Legal
Privacy notice
In effect since
This notice explains what personal data Palmye collects when you use palmye.com, why, who it is shared with, how long it is kept and what rights you have. It is written to meet the EU General Data Protection Regulation (GDPR) and the UK GDPR; where Turkish data protection law (KVKK) applies to you, the rights it gives you are set out below as well.
1. Who is responsible
The controller of your data is Palmye LLC, 131 Continental Dr, Suite 305, Newark, DE 19713, United States, trading as Palmye. You can reach us about anything in this notice at support@palmye.com.
2. What we collect
Account data: your name, your e-mail address, the time you confirmed it, a hash of your password, and the country you tell us you live in. For each sign-in we also keep the IP address it came from, the browser or app it was made with, and when it was opened and last used. If you sign in with Google or Apple, we receive the name, the e-mail address and the account identifier they share with us, and from Google also the address of the profile photo on your Google account; we never receive your password for those services. We keep the address of that photo, not the photo itself, and use it only to show the photo next to your account in the site's menu. Your browser loads the photo from Google's servers, so Google receives your IP address with that request, as it does for any image it serves. The address is refreshed each time you sign in with Google and erased when you disconnect Google or delete your account. Apple shares no photo. An account opened that way starts from the country your connection comes from, and we ask you to confirm or correct it before anything else.
Orders and wallet: the plans you bought, when, for which destination and at what price; every top-up and every charge to your wallet; the payment provider's reference for each card payment. Card numbers and security codes go to Stripe directly and never reach us. When you pay by card, Stripe's payment form on the site and in the apps also collects information about the device or browser you pay from — identifiers Stripe assigns to it, its model, operating system, screen, language, time zone and IP address — to detect fraud and to make the payment work; this goes to Stripe directly, not through us. With each order we also keep the evidence of where you live that tax law asks for: the IP address the order was placed from and the country it resolves to, the country that issued the card behind the payment as Stripe reports it, the country on your account at that moment, and the country and VAT rate the order was recorded under. With each order and each payment we also keep your name and e-mail address as your account showed them at the time, and with each payment the IP address it was started from and the country that address resolves to.
eSIM data: the profile identifiers the provider issues for each plan, the installation state the provider reports, and the raw usage counters, which arrive two to three hours behind. We do not see which sites you visit or the content of your traffic.
The app and notifications: if you use our iPhone or Android app and allow notifications, we store the notification token the operating system issues for that phone, the phone's platform, its language, its time zone and the app version. The token identifies the phone, not you; it is used to send a notification to the right device, and the time zone is used to hold reminders back to a waking hour in the phone's own time. We also keep which kinds of notification you left switched on, and the subject and delivery result of every notification we send; we do not store the text of a notification, which is written afresh from your data at the moment it is sent. We keep the time you last opened one of your eSIM's pages, only so that an installation reminder is not sent to someone who has already looked.
Legal confirmations: when you register and when you pay, a copy of the legal texts you confirmed, the statement you ticked, the time and the request identifier are stored so that both of us can see what was agreed.
Technical data: your IP address, the country it resolves to, your browser's language, the time of each request and a request identifier, in server logs kept for security and abuse prevention. Your country is also used to decide whether we may sell to you and which destination the home page features.
Support: the content of the e-mails you send us and anything you attach.
Measurement, only with your permission: which page or campaign brought you to the site and which pages you view; in the app, which screens you open and which steps of a purchase you complete; tied to a random identifier and, once you have an account, to your account's own identifier, never to your e-mail address. PostHog stores with these events an approximate location it derives from your IP address, as described for crash reports below, not the address itself. On the site you give and withdraw permission on the cookie banner, in the app on the account tab or in the app settings; the answer you give on one device is also recorded on your account. See the Cookie notice.
Crash reports: if our iPhone or Android app runs into an error or closes unexpectedly, we send PostHog the error itself and where in our code it happened; the app's version and build number; the phone's manufacturer, model, operating system and its version, language, time zone and screen size; whether it is connected over Wi-Fi or a mobile network and, on Android, the name of its mobile carrier; a random identifier created for that installation and one for the current use of the app. PostHog receives the phone's IP address with each report and stores the approximate location it derives from it — city, postal code and coordinates — but not the address itself. These reports are sent even if you have not allowed measurement, but then they are not linked to your account; if you have allowed measurement, they are linked to your account's identifier, never to your e-mail address. The eSIM's installation code and the parameters in link addresses are removed from a report before it is sent. Errors that occur on the site's server are also recorded, with the page they occurred on and without being linked to any person.
3. Why we use it and on what basis
To open and run your account, take your order, deliver the eSIM, show your usage and answer your support requests: this is necessary to perform our contract with you.
To send notifications to your phone about your order, your eSIM, your wallet and your support requests: this is also necessary to perform our contract with you. You can switch notifications off at any time, subject by subject, in your phone's settings or on the Notifications screen in the app. Marketing messages are outside this and are sent only with separate consent given for that purpose; when you gave it and to which wording is recorded, every message carries a one-click unsubscribe link, and your withdrawal is recorded too.
To keep invoices, tax and accounting records — including the evidence of where you live that decides which country's VAT an order carries, and, once an account has been deleted, its encrypted archive described in section 6 — and the record of what you confirmed: this is a legal obligation, and it is how we can prove what was agreed if there is a dispute.
To answer a dispute raised through the bank that issued your card, and to prevent fraud, we use the record of that payment and of what it bought, including your name, e-mail address and the IP address the payment was started from, and, once an account has been deleted, its encrypted archive described in section 6: this is our legitimate interest in establishing, exercising and defending legal claims and in preventing fraud.
To protect the site and our customers, to prevent fraud and payment abuse, to apply sanctions law and country restrictions, and to improve the service: this is our legitimate interest, which we weigh against yours; you can object at any time.
To see and fix the app's crashes and the site's errors: this is the same legitimate interest; a report is linked to your account only if you have allowed measurement.
To measure which pages, screens and campaigns work: only with your consent, given on the cookie banner or in the app, which you can withdraw at any time.
To learn which of our ads led to a purchase, by telling Google Ads and Microsoft Advertising about that purchase as described in section 4: only with your consent, given on the cookie banner or in the app, which you can withdraw at any time.
We do not sell your data and we do not build advertising profiles. Nothing else reaches an advertising network: not your name, your e-mail address, your account or your eSIM usage.
4. Who we share it with
We use the following service providers, each bound by a data processing agreement:
Stripe, payment processing. Receives from us the amount, a transaction reference, your account's identifier, the name of the plan you are buying, and your name and e-mail address, which Stripe keeps with the payment so that a dispute raised through your bank can be answered. Receives directly from you, in its payment form, your card details, the billing details the form asks for and the device information described above, and uses them to process the payment and to detect fraud. When your bank checks a card payment (3-D Secure), Stripe passes part of that device information to the bank that issued your card. Stripe operates globally, including in the United States.
Our wholesale eSIM provider, profile issuance. Receives an order reference and the plan you chose, which is necessary for the eSIM to exist; sends us the profile identifiers and usage counters. The provider operates internationally.
Resend, transactional e-mail. Receives your e-mail address and the content of the e-mails we send you (confirmation links, order confirmations, refund notices, copies of the legal texts).
Apple, notification delivery to the iPhone app (Apple Push Notification service). Receives your phone's notification token and the title and text of the notification we send. Apple operates globally, including in the United States.
Google, notification delivery to the Android app (Firebase Cloud Messaging), only if you use the Android app. Receives your phone's notification token and the title and text of the notification we send. Google operates globally, including in the United States.
Railway, hosting of the application, its database and its cache. All application data is stored on this infrastructure.
Google Ads (Google) and Microsoft Advertising (Microsoft), measurement of our own ads, only if you gave permission on the cookie banner or in the app. When you reach the site through one of their ads, the link carries a click identifier the ad network created for that click. If you then buy, we send that network the identifier, the time of the purchase, its value and currency and our reference for the order, so that it can tell us which ad led to a sale; it receives nothing else about you. Purchases made in our iPhone app are never sent. If you withdraw your permission, nothing more is sent from that moment; if you delete your account, the click identifiers are erased from your orders. What was already sent stays with Google or Microsoft under their own terms. Both operate globally, including in the United States.
Cloudflare, DNS and edge network in front of the site. Sees the technical data of every request.
PostHog, product analytics and crash reports, hosted in the European Union. Product analytics only if you consented on the cookie banner or in the app; crash reports from everyone who uses the app, not linked to your account unless you consented. Receives the IP address of each event and keeps the approximate location derived from it, not the address.
Your country is detected by Cloudflare from your IP address as part of the request data above; we use no separate location service.
We disclose data to authorities where the law requires it, and to advisers under a duty of confidentiality where we need advice.
5. International transfers
Some of these providers process data outside the European Economic Area and the United Kingdom, in particular in the United States. Where they do, the transfer rests on an adequacy decision or on the European Commission's standard contractual clauses (and the UK addendum where relevant), together with the provider's own safeguards. You can ask us for details of the safeguard used for a given provider.
6. How long we keep it
Account data: for as long as your account exists. When you delete your account, your name, your e-mail address, your password and every connected sign-in method are erased from it and every session ends. The account record itself is not deleted: its personal fields are cleared and it is kept under its identifier, so that the orders, payments and wallet movements in the next line still belong to something. Your name and e-mail address do stay on the record of each order and payment, as the next line says. We also keep, in an encrypted archive tied to that identifier, your account's name, e-mail address, country, when you confirmed the country and when the account was opened, and the sign-ins still on record when the account is deleted (roughly the last few weeks: their IP addresses, devices and times), for tax, accounting, card-dispute and fraud-prevention purposes; the archive is kept for as long as tax, accounting and consumer law require us to keep it and while a card dispute or a fraud claim about it can still be raised. Only our staff can open the archive, and every opening is recorded with who opened it and why; when that period ends it is deleted. Deleting the account cannot be undone, and it is not the complete erasure of everything we hold — what stays, and for how long, is the rest of this section. If a card payment on your account has been disputed through the bank that issued the card, your account cannot be deleted until the dispute is resolved and the hold on your account ends (see the Terms of service under Suspension and termination), so that we can respond to the dispute; your account keeps your name and e-mail address until then. Once the hold ends, you can delete your account or ask us to; the record of the dispute is kept for as long as the orders and wallet movements in the next line.
Orders and payments, with the evidence of your country, your name and e-mail address as they were at the purchase and the IP address of each payment kept beside them, wallet movements, invoices and the record of the legal texts you confirmed: for as long as tax, accounting and consumer law require us to keep them and while a card dispute or a fraud claim about them can still be raised, including after your account is deleted. Your name, e-mail address and that IP address are used there only for tax records, to answer a card dispute and to prevent fraud.
eSIM identifiers and usage counters: for the life of the plan and then with the order they belong to.
Sessions: a session ends when you sign out or after 30 days, and expired sessions are deleted automatically, except the copy kept in the archive when an account is deleted.
Notification tokens: a token is withdrawn from use when you sign out on that phone, when you delete your account, or when Apple or Google tells us it is no longer valid; a withdrawn token is never sent another notification. The record itself is kept rather than deleted, so that the same phone is recognised if it registers again. The subject and delivery result of the notifications we sent remain as a record, as they do in our e-mail book; the text of a notification is never stored. The record of your marketing consent — when you gave it, to which wording, and when you withdrew it — is kept because it is the proof of that consent.
Server logs: for a short period, then deleted or anonymised.
Support requests: the messages, the subject, your name and address and any file you attached are erased 12 months after the request is closed; the request's number and a line saying the content was erased remain. Attached files are deleted from storage after 180 days in any case. You can ask us to erase a request sooner.
7. Security
Passwords are stored as a one-way hash. Session secrets are stored as a hash, so a copy of our database cannot be used to sign in. Card data never reaches us. Connections to the site are encrypted. No system is perfectly secure; if we learn of a breach affecting you, we tell you and, where required, the supervisory authority.
8. Your rights
You can ask us to show you the data we hold about you, to correct it, to delete it, to restrict how we use it, to give it to you in a portable format, and you can object to processing based on our legitimate interest. Where processing rests on your consent, you can withdraw it at any time without affecting what was done before.
To use any of these rights, write to support@palmye.com from the e-mail address of your account. We answer within one month. You can also complain to the data protection authority of the country where you live.
If KVKK applies to you, you additionally have the rights set out in its Article 11: to learn whether your data is processed and, if so, to be informed about it, to learn the purpose and whether the data is used accordingly, to know the third parties it is transferred to, to request correction, deletion or destruction, to ask that these be notified to recipients, to object to a result produced solely by automated analysis, and to claim compensation for damage caused by unlawful processing. Requests under KVKK can be sent to support@palmye.com.
9. Children
The service is for adults. We do not knowingly collect data from anyone under 18; if we learn that we have, we delete the account.
10. Changes
We may update this notice. The date at the top of the page shows the version in force, and we tell every registered customer by e-mail whenever it changes.