BitBrain Academy AG Communication and Automation Industry Ltd, operating as eSIM-Türkiye, acknowledges and highly values the importance of your privacy. This privacy policy outlines the collection and utilization of personal information. eSIM-Türkiye reserves the right to periodically modify this privacy policy, as outlined in section '9. Changes to This Policy' below. By creating an account or accessing/using any of eSIM-Türkiye's websites, applications, products, software, tools, data feeds, and/or services (collectively referred to as the "Service"), you acknowledge and agree to the terms detailed in this policy. Please take the time to thoroughly review this policy.

If you have any unresolved concerns about privacy or data usage that have not been adequately addressed, please contact us directly at [email protected] or refer to section '7. How Does A User Change Or Update Information' for more information.

eSIM-Türkiye is committed to protecting your privacy. This privacy notice explains how we collect, use, disclose, retain, and safeguard your personal information.

Several key principles under GDPR:

• Relevant Data: The controller must only collect data that is strictly necessary for processing, adhering to the principle of minimal collection.
• Clear Purpose: The controller must explicitly inform the customer about the use of their personal data at the time of collection.
• Rights of Individuals: Individuals have the right to access, rectify, or delete the personal data held by the controller.
• Retention Period: Personal data should be retained for the duration necessary for the controller to achieve its purpose; after this period, the data must be deleted.

1.What Information Do We Collect?

1.1. Personally-Identifiable Information

We collect personally identifiable information when you knowingly provide it to us. This may occur when you sign up for our newsletter or chat, create an account, request more information on our contact us page, respond to a survey or questionnaire, and provide personal information such as your email address, name, phone number, or other relevant details. In accordance with applicable law, personally identifiable information includes personal data.

1.2. Sensitive Personal Data

Please refrain from providing or disclosing any sensitive personal information, such as social security numbers, details concerning racial or ethnic origin, political opinions, religious or other beliefs, health-related data, biometric or genetic characteristics, criminal background, or trade union membership, through our services or otherwise. If such sensitive personal data is inadvertently sent or disclosed to us when submitting content through our services, you thereby consent to our processing and utilization of said sensitive personal data in compliance with our policy. If you do not agree to our processing and use of this sensitive personal data, please refrain from submitting such content. It's important to note that even if this information is provided, we will not store it on our side.

1.3. Non-Personally-Identifiable Information

We may gather and combine non-personally identifiable information that does not individually or in combination allow for your identification by itself or with other data accessible to a third party. This data might encompass details such as the referring website, your IP address, browser specifications and language, hardware specifications, geographical location, and the times and durations of access. Additionally, we might accumulate navigation-related data, including the content or pages of the service you view, the links you interact with, and other activities associated with the service. We utilize this information to analyze usage patterns, aiding in the enhancement of the Service.

1.4. Cookies, Pixels and Local Storage

We might gather data through the use of cookies, small files stored on your computer or mobile device's hard drive by a website. These cookies may be both session-based (which expire upon closing your web browser) and persistent (which remain until deleted) to offer a more personalized and interactive experience while using the Services. Our use of cookies falls into two primary categories: (1) first-party cookies, exclusively served by us to recognize your device when revisiting any site or application within the Services, and (2) third-party cookies, served by service providers on sites or applications, allowing such providers to identify your device when visiting other websites.

2. Cookies We Use

2.1. Type of Cookies

The Services employ various types of cookies serving different purposes:

• Strictly Necessary Cookies: These cookies are essential for accessing the Services, allowing you to use specific features like logging into secure areas and facilitating fast loading of content.
• Functionality Cookies: They help in remembering your preferences, language settings, login details, and adjustments made to your account or preferences, aiming to provide a personalized experience.
• Performance Cookies: Used to collect aggregated data about service traffic and usage patterns without identifying individual visitors, enabling more efficient operation and monitoring of service activity.
  We utilize Google Analytics for this purpose, which uses its own cookies. More information about Google Analytics cookies can be found here. You can learn about Google's data protection here. To opt-out of Google Analytics, you can use this link.
• Targeting Cookies / Advertising Cookies: These deliver relevant ads, control ad frequency, and measure campaign effectiveness. They're often placed with the operator's permission by advertising networks, remembering website visits and sharing information with other organizations.

2.2. Disabling Cookies

Information about disabling cookies, Google AdWords Conversion Tool, and opt-out options can be found at the provided links.

2.3. Facebook Custom Audiences

Explanation about Facebook communication tools, the generation of non-personal checksums, and opt-out information can be found in the provided links.

2.4. Pixel Tags

Pixel tags, also known as web beacons, are used to track user actions without storing data on users' devices, assisting in marketing campaign success and content management.

2.5. Do Not Track Signals

Information is provided regarding the Services' response to "Do Not Track" signals and where to find further details on the topic.

3. What Do We Do With The Information That We Collect?

3.1. Information That We Collect

Information Collection and Usage

eSIM-Türkiye does not share personal information with outside parties except as disclosed in this privacy policy. Your provided personally identifiable information is used for specific purposes:

• Operating, maintaining, and enhancing the Services
• Managing accounts, communication, and customer service
• Administering promotions and sending necessary information
• Processing payments and complying with applicable laws

Sharing of Information

We may share information with service providers for necessary functions and use data to offer improved services. With consent, marketing emails and messages may be sent. Data may be transferred to MailChimp for processing, following their Privacy Policy and Terms.

Data Retention and User Rights

We retain your information as required for service provision or as permitted by law. Users can access, correct, or request the deletion of their data. Opting out may affect certain service functionalities.

eKYC Information

For identity verification, an electronic Know Your Customer (eKYC) check may be required, partnering with Jumio for verification purposes, ensuring data is not stored in our systems.

4.Disclosure of Information

eSIM-Türkiye prioritizes safeguarding your personally identifiable information and generally refrains from disclosing it except in the following circumstances:

1. When we have your explicit permission, including the permission granted through your acceptance of this Privacy Policy.
2. In good faith, when legally required by relevant statutes, regulations, ordinances, court orders, or subpoenas.
3. If the disclosure is essential to rectify false or misleading information, address manipulative or deceptive activities, or respond to violations of the law; or if you are informed at the time of data collection.
4. When sharing your information is necessary to provide the product or service you've requested.
5. In cases of a sale, merger, transfer, or disposition of business assets or stock, where disclosure is made under confidentiality restrictions. eSIM-Türkiye may share non-personally identifiable information, in aggregate form only, with advertisers and partners.

5.Children’s Policy

The Terms of Service explicitly state that Users must:

1. Be 18 years or older, or
2. Be 13 years or older if (a) an emancipated minor or (b) possess legal parental or guardian consent.

eSIM-Türkiye does not knowingly collect personally identifiable information from users under 13 years of age. If we become aware that we have unintentionally gathered personal information from a user under the age of 13, we will take steps to identify and remove that information from our database.

6.International Usage

The Service, owned by eSIM-Türkiye, is accessible in Europe and globally. For data protection, eSIM-Türkiye acts as the controller and, unless specified otherwise, is the data processor. Information collected might be stored, processed, and accessed in jurisdictions where privacy laws might differ and offer less protection compared to your home jurisdiction.

eSIM-Türkiye has engaged third-party service providers to handle logistics and customer support for an efficient 24/7 service. Some data must be shared with and transferred to these third parties to ensure service fulfillment. All involved third parties are bound by confidentiality agreements and have limited access to eSIM-Türkiye's database solely for providing support.

7.How to Change or Update Information

If you have inquiries or concerns regarding this privacy policy or wish to have your personally identifiable information removed from our records, please reach out to eSIM-Türkiye via email at [email protected].

8.Security and Encryption

We adhere to widely accepted industry standards to safeguard your personal information. While we employ physical, electronic, and procedural measures to maintain the confidentiality of online-collected information, it's essential to note that no method of transmission or electronic storage is entirely secure.

Our service incorporates security measures to mitigate the risk of data loss, misuse, or alteration. We utilize standard Secure Socket Layer (SSL) encryption for transmitted information and maintain all service data on secure servers. Stored data access is fortified with multi-layered security controls, including firewalls, role-based access, and password protection.

It is your responsibility to ensure the security of your password. If you suspect that the security of your interaction with us has been compromised, please promptly notify us by contacting [email protected].

9.Changes to This Policy

We retain the right to modify the terms of this privacy policy at any time. In case of any alterations, we will update the "last updated" date at the top of the policy. Should there be significant changes in this statement or in the way we intend to use your personal information, we will notify you by prominently displaying the changes here, on our home page, or by sending you an email. We encourage you to review this policy whenever you visit our websites or applications.

2023 BitBrain Academy AG Communication and Automation Industry Ltd

All rights reserved.