Privacy Policy

Last Updated: August 8, 2025

PRIVACY POLICY

These Terms and Conditions have been prepared to cover the Republic of Turkey Law No. 6698, GDPR (General Data Protection Regulation), Delaware Online Privacy and Protection Act (DOPPA), the FTC Act, the Children’s Online Privacy Protection Act (COPPA), the Communications Act (FCC), and the Electronic Communications Privacy Act (ECPA). RIVIO Inc. and its affiliates are aware of the importance of your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information, also known as personal data. It also describes your rights regarding your personal information, your choices, and how you can contact us to get answers to your questions.

Rivio eliminates the need for physical SIM cards for travelers by offering data, voice, text, and video packages in many countries. Our goal is to provide various packages that can be used immediately on any eSIM-compatible device, ensuring seamless connectivity. Rivio is a global eSIM store that makes international connectivity more accessible through eSIM technology.

Customer Account and Responsibilities

To use the Services, a Customer must create an account with Rivio. The Customer is the sole authorized user of the Customer Account. As part of this service, our system requires the Customer to provide certain information, including but not limited to name, full address, telephone number, and email address. By using the Services, the Customer agrees to provide true, accurate, current, and complete information as requested during the registration process and to maintain and promptly update this information.

The Customer is responsible for maintaining the confidentiality of the login information, password, and Account number provided by Rivio or the Customer to access the Services. The Customer is solely and fully responsible for all activities that occur under their password or Account, even if not authorized by the Customer.

By creating an account or by using or visiting any Rivio website, application, product, software, or service (collectively “Service”), you understand and agree to the terms of this policy.

1. Scope of the Privacy Policy

This Privacy Policy explains how Rivio collects and uses data and applies to all Rivio users worldwide, unless they use a service covered by a separate privacy notice. This policy specifically applies to the following individuals:

• End Users: Individuals who use the Services through Rivio accounts for their personal use and interact directly with the Services.
• Corporate Users: Institutions (“Corporate Users”) that provide us, directly or indirectly, with the personal information of End Customers.
• End Customers: Individuals who receive services requested by other Rivio account holders.
• Job Applicants: Individuals who apply for a job at Rivio.

2. How We Collect, Share, and Use Personal Information

Depending on your interaction with us and our Services, we collect various types of information about you:

• Identity Information: Name, surname, T.R. ID Number, father’s name, place of birth, date of birth.
• Contact Information: GSM number, email address, and address data.
• Payment and Financial Information: Bank/account/card information, payment/top-up habits.
• Device Information: IP address, IMSI, IMEI, device brand and model, operating system, phone usage language, application version, operator information, country information, internet connection type, signal level, signal quality, technical device information, traffic, and location data.
• Product and Service Usage Information: Application login times, errors occurring during use, usage preferences, habits, behavioral information, and cookies.

Methods of Information Collection:

• Directly from You: We collect information directly from you when you register for an account, place an order, or contact us via phone, email, etc.
• Automatically: When you interact with our Services, we automatically collect information through cookies, server logs, and similar technologies, where permitted by law.
• From Other Sources: We may receive information from other sources, including our affiliates, business partners, social media networks, and other third parties or publicly available sources.

Rivio acts as a “Data Controller” and a “Data Processor”:

• Rivio as Data Controller: Determines the purposes and means of processing personal data. Activities include providing services, fraud prevention, legal compliance, service improvement, and processing job applications.
• Rivio as Data Processor: Acts as a data processor in scenarios where it provides services on behalf of and according to the instructions of a Corporate User.

Environments for Storing Personal Data:

• a) Printed Media: Paper or microfilms.
• b) Local Digital Media: Servers, fixed/portable disks, optical disks.
• c) Cloud Environments: Encrypted, internet-based systems.

3. Ensuring the Security of Environments

Rivio takes all necessary technical and administrative measures to ensure the secure storage of personal data and to prevent its unlawful processing.

3.1. Technical Measures

• Using up-to-date and secure systems.
• Employing security systems for the environments.
• Conducting security tests to identify vulnerabilities and mitigate risks.
• Restricting data access to authorized personnel only and logging all access.
• Maintaining sufficient technical staff to ensure security.

3.2. Administrative Measures

• Raising awareness among employees on information security, personal data, and privacy.
• Seeking legal and technical consultancy to follow developments and take necessary actions.
• Signing protocols with third parties in case of data transfer.
• Conducting internal audits for compliance with the Personal Data Storage and Disposal Policy.
• Notifying the relevant person and the Board immediately in case of a data breach.

4. Information We Collect and Its Purpose

5. Legal Basis for Data Storage and Processing

Your personal data is processed based on the following legal grounds:

• Explicitly Provided for by Law: For identity verification, fraud prevention, and legal retention obligations.
• Necessary for the Establishment or Performance of a Contract: For providing products/services, billing, and order tracking.
• Necessary for Rivio to Fulfill Its Legal Obligations: For resolving consumer complaints and taking information security measures.
• Made Public by You: For product development and customer satisfaction research.
• Necessary for the Establishment, Exercise, or Protection of a Right: For managing complaint processes.
• Legitimate Interests of Rivio: For fraud prevention, service improvement, and information security, provided it does not harm your fundamental rights and freedoms.
• Your Explicit Consent: For marketing and promoting products/services, and offering you personalized deals and promotions.

6. Transfer of Personal Data

We may transfer your personal data to the following domestic and international recipient groups for the purposes stated in this policy and in accordance with the Law and other legislation:

• Our domestic and international business partners, Rivio affiliates, and suppliers.
• Suppliers and business partners for product procurement or delivery.
• Business partners for offering and promoting products and services.
• Authorized institutions or organizations entitled to request your personal data.

7. How We Share Personal Information

• Affiliates and Acquisitions: We may share information with our corporate affiliates. If another company acquires our company, business, or assets, we will share information with that company.
• Other Disclosures without Your Consent: We may disclose information in response to legal processes, to protect our rights, to investigate illegal activities, or as otherwise required by law.
• Partner Promotions: We may offer promotions with third-party partners. If you decide to participate, the information you provide will be shared with us and them.
• Service Providers: We may share your information with service providers who help us manage our website, provide technical support, and process payments.

8. Your Rights

Depending on your location and applicable laws, you may have the following rights:

• Access to Your Data: The right to request that we share with you the personal information we have collected.
• Request Correction: The right to request that we correct any inaccurate personal information.
• Request Deletion: The right to request that we delete the personal information we have collected.
• Withdraw Consent: The right to withdraw your consent where you have previously given it.
• Object to Processing: The right to object to the processing of your personal information.

These rights are not absolute and may be limited by law. To exercise your rights, please contact us using the information below. We may request additional information to verify your identity.

• Opting Out of Marketing Emails: You can unsubscribe from marketing emails by using the unsubscribe function in your Profile Settings or by contacting us at [email protected].
• How to Delete My Account: You can delete your account using the “Delete Account” function in your Profile Settings.

9. Data Transfer and International Data Transfer

Our Service is accessible from Europe and abroad. This means your information may be processed in a foreign country where privacy laws may be less stringent than in your country. By submitting your personal information to us, you consent to the transfer, storage, and processing of your information in a country other than your country of residence, including the United States.

10. Security

We follow generally accepted industry standards to help protect your personal information. However, no method of transmission over the Internet is 100% secure. Users are responsible for keeping their password and identity credentials secure. If you suspect a security vulnerability, please notify us at [email protected].

11. Changes to This Policy

We reserve the right to change this Privacy Policy at any time. We will notify you of material changes by posting a notice on our website or by sending you an email.

12. Children

Our Services are not directed at children under 13. We do not knowingly collect personal information from children under 16 without parental consent.

13. Contact Information

For any questions, comments, or complaints regarding our privacy practices:

• Email: [email protected]
• US Phone Number: +1 (302) 244-7494

14. Additional Information for Residents of DELAWARE

In accordance with DELAWARE law, we must provide additional information. We do not “sell” your personal information for monetary consideration. However, we use cookies and similar technologies for targeted advertising.