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Holafly Subscription Service Terms & Conditions

1. Introduction

These terms and conditions (“Terms”) constitute a legally binding agreement made between you (the “User” or “you”) and Holafly Limited, a private limited company incorporated and registered in Ireland with company registration number 745325 and having its registered office at 6th Floor, 2 Grand Canal Square, Dublin 2, D02 A342, Ireland (“Holafly”, “we” or “us”).

These Terms apply to your purchase of a monthly data subscription plan (“Data Subscription Plan”), which is provided via an eSIM (“eSIM”), for use on your personal device (“Device”). "Subscription Service " means (i) the Data Subscription Plan, (ii) the eSIM, and (iii) where enabled, Holafly’s “Always On” backup connectivity feature (“Always On Service”).

If you sign up for any other Holafly service in the future, you may be asked to agree to extra terms that apply only to that service. These will be published on our website or application (each referred to as an “Application”).

We recommend that you print or save a copy of these Terms for future reference.

2. Purchase of Subscription and eSIM Activation

To purchase a Data Subscription Plan, the User needs to provide an email and agree to these Terms. Holafly’s Privacy Policy and Cookies Policy are displayed on the Application when the User registers to purchase. By completing the purchase, the User enters into a contractual agreement for the acquisition of an eSIM and commits to paying all applicable charges in accordance with the selected Data Subscription Plan and these Terms. No password is required to log in to the User’s account. Instead, access will be granted via a one-time login link sent to the User’s email each time they attempt to sign in.

The Data Subscription Plan allows the User to purchase and install a single eSIM and pay for the service on a monthly basis. No additional installation is required. The eSIM will remain valid until uninstalled by the User and can be used for the subsequent purchase of other Holafly services. There is no minimum or maximum subscription period as the eSIM itself does not have an expiration date. However, once the eSIM is purchased, the automatic subscription renewal process begins, and billing renewals are calculated from the purchase date - not the activation date. After 30 days from the purchase date, the charge for the following month will be applied.

The Data Subscription Plan operates on a rolling monthly basis and will automatically renew at the end of each 30-day billing cycle unless the User cancels before the renewal date. Since the billing cycle is tied to the date of purchase, Holafly recommends activating the eSIM as soon as possible after purchase to ensure alignment between the days of actual use and the subscription renewal cycle.

During the purchase process, you will be asked to set up your payment method, which will be used for automatic renewals. The download and activation of the eSIM, as well as any selected Data Subscription Plan, will require a stable internet connection. The User acknowledges that delays in activation do not postpone, pause, or alter the subscription billing cycle, which runs strictly from the purchase date.

By availing of the Subscription Service, the User acknowledges that they have an unlocked, eSIM-compatible Device, which is required in order to access the eSIM. The User further acknowledges that they have read the relevant product description page and that the purchased Subscription Service is suitable for their intended use.

3. Duration and Termination

These Terms shall commence as soon as you purchase the Data Subscription Plan. After downloading the eSIM, it will remain on your Device, with the Data Subscription Plan renewing automatically every 30 days until the subscription is cancelled, or the payment method fails. The User may remove the eSIM from their Device at any time through the settings, but we recommend that the eSIM is not removed unless the subscription is cancelled, or the service is terminated, or if the User wishes to avail of the Always On Service. Downloading and activating the eSIM and Data Subscription Plan requires a stable internet connection. The subscription period will renew every 30 days, commencing at the time of activation of the eSim (e.g., from 4:00 PM on the activation day to 4:00 PM on the last day of the period).

End of Subscription Data Plan

  1. The duration of these Terms will continue on a month-to-month basis, with automatic renewal every 30 days until the subscription is cancelled, the payment method fails or it is terminated in accordance with these Terms. The User may cancel the plan at any time, with no minimum (or maximum) commitment period.

  2. These Terms will terminate in the following cases:

    a. When the Data Subscription Plan is cancelled by the User and its subscription period ends according to Clause 3.2.1.

    b. If the payment method fails, leading to the suspension or termination of the Data Subscription Plan.

    c. If the User breaches these Terms (including applicable laws) or Holafly has reasonable suspicions of a breach, resulting in the suspension or termination of the eSIM or Data Subscription Plan by Holafly.

  3. The ending of the Data Subscription Plan does not terminate these Terms. These Terms will continue to apply to (a) any Always On Service available to you, and (b) any clauses intended to survive beyond the Data Subscription Plan (including those relating to consumer rights, liability, complaints, and dispute resolution) provided the eSIM remains on your Device.

Status of eSIM After Data Subscription Plan Ends

  1. Once the Data Subscription Plan ends, it will no longer provide data connectivity, except where the Always On Service is enabled, in which case backup connectivity may continue in accordance with Clause 19 below. If you do not have access to the Always On Service, the eSIM will not provide connectivity unless you purchase another Data Subscription Plan or Holafly service.

  2. The eSIM profile may remain installed on your Device after the Data Subscription Plan ends. We recommend deleting the eSIM if you do not intend to use the Always On Service or purchase further services, to avoid confusion or accidental use.

  3. Termination of the Data Subscription Plan does not affect your statutory rights under applicable consumer law, nor does it limit Holafly’s responsibility for the eSIM to the extent required by law (including in relation to defects or damage caused by the eSIM). No ongoing service or support is provided in respect of an expired Data Subscription Plan unless the Always On Service is enabled, and/or until a new plan is purchased.

4. Data Usage, Plan Changes, and Cancellations

For Plans which have a specified included volume of data, if the User runs out of data before the renewal date, there are no “out of bundle” usage options. In order to continue using Holafly services, the User has the option to:

  1. purchase a prepaid international data plan for a specified number of days and designated destination(s) (“Trip Data Plan”) which is provided via an eSIM for use on your Device (https://esim.holafly.com/esim-global/). This is entirely at the User’s discretion and is not a requirement. This is a separate Holalfy offering, subject to its own terms [here], and once purchased must be installed, activated, and used separately to the Subscription Service;

OR

  1. upgrade/downgrade to a different Data Subscription Plan by contacting customer support to cancel the current plan, buy a superior one, get a new eSIM, install it, activate it, and start a new billing cycle on that same day. If the User opts for a downgrade, they will continue using their current plan until the end of the billing cycle. Customer support will assist in cancelling the existing plan and facilitating the purchase of a lower-tier plan, which will take effect once the current billing cycle ends.

The User may cancel their Data Subscription Plan at any time, without any minimum notice period. Cancellation may be executed through the User’s online account or by contacting customer support through the channels indicated by Holafly. Notwithstanding the cancellation request, the Data Subscription Plan will remain active until the end of the current billing cycle, with no entitlement to refunds, prorated reimbursements, or credits for any unused portion of the subscription.

The User is not able to pause the Data Subscription Plan. If the User cancels, they will not be able to reactivate the previous plan.

5. Plan Modifications

We reserve the right to modify or update the terms of the Data Subscription Plan. In the event of any material changes, we will provide the User with at least 30 days’ prior notice. If the modification adversely affects the User’s rights or obligations, the User may cancel their subscription without penalty before the change takes effect.

If the User does not express their objection to the changes within 30 days of receiving notice and continues to use the Subscription Service thereafter, such continued use will be deemed as acceptance of the updated terms.

6. Cancellation Rights

The User has the right to withdraw from the Data Subscription Plan within 14 days from the date of purchase, without penalty and without the need to provide any justification, in accordance with applicable consumer protection laws.

The User may access and manage their Data Subscription at any time through their user account on our website.

7. Warranty

These Terms are in addition to your statutory rights as a consumer.

Holafly provides the Subscription Service with reasonable care and skill and in conformity with these Terms. Holalfy gives no warranty and makes no representations in relation to the Data Subscription Plan, the eSIM, or the Subscription Service, and all warranties and conditions (save to the extent that they are required by applicable laws), whether express or implied by statute, common law or otherwise, are excluded to the extent permitted by law. Nothing in this clause limits your statutory consumer rights.

Holafly reserves the right, at its sole discretion, to discontinue the sale, provision or support of any Data Subscription or eSIM at any time.

8. Subscription Service Availability

Holafly’s services are to be used solely for international travel and not for Domestic Use. “Domestic Use” refers to the country where the customer is based at the time of purchase. For EU-based customers, this encompasses the entire EU. In addition, each separate period of continuous roaming in a particular destination must not exceed 90 days.

Holafly shall take commercially reasonable steps to ensure the Subscription Service is available to you at all times, contingent upon Holafly and its service providers’ ability to maintain network capacity and connection availability.

Holafly partners with service providers to provide the Subscription Service, including network service providers. These vary from jurisdiction to jurisdiction.

If you purchase an Unlimited Data Subscription Plan, please note that this means there is no fixed data volume allowance that limits data use, but your data coverage and speed may be subject to a fair use policy. This means that in order to ensure a high quality of service for all users, the network service provider or Holafly reserves its right to impose restrictions or limitations on data usage or speed if your usage is deemed excessive or if it negatively impacts the network performance of other users.

Holafly does not guarantee network capacity, network quality, or connection availability of the Subscription Service. This includes (but is not limited to) any of the following circumstances:

  1. when our service providers need to perform upgrading, maintenance, or other work on its network services;

  2. when you are in areas not covered by the network of our service providers or in accordance with the areas specified in your Data Subscription Plan;

  3. where factors outside of our control cause disruption, including, by way of example but not limited to: disruption caused by the features or functionality of your Device, regulatory requirements, faults in communication networks, the weather, radio interference, or other physical obstructions.

9. User Obligations

The User agrees that it shall:

  1. use the eSIM and Services in compliance with these Terms;

  2. use the eSIM and Services in accordance with all applicable laws and regulations of the country in which the User is present or ordinarily resident;

  3. not use the eSIM or Services to engage in any action that is fraudulent, criminal, or illegal, or causes the network to be impaired or damaged;

  4. not use the eSIM or Services to copy, store, modify, publish, or distribute Holafly’s commercial information (including trade secrets) except where we give you permission.

  5. use the eSIM or Services to download, send, or upload content of an excessive size, quantity, or frequency; and

  6. not use the eSIM or Services in a way that breaches the intellectual property rights of a third party.

  7. not decompile, disassemble, reverse engineer or otherwise attempt to derive source code from any Holafly content or the content of Holafly’s service providers (including but not limited to the eSIM),

The User agrees that any credits, promotions, and referrals for the Subscription Service (the “Promotions”) shall not be used to undermine the fairness, integrity, or legitimate operation of the Subscription Service, including but not limited to, creating fake User registrations or using fictitious identities to participate in the Promotions to receive rewards.

The User agrees that Holafly may suspend temporarily or permanently the Data Subscription Plan where reasonably necessary due to a material breach of these Terms. Where the Subscription Service is suspended due to the User’s material breach, the User remains liable for any charges properly accrued under these Terms up to the effective date of suspension. Holafly reserves the right to seek appropriate remedies and damages (including reasonable legal costs) to the fullest extent permitted by the law.

Holafly may suspend or terminate the User’s access to the Subscription Service, including the Data Subscription Plan, or suspend or deactivate the eSIM if there are reasonable grounds to suspect that:

  1. The User has breached these Terms, including but not limited to unauthorized use, resale, or fraudulent activity related to the Subscription Service;

  2. The User has engaged in any activity that violates applicable laws, regulations, or third-party rights, including intellectual property rights and consumer protection laws;

  3. The Subscription Service is being used in a manner that may compromise its integrity, security, or availability to other users, including excessive or abusive use that goes beyond reasonable consumer expectations;

  4. The User has provided false, inaccurate, or misleading information during registration, payment, or verification processes;

  5. There is suspected fraudulent, unauthorized, or unlawful activity associated with the User’s account, including chargebacks, identity theft, or payment fraud.

Except where urgent action is required (e.g., fraud, security incidents), Holafly will provide the User with reasonable prior notice of any intended removal, suspension, or disqualification, including the reason for the decision and information on how the User may contact customer support or contest the action.

10. Payment Terms

The User may purchase the Data Subscription Plan on the Application. Payment shall be processed by an authorised agent of Holafly.

The Data Subscription Plan operates on a rolling 30-day billing cycle, commencing at the time of purchase. It will automatically renew at the end of each cycle unless canceled by the User before the renewal date.

Unless otherwise specified, all Subscription fees include any applicable Indirect Taxes. If any additional charges apply, Holafly will display these clearly and transparently before the User completes the purchase. The applicable Indirect Taxes will be calculated based on the postcode provided by the User when submitting payment information to Holafly.

Please note that some banks or financial institutions may impose additional charges, fees, or surcharges (including foreign transaction or cross-border fees) in accordance with their policies. These fees are not charged by Holafly, nor does Holafly have any influence on when the relevant fees are charged. Holafly will not apply any additional fees unless clearly disclosed to the User prior to purchase.

“Indirect Taxes” in this Clause 10 means any sales tax, value-added tax, and any similar levies or taxes as may be applicable at the time of sale of the Data Subscription Plan relating to an eSIM.

Payment for all services can be made on our Application by credit or debit card, or other payment method made available by Holafly. Payments are processed automatically using the payment method chosen by the user during the first purchase.

The User may choose to save the payment method during the payment process with the User’s explicit consent in accordance with data protection requirements and under the service provider’s administration, so that for future purchases this information is automatically added without the User having to re-enter it. If the User wishes to update their payment method, they may do so at any time in the “Account Details” section on the User account.

Certain payment methods made available by Holafly require the User to hold an active, pre‑existing account or agreement with the relevant third‑party payment provider. The availability and eligibility for the use of such payment methods are determined solely by the respective provider, and Holafly has no control over (and accepts no responsibility or liability for) any decision made by these providers regarding User access or use. The User acknowledges and agrees that the use of third‑party payment services is governed exclusively by the provider’s own terms, conditions, and privacy policies. Accordingly, Holafly bears no responsibility for the provider’s handling of the User’s personal or transactional data, nor for any acts, omissions, errors, or service issues arising from the User’s engagement with such third‑party providers.

To ensure the integrity of User transactions and to safeguard against fraud, Holafly may carry out verification and validation checks on the information provided by the User. Holafly will undertake these checks using procedures that are fair, proportionate, and transparent to the User.

  1. Holafly reserves the right to screen all transaction details for indicators of potential fraud, unauthorised activity, sanctions compliance concerns, or other suspicious behaviour; and

  2. Holafly may refuse or cancel an order where fraudulent, unauthorised, or illegal activity is reasonably suspected.

Where Holafly cancels an order under this clause 10.9, the User will be provided with a full refund of any amount paid for the affected order via the original payment method

If payment from a User is not successfully processed within five (5) days of the billing date, the Subscription Services will be suspended. If payment remains outstanding for thirty (30) consecutive days, the Subscription Services will be terminated, and the eSIM will be deactivated permanently. This termination does not exclude any legal action that Holafly may take against the User.

11. Legal Right of Withdrawal

If you are purchasing an eSIM as a consumer, you have the legal right to withdraw from these Terms within fourteen (14) days from the date of purchase, without the need to provide any justification.

If you request or allow the Subscription Data Plan to begin during this 14‑day withdrawal period (for example, by activating the eSIM), you will expressly request that we begin supplying the service during the withdrawal period, and you acknowledge that you will be required to pay a proportionate amount for the service supplied up to the time you notify us of your decision to withdraw.

If the Subscription Data Plan is fully performed within the 14‑day period, you will lose your right of withdrawal only where, prior to activation, you provided your express request for immediate performance and your acknowledgment that you would lose the right to withdraw once the service was fully performed.

To exercise your right of withdrawal, you must inform us of your decision to withdraw from these Terms by an unequivocal statement. Please contact Holafly Limited, c/o Customer Support, the details of which can be found at Clause 22 below.

12. Refund and Returns Policy

You will receive the Subscription Service in conformity with these Terms. If you believe that the Subscription Service which has been delivered to you does not comply, or does not comply with your statutory consumer rights, please let us know. Where the Subscription Service is not in conformity, we will provide the remedies required under the Consumer Rights Act 2022, which may include bringing the service into conformity, a proportionate price reduction, or a refund where appropriate. Nothing in this Clause 12 affects your statutory rights.

For a full refund from Holafly, based on a change of mind withdrawal, the User must meet the following requirements:

  1. the eSIM must have been purchased directly from Holafly via one of its direct sales channels (the Holafly website or the official Holafly phone app) and not from Third Parties;

  2. the eSIM or Data Subscription Plan must not have been activated; and

  3. the refund request must be submitted within six (6) months from the date of purchase.

(These conditions apply only to refunds under the withdrawal right, not to statutory remedies for non-conformity.)

In addition to the withdrawal right, you may also be entitled to remedies under the Consumer Rights Act 2022 where the Subscription Service is not in conformity. These statutory remedies apply regardless of activation status. Remedies may include a proportionate reduction in price or a refund where the service cannot be brought into conformity:

  1. If the Subscription Service fails to function as described, we will assess conformity under the Consumer Rights Act 2022 and provide the appropriate legal remedy.

  2. Where the User purchases an eSIM and downloads it onto an incompatible or locked Device, Holafly will provide to the User a full refund, provided that the User has complied with the requirements of Clauses 12.2.1 - 12.2.3.

13. Intellectual Property Rights

Except as otherwise indicated, the Data Subscriptions, eSIM and Subscription Services are our (or our licensor’s) proprietary property and all source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Application (collectively, the “Content”) and the trade marks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights.

Except as expressly provided in these Terms, no part of the eSIM, the Application and no Content or Marks may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.

14. Data Protection

By purchasing a Subscription Service, you acknowledge that Holafly will process personal information relating to you (“Personal Data”) for different purposes, including to make the Subscription Service available to you, to monitor, to improve the Subscription Service, to prevent unauthorised use of the Subscription Service, and to comply with our legal obligations.

You must provide truthful information, and the impersonation of identity or the use of aliases or anonymous names is prohibited. You may not, when providing any data that may be requested from you on the channels, choose expressions that are offensive, coincide with trade marks, trade names, names, or pseudonyms of public figures or celebrities that you are not authorised to use. So that the information provided is always up to date and does not contain errors, you must inform Holafly, as soon as possible, of any changes to your Personal Data that may occur.

For further information on how Users’ Personal Data is used or for any queries in relation to how we may process your Personal Data, please see our Privacy Policy available and our Cookies Policy.

15. Indemnity

The User agrees to indemnify and keep indemnified Holafly against all losses that are a direct and reasonably foreseeable result of the User’s material breach of these Terms or an unlawful misuse of the Subscription Service.

16. Limitation of Liability

To the extent permitted by law, we exclude all liability (whether arising in contract, in negligence or otherwise) for any loss or damage which you may incur in connection with your use of the Subscription Service, including the eSIM or any Subscription Data Plan.

We will not be liable for any loss that is not reasonably foreseeable at the time you enter into these Terms.

We will not be liable for (i) loss of profits, loss of business, business interruption, or (ii) indirect or consequential loss, in each case arising in connection with the Subscription Service.

Notwithstanding the foregoing, Holafly’s liability under or in connection with these Terms, whether arising from contract, negligence, or otherwise, shall in no event exceed the amount of charges payable by the User to Holafly under the relevant Subscription Data Plan in the 12 months preceding the date of the event giving rise to such liabilities having occurred, or €100, whichever is greater.

This does not affect our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, or any other liability which cannot be excluded or limited under applicable law.

Nothing in these Terms excludes or limits:

  1. liability for death or personal injury caused by our negligence;

  2. liability for fraud or fraudulent misrepresentation;

  3. liability for wilful misconduct; or

  4. any liability or consumer remedies that cannot be excluded or limited under applicable law, including your statutory rights under the Consumer Rights Act 2022.

17. Governing Law and Legal Compliance

Except as applicable mandatory laws may determine: (a) these Terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them or their subject matter or formation shall be governed by and construed in accordance with the laws of Ireland, and (b) the courts of Ireland shall have non-exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms or their subject matter or formation. Nothing in this clause affects your right, where provided for under applicable consumer protection law, to bring proceedings in the courts of your country of residence.

Other applicable mandatory laws of other states may also apply to your use of the eSIM or Data Subscription Plan. You may also benefit from mandatory consumer protection laws of your country of residence, and nothing in these Terms affects any such rights

The Subscription Service, Data Subscription, and the Application are not intended for use by any person or entity in any jurisdiction or country where such use would be contrary to relevant law or regulation. Accordingly, persons who choose to access the Subscription Service and/ or Application from locations that prohibit such use do so on their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable.

18. Variation of these Terms

We may vary these Terms or any future terms, including relating to our Data Subscription Plan, on the following basis:

any updated Terms and new terms will be available on our Application, website or official page;

We will give you at least 30 days’ notice by email of any material variations to these Terms that are to your disadvantage, including changes to pricing, features, or limitations. You may cancel and stop using the Subscription Service before the change takes effect. If you continue to use the Subscription Service after the 30-day period, we will deem you to have accepted the changes. Changes that are exclusively to your benefit, purely administrative, or required by law may take effect without this notice period.

if you continue to use the Subscription Service, Data Subscription, or eSIM after the variation of these Terms commences, you will be deemed to have accepted the variation.

19. Always On Backup Connectivity Service

From 4 November 2025 (CET), when you purchase a Subscription Data Plan, Holafly automatically provides you with the Always On Service, even if you stop your recurring plan, and at no extra charge. The Always On Service becomes available as your current period ends.

The Always On Service provides data coverage in the following countries:

  • Europe: Albania, Andorra, Armenia, Austria, Azerbaijan, Belgium, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Georgia, Germany, Gibraltar, Greece, Guernsey, Hungary, Iceland, Ireland, Isle of Man, Italy, Jersey, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Moldova, Montenegro, Netherlands, North Macedonia, Norway, Poland, Portugal, Romania, Russia, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Ukraine, United Kingdom.

  • Asia: Bahrain, Bangladesh, Brunei, Cambodia, China, Hong Kong, India, Indonesia, Israel, Japan, Jordan, Kazakhstan, Kuwait, Kyrgyzstan, Laos, Macao, Malaysia, Pakistan, Philippines, Qatar, Saudi Arabia, Singapore, South Korea, Sri Lanka, Taiwan, Tajikistan, Thailand, Turkey, United Arab Emirates, Uzbekistan, Vietnam.

  • North America: United States, Canada, México.

  • Central America & Caribbean: Antigua and Barbuda, Bahamas, Barbados, Belize, British Virgin Islands, Cayman Islands, Costa Rica, Dominica, Dominican Republic, El Salvador, Grenada, Guatemala, Honduras, Jamaica, Nicaragua, Panama, Puerto Rico, St. Kitts and Nevis, St. Lucia, St. Vinc. & Gran., Turks and Caicos.

  • South America: Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, French Guiana, Paraguay, Peru, Suriname, Uruguay.

  • Africa: Algeria, Botswana, Burkina Faso, Cameroon, Central African Republic, Chad, Democratic Republic of Congo, Egypt, Eswatini, Gabon, Ghana, Guinea-Bissau, Ivory Coast, Kenya, Liberia, Madagascar, Malawi, Mali, Mauritius, Morocco, Niger, Nigeria, Republic of Congo, Reunion, Rwanda, Senegal, Seychelles, South Africa, Tanzania, Tunisia, Uganda, Zambia.

  • Oceania: Australia, Guam, Hawaii, New Zealand.

19.3 Holafly will endeavor to maintain the countries in which the Always On Service is available. However, from time to time, it may be necessary to remove countries from the available service coverage. The Always On Service is provided to you at no additional charge. It is not intrinsic to the operation of the purchased Subscription Data Plan, and any reduction to the countries it is available in does not constitute a material change to the contracted services.

The Always On Service provides you with a monthly data allowance of 1 GB. This allowance renews automatically every 30 days from the date that your eSIM plan ends on your Device (and not by reference to any calendar month).

The Always On Service remains available after your Subscription Data Plan ends, provided that:

  1. the eSIM remains installed on your Device;

  2. the eSIM remains turned on; and

  3. Data Roaming is enabled on your Device.

If you delete the eSIM from your Device, the Always On Service will automatically end and cannot be reinstated unless you purchase a new Subscription Service and install a new Holafly eSIM.

The availability, speed and performance of the Always On Service may vary depending on your destination, network conditions, and Device compatibility. Holafly does not guarantee uninterrupted availability of the Always On Service.

The Always On service is provided to Users at no additional charge, and therefore is not eligible for any refunds, whether partial or full, under any circumstances.

Nothing in this Clause 19 limits your statutory consumer rights or Holafly’s responsibility for the eSIM or the Always On Service to the extent required by applicable law.

20. Affiliate Partnerships and Third-Party Services

Holafly may provide links to products or services offered by independent third parties (“Affiliate Partners”), including travel services, insurance providers, and event booking platforms. Holafly may receive a commission when Users use these links, at no additional cost to the User.

All affiliate services are provided directly by Affiliate Partners. Holafly acts solely as a referral source and does not control, guarantee, or assume responsibility for the availability, quality, or performance of any third-party services. The User’s contractual relationship for any such services is with the relevant Affiliate Partner, and the customer agrees to review and comply with the Affiliate Partner’s terms and conditions before use.

To the maximum extent permitted by law, Holafly is not liable for any acts, errors, omissions, delays, damages, losses, or expenses arising from third-party services obtained through affiliate links, including service quality, cancellations, or disputes with Affiliate Partners.

21. General

Holafly may assign, transfer, or subrogate to any company of its group the rights and obligations arising from these Terms without the express consent and authorisation of the User.

If at any time any provision of these Terms (or part of any provision) is or becomes illegal, invalid, or unenforceable but would be legal, valid, and enforceable if some part of it were deleted or modified, the provision or part-provision in question shall apply with such deletions or modifications as may be necessary to make the provision legal, valid, and enforceable.

No failure or delay by either party to exercise any right or remedy under these Terms shall be construed as a waiver of that right or remedy, nor shall any single or partial exercise of any right or remedy preclude the further exercise of that right or remedy. No waiver by either party of any breach by the other of any provision of these Terms shall be considered as a waiver of preceding or subsequent breach. The rights and remedies provided in under these Terms are cumulative and are not exclusive of any rights or remedies provided by law.

These Terms are drafted in the English language. In the event that there is a conflict between this English language version of these Terms and any translated copies of these Terms, the English version shall prevail.

22. Holafly Contact Details

For support, general enquiries or to issue a complaint, you can reach our team 24/7 through the following channels:

Holafly Ultra Plan Terms & Conditions

1. Introduction

These terms and conditions (“Terms”) constitute a legally binding agreement made between you (the “User” or “you”) and Holafly Limited, a private limited company incorporated and registered in Ireland with company registration number 745325 and having its registered office at 6th Floor, 2 Grand Canal Square, Dublin 2, D02 A342, Ireland (“Holafly”, “we” or “us”).

These Terms apply to your purchase of the Holafly Ultra subscription plan (the “Ultra Plan”). The Ultra Plan is a bundled subscription comprising (i) an unlimited data subscription plan (the “Data Subscription Plan”), which is provided via an eSIM (“eSIM”) for use on your personal device (“Device”), (ii) access to certain travel assistance benefits provided by AirHelp, (iii) access to certain telehealth and wellbeing services provided by Meeting Doctors, (iv) where enabled, Holafly’s “Always On” backup connectivity feature (“Always On Service”), and (v) any additional or replacement third-party benefits made available by Holafly in accordance with these Terms (together, the “Subscription Service”). AirHelp, Meeting Doctors and any other independent provider of a benefit included in the Ultra Plan are referred to in these Terms as “Third-Party Providers”, and their relevant services as “Third-Party Benefits”.

Certain Third-Party Benefits included in the Ultra Plan are provided by independent Third-Party Providers and are subject to the terms and eligibility requirements applicable to those services. These Terms regulate the User’s subscription to the Ultra Plan as a whole.

2. Purchase of Subscription and eSIM Activation

To purchase an Ultra Plan, the User needs to provide an email and agree to these Terms. Holafly’s Privacy Policy and Cookies Policy are displayed on the Application when the User registers to purchase. Before completing the purchase, the User will also be given access to, and where required must accept, the terms and conditions applicable to the Third-Party Benefits included in the Ultra Plan. By completing the purchase, the User enters into a contractual agreement with Holafly for the Ultra Plan, including the acquisition of an eSIM and access to the Third-Party Benefits, and commits to paying all applicable charges in accordance with the selected billing option and these Terms. No password is required to log in to the User’s account. Instead, access will be granted via a one-time login link sent to the User’s email each time they attempt to sign in.

The Ultra Plan allows the User to purchase and install a single eSIM and access the Subscription Service for the billing period selected at checkout (monthly, quarterly or annual). No additional installation is required for the eSIM. The eSIM will remain valid until uninstalled by the User and can be used for the subsequent purchase of other Holafly services. Once the Ultra Plan is purchased, the automatic subscription renewal process begins, and billing renewals are calculated from the purchase date - not the activation date. The next charge will be applied at the end of the billing period selected by the User.

The Ultra Plan operates on a rolling monthly, quarterly or annual basis, according to the billing option selected by the User, and will automatically renew for the same billing period unless the User cancels before the renewal date. Since the billing cycle is tied to the date of purchase, Holafly recommends activating the eSIM and accessing the Subscription Service as soon as possible after purchase to ensure alignment between the period of actual use and the subscription renewal cycle.

During the purchase process, you will be asked to set up your payment method, which will be used for automatic renewals. The download and activation of the eSIM, as well as the connectivity component of the Ultra Plan, will require a stable internet connection. The User acknowledges that delays in activation or use of any component of the Subscription Service do not postpone, pause, or alter the subscription billing cycle, which runs strictly from the purchase date.

By availing of the Subscription Service, the User acknowledges that they have an unlocked, eSIM-compatible Device, which is required in order to access the eSIM. The User further acknowledges that they have read the relevant product description page and that the purchased Subscription Service is suitable for their intended use.

3. Duration and Termination

These Terms shall commence as soon as you purchase the Ultra Plan. After downloading the eSIM, it will remain on your Device, with the Ultra Plan renewing automatically for the billing period selected by the User until the subscription is cancelled, the payment method fails, or the Ultra Plan is otherwise terminated in accordance with these Terms. The User may remove the eSIM from their Device at any time through the settings, but we recommend that the eSIM is not removed unless the subscription is cancelled or terminated, or if the User wishes to avail of the Always On Service. Downloading and activating the eSIM requires a stable internet connection. The applicable subscription period commences on the date of purchase and renews on the corresponding renewal date for the selected monthly, quarterly or annual billing option.

End of Ultra Plan

1. The duration of these Terms will continue for successive monthly, quarterly or annual billing periods, according to the billing option selected by the User, with automatic renewal for the same billing period until the subscription is cancelled, the payment method fails, or it is terminated in accordance with these Terms. The User may cancel the Ultra Plan at any time, with no minimum commitment period beyond the current paid billing period.

2. These Terms will terminate in the following cases:

a. When the Ultra Plan is cancelled by the User and its current paid subscription period ends according to this clause.

b. If the payment method fails, leading to the suspension or termination of the Ultra Plan.

c. If the User breaches these Terms (including applicable laws) or Holafly has reasonable suspicions of a breach, resulting in the suspension or termination of the eSIM or Ultra Plan by Holafly.

3. The ending of the Ultra Plan does not terminate those provisions of these Terms that are intended to survive termination, including those relating to consumer rights, liability, complaints and dispute resolution. Any Always On Service that remains available after the Ultra Plan ends will continue in accordance with these Terms.

Status of eSIM After Ultra Plan Ends

4. Once the Ultra Plan ends, the Data Subscription Plan will no longer provide data connectivity, except where the Always On Service is enabled, in which case backup connectivity may continue in accordance with these Terms. Access to Third-Party Benefits will also end in accordance with these Terms, subject to any rights or claims validly arising while the Ultra Plan was active and any applicable claim submission period under the relevant Third-Party Provider terms.

5. The eSIM profile may remain installed on your Device after the Data Subscription Plan ends. We recommend deleting the eSIM if you do not intend to use the Always On Service or purchase further services, to avoid confusion or accidental use.

6. Termination of the Ultra Plan does not affect your statutory rights under applicable consumer law, nor does it limit Holafly’s responsibility for the eSIM or any other element of the Subscription Service to the extent required by law. No ongoing Ultra Plan service or support is provided after the paid subscription period ends, except for any Always On Service that remains available and any surviving rights relating to Third-Party Benefits as expressly provided in these Terms or the applicable Third-Party Provider terms.

4. Data Usage, Plan Changes, and Cancellations

The Ultra Plan includes unlimited mobile data, subject to the fair use and network availability provisions in these Terms. There are no “out of bundle” charges based on a fixed data volume allowance under the Ultra Plan.

The User may cancel their Ultra Plan at any time, without any minimum notice period. Cancellation may be executed through the User’s online account or by contacting customer support through the channels indicated by Holafly. Notwithstanding the cancellation request, the Ultra Plan and all benefits included in it will remain active until the end of the current paid billing period, with no entitlement to refunds, prorated reimbursements, or credits for any unused portion of that period, except where a refund or other remedy is available under these Terms or mandatory law.

The User is not able to pause the Ultra Plan. A cancellation prevents the next automatic renewal but does not interrupt the current paid billing period.

5. Plan Modifications

We reserve the right to modify or update the Ultra Plan, including its features and the composition of the Third-Party Benefits, and may add, replace or remove Third-Party Providers in accordance with these Terms. In the event of any material change that is to the User’s disadvantage, we will provide the User with at least 30 days’ prior notice. If the modification adversely affects the User’s rights or obligations, the User may cancel their subscription without penalty before the change takes effect.

If the User does not express their objection to the changes within 30 days of receiving notice and continues to use the Subscription Service thereafter, such continued use will be deemed as acceptance of the updated terms.

6. Warranty

These Terms are in addition to your statutory rights as a consumer.

Holafly provides the elements of the Subscription Service for which Holafly is responsible with reasonable care and skill and in conformity with these Terms. Holafly gives no warranty and makes no representations in relation to the Data Subscription Plan, the eSIM, or the Subscription Service, and all warranties and conditions (save to the extent that they are required by applicable laws), whether express or implied by statute, common law or otherwise, are excluded to the extent permitted by law. Third-Party Benefits are provided by the relevant Third-Party Provider in accordance with these Terms and the applicable provider terms. Nothing in this clause limits your statutory consumer rights.

Holafly reserves the right, at its sole discretion, to discontinue the sale, provision or support of any Data Subscription or eSIM at any time, subject to the rights of existing Ultra Plan Users and applicable law.

7. Subscription Service Availability

Holafly’s services are to be used solely for international travel and not for Domestic Use. “Domestic Use” refers to the country where the customer is based at the time of purchase. For EU-based customers, this encompasses the entire EU. In addition, each separate period of continuous roaming in a particular destination must not exceed 90 days.

Holafly shall take commercially reasonable steps to ensure that the connectivity component of the Subscription Service is available to you at all times, contingent upon Holafly and its network service providers’ ability to maintain network capacity and connection availability.

Holafly partners with service providers to provide the Subscription Service, including network service providers and the Third-Party Providers identified in these Terms. These providers may vary from jurisdiction to jurisdiction.

If you purchase an Unlimited Data Subscription Plan, please note that this means there is no fixed data volume allowance that limits data use, but your data coverage and speed may be subject to a fair use policy. This means that in order to ensure a high quality of service for all users, the network service provider or Holafly reserves its right to impose restrictions or limitations on data usage or speed if your usage is deemed excessive or if it negatively impacts the network performance of other users.

Holafly does not guarantee network capacity, network quality, or connection availability of the connectivity component of the Subscription Service. This includes (but is not limited to) any of the following circumstances:

1. when our service providers need to perform upgrading, maintenance, or other work on its network services;

2. when you are in areas not covered by the network of our service providers or in accordance with the areas specified in your Data Subscription Plan;

3. where factors outside of our control cause disruption, including, by way of example but not limited to: disruption caused by the features or functionality of your Device, regulatory requirements, faults in communication networks, the weather, radio interference, or other physical obstructions.

8. User Obligations

The User agrees that it shall:

1. use the eSIM and Services in compliance with these Terms;

2. use the eSIM and Services in accordance with all applicable laws and regulations of the country in which the User is present or ordinarily resident;

3. not use the eSIM or Services to engage in any action that is fraudulent, criminal, or illegal, or causes the network to be impaired or damaged;

4. not use the eSIM or Services to copy, store, modify, publish, or distribute Holafly’s commercial information (including trade secrets) except where we give you permission.

5. use the eSIM or Services to download, send, or upload content of an excessive size, quantity, or frequency; and

6. not use the eSIM or Services in a way that breaches the intellectual property rights of a third party.

7. not decompile, disassemble, reverse engineer or otherwise attempt to derive source code from any Holafly content or the content of Holafly’s service providers (including but not limited to the eSIM),

The User agrees that any credits, promotions, and referrals for the Subscription Service (the “Promotions”) shall not be used to undermine the fairness, integrity, or legitimate operation of the Subscription Service, including but not limited to, creating fake User registrations or using fictitious identities to participate in the Promotions to receive rewards.

The User agrees that Holafly may suspend temporarily or permanently the Ultra Plan where reasonably necessary due to a material breach of these Terms. Where the Subscription Service is suspended due to the User’s material breach, the User remains liable for any charges properly accrued under these Terms up to the effective date of suspension. Holafly may also instruct the relevant Third-Party Providers to suspend access to the Third-Party Benefits where necessary to give effect to that suspension. Holafly reserves the right to seek appropriate remedies and damages (including reasonable legal costs) to the fullest extent permitted by the law.

Holafly may suspend or terminate the User’s access to the Subscription Service, including the Ultra Plan and the Data Subscription Plan, or suspend or deactivate the eSIM if there are reasonable grounds to suspect that:

8. The User has breached these Terms, including but not limited to unauthorized use, resale, or fraudulent activity related to the Subscription Service;

9. The User has engaged in any activity that violates applicable laws, regulations, or third-party rights, including intellectual property rights and consumer protection laws;

10. The Subscription Service is being used in a manner that may compromise its integrity, security, or availability to other users, including excessive or abusive use that goes beyond reasonable consumer expectations;

11. The User has provided false, inaccurate, or misleading information during registration, payment, or verification processes;

12. There is suspected fraudulent, unauthorized, or unlawful activity associated with the User’s account, including chargebacks, identity theft, or payment fraud.

Except where urgent action is required (e.g., fraud, security incidents), Holafly will provide the User with reasonable prior notice of any intended removal, suspension, or disqualification, including the reason for the decision and information on how the User may contact customer support or contest the action.

The User must also comply with the applicable Third-Party Provider terms when accessing or using any Third-Party Benefit and must not misuse, resell, transfer or permit another person to use a benefit where the applicable provider terms restrict that benefit to the Ultra Plan subscriber.

9. Payment Terms

The User may purchase the Ultra Plan on the Application. Payment shall be processed by an authorised agent of Holafly.

The Ultra Plan operates on the billing cycle selected by the User at checkout (monthly, quarterly or annual), commencing on the date of purchase. It will automatically renew for the same billing period at the end of each cycle unless cancelled by the User before the renewal date.

Unless otherwise specified, all Subscription fees include any applicable Indirect Taxes. If any additional charges apply, Holafly will display these clearly and transparently before the User completes the purchase. The applicable Indirect Taxes will be calculated based on the postcode provided by the User when submitting payment information to Holafly.

Please note that some banks or financial institutions may impose additional charges, fees, or surcharges (including foreign transaction or cross-border fees) in accordance with their policies. These fees are not charged by Holafly, nor does Holafly have any influence on when the relevant fees are charged. Holafly will not apply any additional fees unless clearly disclosed to the User prior to purchase.

“Indirect Taxes” in this clause means any sales tax, value-added tax, and any similar levies or taxes as may be applicable at the time of sale of the Ultra Plan.

Payment for all services can be made on our Application by credit or debit card, or other payment method made available by Holafly. Payments are processed automatically using the payment method chosen by the user during the first purchase.

The User may choose to save the payment method during the payment process with the User’s explicit consent in accordance with data protection requirements and under the service provider’s administration, so that for future purchases this information is automatically added without the User having to re-enter it. If the User wishes to update their payment method, they may do so at any time in the “Account Details” section on the User account.

Certain payment methods made available by Holafly require the User to hold an active, pre-existing account or agreement with the relevant third-party payment provider. The availability and eligibility for the use of such payment methods are determined solely by the respective provider, and Holafly has no control over (and accepts no responsibility or liability for) any decision made by these providers regarding User access or use. The User acknowledges and agrees that the use of third-party payment services is governed exclusively by the provider’s own terms, conditions, and privacy policies. Accordingly, Holafly bears no responsibility for the provider’s handling of the User’s personal or transactional data, nor for any acts, omissions, errors, or service issues arising from the User’s engagement with such third-party providers.

To ensure the integrity of User transactions and to safeguard against fraud, Holafly may carry out verification and validation checks on the information provided by the User. Holafly will undertake these checks using procedures that are fair, proportionate, and transparent to the User.

1. Holafly reserves the right to screen all transaction details for indicators of potential fraud, unauthorised activity, sanctions compliance concerns, or other suspicious behaviour; and

2. Holafly may refuse or cancel an order where fraudulent, unauthorised, or illegal activity is reasonably suspected.

Where Holafly cancels an order under this clause, the User will be provided with a full refund of any amount paid for the affected order via the original payment method

If payment from a User is not successfully processed within five (5) days of the billing date, the Subscription Service may be suspended, including access to the Third-Party Benefits. If payment remains outstanding for thirty (30) consecutive days, the Subscription Service will be terminated, the eSIM will be deactivated permanently, and Holafly may instruct the Third-Party Providers to terminate the User’s access to their respective benefits. This termination does not exclude any legal action that Holafly may take against the User.

10. Legal Right of Withdrawal

If you are purchasing an Ultra Plan as a consumer, you have the legal right to withdraw from these Terms within fourteen (14) days from the date of purchase, without the need to provide any justification.

If you request or allow any part of the Subscription Service to begin during this 14-day withdrawal period (for example, by activating or using the eSIM, using an AirHelp benefit, or accessing a Meeting Doctors consultation), you expressly request that we begin supplying the Subscription Service during the withdrawal period, and you acknowledge that, to the extent permitted by applicable law, you may be required to pay a proportionate amount for the service supplied up to the time you notify us of your decision to withdraw.

If any service included in the Ultra Plan is fully performed within the 14-day period, you will lose your right of withdrawal in respect of that fully performed service only where, prior to performance, you provided your express request for immediate performance and your acknowledgment that you would lose the right to withdraw once the service was fully performed, where required by applicable law.

To exercise your right of withdrawal, you must inform us of your decision to withdraw from these Terms by an unequivocal statement. Please contact Holafly Limited, c/o Customer Support, the details of which can be found at the end of these Terms.

11. Refund and Returns Policy

You will receive the Subscription Service in conformity with these Terms. If you believe that the Subscription Service which has been delivered to you does not comply, or does not comply with your statutory consumer rights, please let us know. Where the Subscription Service is not in conformity, we will provide the remedies required under the Consumer Rights Act 2022, which may include bringing the service into conformity, a proportionate price reduction, or a refund where appropriate. Nothing in this clause affects your statutory rights.

For a full refund from Holafly based on a change-of-mind withdrawal during the fourteen (14) day withdrawal period, the User must meet the following requirements:

1. the Ultra Plan must have been purchased directly from Holafly via one of its direct sales channels (the Holafly website or the official Holafly phone app) and not from Third Parties;

2. no part of the Subscription Service must have been used, including activation or use of eSIM data, use of AirHelp services or benefits, or use of a Meeting Doctors consultation; and, where the User has registered a flight for the AirHelp benefit, the relevant flight must not have departed; and

3. the refund request must be submitted within fourteen (14) days from the date of purchase.

(These conditions apply only to refunds under the withdrawal right, not to statutory remedies for non-conformity.)

In addition to the withdrawal right according to these Terms, you may also be entitled to remedies under the Consumer Rights Act 2022 where the Subscription Service is not in conformity. These statutory remedies apply regardless of activation status. Remedies may include a proportionate reduction in price or a refund where the service cannot be brought into conformity:

4. If the Subscription Service fails to function as described, we will assess conformity under the Consumer Rights Act 2022 and provide the appropriate legal remedy.

5. Where the User purchases an Ultra Plan and downloads the eSIM onto an incompatible or locked Device, Holafly will provide the User with the remedy required by applicable consumer law and, where the conditions for a full change-of-mind refund under these Terms are met, a full refund.

Individual components of the Ultra Plan, including the Data Subscription Plan, AirHelp benefits and Meeting Doctors benefits, are not eligible for separate refunds. Any refund of the Ultra Plan will be assessed in accordance with this clause and applicable consumer law.

Where Holafly grants a refund that takes effect before the end of the current paid billing period, the User’s entitlement to use the Ultra Plan and its Third-Party Benefits ends when the refund becomes effective. Holafly will send the relevant Third-Party Providers an instruction to terminate access as soon as the refund is processed. Technical deactivation by a Third-Party Provider may take up to two (2) days, but any such technical delay does not extend the User’s entitlement to initiate new use of that benefit after the refund has become effective.

A refund or termination does not retrospectively invalidate a Third-Party Benefit validly used while the Ultra Plan was active, nor does it invalidate a claim arising from an event that occurred while the User was eligible for the relevant benefit. Any continuing claim submission or processing period is subject to the applicable Third-Party Provider terms, including any AirHelp claim submission period for qualifying events occurring while the Ultra Plan was active.

Where a refund or price reduction is granted because the connectivity service provided by Holafly has not been supplied in conformity with these Terms, Holafly may, where appropriate and without limiting the User’s statutory rights, calculate a proportionate refund by reference to the unused portion of the relevant billing period. At launch, Holafly will not apply a separate deduction corresponding specifically to the AirHelp or Meeting Doctors benefits when calculating such a refund.

12. Intellectual Property Rights

Except as otherwise indicated, the Data Subscriptions, eSIM and Subscription Services are our (or our licensor’s) proprietary property and all source code, databases, functionality, software, website designs, audio, video, text, photographs, and graphics on the Application (collectively, the “Content”) and the trade marks, service marks, and logos contained therein (the “Marks”) are owned or controlled by us or licensed to us, and are protected by copyright and trademark laws and various other intellectual property rights. Content, trade marks and materials made available by Third-Party Providers remain the property of the relevant Third-Party Provider or its licensors.

Except as expressly provided in these Terms, no part of the eSIM, the Application and no Content or Marks may be copied, reproduced, aggregated, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted, distributed, sold, licensed, or otherwise exploited for any commercial purpose whatsoever, without our express prior written permission.

13. Data Protection

By purchasing a Subscription Service, you acknowledge that Holafly will process personal information relating to you (“Personal Data”) for different purposes, including to make the Subscription Service available to you, to monitor, to improve the Subscription Service, to prevent unauthorised use of the Subscription Service, and to comply with our legal obligations.

For further information on how Users’ Personal Data is used or for any queries in relation to how we may process your Personal Data, please see our Privacy Policy available and our Cookies Policy.

14. Indemnity

The User agrees to indemnify and keep indemnified Holafly against all losses that are a direct and reasonably foreseeable result of the User’s material breach of these Terms or an unlawful misuse of the Subscription Service.

15. Limitation of Liability

To the extent permitted by law, we exclude all liability (whether arising in contract, in negligence or otherwise) for any loss or damage which you may incur in connection with your use of the Subscription Service, including the eSIM, any Data Subscription Plan or any Third-Party Benefit, except to the extent such liability arises from Holafly’s own breach of these Terms or cannot be excluded under applicable law.

We will not be liable for any loss that is not reasonably foreseeable at the time you enter into these Terms.

We will not be liable for (i) loss of profits, loss of business, business interruption, or (ii) indirect or consequential loss, in each case arising in connection with the Subscription Service.

AirHelp, Meeting Doctors and any other Third-Party Provider are responsible for the performance of the underlying Third-Party Benefits in accordance with their applicable terms. Holafly does not provide medical or healthcare services, does not assess or decide AirHelp claims, and does not assume responsibility for professional judgments or provider-specific decisions made by a Third-Party Provider. This allocation of responsibilities does not limit Holafly’s liability for its own acts or omissions, its obligations under these Terms, or any liability or consumer remedy that cannot be excluded or limited under applicable law.

Notwithstanding the foregoing, Holafly’s liability under or in connection with these Terms, whether arising from contract, negligence, or otherwise, shall in no event exceed the amount of charges payable by the User to Holafly under the relevant Ultra Plan in the 12 months preceding the date of the event giving rise to such liabilities having occurred, or €100, whichever is greater.

This does not affect our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, or any other liability which cannot be excluded or limited under applicable law.

Nothing in these Terms excludes or limits:

1. liability for death or personal injury caused by our negligence;

2. liability for fraud or fraudulent misrepresentation;

3. liability for wilful misconduct; or

14. any liability or consumer remedies that cannot be excluded or limited under applicable law, including your statutory rights under the Consumer Rights Act 2022.

16. Governing Law and Legal Compliance

Except as applicable mandatory laws may determine: (a) these Terms and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them or their subject matter or formation shall be governed by and construed in accordance with the laws of Ireland, and (b) the courts of Ireland shall have non-exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms or their subject matter or formation. Nothing in this clause affects your right, where provided for under applicable consumer protection law, to bring proceedings in the courts of your country of residence.

Other applicable mandatory laws of other states may also apply to your use of the eSIM, the Ultra Plan or the Third-Party Benefits. You may also benefit from mandatory consumer protection laws of your country of residence, and nothing in these Terms affects any such rights.

The Subscription Service, Ultra Plan, and the Application are not intended for use by any person or entity in any jurisdiction or country where such use would be contrary to relevant law or regulation. Accordingly, persons who choose to access the Subscription Service and/or Application from locations that prohibit such use do so on their own initiative and are solely responsible for compliance with local laws, if and to the extent local laws are applicable.

17. Variation of these Terms

We may vary these Terms or any future terms, including those relating to our Ultra Plan, on the following basis:

any updated Terms and new terms will be available on our Application, website or official page;

We will give you at least 30 days’ notice by email of any material variations to these Terms that are to your disadvantage, including changes to pricing, features, or limitations. You may cancel and stop using the Subscription Service before the change takes effect. If you continue to use the Subscription Service after the 30-day period, we will deem you to have accepted the changes. Changes that are exclusively to your benefit, purely administrative, or required by law may take effect without this notice period.

if you continue to use the Subscription Service, Ultra Plan, or eSIM after the variation of these Terms commences, you will be deemed to have accepted the variation.

18. Always On Backup Connectivity Service

From 4 November 2025 (CET), Holafly automatically provides you with the Always On Service, even if you stop your recurring plan, and at no extra charge. The Always On Service becomes available as your current paid subscription period ends.

The Always On Service provides data coverage in the following countries:

  • Europe: Albania, Andorra, Armenia, Austria, Azerbaijan, Belgium, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Georgia, Germany, Gibraltar, Greece, Guernsey, Hungary, Iceland, Ireland, Isle of Man, Italy, Jersey, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Moldova, Montenegro, Netherlands, North Macedonia, Norway, Poland, Portugal, Romania, Russia, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Ukraine, United Kingdom.

  • Asia: Bahrain, Bangladesh, Brunei, Cambodia, China, Hong Kong, India, Indonesia, Israel, Japan, Jordan, Kazakhstan, Kuwait, Kyrgyzstan, Laos, Macao, Malaysia, Pakistan, Philippines, Qatar, Saudi Arabia, Singapore, South Korea, Sri Lanka, Taiwan, Tajikistan, Thailand, Turkey, United Arab Emirates, Uzbekistan, Vietnam.

  • North America: United States, Canada, México.

  • Central America & Caribbean: Antigua and Barbuda, Bahamas, Barbados, Belize, British Virgin Islands, Cayman Islands, Costa Rica, Dominica, Dominican Republic, El Salvador, Grenada, Guatemala, Honduras, Jamaica, Nicaragua, Panama, Puerto Rico, St. Kitts and Nevis, St. Lucia, St. Vinc. & Gran., Turks and Caicos.

  • South America: Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, French Guiana, Paraguay, Peru, Suriname, Uruguay.

  • Africa: Algeria, Botswana, Burkina Faso, Cameroon, Central African Republic, Chad, Democratic Republic of Congo, Egypt, Eswatini, Gabon, Ghana, Guinea-Bissau, Ivory Coast, Kenya, Liberia, Madagascar, Malawi, Mali, Mauritius, Morocco, Niger, Nigeria, Republic of Congo, Reunion, Rwanda, Senegal, Seychelles, South Africa, Tanzania, Tunisia, Uganda, Zambia.

  • Oceania: Australia, Guam, Hawaii, New Zealand.

Holafly will endeavor to maintain the countries in which the Always On Service is available. However, from time to time, it may be necessary to remove countries from the available service coverage. The Always On Service is provided to you at no additional charge. It is not intrinsic to the operation of the purchased Data Subscription Plan, and any reduction to the countries it is available in does not constitute a material change to the contracted services.

The Always On Service provides you with a monthly data allowance of 1 GB. This allowance renews automatically every 30 days from the date that your eSIM plan ends on your Device (and not by reference to any calendar month).

The Always On Service remains available after your Ultra Plan ends, provided that:

  1. the eSIM remains installed on your Device;

  2. the eSIM remains turned on; and

  3. Data Roaming is enabled on your Device.

If you delete the eSIM from your Device, the Always On Service will automatically end and cannot be reinstated unless you purchase a new Subscription Service and install a new Holafly eSIM.

The availability, speed and performance of the Always On Service may vary depending on your destination, network conditions, and Device compatibility. Holafly does not guarantee uninterrupted availability of the Always On Service.

The Always On service is provided to Users at no additional charge, and therefore is not eligible for any refunds, whether partial or full, under any circumstances.

Nothing in this clause limits your statutory consumer rights or Holafly’s responsibility for the eSIM or the Always On Service to the extent required by applicable law.

19. Third-Party Benefits

The Ultra Plan is sold by Holafly as a single bundled subscription. It includes connectivity services supplied by Holafly together with access to Third-Party Benefits supplied by independent Third-Party Providers, initially AirHelp and Meeting Doctors. The Third-Party Benefits form part of the Ultra Plan for commercial and billing purposes but are provided by the relevant Third-Party Provider under the provider terms applicable to that service.

The User pays a single price to Holafly for the Ultra Plan. Third-Party Benefits included in the Ultra Plan cannot be purchased, cancelled, suspended or refunded individually through Holafly. Subject to applicable consumer law, cancellation of the Ultra Plan affects the bundle as a whole.

Before purchasing the Ultra Plan, the User will be given access to the terms applicable to the AirHelp and Meeting Doctors benefits and must accept them where required in order to receive those benefits. A Third-Party Provider may also request confirmation or renewed acceptance of its terms when the User first accesses its service. Those provider terms govern the underlying service provided by the relevant Third-Party Provider, while these Terms govern the User’s Ultra Plan subscription with Holafly, including billing, renewal, cancellation and access to the bundled benefits. Nothing in this Clause limits any mandatory rights the User may have against Holafly or a Third-Party Provider.

Holafly may add, remove or replace a Third-Party Provider or Third-Party Benefit during an Ultra Plan subscription. Where a change materially reduces the Ultra Plan or is otherwise materially disadvantageous to the User, Holafly will provide the notice and cancellation rights described in these Terms. Where a new or replacement benefit requires the User to accept additional provider terms, those terms will be made available before the User is required to use or activate that benefit.

Holafly is responsible for the obligations it assumes under these Terms, including subscription billing, the connectivity services it provides, and providing access to the bundled benefits as described. The relevant Third-Party Provider remains responsible for the performance of its underlying service, including professional, claims-handling or other provider-specific decisions. Nothing in these Terms excludes or limits any responsibility that cannot lawfully be excluded or any statutory rights the User may have in relation to the Ultra Plan.

20. AirHelp Services

The Ultra Plan includes access to certain flight disruption and baggage assistance services provided by AirHelp. AirHelp, and not Holafly, is responsible for administering those services, assessing and handling claims, and providing related support. Use of the AirHelp services is subject to the applicable AirHelp terms presented to the User in connection with the Ultra Plan.

The AirHelp benefits are intended for the primary Ultra Plan subscriber. They include assistance with eligible flight disruption compensation claims and baggage-related assistance, including the benefits described in the Application at the time of purchase. Eligibility, exclusions, required documentation, compensation amounts, baggage payout conditions and claim procedures are determined in accordance with the applicable AirHelp terms and applicable passenger rights rules.

AirHelp flight disruption assistance applies to qualifying flights taken while the Ultra Plan is active, including flights booked before the Ultra Plan was purchased where the subscription is active before the relevant flight date. Flights taken before the Ultra Plan start date are not eligible. Where permitted by the applicable AirHelp terms, a User may continue to submit or pursue a claim after the Ultra Plan ends if the relevant disruption occurred while the benefit was active, including during any applicable post-termination claim submission period.

Baggage assistance is subject to the applicable AirHelp terms and, as currently offered, is limited to the primary Ultra Plan subscriber and a maximum of one checked bag per flight. Claims and supporting evidence must be submitted through AirHelp in accordance with the documentation and time requirements communicated by AirHelp.

AirHelp claims, baggage requests and related support are handled through AirHelp’s platform. Holafly does not determine whether a flight or baggage event qualifies, does not assess the amount of compensation payable by an airline or insurer, and does not make claim decisions on AirHelp’s behalf.

21. Meeting Doctors Services

The Ultra Plan includes access to telehealth and wellbeing services provided by Meeting Doctors. Meeting Doctors, and not Holafly, is responsible for the healthcare and professional services provided through its platform, including any medical advice, diagnosis, treatment recommendation, prescription, report or other professional decision. Use of the Meeting Doctors services is subject to the applicable Meeting Doctors terms presented to the User in connection with the Ultra Plan.

The services currently available through the Ultra Plan include 24/7 medical chat for General Medicine and Pediatrics in English and Spanish, Gynecology and Veterinary chat in Spanish, General Medicine video consultations in Spanish, and scheduled wellbeing consultations such as Psychology, Nutrition and Personal Training, subject in each case to availability, the language selected, local law and the applicable Meeting Doctors terms.

Meeting Doctors provides remote telehealth and wellbeing services only. The benefit is not health insurance and does not include in-person medical care, emergency evacuation or hospital admission. The availability of prescriptions, medical reports and particular services may vary by country and is determined by Meeting Doctors in accordance with applicable law and its terms.

Users access the Meeting Doctors benefit through the Holafly Application and are then connected to the Meeting Doctors service for the relevant consultation. Holafly facilitates access to the benefit but does not supervise, control or validate the clinical or professional acts performed by Meeting Doctors or the professionals providing the service.

22. General

Holafly may assign, transfer, or subrogate to any company of its group the rights and obligations arising from these Terms without the express consent and authorisation of the User.

If at any time any provision of these Terms (or part of any provision) is or becomes illegal, invalid, or unenforceable but would be legal, valid, and enforceable if some part of it were deleted or modified, the provision or part-provision in question shall apply with such deletions or modifications as may be necessary to make the provision legal, valid, and enforceable.

No failure or delay by either party to exercise any right or remedy under these Terms shall be construed as a waiver of that right or remedy, nor shall any single or partial exercise of any right or remedy preclude the further exercise of that right or remedy. No waiver by either party of any breach by the other of any provision of these Terms shall be considered as a waiver of preceding or subsequent breach. The rights and remedies provided in under these Terms are cumulative and are not exclusive of any rights or remedies provided by law.

These Terms are drafted in the English language. In the event that there is a conflict between this English language version of these Terms and any translated copies of these Terms, the English version shall prevail.

23. Holafly Contact Details

For support, general enquiries or to issue a complaint, you can reach our team 24/7 through the following channels: