1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy set out below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section ‘Information on the controller’ in this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter in a contact form.

Other data is collected by our IT systems automatically or after your consent when you visit the website. This is mainly technical data (e.g. internet browser, operating system or time of the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the data transmitted will also be processed for contract offers, orders or other order enquiries.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

Analysis tools and third-party tools

When you visit this website, your browsing behaviour may be statistically evaluated. This is done mainly with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. Hosting

We host the content of our website with the following provider:

External hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, metadata and communication data, contract data, contact details, names, website access data and other data generated via a website.

External hosting is carried out for the purpose of performing the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act), insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

Our host(s) will process your data only to the extent necessary to fulfil its/their performance obligations and will follow our instructions with regard to this data.

We use the following host(s):

HOSTINGER operations, UAB

Švitrigailos str. 34, Vilnius 03230 Lithuania

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected.

Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Information on the controller

The body responsible for data processing on this website is:

Daniel Fraidych

Rudolf-Wilhelm-Str. 76

66131 Saarbrücken

Phone: +49 160 5741177

Email: service@povnomad.com

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a justified request for erasure or withdraw your consent to data processing, your data will be erased unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, erasure will take place once these reasons cease to apply.

General information on the legal bases for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, where special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your terminal device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of § 25(1) TDDDG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data where it is required to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR.

Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the legal bases relevant in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of personal data

In the course of our business activities, we work together with various external bodies. In some cases, this also requires the transfer of personal data to these external bodies. We only pass on personal data to external bodies if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR or if another legal basis permits the disclosure of the data. When using processors, we only pass on our customers’ personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.

Access, rectification and erasure

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to rectification or erasure of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.

How to make a request and how long it takes us

Please send requests concerning your rights — access and a copy of your data, rectification, erasure, restriction, data portability and objection — to service@povnomad.com, ideally from the email address linked to your account or your order. We confirm receipt and respond without undue delay, and at the latest within one month (Art. 12(3) GDPR); if, in an exceptional case, we need longer, we will tell you so, together with the reason, within that month. We delete an account within 30 days of a request by email; in the app, this happens immediately. If we have reasonable doubts about who is making the request, we will ask for additional information to verify your identity (Art. 12(6) GDPR). This is free of charge for you.

Record of your request. So that we can prove that we handled your request on time, we store the date of receipt, the type of request, your email address, the subject line, a shortened excerpt of your message, the deadline, and how and when we dealt with it. Legal basis: Art. 6(1)(c) GDPR in conjunction with Art. 5(2) and Art. 12 GDPR. We delete the excerpt of your message after 12 months and the rest of the record three years after the request has been closed. So that we can recognise such requests at all, a copy of the messages sent to service@povnomad.com runs through our automation service Make (processor, EU); only what indicates a request concerning your rights is kept there, and everything else is not processed further.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.

If we no longer need your personal data but you need it for the exercise, defence or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.

If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address bar of the browser changes from ‘http://’ to ‘https://’ and by the padlock symbol in your browser bar.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to promotional emails

We hereby object to the use of contact details published within the scope of the legal notice obligation for sending advertising and information materials that have not been expressly requested. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, for example by spam emails.

4. Data collection on this website

Cookies

Our website uses so-called ‘cookies’. Cookies are small data packets and do not cause any damage to your terminal device. They are stored on your terminal device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or until they are automatically deleted by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies may be used to evaluate user behaviour or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping basket function) or to optimise the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is stated. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent can be withdrawn at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

You can find out which cookies and services are used on this website in this privacy policy.

We use Real Cookie Banner to accept, reject or customise the use of cookies.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be collected.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with us until you ask us to delete it, withdraw your consent to storage or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Enquiry by email, telephone or fax

If you contact us by email, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be withdrawn at any time.

The data you send to us via contact requests will remain with us until you ask us to delete it, withdraw your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

We process personal data that you provide when placing an order in our online shop (e.g. name, billing address, delivery address, email address, payment data). The processing is carried out for the performance of the contract on the basis of Art. 6(1)(b) GDPR. We store this data until the statutory retention periods have expired.

Payments in our shop are processed via payment service providers such as Stripe or PayPal. In this process, payment information (e.g. credit card data, name, billing address, email address) is transmitted to the respective provider. The processing is carried out exclusively for the purpose of payment processing (Art. 6(1)(b) GDPR, performance of the contract). Further information: Stripe: https://stripe.com/de/privacy · PayPal: https://www.paypal.com/de/webapps/mpp/ua/privacy-full

When an eSIM is activated, technical data of your terminal device (e.g. device identifier or IMEI) may be transmitted to the respective telecommunications provider. This transmission takes place exclusively for the purpose of providing and using the eSIM and is technically the responsibility of the respective network operator. We ourselves do not pass on any personal data to third parties unless this is necessary for the performance of the contract.

5. Social media

Facebook

Elements of the social network Facebook are integrated on this website. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. According to Facebook, however, the data collected is also transferred to the USA and other third countries.

You can find an overview of the Facebook social media elements here: https://developers.facebook.com/docs/plugins/?locale=de_DE.

When the social media element is active, a direct connection is established between your terminal device and the Facebook server. As a result, Facebook receives the information that you have visited this website with your IP address. If you click the Facebook ‘Like button’ while you are logged into your Facebook account, you can link the content of this website to your Facebook profile. This allows Facebook to associate the visit to this website with your user account. Please note that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by Facebook. Further information on this can be found in Facebook’s privacy policy at: https://de-de.facebook.com/privacy/explanation.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be withdrawn at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. You can find the wording of the agreement at:

https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the data protection information when using the Facebook tool and for the privacy-compliant implementation of the tool on our website. Facebook is responsible for the data security of the Facebook products. You can assert data subject rights (e.g. requests for access) regarding the data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:

https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/4452.

Instagram

Functions of the Instagram service are integrated on this website. These functions are offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

When the social media element is active, a direct connection is established between your terminal device and the Instagram server. As a result, Instagram receives information about the visit to this website by you.

If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking the Instagram button. This allows Instagram to associate the visit to this website with your user account. Please note that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by Instagram.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be withdrawn at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. You can find the wording of the agreement at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the data protection information when using the Facebook or Instagram tool and for the privacy-compliant implementation of the tool on our website. Facebook is responsible for the data security of the Facebook or Instagram products. You can assert data subject rights (e.g. requests for access) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:

https://www.facebook.com/legal/EU_data_transfer_addendum, https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381.

Further information on this can be found in Instagram’s privacy policy: https://privacycenter.instagram.com/policy/.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link:

https://www.dataprivacyframework.gov/participant/4452.

Voucher campaign on Instagram

On our Instagram profile @povnomad_ we run a voucher campaign: if you comment a keyword under one of our posts or send us “CODE” as a direct message, we automatically send you a direct message with a personal voucher code. To receive it, you need to follow our profile.

Data we process: your Instagram username, the user ID assigned by Instagram, the content of your comment or message, and whether you follow our profile. We only check the latter with Instagram at the moment of your request.

Purpose and legal basis: sending the voucher you requested and answering your questions about it. The legal basis is Art. 6(1)(b) GDPR, as you request the voucher yourself.

Service providers: We send the automated messages via the automation platform Make, operated by Celonis s.r.o., Křižíkova 148/34, 186 00 Prague, Czech Republic. A data processing agreement is in place with Celonis. For transfers of data by Meta to third countries, see the section “Instagram”.

Voucher code: The code is stored in our shop system. We do not store any Instagram data there. We derive the code pseudonymously from your user ID so that you receive the same code if you ask more than once.

Evaluation: To measure the success of the campaign, we store pseudonymised records of which steps were completed (e.g. request, follow confirmed, code created), each with a timestamp but without your username or Instagram ID. This data is held by our processor Supabase in a data centre in Frankfurt am Main and deleted after twelve months. The legal basis is our legitimate interest in measuring the success of our promotion (Art. 6(1)(f) GDPR).

Retention: Your messages remain in our Instagram inbox until you or we delete the chat. We delete unredeemed voucher codes once they expire. Redeemed codes are kept as part of the order in line with statutory retention obligations.

6. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. Further data is not collected or is collected only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw the consent you have given to the storage of the data and the email address and their use for sending the newsletter at any time, for example via the ‘Unsubscribe’ link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the withdrawal.

The data you have deposited with us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter or once the purpose no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6(1)(f) GDPR.

Data stored by us for other purposes remains unaffected by this.

After you have been removed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, if this is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

In addition, we also use your email address, which we have received in connection with the sale of goods or services, for direct marketing of our own similar products (§ 7(3) UWG (German Act against Unfair Competition) in conjunction with Art. 6(1)(f) GDPR). You can object to this use at any time without incurring any costs other than the transmission costs according to the basic rates. You will find a corresponding notice in every email. An objection can be sent informally to service@povnomad.com.

7. Plugins and tools

YouTube with enhanced data protection

This website embeds videos from the website YouTube. The operator of the website is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of the pages of this website on which YouTube is embedded, a connection to the YouTube servers is established. In the process, the YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your browsing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in privacy-enhanced mode. According to YouTube, videos played in privacy-enhanced mode are not used to personalise browsing on YouTube. Advertisements displayed in privacy-enhanced mode are also not personalised. No cookies are set in privacy-enhanced mode. Instead, however, so-called local storage elements are stored in the user’s browser, which, similar to cookies, contain personal data and can be used for recognition. Details on privacy-enhanced mode can be found here: https://support.google.com/youtube/answer/171780.

After a YouTube video has been activated, further data processing operations may be triggered over which we have no influence.

YouTube is used in the interest of an appealing presentation of our online offerings.

This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

Further information on data protection at YouTube can be found in its privacy policy at: https://policies.google.com/privacy?hl=de.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Fonts (local hosting)

For the uniform display of fonts, this site uses so-called Google Fonts, which are provided by Google. The Google Fonts are installed locally. No connection to Google servers takes place in the process.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de.

Google Maps

This site uses the map service Google Maps. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of this service, we can embed map material on our website.

To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. If Google Maps is activated, Google may use Google Fonts for the purpose of displaying fonts uniformly. When you call up Google Maps, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

Google Maps is used in the interest of an appealing presentation of our online offerings and to make the locations indicated by us on the website easy to find. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:

https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

More information on the handling of user data can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=de.

The company is certified under the ‘EU-US Data Privacy Framework’ (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.

Contact information:

If you would like to get in touch with us to find out more about this policy, or if you would like to contact us about a matter concerning your personal rights and your personal data, you can send an email to service@povnomad.com.

8. Analytics, advertising and other services on this website

We use the following services on povnomad.com in addition to those described above. Services that set cookies or collect data for analytics or advertising purposes are only loaded after you have given your consent in the cookie banner (Art. 6(1)(a) GDPR, § 25(1) TDDDG). You can withdraw your consent at any time via the privacy settings in the footer.

Google Analytics 4 and Google Tag

This website uses Google Analytics 4 via the Google Tag. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables us to statistically evaluate the behaviour of website visitors (pages viewed, time spent on the site, origin, device used, purchases). For this purpose, cookies such as _ga and _ga_* are set (lifetime of up to 2 years). Google Analytics 4 does not store complete IP addresses. The data collected is usually transferred to Google servers in the USA. Google is certified under the EU-US Data Privacy Framework; in addition, the standard contractual clauses of the EU Commission apply. Use takes place exclusively on the basis of your consent in the cookie banner; the usage data is deleted by Google after 14 months. Details: https://policies.google.com/privacy.

OpenAI Ads Pixel (advertising in ChatGPT)

We place advertisements in ChatGPT and measure their success with OpenAI’s advertising pixel. The provider is OpenAI Ireland Ltd, 1st Floor, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, Ireland, with data processing by OpenAI, L.L.C., 1455 3rd Street, San Francisco, CA 94158, USA. If you reach our website via a ChatGPT advertisement, a click identifier is stored in the first-party cookie __oppref (lifetime of up to 90 days). If you complete an order, the pixel transmits the event ‘Order’ with the order value, currency and this click identifier to OpenAI so that we know which advertisements lead to purchases. No names, email addresses or address data are transmitted. The data transfer to the USA takes place on the basis of the standard contractual clauses of the EU Commission. The pixel is only loaded with your consent in the cookie banner. Details: https://openai.com/policies/privacy-policy/.

Google reCAPTCHA

In the shopping basket and at checkout, we use Google reCAPTCHA v3 (provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to prevent misuse by automated programs. reCAPTCHA analyses the visitor’s behaviour in the background (e.g. IP address, time spent on the site, mouse movements) and transmits this data to Google, usually to servers in the USA (certification under the EU-US Data Privacy Framework). The service is only loaded after your consent in the cookie banner. Without consent, the ordering process remains possible. Details: https://policies.google.com/privacy.

Trustpilot (reviews and review invitations)

We embed review widgets from Trustpilot. The provider is Trustpilot A/S, Pilestræde 58, 5th floor, 1112 Copenhagen, Denmark. When the widget is loaded, a connection to Trustpilot servers is established and your IP address is transmitted; the widget is only loaded after your consent in the cookie banner. After an order has been completed, we also transmit your name, your email address and the order number to Trustpilot so that you are invited once by email to review your purchase. The legal basis is our legitimate interest in genuine customer reviews (Art. 6(1)(f) GDPR) in conjunction with § 7(3) UWG. You can object to this use at any time, for example by email to service@povnomad.com or via the unsubscribe link in the invitation. Details: https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.

Google Customer Reviews

On the order confirmation page, you may be shown an opt-in dialogue from Google Customer Reviews (Google Ireland Limited). Only if you actively agree there will your email address and order data be transmitted to Google so that Google can ask you for a review. Without your consent, no transmission takes place (Art. 6(1)(a) GDPR).

AI chatbot (POVNOMAD Bot)

On our website, you can ask questions to an AI-powered chatbot. Your entries are transmitted to our AI service providers in order to answer them: OpenAI Ireland Ltd, 1st Floor, The Liffey Trust Centre, 117–126 Sheriff Street Upper, Dublin 1, Ireland, and Anthropic Ireland, Limited, 6th Floor, South Bank House, Barrow Street, Dublin 4, Ireland. Processing may take place on servers in the USA; the basis for this is the standard contractual clauses of the EU Commission. We do not store the conversation histories permanently in our system. Please do not enter any sensitive data (e.g. payment data, passwords) in the chat; for matters relating to your order, the order number is sufficient. The legal basis is your consent through the use of the chat or our legitimate interest in fast customer service (Art. 6(1)(a) and (f) GDPR).

WhatsApp customer service with AI assistant

You can contact us via WhatsApp at +49 160 5741177. Using this service is voluntary. You can also resolve any query by email to service@povnomad.com.

What data we process. If you write to us via WhatsApp, we process your phone number and your WhatsApp profile name, the content of your messages, images you send us (for example screenshots of your mobile network settings) and voice messages, the times and delivery status of the messages, and our replies. If you give us an order number or ICCID, we match the chat to your order. Please do not send us any payment or identity data, or any data about other people, via WhatsApp; for screenshots, the area showing the mobile network settings is sufficient.

Purposes and legal bases. We process this data to answer your enquiry and resolve problems with your eSIM. If your enquiry relates to an order or an intended purchase, the legal basis is Art. 6(1)(b) GDPR; for general enquiries, it is our legitimate interest in fast, round-the-clock customer service (Art. 6(1)(f) GDPR). For the automated evaluation by our AI service provider, we have weighed our interest in fast and accurate error diagnosis against your interest in disclosing as little data as possible. That is why we only ask for screenshots of the relevant area and allow you to request purely personal handling at any time (see below). We also evaluate the chats in pseudonymised form to improve our support: for example, how often which issues occur, which reply templates we are still missing and how good the AI assistant’s replies are. For this we only use texts without your phone number and your name, only within the 90-day storage period and without disclosure to third parties. The legal basis is our legitimate interest in good customer service (Art. 6(1)(f) GDPR); you can also object to this evaluation at any time (see below).

Shipping confirmation via WhatsApp. If you provide your WhatsApp number during the ordering process, we will use it to send you the shipping confirmation, information about your eSIM and instructions on topping up. The messages are sent via the automation platform Make (see ‘Order processing: eSIM supplier and automation’) and the WhatsApp Business Platform. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR). We do not send advertising via WhatsApp. You can unsubscribe from these messages at any time by replying ‘STOP’.

AI assistant. Incoming text and image messages may be evaluated by an AI system that recognises the language, the device and the likely problem (for example, mobile data roaming switched off). For this we use the AI model Qwen3-VL, a freely published model (open-weight model) that Amazon Web Services operates for us in Ireland. The developer of the model (Alibaba Cloud) does not receive any data, and no data is transferred to China. On this basis, the assistant can send you replies from text templates that we have pre-formulated and approved. At the start of every enquiry, we inform you in the chat that an AI assistant will respond first (Art. 50 AI Act). Voice messages are not evaluated automatically, but are only listened to by our agents. The AI assistant does not make any decisions against you: decisions on replacement eSIMs, goodwill gestures and refunds are generally made by our service agents. There is one exception if you ask for a refund: our system can then trigger it automatically if fixed rules set by us are met (the eSIM has not been used, we have been able to identify you as the buyer, and the money is only returned to the original payment method). Whether these rules are met is checked by our system using the order data and the eSIM status at our supplier, not by the AI alone. This automated decision (Art. 22 GDPR) is only made at your request and only in your favour; it serves to perform our contract with you (Art. 22(2)(a) GDPR). If the rules are not met, the assistant does not refuse your request but forwards it to our agents. If you type ‘agent’, a person will review your query at any time; you can also put forward your point of view.

Recipients and transfer to third countries.

You can obtain a copy of the standard contractual clauses on request from service@povnomad.com. Our service phone also uses the WhatsApp Business App. WhatsApp Ireland Limited is itself responsible for data that WhatsApp processes for its own purposes in this process (for example usage and device data); its privacy policy applies: https://www.whatsapp.com/legal/privacy-policy-eea.

Storage period. We automatically delete messages, images and the AI assistant’s evaluation from our system 90 days after they are received. If the chat relates to a business transaction (for example a refund), we retain the messages relevant to it for as long as this is legally required (up to 6 years, § 147 AO (German Fiscal Code)). Amazon Web Services does not store the content transmitted for AI evaluation, does not use it to train AI models and does not pass it on to the developer of the model. We delete the chat history in the WhatsApp app on our service phone as soon as it is no longer needed for handling your query, and at the latest upon your request.

Objection and personal handling. You can object at any time to the processing based on our legitimate interest (Art. 21 GDPR). To do so, type ‘no AI’ in the chat: from that point on, your query will be handled exclusively by our agents, without AI evaluation. If you instead type ‘agent’, we will forward your query to our agents; until they reply, our AI assistant can continue to help you. Since your first message may already be evaluated automatically before you object, the objection applies to further handling. If you would prefer no AI evaluation from the outset, please write to us at service@povnomad.com. Your other rights (access, rectification, erasure, restriction, data portability, complaint to a supervisory authority) are described above in this privacy policy.

Order processing: eSIM supplier and automation

To provide your eSIM, we transmit order data (selected package, order number, destination country) to our eSIM supplier, which provides the eSIM profile in the mobile network of the country of travel. Your email address and your name are only transmitted in the process insofar as this is necessary for the provision, activation or support of the eSIM. For the automated processing of orders (forwarding to the supplier, sending the eSIM email, status synchronisation), we use the automation platform Make of Celonis s.r.o., Křižíkova 148/34, 186 00 Prague, Czech Republic, as well as database and server services from Supabase (see the section on the app). Data processing agreements are in place with these service providers. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR).

Installation page (go.povnomad.com)

In our emails and WhatsApp messages, the “View my eSIM” button takes you to our own installation page at go.povnomad.com; in the POVNOMAD app, the “Open install page” button takes you there. The address contains a random key with no connection to your person. When you open the page, it loads from our database only what belongs to this eSIM: package, data allowance and validity, POVNOMAD-Code for the app, the deadlines, the status, the ICCID, the activation date, and the SM-DP+ address and activation code. If the eSIM is already active, it also shows your data usage so far together with the time of the last synchronisation and, based on this, a projection of how long your data will last at the same rate; these figures come from our own database, the page does not query our supplier for them, and if the last synchronisation was more than 30 days ago, it shows no usage figures at all. It does not show your name, your email address or the order number. The page does not set any cookies and does not embed any third-party content. When the page is accessed, we technically process your IP address: our web host (Hostinger) writes it, together with the time and the address accessed, to the server log files, as described in the section “Server log files”. The same applies to the query to our database service provider (Supabase): there, too, the time, IP address and address accessed are recorded in the access log; it is deleted there after 1 day. Because the address contains the key, the key is also included in these logs. In addition, we create a hash of your IP address using a secret key in order to slow down mass requests; we do not store the address itself for this purpose, and we delete the hash after 2 days at the latest. For the link itself, we store when we created it, how often and when it was last opened, and whether and why we blocked it. If your eSIM is already installed, the page only shows the activation code when you expressly request it again. After a withdrawal, a refund, a 30-day return, a cancellation or the deletion of your account, we block the link. If an eSIM is given as a gift, it receives a new link. Topping up always takes you from the page to the app. If you tap “Install on this iPhone” on an iPhone, Apple’s installation page (esimsetup.apple.com) opens, and your device transmits the SM-DP+ address and activation code to Apple; Apple processes this data under its own responsibility. On Android 13 and later, the same button is available as “Install on this Android”: it opens Google’s setup page (esimsetup.android.com) and also passes the SM-DP+ address and activation code to it; Google, too, processes this data under its own responsibility. The same applies to the same button in the app. Legal basis: Art. 6(1)(b) GDPR; rate limiting and counter: our legitimate interest in protecting the installation data against links being tried out (Art. 6(1)(f) GDPR).

Storage period. For the installation link, we store the number of times it has been opened and the time it was last opened until 12 months after the link expires or is blocked; if it has no expiry date, 16 months after it was created. We delete the hash of your IP address from accessing the installation page after 2 days at the latest; the rate limit itself already lapses after 24 hours. The access log of our database service provider contains the time, IP address and the address accessed (including the key) for 1 day. For the server log files of our web host, the section “Server log files” applies.

Recipients and transfer to third countries.

Feedback on your eSIM (go.povnomad.com/feedback)

If you indicate in the POVNOMAD app that your eSIM is not working as expected (thumbs down), we reply by email with tips that match the status of your eSIM. To do this, we compare your feedback with the status and data usage of your eSIM, which we retrieve from our eSIM supplier. For plans with a daily data allowance (Unlimited), we also store the usage level every hour to detect whether the daily allowance has been reached and the speed has therefore been reduced. A few days later, we ask by email whether your eSIM is working now. Both emails go to the email address of your account or, if you have no account, to the address of your order; we send them via Resend (Resend, Inc., USA, processor; standard contractual clauses). The button in the follow-up email leads to our page at go.povnomad.com/feedback. The address contains a random key with no reference to you; we only store a hash of it. The page shows your email address only in shortened form (for example “ma•••@gmail.com”); it does not show your name or order number. There you can tell us whether your eSIM works, tap notes (for example “Data roaming is on”), write us a text and request help, a replacement eSIM or a refund. We store your selection with the time, and your text only in encrypted form. If you tap thumbs down or make a request, we notify our service team by email to our service mailbox and with a short WhatsApp message to our service phone; in the WhatsApp message, your email address and phone number appear only in shortened form. The page does not set cookies and does not embed any third-party content; the links to review platforms only open their pages. When you open the page, our web host (Hostinger) writes your IP address, together with the time and the address accessed (including the key), to the server log files, as described in the section “Server log files”. The page transmits the key to our database service provider (Supabase) only in the body of the request, so it does not appear in their access log; the time and IP address are kept there for one day. Legal basis: Art. 6(1)(b) GDPR; for the follow-up email and the hourly usage level, our legitimate interest in detecting and following up on reported problems with your eSIM (Art. 6(1)(f) GDPR).

Voluntary WhatsApp number and different reply address. On the page, you can voluntarily provide a WhatsApp number so that we can reach you faster about your request, and a different email address for our reply. Without these details, we handle your request in exactly the same way and reply by email. We use the number only to contact you about this request, for example for questions or help with setting up your eSIM, and never for advertising; we do not add it to your customer account or your order. We store the number and address encrypted with AES-256 in our database (Supabase, Frankfurt am Main); afterwards, the page shows them only in shortened form. Only our service team sees them in full, in the notification to our service mailbox. If you change the reply address, we inform the previous address to protect against forwarded links, without stating the new one in full. If we write to you via WhatsApp or you reply to us there, the section “WhatsApp customer service with AI assistant” applies. The legal basis for the WhatsApp number is your consent (Art. 6(1)(a) GDPR), for the reply address Art. 6(1)(b) GDPR. You can withdraw your consent at any time with effect for the future, by email to service@povnomad.com or by WhatsApp message; we will then delete the number.

Storage period. We automatically delete your text, a changed reply address and your WhatsApp number 90 days after our follow-up email; if you have made a request, 90 days after it has been completed, but no later than 12 months after the request. The link to the page then stops working. Your selection (thumbs, tapped notes, type of request) remains with your feedback from the app without text or contact details and is deleted together with it after 24 months. We delete the hourly usage levels after 40 days. The section “Enquiry by email, telephone or fax” applies to the notifications in our service mailbox.

Orders via Amazon and eBay

If you buy an eSIM via our shop on Amazon (Amazon EU S.à r.l., 38 avenue John F. Kennedy, L-1855 Luxembourg) or eBay (eBay GmbH, Albert-Einstein-Ring 2–6, 14532 Kleinmachnow), we receive from the platform the data required for processing (name, order number, where applicable an email address assigned by the platform, product purchased) and transfer it to our shop system in order to provide the eSIM. The data processing on the respective platform is governed by its privacy notices. The legal basis is the performance of the contract (Art. 6(1)(b) GDPR).

Content delivery networks (amCharts, jsDelivr)

For the interactive world map, we load map libraries from cdn.amcharts.com (amCharts, Vilnius, Lithuania) and, for the display of emojis, the Twemoji library from cdn.jsdelivr.net (jsDelivr, operated by Prospect One, ul. Królewska 65a/1, 30-081 Kraków, Poland). When loading, your IP address is transmitted to the respective provider; no cookies are set in the process. The legal basis is our legitimate interest in a fast and error-free presentation of the website (Art. 6(1)(f) GDPR).

Checkout and payment

For the ordering process, we use the shop system WooCommerce with the extensions Germanized and FunnelKit; these run on our server, so no transfer to third parties takes place as a result. Payments are processed via Stripe (incl. Apple Pay, Google Pay and credit card) and PayPal; further details can be found in the sections on the payment services.

Reminder after an incomplete purchase. If you do not complete a purchase on our website or in the app, for example because the payment was declined or cancelled, we send you a single email to the order’s address about 30 minutes later. It says that we have not sent an eSIM yet and have not charged anything, which plan you had chosen and at what price, plus a link to try again. If you have paid in the meantime, with the same email address or the same account, we do not send it. Each email address receives at most one such reminder in 7 days. If there are many unpaid orders within a short time, we send none, as this suggests misuse. The email contains no advertising. For this we process the order details (email address, first name, plan, price, time, language and status). We store a copy of the email with the time and delivery result as proof and delete it after 12 months. Legal basis: Art. 6(1)(b) GDPR, because the reminder concerns the purchase you started. Comparing it with your other orders and limiting it to one reminder is based on our legitimate interest in not sending you unnecessary emails and in detecting misuse (Art. 6(1)(f) GDPR). If you do not want such reminders, a short message to service@povnomad.com is enough.

This section last updated: 7 October 2026.

Privacy notice for the POVNOMAD app (Android)

Controller

Daniel Fraidych · Rudolf‑Wilhelm‑Str. 76 · 66131 Saarbrücken Email: service@povnomad.com · Phone: +49 160 5741177

What data the app processes

Account & login. To access purchased eSIMs, you enter your email address and receive a one‑time access link by email (valid for 1 hour). For this purpose, we process your email address and a technical access token. Legal basis: Art. 6(1)(b) GDPR (performance of a contract).

Orders & eSIMs. To display and manage your eSIMs, we process order data (order ID, plan booked, billing email), eSIM identifiers (ICCID), activation/installation data (QR code content, APN) and usage data (used/remaining data volume, current network, status). Legal basis: Art. 6(1)(b) GDPR.

Trip planning (optional). Destinations/trips you add yourself and countries you have visited are stored and assigned to your account in order to display trip and eSIM suggestions. Legal basis: Art. 6(1)(b) or (a) GDPR.

Payment. Purchases and top‑ups are processed via a secure web checkout (payment service provider Stripe, incl. Google Pay). You enter payment data (e.g. card details) directly with the payment service provider; the app itself does not store any complete payment data. Legal basis: Art. 6(1)(b) GDPR.

Contact/support (optional). For queries, you can voluntarily provide a WhatsApp number; support email and a chatbot are also available. In the case of contact via WhatsApp, Meta’s privacy policy also applies.

Technical data. For the provision, error diagnosis and security, technical connection data (e.g. IP address, time, basic app/device information) is processed by our back‑end services (Art. 6(1)(f) GDPR).

Local storage on your device. So that your eSIM data and the QR code are also available offline, the app stores the eSIM list (ICCID, QR content, installation links, plan, APN, country) and the QR image locally on the device. This data does not additionally leave the device and is deleted when you log out.

Recipients / processors of the app

Where processing takes place outside the EU, we base the transfer on EU standard contractual clauses or the EU‑US Data Privacy Framework. Data processing agreements (Art. 28 GDPR) are in place with processors.

Storage period

eSIM and order data is stored for as long as your account exists or statutory retention periods (under tax/commercial law) are running. Access tokens expire after 1 hour. Local device data is removed when you log out.

Your rights & deleting your account

You have the rights of access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR) as well as the right to lodge a complaint with a supervisory authority.

Delete account: directly in the app under Settings → Delete account, or by email to service@povnomad.com.

Privacy notice for the POVNOMAD app (iOS)

Controller

Daniel Fraidych · Rudolf‑Wilhelm‑Str. 76 · 66131 Saarbrücken Email: service@povnomad.com · Phone: +49 160 5741177

What data the app processes

Account & login. To access purchased eSIMs, you enter your email address and receive a one‑time access link by email (valid for 1 hour). For this purpose, we process your email address and a technical access token. Legal basis: Art. 6(1)(b) GDPR (performance of a contract).

Orders & eSIMs. To display and manage your eSIMs, we process order data (order ID, plan booked, billing email), eSIM identifiers (ICCID), activation/installation data (QR code content, APN) and usage data (used/remaining data volume, current network, status). Legal basis: Art. 6(1)(b) GDPR.

Trip planning (optional). Destinations/trips you add yourself and countries you have visited are stored and assigned to your account in order to display trip and eSIM suggestions. Legal basis: Art. 6(1)(b) or (a) GDPR.

Payment. Purchases and top‑ups are processed via a secure checkout (payment service provider Stripe, incl. Apple Pay). Google Pay is not available on iOS and is therefore not used. You enter payment data (e.g. card details) directly with the payment service provider or via Apple Pay; the app itself does not store any complete payment data. Legal basis: Art. 6(1)(b) GDPR.

Contact/support (optional). For queries, you can voluntarily provide a WhatsApp number; support email and a chatbot are also available. In the case of contact via WhatsApp, Meta’s privacy policy also applies.

Technical data. For the provision, error diagnosis and security, technical connection data (e.g. IP address, time, basic app/device information) is processed by our back‑end services (Art. 6(1)(f) GDPR).

Local storage on your device. So that your eSIM data and the QR code are also available offline, the app stores the eSIM list (ICCID, QR content, installation links, plan, APN, country) and the QR image locally on your device. Your access token is stored encrypted in the iOS keychain (Keychain). This data does not additionally leave the device and is deleted when you log out.

Recipients / processors of the app

Where processing takes place outside the EU, we base the transfer on EU standard contractual clauses or the EU‑US Data Privacy Framework. Data processing agreements (Art. 28 GDPR) are in place with processors.

Storage period

eSIM and order data is stored for as long as your account exists or statutory retention periods (under tax/commercial law) are running. Access tokens expire after 1 hour. Local device data is removed when you log out.

Your rights & deleting your account

You have the rights of access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR) as well as the right to lodge a complaint with a supervisory authority.

Delete account: directly in the app under Settings → Delete account, or by email to service@povnomad.com.