In short
- Kiazo Mobile is the data controller.
- Your data is processed only for the purposes and legal grounds listed.
- You may exercise your rights under Article 11 of the KVKK.
Under Turkish Personal Data Protection Law No. 6698 (“KVKK”), as data controller we inform you about how your personal data is processed.
Data controller
PAYKIAZO BILGI TEKNOLOJILERI TICARET ANONIM SIRKETI
Personal data processed
- Identity: first and last name
- Contact: email, phone
- Customer transactions: orders, invoices and plan details
- Transaction security: IP address, session logs
- Marketing: communication preferences, only with explicit consent
- Ad measurement: only with your explicit consent, the Google Ads click ID, the order amount and the hashed email address
Purposes
- Entering into and performing the contract
- Creating and delivering the eSIM profile
- Billing and meeting legal obligations
- Customer support
- Information security
- Only with your explicit consent, measuring how well ad campaigns work
Legal grounds
Data is processed under KVKK Art. 5/2 for performance of contract, legal obligation and legitimate interest; marketing communications and ad measurement with marketing cookies rely on your explicit consent under Art. 5/1.
Transfers
Data may be transferred, to the extent required to deliver the service, to payment providers, the eSIM profile provider, local carriers and suppliers acting on our behalf, in line with KVKK Art. 8. Transfers abroad are listed by recipient and country in the next section.
Transfers abroad (KVKK Art. 9)
To provide the service, we transfer personal data to the recipients named below with their countries. These transfers rely on the standard contracts published by the Turkish Personal Data Protection Board under KVKK Art. 9(4). Each standard contract is notified to the Board within five business days of signature.
Where a standard contract cannot be used and the transfer is occasional, data is transferred on the basis of your explicit consent under KVKK Art. 9(6)(a), after you have been informed of the possible risks. You may withdraw your consent at any time. Recipients and their countries:
- Stripe (Ireland, USA): processing card, Apple Pay and Google Pay payments and fraud checks; identity, contact and transaction data.
- Lava (Russia): payments made with Lava payment methods; contact and transaction data.
- eSIM Access (Hong Kong) and the local mobile carriers in the countries you travel to: creating and delivering the eSIM profile and providing connectivity; order and plan data.
- ZeptoMail / Zoho (EU, India): sending order, sign-in code and account emails; name and email address.
- Google / Firebase (USA): app notifications, only if you allow them, and Sign in with Google, only if you choose it; device notification token and sign-in data.
- Apple (USA): app notifications, only if you allow them, and Sign in with Apple, only if you choose it; device notification token and sign-in data.
- The hosting provider that runs our servers: the data kept for the service, in the country where the servers are located and under the same safeguards.
- Google Ads (Google Ireland Limited, Ireland; Google LLC, USA): ad conversion measurement, only if you allow marketing cookies; the ad click ID, the order number, amount and currency, and the email address hashed in your browser. This transfer rests on your explicit consent given in the cookie notice (KVKK Art. 9/6-a); withdraw it through “Cookie preferences”.
Your rights (Art. 11)
- Learn whether your data is processed
- Request information about processing
- Learn the purpose and whether it is used accordingly
- Know third parties to whom data is transferred
- Request correction of incomplete or inaccurate data
- Request erasure or destruction
- Claim compensation for damages
Applications
Send requests to kvkk@kiazo.mobile or in writing to our registered address. Requests are resolved free of charge within 30 days.
Have a question?
Send us any questions about our legal documents and we’ll reply within 3 business days.