categories of personal data.

Account and contact information

This may include:

• your name;
• email address;
• Jetpac account ID;
• telephone number;
• the country associated with your verified telephone number; and
• other information associated with your Jetpac account.

We use this information to create and administer your Eterna entitlement, verify eligibility, communicate with you about Eterna and provide customer support.

Campaign and attribution information

If you access Eterna through a partner, creator, campaign, referral or other promotional channel, we may process information such as:

• campaign or partner identifiers;
• referral or attribution information;
• promotional tokens or codes;
• market or country;
• language or community information, where applicable; and
• information about how you accessed or redeemed the Eterna offer.

We use this information to enforce quotas, determine eligibility, apply campaign limits, attribute redemptions, measure campaign performance and reconcile payments or other obligations with authorised partners.

Device and eSIM information

We may process information relating to the device and eSIM you use with Eterna, including:

• device identifiers;
• eSIM identifiers;
• device model and operating system;
• device and eSIM compatibility information; and
• eSIM installation and activation events.

We use this information to determine device compatibility, provision and support your eSIM, prevent duplicate or abusive use and troubleshoot technical issues.

Network and travel information

When you use Eterna while travelling, we may process technical information such as:

• serving country or network;
• roaming status;
• activation and usage timestamps;
• destination or network information; and
• other technical signals.

We use this information to provide Eterna, apply applicable international-use and trip limits, home-country exclusion, prevent misuse, support connectivity and reconcile relevant supplier charges.

Usage and technical information

We may process information about your use of Eterna, including:

• data allowance events;
• named-app traffic class;
• activation and deactivation events;
• failed activation attempts;
• error and diagnostic information; and
• technical service events.

We use this information to provide and maintain Eterna, deliver benefits, monitor technical performance, troubleshoot problems, detect and prevent abuse and calculate contribution cost.

Payment information

Eterna does not require payment information presently. If a payment method is required as part of a particular Eterna eligibility, verification or top-up process, we may receive information from our payment service provider, such as a payment-method token or confirmation that a payment method has been successfully validated.

Where payment information is processed directly by a payment provider, Jetpac does not need to receive or store your full payment card number.

We will use this information to run the selected card-gating experiment and enable a separately confirmed top-up.

We may collect personal data:

• directly from you when you redeem or use Eterna;
• from your existing Jetpac account;
• automatically from your device, eSIM or network connection when you use Eterna;
• from partners, creators or other authorised campaign distributors when you access Eterna through them;
• from service providers that support Eterna; and
• from payment providers where relevant to a payment or verification process.

We may also receive information generated through your use of Eterna, such as technical, network and usage information.

If we receive your personal data from another organisation, we will process it in accordance with applicable data protection laws and the purposes described in this Privacy Notice and the Circles Global Privacy Policy.

To provide and administer Eterna

We may use your information to:

• create and administer your Eterna entitlement;
• verify your eligibility;
• install, activate and operate your eSIM;
• provide the benefits available under Eterna;
• monitor your allowance and eligibility;
• apply applicable trip, destination and usage restrictions; and
• provide customer support.

To prevent fraud and misuse

We may process account, device, eSIM, campaign, network and usage information to:

• detect duplicate or fraudulent claims;
• prevent abuse of the complimentary benefit;
• prevent use that does not meet Eterna’s eligibility requirements;
• protect Jetpac, our customers and our service providers; and
• enforce applicable terms and conditions.

To operate, monitor and improve Eterna

We may use technical, usage and campaign information to:

• monitor the performance and reliability of Eterna;
• identify and resolve technical problems;
• understand how Eterna is used;
• improve Eterna and related Jetpac services;
• evaluate the effectiveness of the offer; and
• produce aggregated or anonymised information and statistics where appropriate.

To administer campaigns and partnerships

Where Eterna is provided through a partner, creator or promotional campaign, we may process campaign and attribution information to:

• determine eligibility;
• apply campaign limits;
• attribute redemptions;
• report campaign performance;
• reconcile supplier or partner charges; and
• meet our contractual obligations to authorised partners.

To process payments and top-ups

Where applicable, we may process information necessary to validate a payment method, process a paid top-up, issue a receipt or meet accounting and financial obligations.

To provide customer support

We may process information about your account, device, eSIM, network connection and support request to investigate and resolve problems and respond to your enquiries.

To comply with legal and regulatory requirements

We may process and retain information where necessary to comply with applicable laws, regulations, legal processes or regulatory requests, or to establish, exercise or defend legal claims.

To communicate

We may use your contact information to send service-related communications, including information about your Eterna entitlement, activation, usage, technical issues or important changes to Eterna or our services.

Where required by applicable law, we will obtain your consent before sending marketing communications. You can opt out of marketing communications at any time using the unsubscribe mechanism provided in the communication or through the methods described in the Circles Global Privacy Policy.

Depending on your location and the processing activity involved, we may rely on one or more of the following legal bases under applicable data protection laws:

Performance of a contract

We may process your personal data where it is necessary to provide Eterna or another service you have requested, or to take steps at your request before providing the service.

Legitimate interests

We may process your personal data where it is necessary for our legitimate interests, including:

• preventing fraud and misuse;
• securing our services and systems;
• administering campaigns and partnerships;
• operating and improving Eterna;
• understanding service performance and usage;
• protecting our business, customers and service providers; and
• establishing, exercising or defending legal claims.

Where we rely on legitimate interests, we consider the impact of the processing on your rights and interests and only process personal data where our interests are not overridden by those rights and interests.

Legal obligations

We may process your personal data where necessary to comply with a legal or regulatory obligation applicable to us.

Consent

Where applicable law requires us to obtain your consent for a particular processing activity, we will ask for your consent before carrying out that processing.

Where we rely on consent, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Eterna may include complimentary access to certain services or applications, such as WhatsApp, Google Maps, Uber or Grab, subject to the applicable Eterna benefit terms and technical conditions.

We don’t access the content of your WhatsApp messages, Google Maps searches, Uber activity or Grab activity to provide Eterna.

Where technically necessary to provide an included benefit, we may process technical network or traffic information needed to determine whether relevant traffic qualifies for that benefit.

We do not use the content of your communications or searches to determine your Eterna eligibility.

Circles group companies

We may share information with relevant companies within the Circles group where necessary to provide services, administer our business, maintain systems, provide customer support or perform the purposes described in this Privacy Notice and the Circles Global Privacy Policy.

eSIM, telecommunications and connectivity providers

We may share relevant technical information with eSIM, telecommunications, network and connectivity providers where necessary to provision, operate, monitor or account for your connectivity service.

This may include service providers such as Telna, where applicable to your Eterna service.

Technology and service providers

We may use service providers that support functions such as:

• cloud hosting;
• authentication and OTP;
• analytics;
• customer support;
• fraud prevention;
• payment processing;
• campaign attribution; and
• other technical and operational functions.

These providers may process personal data on our behalf and are required to handle it in accordance with applicable contractual and legal requirements.

Campaign and distribution partners

Where you access Eterna through an authorised partner, creator or campaign distributor, we may share limited information necessary for attribution, reporting, eligibility or reconciliation.

We will not share your personal data with a campaign partner for unrelated purposes unless permitted by applicable law and appropriately disclosed.

Authorities and professional advisers

We may disclose personal data where required or permitted by law, including to courts, regulators, law enforcement authorities, auditors, lawyers, insurers or other professional advisers where necessary.

International transfers, safeguards and retention periods must follow the current Circles policy and local law.

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Notice, the Circles Global Privacy Policy, Jetpac Global Privacy Policy and applicable legal or regulatory requirements.

Different categories of personal data may therefore be retained for different periods.

For example:

• account and entitlement information may be retained while your Jetpac account or Eterna entitlement remains relevant;
• technical and usage information may be retained for the period necessary to provide the service, investigate issues, prevent fraud and maintain appropriate records;
• campaign and attribution information may be retained for the period necessary to administer and reconcile the campaign; and
• payment and accounting information may be retained for the period required by applicable financial, tax or accounting requirements.

When personal data is no longer required, we will delete it, anonymise it or otherwise securely dispose of it in accordance with our retention policies and applicable law.

Depending on where you live and the laws that apply to you, you may have certain rights in relation to your personal data.

These may include the right to:

• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to certain processing;
• withdraw consent where we rely on consent;
• request portability of certain personal data; and
• exercise rights relating to certain automated decision-making or profiling, where applicable.

You may also have the right to lodge a complaint with the data protection or privacy regulator in your country.

The availability and scope of these rights depend on applicable law, and certain exceptions may apply.

To exercise your rights, please contact us using the contact details below or follow the process described in the Circles Global Privacy Policy.

The verified phone country and lawful network/roaming signals are used to determine eligibility and prevent domestic use. Eterna is intended for the verified account holder; it is not a service for creating a hidden domestic connection for children or other household members.

We use appropriate technical and organisational measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss or destruction.

Access to personal data is limited to employees, contractors and service providers who need it for legitimate business purposes and who are subject to appropriate confidentiality and security requirements.

However, no method of transmitting or storing information can be guaranteed to be completely secure.

We may update this Privacy Notice when:

• the way we process personal data changes;
• Eterna’s features or benefits change;
• our service providers change;
• applicable laws or regulatory requirements change; or
• other circumstances require us to update the information provided to you.

Where appropriate, we will provide notice of material changes through the Eterna offer page, Jetpac app, email or another appropriate channel.

The current version of this Privacy Notice and its effective date will be available on the official Eterna offer page.

If you, at any time, have any queries on this Policy or any other related queries, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:

Data Protection Officer 63 Alexandra Terrace #06-18 Singapore 119937 Email: dpo@jetpacglobal.com