Privacy Policy

Last Updated: August 11, 2026

This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with the Law of Georgia on Personal Data Protection and the General Data Protection Regulation (GDPR).

1. General Provisions

The data controller responsible for processing your personal data is Simio LLC (Identification Code: 454413750; Legal Address: 2B S. Akhmeteli Street, Tbilisi, Georgia; Email: support@simio.to).

2. What Data We Collect

The Simio mobile applications are published on the App Store and Google Play by Simio OÜ (Registry Code: 16972090; registered address: Narva mnt 5, Kesklinna linnaosa, Tallinn, Harju maakond, Estonia), a company affiliated with us. Simio OÜ distributes the applications only and does not process your personal data as a controller; the company named above remains responsible for the processing described in this policy.

We collect only the minimum amount of data necessary for the proper functioning of our service and provision of support:

• Identification and Authentication Data: Email address and optional nickname. When using Apple Sign-In with the "Hide My Email" feature, we do not receive your real email address. The authentication process is fully secured, and we do not have access to your passwords.
• Transaction and Payment Card Data: Purchased product history, amount, currency, payment status, and transaction reference code.

  Note on Payment Cards: We do not have access to, nor do we store, your full credit/debit card numbers or security code (CVV/CVC). Payments are processed securely via a certified payment provider (Tpay LLC / Flitt). When saving a card, only an encrypted security token and the minimum digits required for card identification are stored.

• eSIM and Network Data: eSIM identifiers (ICCID), activated data plan, consumed data volume (GB), and status (whether the profile is installed and connected to the network).

  Important: We do not track, monitor, or store information regarding the websites you visit, applications you use, content of messages sent, or your precise geographical location (geolocation).

• Technical Data: IP address, device type, operating system, app version, and technical crash logs.

3. Purposes of Data Processing

Your personal data is processed for the following purposes:

• Account creation, management, and authentication on the platform;
• eSIM generation, delivery, activation, and internet service provision;
• Processing payments, financial accounting, and managing refunds;
• Displaying consumed data balance and issuing low-balance/expiration alerts;
• Sending service notifications (e.g., order confirmations, installation instructions);
• Providing customer support and technical assistance;
• Fraud prevention, system security maintenance, and statutory legal compliance (tax and anti-money laundering obligations);
• Sending marketing communications, strictly subject to your prior consent (which can be withdrawn at any time).

4. Data Sharing with Third Parties

We do not sell your personal data nor use it for third-party advertising purposes. Data is shared exclusively with functional partners necessary for service delivery:

• eSIM Go Limited (United Kingdom): International eSIM provider. Data is transferred strictly to the extent required for profile generation and roaming cellular connectivity.
• Tpay LLC / Flitt (Georgia): Authorized payment service provider (licensed by the National Bank of Georgia, PCI DSS certified).
• State Authorities: Cases directly provided for by Georgian legislation or to defend the company's legal rights in legal disputes.

5. International Data Transfers

Since eSIM services are inherently international, your internet traffic is processed by local operators in destination countries. Our partners are located in Georgia, the United Kingdom, the European Economic Area (EEA), and the United States. International data transfers rely on adequate data protection safeguards and Standard Contractual Clauses (SCCs).

6. Data Retention Periods

• Account and Profile Data: Retained for as long as your account remains active.
• Transactions and Financial Records: Retained after account closure for the mandatory period prescribed by Georgian tax and accounting legislation.

7. User Rights

In accordance with Georgian legislation and the GDPR, you have the right to:

• Request information regarding the processing of your personal data;
• Request correction or updating of inaccurate, incomplete, or outdated data;
• Request termination of data processing, erasure, or account deletion directly within the application or by contacting support@simio.to;
• Opt out of receiving marketing communications at any time.

Effects of Account Deletion: Deleting your account will remove your profile, saved card tokens, and support communication history. The company retains only the minimum financial records required by law.

8. Security

We implement modern technical and organizational measures to safeguard your data. Data exchange between the application and servers is fully encrypted (SSL/TLS). Saved payment card tokens are stored in encrypted format.

9. Minors

The Simio platform and services are not intended for minors. Users must be at least 18 years old to create an account and use services. If we discover that personal data of an individual under 18 has been collected, such data will be deleted immediately.

10. Changes to this Policy

The company reserves the right to update this Privacy Policy. Any changes will be published on the platform with an updated date. Users will be notified of material changes via email or in-app notification.