Privacy Policy

1. Data Controller

The data controller responsible for the processing of your personal data on esim-alrialo.online is:
eSIM Pathfinder
Berlin, Germany (Online Service)
Email: [email protected]
Phone: +49 30 1234 0404

We are dedicated to handling your personal information with care and in compliance with data protection regulations.

2. Data Collected

eSIM Pathfinder operates with a strong focus on data minimization. We only collect data that is strictly necessary for the purpose of providing our services and responding to your inquiries. The primary way we collect personal data is through our contact form.

When you use our contact form on esim-alrialo.online, we collect the following information:

• Your Name: To address you personally and identify your inquiry.
• Your Email Address: To respond to your message and communicate with you regarding your inquiry.
• Your Message: The content of your inquiry, which may contain other personal details you choose to disclose.

We do not actively collect any other personal data through our website for tracking or profiling purposes. We do not require you to create an account or provide extensive personal details to browse our informational content.

3. Cookies and Local Storage

eSIM Pathfinder is committed to a privacy-first approach. We only use cookies or local storage where absolutely essential for the basic functionality of the website and to respect your choices.

Specifically, our website esim-alrialo.online uses:

• Cookie Consent Mechanism: We may use a single local storage item or a temporary cookie to record your preference regarding our cookie policy, ensuring that we don't repeatedly ask for consent on subsequent visits within a reasonable timeframe. This helps us comply with legal requirements and improve your browsing experience.

We explicitly state that:

• No Tracking Cookies: We do not use any cookies for tracking your browsing behavior across our site or other websites.
• No Analytics Cookies: We do not employ any cookies for website analytics (e.g., Google Analytics, Matomo, etc.).
• No Advertising Pixels: We do not integrate any advertising pixels or similar technologies that collect data for targeted advertising.
• No Third-Party Cookies: We do not allow third-party cookies on esim-alrialo.online.

You can typically control cookies through your browser settings. Most browsers allow you to refuse or accept cookies, or to delete specific cookies. However, please note that if you choose to block all cookies, the functionality of some websites, including potentially our cookie consent mechanism, might be affected.

4. Legal Basis for Processing

The processing of your personal data by eSIM Pathfinder is based on specific legal grounds as required by data protection regulations:

• Legitimate Interest (Art. 6(1)(f) GDPR): When you submit an inquiry via our contact form, we process your name, email, and message based on our legitimate interest in responding to your communication, providing customer support, and improving our services. We ensure that this interest is balanced against your fundamental rights and freedoms.
• Consent (Art. 6(1)(a) GDPR): In specific instances, we may ask for your explicit consent for certain data processing activities. If we do, you will be clearly informed about the purpose of the processing, and you will have the right to withdraw your consent at any time.
• Compliance with Legal Obligations (Art. 6(1)(c) GDPR): In rare cases, we may need to process your data to comply with legal obligations, such as responding to lawful requests from public authorities.

We do not process your data for purposes incompatible with the ones for which it was originally collected, unless we have obtained your explicit consent or are legally obliged to do so.

5. Data Sharing and Disclosure

eSIM Pathfinder does not sell, trade, or otherwise transfer your personally identifiable information to outside parties. Your privacy is paramount, and we are committed to keeping your data confidential.

We will only disclose your personal data in the following limited circumstances:

• Service Providers: We may engage trusted third-party service providers to assist us in operating our website or conducting our business, such as hosting providers or email communication platforms. These parties are contractually obligated to keep your information confidential and are only permitted to use your data for the specific purposes for which we have engaged them, and in compliance with data protection laws.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• Protection of Rights: We may disclose your information when we believe it is appropriate to protect the rights, property, or safety of eSIM Pathfinder, our users, or others.

We do not engage in any form of third-party analytics or advertising, meaning your data is not shared with such entities for those purposes.

6. Retention Period

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Specifically:

• Contact Inquiries: Information submitted through our contact form (name, email, message) will be retained for a period of up to 12 months from the date of your last interaction. This allows us to refer back to previous communications if you have follow-up questions or if we need to track the resolution of an issue. After this period, the data will be securely deleted or anonymized.
• Cookie Consent Preferences: Your cookie consent preference (stored locally) will be retained for a period consistent with legal requirements, typically up to 12 months, or until you clear your browser's local storage/cookies.

In some cases, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Your Data Protection Rights

Under applicable data protection laws, including the GDPR, you have several important rights concerning your personal data. eSIM Pathfinder is committed to facilitating the exercise of these rights:

• Right to Access (Art. 15 GDPR): You have the right to request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16 GDPR): You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Art. 17 GDPR - "Right to be Forgotten"): You have the right to request the deletion of your personal data under certain circumstances (e.g., if the data is no longer necessary for the purposes for which it was collected).
• Right to Restriction of Processing (Art. 18 GDPR): You have the right to request that we restrict the processing of your personal data under certain conditions (e.g., if you contest the accuracy of the data).
• Right to Data Portability (Art. 20 GDPR): You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to Object (Art. 21 GDPR): You have the right to object to the processing of your personal data where we are relying on a legitimate interest as the legal basis for processing (see Section 4).
• Right to Withdraw Consent (Art. 7(3) GDPR): Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the legally required timeframe.

8. Right to Complain to a Supervisory Authority

If you believe that eSIM Pathfinder has not complied with its obligations under applicable data protection laws, you have the right to lodge a complaint with a supervisory authority.

For individuals in the European Union, the relevant supervisory authority is typically the data protection authority in your country of residence or the authority responsible for the data controller's location. As eSIM Pathfinder is based in Berlin, Germany, the primary supervisory authority for us would be:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin, Germany
Email: [email protected]

We encourage you to contact us directly at [email protected] first, so we can attempt to resolve any concerns you may have regarding your privacy.

9. Changes to This Privacy Policy

eSIM Pathfinder reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors.

We will notify you of any significant changes by posting the new Privacy Policy on esim-alrialo.online with a new "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our website after any modifications indicates your acceptance of the updated Privacy Policy.

10. Contact Us

If you have any questions about this Privacy Policy, our data practices, or if you wish to exercise any of your data protection rights, please do not hesitate to contact us:

eSIM Pathfinder
Berlin, Germany (Online Service)
Email: [email protected]
Phone: +49 30 1234 0404