About Us

Talkesim provide a simple and powerful eSIM solution for individual consumers and enterprises that provides cellular roaming services for phone calls and internet bandwidth, while offering its users different roaming services options, by connecting to international and local roaming service providers, to enable its users to utilize the best roaming plan. This website is available through: Talkesim| About us, (or any linked domains) (the “Website”). By registering an account or otherwise using or accessing, visiting or using any our Website, our application as may be updated from time to time, (eSIM product(s) and related services (collectively the “ Services”) you understand and agree to the terms of this policy. Please read this policy carefully.

The Website and related Services are operated by Talkesim LLC., incorporated in the State of Turkiye, and their affiliates (the “ Company”, “Talkesim”, “ we,” or “us”).

This privacy policy provides you with information about how we handle and protect the Personal Information (as defined below) that we collect, use or otherwise process about any user that access and engages with our Website and Services (referred to as “ User”, “you” or "your"). This Website is not intended to be used by children under the age of 18.

What Personal Information do we collect about you?

As you use the browse and interact with our Website and Services, we collect and process certain Personal Information directly from you and/or automatically generate it as you use our Website and Services, as detailed here:

• Personal Information that you give to us:
• Website and Technical information collected and processed through our Services
• Your Contact information
• Information about Payments
• Information we Collect from Other Sources
• Sensitive Personal Data
• Children's Privacy

Use of Tracking technologies and Cookies

To help make the Website usable we use certain necessary cookies to allow basic functions like page navigation and access to secure areas of the Website, to improve your user experience and preferences.

Necessary Cookies

• persist:root - This cookie stores visitor credentials in an encrypted cookie in order to allow the visitor to stay logged in on reentry, if the visitor has accepted the 'stay logged in' button.
• rc::a - google.com - Persistent - This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their web site.
• rc::c - google.com - Persistent - This cookie is used to distinguish between humans and bots.

Preferences Cookies

• i18nextLng - talkesim - Persistent - Determines the preferred language of the visitor. Allows the website to set the preferred language upon the visitor's re-entry.

How do we use the Personal Information we collect and process about you?

We collect and process the Personal Information where it is necessary for the adequate performance of the contract regarding the your engagement with our Web and Services.

• To allow you to access the Website and related Services;
• To provide technical support;
• To ensure that the Website and Services are functioning correctly and to monitor, investigate any bug with, and improve them;
• To process payments you make via a third party service provider, PCI certified payment vendor (Tranzila);
• For research purposes and for further analysis and statistics, where data will be anonymized where possible, to improve our Website (for example, we analyze information collected through cookies to help us understand behavior when accessing the Website); and
• To improve your user experience; for example, change the location of certain buttons in the screens in our Website and Services.
• To communicate with you, to respond to any of your questions or requests, including any data subject's rights requests, to update, notify and inform you on any updates concerning our Website and our Services.
• To analyze and compile information, including statistical information collected from all our users, for modelling structure or to allow us to decide on certain changes in connection with your use of our Services and/or Website.
• For data security.
• To create aggregated statistical data, inferred Non-Personal Information or anonymized or pseudonymized data (rendered non-personal), which we or our subsidiaries may use to provide and improve our respective services;
• If it is in our legitimate interests, for business development and marketing purposes:

What is our legal justification for using your Personal Information?

We will only use your Personal Information for the purposes set out in this privacy policy where we have a "legal basis" for handling it. This means that at least one of the following conditions apply in each situation where your personal information is used by us:

• Performance of a contract: Our use of your Personal Information is necessary to enable the use of the Website and Services, and our contractual obligations to our users;
• Our use of your Personal Information is necessary for complying with our legal obligations: for example, if we are requested to disclose your Personal Information to regulatory bodies or law enforcement authorities;
• Where neither (a) nor (b) apply, use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Website and Services).
• With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent to such specific purposes at any time: for example, we ask for your consent to send you newsletters or provide you with personalized content;

With whom do we share your Personal Information?

Except as disclosed in this privacy policy, Talkesim do not share your Personal Information with any outside parties. We share your Personal Information to authorized third parties, as described below:

• Third-Parties Service providers: we share Personal Information with our trusted service providers including technical, IT, hosting (including cloud base computing services, such as OVH), logistical or administrative services providers and, accountants, consults, insurers, as well as other outsourcing services that may be required to provide our services and operate our Website and certain Services functionalities, for the purposes stated in this privacy policy only or upon your request.
• Legal requirements: to the extent required or authorized by law, if we think it is necessary to comply with the law or if we need to do so to protect or defend our legal rights, or the rights of others (including to investigate and protect our users from fraudulent or unlawful use of the Website), we will share your Personal Information with third parties requiring information for legal reasons or third party investigators, authorities, regulators or law enforcement bodies.
• Official Authorities. We may need to disclose Personal Information in response to lawful requests by public authorities or law enforcement officials, law enforcement requirements.
• Marketing: We may use authorized third parties services providers that may assist us in our marketing, advertising and promotional activities of our Services;

How is your personal information transferred outside of the EEA?

The Personal Information will be used, stored and/or accessed by staff operating outside the EEA working for us, our affiliates or third-party suppliers.

• In accordance with Article 46.2 of the General Data Protection Regulation (GDPR), include the standard contractual clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties; or
• In accordance with Article 45 of the GDPR, ensure that the country in which your personal information will be handled (such as the State of Turkiye, where our Company is based) has been deemed "adequate" by the European Commission.

How long do we keep your personal information for?

We will only retain your Personal Information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). If you withdraw your consent to us processing your Personal Information, we will erase your Personal Information from our systems, unless the data is required for the Company to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.

How do we keep your personal information secure?

We use appropriate technical and organizational measures to protect personal information against accidental or unlawful destruction or accidental loss, alteration unauthorized disclosure or access, in accordance with applicable law. We use, among other things, encryption mechanisms and other protections to maintain confidentiality, privacy and prevent unauthorized interruption into our data base(s) and Personal Information, and review these mechanisms from time to time.

• In the course of provision of your Personal Information to us, your Personal Information is likely to be transferred over the internet and/or stored on a cloud-based server. Although we make every effort to protect the Personal Information which you provide to us, the transmission of information over the internet and storage in a cloud-based server is not completely secure. As the communications with the Services is done by means of the internet, and as an online platform, we cannot guarantee that the use of the App and Services or the interaction therewith will be 100% free viruses, worms, Trojans, and all other malware which are otherwise out of our reasonable control.
• As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to or automatically created by the Services we offer and that any such transmission is at your own risk. We will not be liable for any damage caused by such unauthorized access or use, as long as we adhere to acceptable information procedures and measures.
• Please note that you are responsible for the use of personally identifiable information and your device. For example: in order to protect your Personal Information from data incidents such online fraud ("phishing"), as do not provide identifying information to others (e.g. by e-mail), make sure that the contact information you provide us (including your phone number and e-mail address) is correct. You should take steps to protect against unauthorized access to your device by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private, use anti-virus measures, and computer security means on your end equipment from which you browse our Website. You should make sure to update software, downloads only from official sites, use encryption, avoid using public computers or public WIFI networks, do not share sensitive information on social networks.
• If you are concerned that information that you provided to us about you has reached unauthorized third parties, please contact us immediately at our chat channel or at: info@talkesim.com
• Where there is a concern that you have violated this Privacy Policy or our a concern to our users data security, we may, at any time, suspend or disable your access to our Website temporarily or permanently, in addition to any other remedy that may be available to us under applicable law.

What choices and rights do you have regarding your personal information?

Access or correct your personal information. If you wish to access the personal information we process about you, or exercise your rights in relation to such personal information under applicable law, you may contact us at: info@talkesim.com

Rights of individuals in the European Union:

• Confirm whether or not Personal Information about you is being processed;
• Provide you with further details about how we process your Personal Information;
• Provide you with a copy of any Personal Information which we hold about you;
• Update/correct any of your Personal Information;
• Delete any Personal Information which we hold about you;
• Restrict the way that we process your Personal Information;
• Consider any valid request to transfer your Personal Information to a third-party provider of services (data portability);
• Consider any valid objections which you have to our use of your Personal Information.

You can send us your request with respect to such rights at: info@talkesim.com. We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note that those rights do not always apply and there are certain exceptions to them. We will also need to confirm your identity before acting on certain requests. Please note, as set forth in this Privacy Policy, we may share Personal Information about you with third parties. You are aware and hereby acknowledge that, if you ask us to update or delete information about you, we will not be able to update or delete information that was shared and held by such third parties which is subject to their own terms and privacy policies. If you have a complaint about how we use your Personal Information, we would always prefer you to contact us first. However, you may also make a complaint to your local data protection authority in the EU country where you are based. If you are unsure which data protection authority to contact, please contact us at info@talkesim.com

Does this privacy policy apply to third party links?

During your visit to our Website you may access links to other websites operated by third parties outside Talkesim. Please note that this privacy policy only applies to the Personal Information that we (or third parties on our behalf) collect from or about you and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or third-party terms and conditions or policies.

How do we approach changes to this privacy policy?

We will change this privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page with the “last updated” date at the bottom of this page amended accordingly. You are responsible for viewing these Privacy Policy periodically for updates by checking the ‘Updated’ date which appears at the top of this Policy. Your continued use of our Web and the Services after a change, modification, or update of this Policy has been made shall constitute your acceptance of the updated Policy. If you do not agree to this Privacy Policy after such an update, your are requested to stop using our Web and Services and your sole remedy shall be to discontinue your use of the Services and to cancel any account(s) you may have created for use of the Services.

Governing Law and Jurisdiction

This Privacy Policy will be governed and interpreted pursuant to the laws of the State of Turkiye without giving effect to its choice of law rules. You expressly agree that the exclusive jurisdiction for any claim or action arising out of or relating to this Privacy Policy shall be to the competent courts in Istanbul, Turkiye, to the exclusion of any other jurisdiction.

Contact us

If you have any comments or questions regarding this privacy policy or the Personal Information practices in connection with our website and related services, please contact us at: info@talkesim.com. Our offices address Octopay Kurumsal Danışmanlık Hizmetleri A.Ş , Istasyon mah. Ayhan sok. Yelken sitesi. B. BL. D:4 Tuzla/Istanbul/Turkiye. e-mail : info@talkesim.com