Privacy Policy for “Travel eSIM” Service
Prepared in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Act CXII of 2011 on Informational Self-Determination and Freedom of Information (Privacy Act).
Introduction
This Privacy Policy is issued by Telemeteor Kft. (the “Data Controller”) to inform Users about how their personal data is processed in connection with the Travel eSIM service.
Telemeteor Kft. handles all personal data in compliance with applicable data protection laws, including GDPR and the Hungarian Privacy Act.
Name and Contact Details of the Data Controller
- Company Name: Telemeteor Korlátolt Felelősségű Társaság (Telemeteor Kft.)
- Registered Address: 1044 Budapest, Julianus barát utca 1/B, 4/49, Hungary
- Email (Privacy Inquiries): privacy@telemeteor.com
- Website: www.telemeteor.com
Principles of Data Processing
In accordance with GDPR, Telemeteor Kft. ensures that personal data is:
- Processed lawfully, fairly, and transparently.
- Collected for specific, explicit, and legitimate purposes.
- Adequate, relevant, and limited to what is necessary for service provision.
- Accurate and kept up to date.
- Stored securely and protected against unauthorized access, loss, or destruction.
Data Protection Officer (DPO) Contact Information
Telemeteor Kft. ensures compliance with GDPR and handles data protection matters internally. However, the company does not have a formally appointed Data Protection Officer (DPO), as it is not legally required.
For any questions or concerns regarding data protection and privacy, Users may contact Telemeteor Kft. at:
- Email: privacy@telemeteor.com
- Postal Address: 1044 Budapest, Julianus barát utca 1/B, 4/49, Hungary
Scope, Purpose, and Legal Basis of Data Processing
Categories of Processed Data
The Data Controller processes the following personal data in relation to the Travel eSIM service:
Processing Activity | Purpose | Categories of Data | Legal Basis (GDPR) | Data Source |
---|---|---|---|---|
User Registration | Creating an account and enabling service access | Name, email address | Article 6(1)(b) GDPR (Performance of Contract) | Directly from User |
eSIM Purchase & Activation | Processing payments, issuing invoices, and service activation | Name, email, billing details | Article 6(1)(b) GDPR | Directly from User |
Customer Support & Complaints | Resolving user inquiries and complaints | Name, email, complaint details | Article 6(1)(b) GDPR | Directly from User |
Marketing & Promotions (if consented) | Sending promotional offers | Name, email | Article 6(1)(b) GDPR (Consent) | Directly from User |
Data Recipients and Third-Party Processors
The personal data collected by Telemeteor Kft. may be shared with:
- Payment Processors - e.g., Stripe for handling payments securely.
- Legal Advisors - for regulatory compliance and dispute resolution.
- Cloud Storage Providers - for secure data storage.
A current list of third-party data processors is available at: www.telemeteor.com/privacy-policy.
Data Security Measures
Telemeteor Kft. applies state-of-the-art technical and organizational security measures to protect personal data against unauthorized access, loss, destruction, or alteration.
Access to electronically stored data is restricted to authorized personnel and regularly reviewed.
Data Retention Period
Personal data is retained only for as long as necessary to fulfill contractual obligations, comply with legal requirements, or resolve disputes.
Processing Activity | Retention Period |
---|---|
Account registration data | Until account deletion |
eSIM purchase records | 5 years (Hungarian tax laws) |
Complaint handling records | 5 years from case resolution |
After these periods, personal data is securely deleted within 25 days.
Data Transfers Outside the EU/EEA
Telemeteor Kft. does not transfer personal data outside the European Union (EU) or European Economic Area (EEA).
User Rights Under GDPR
Users have the following rights regarding their personal data:
- Right to Access - Obtain confirmation on whether personal data is being processed.
- Right to Rectification - Request correction of inaccurate data.
- Right to Erasure (“Right to be Forgotten”) - Request deletion of personal data under certain conditions..
- Right to Restriction of Processing - Limit how personal data is processed in specific cases.
- Right to Data Portability - Request transfer of data to another service provider.
- Right to Object - Object to processing of personal data for marketing or other purposes.
Requests regarding these rights can be submitted via info@telemeteor.com.
Complaint Procedure
If a User believes their data protection rights have been violated, they may lodge a complaint with the Hungarian Data Protection Authority (NAIH):
- Name: National Authority for Data Protection and Freedom of Information (NAIH)
- Address: 1055 Budapest, Falk Miksa u. 9-11.
- Phone: +36 1 391 1400
- Email: ugyfelszolgalat@naih.hu
- Website: http://naih.hu
Users also have the right to pursue legal action in Hungarian courts if their rights under GDPR are violated.
Dated: February 10, 2025
(For and on behalf of Telemeteor Kft.)
Authorized Representative