Privacy Policy

Privacy Policy

Last Updated: 26/09/2026

1. Introduction

Welcome to the “My Esim” app and website (hereinafter, the “Service”). This Privacy Policy (“Policy”) explains how Noveria Dijital Teknolojiler Limited Şirketi (trading as “Noveria Digital”), registered with the Istanbul Trade Registry under no. 1151424 (MERSİS no. 0632159200900001), with its registered office at Küçükbakkalköy Mah. Selvili Sk. No: 4 İç Kapı No: 20, Ataşehir / Istanbul, Türkiye (“Company,” “we,” or “us”), collects, uses, stores, and shares your personal data when you use our Service.

The Company is the data controller of your personal data under the EU General Data Protection Regulation (GDPR), where applicable, and the Turkish Law on the Protection of Personal Data No. 6698 (KVKK). This Policy also serves as our information notice under Article 10 of KVKK.

By accessing or using the Service, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, please do not use the Service.

2. Data We Collect

  1. Account Information: When creating an account or purchasing an eSIM, we may request:
    • First and Last Name
    • Email Address
    • Phone Number
  2. Location Data:
    • If you explicitly grant permission through your device settings (e.g., enabling “Precise Location”), we collect precise location data (GPS) to provide customized push notifications and location-based features.
    • You can revoke this permission or disable precise location sharing at any time in your device’s settings.
    • If you choose not to grant permission or disable precise location, the Service may only collect approximate location (e.g., city/country) or no location data at all, depending on your settings.
  3. Transaction Data: Payment-related details (e.g., purchase amount) are primarily processed by Stripe. We do not store or handle your full card details.
  4. eSIM Data: Technical details of the eSIMs you purchase, such as the eSIM identifier (ICCID), activation status and data usage, so that we can deliver, manage and support your eSIM.
  5. Usage & Analytics Data: We utilize tools such as Google Analytics and Meta App Events to gather information about your interactions with the Service (e.g., pages visited, in-app actions, purchases). This information helps us improve user experience and measure advertising performance.
  6. Advertising & Attribution Data (Mobile App): When you use our mobile app, we may collect and process app event data used for advertising measurement and attribution, such as app installs, app opens, account registration, viewing of eSIM plans, checkout starts, purchases (including amount and currency), and eSIM activation status. Depending on your device permissions and settings, this may also include advertising identifiers (for example, IDFA on iOS or Advertising ID on Android).
  7. Support Communications: When you contact us by email, phone, WhatsApp or Viber, we process your contact details and the content of your messages in order to respond to and resolve your request.

We process your personal data for the purposes below. For each purpose we state the legal basis under Article 6 GDPR and Article 5 KVKK. Where we rely on consent, this means explicit consent (açık rıza) under KVKK.

  1. Service Provision: We use your personal data to complete the eSIM purchase, activate and manage your account, and provide customer support. Legal basis: performance of a contract.
  2. Notifications & Alerts:
    • We may send push notifications related to your eSIM usage or your location (e.g., availability of new packages or offers), provided you have granted permission.
    • If you have chosen to enable “precise location,” you may receive more tailored location-based alerts.
    • Legal basis: your consent, given through your device permissions, which you can withdraw at any time in your device settings.
  3. Promotional/Marketing Purposes: If you consent, we may use your email or phone number to send mass emails/SMS with special offers, new products, or updates about the Service. You can opt out at any time. Legal basis: your consent.
  4. Analytics & Service Improvement: We use analytics tools (e.g., Google Analytics) to understand how users interact with the Service, enabling us to enhance its features and performance. Legal basis: your consent where required by applicable law; otherwise our legitimate interest in improving the Service.
  5. Legal Compliance: We may process your data if required by law, court order, or governmental request, or if necessary to protect our legal rights. Legal basis: compliance with a legal obligation and the establishment, exercise or defence of legal claims.
  6. Advertising Measurement & Attribution: We use this data to measure the performance of our advertising campaigns (including Meta/Facebook ads), attribute installs and in-app actions to ads, prevent fraud, and improve our marketing effectiveness. On iOS, we may request your permission via Apple’s App Tracking Transparency prompt before accessing certain tracking identifiers. You can change this permission at any time in your device settings. Legal basis: your consent where required by applicable law; otherwise our legitimate interest in measuring advertising performance and preventing fraud.

4. Sharing Your Data with Third Parties

  1. Stripe: Payments are processed through Stripe. We share only the necessary data (e.g., amount, transaction reference) to complete your purchase.
  2. MailChimp & Similar Platforms: For sending newsletters or SMS (if you have consented), we share your email/phone number.
  3. Google Analytics: We use Google Analytics for usage statistics, which generally involves aggregated or anonymized data about your activity on our website/app.
  4. Meta (Facebook): We use the Meta SDK and App Events in our mobile app. We may share app event and advertising measurement data with Meta to run and measure advertising campaigns and attribute installs and purchases. Meta processes such data under its own privacy policy: https://www.facebook.com/privacy/policy
  5. Other Service Providers: We may use additional third-party providers (e.g., eSIM connectivity providers that issue and operate your eSIM, hosting providers, software development partners) who process data on our behalf, under contractual obligations to protect it.
  6. Legal Obligations: We may disclose data if required by law or if we believe in good faith that it is necessary to comply with legal obligations, protect rights, or prevent illegal activities.

We do not sell or rent your personal data to third parties for their own marketing purposes.

5. Data Retention

We retain your personal data for as long as you have an account with our Service and/or as necessary to provide our services (e.g., eSIM activation, purchase history). If you close your account or request deletion, we will delete or anonymize your data unless we are legally required to keep it (e.g., for accounting or tax record-keeping obligations under Turkish law).

6. Your Rights

Under the GDPR (and other applicable laws), you have the right to:

  • Access your personal data and request a copy.
  • Rectify or update any inaccurate data.
  • Erase (right to be forgotten), especially if there is no legal basis for retaining it.
  • Restrict the processing of your data.
  • Object to the processing of your data for direct marketing purposes, and to processing based on our legitimate interests.
  • Data Portability, where technically feasible.
  • Withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
  • Lodge a complaint with a data protection supervisory authority, in particular in the EU member state of your habitual residence (in Greece for example: the Hellenic Data Protection Authority, www.dpa.gr).

Where KVKK applies, you also have the rights set out in Article 11 of KVKK, including the right to learn whether your data is processed, to know the third parties in Türkiye or abroad to whom it is transferred, to object to a result against you arising exclusively from automated analysis, and to claim compensation for damage caused by unlawful processing. You may also lodge a complaint with the Turkish Personal Data Protection Authority (KVKK Kurumu, www.kvkk.gov.tr).

To exercise your rights or request more information, please contact us as described in Section 10. We will respond within the time limits set by law (one month under the GDPR; 30 days under KVKK).

7. Data Security and International Transfers

  1. Security Measures: We employ technical and organizational measures (e.g., TLS encryption, access controls) to protect your data.
  2. Storage Location: Data is stored on servers within the European Union. The Company is established in Türkiye and accesses this data from Türkiye in order to operate the Service.
  3. International Transfers: Some third-party services (e.g., Google, MailChimp, Meta, Stripe) may process data outside the EU and Türkiye, including in the United States. Where such transfers occur, we rely on the appropriate safeguards required by applicable law, such as the European Commission’s Standard Contractual Clauses and, where Turkish law applies, the safeguards and procedures set out in Article 9 of KVKK.

8. Children and Minors

Our Service is intended for adults (18+). We do not knowingly collect personal data from individuals under 16. If you are a parent/guardian and believe your child has provided us with personal information without your consent, please contact us so we can delete the relevant data.

9. Policy Updates

We may update this Privacy Policy whenever necessary. The “Last Updated” date at the top indicates when the latest changes were made. Any changes become effective upon posting the revised Policy on our Service. We encourage you to review this page periodically for the latest information.

10. Contact Us

If you have any questions about this Policy or wish to exercise your rights, please contact us:

  • Data Controller: Noveria Dijital Teknolojiler Limited Şirketi (trading as “Noveria Digital”)
  • Address: Küçükbakkalköy Mah. Selvili Sk. No: 4 İç Kapı No: 20, Ataşehir / Istanbul, Türkiye
  • Email: support@myesim.gr

Requests under KVKK may also be submitted in writing to our registered address or by any other method permitted under Turkish law.

Thank you for using “My Esim”!