Effective date: October 19, 2026
Controller: SE Efanov A. (ԵՖԱՆՈՎ ԱՆԴՐԵՅ ԱՆԴՐԵՅԻ), individual entrepreneur (Ա/Ձ), Yerevan, Republic of Armenia.
Privacy contact: [email protected]
Information and technology partner: Qat Bilişim ve Yazılım Teknolojileri Ltd. Şti., Ankara, Türkiye.
1. Scope and roles
This policy applies to Raqoon eSIM, including the Raqoon website, app, order flow, delivery, balance display, top-ups and support. The seller, SE Efanov A., sells prepaid travel eSIM data plans under the Raqoon brand and determines the purposes of processing order, payment, support and contract data. The seller does not operate a public mobile network, allocate telephone numbers, or provide voice, SMS or emergency-call services.
The eSIM profile and mobile-data connectivity are technically provisioned by E7 Access and its network partners. Those parties may process data under their own legal responsibilities where they determine the purposes and means of processing.
Qat Bilişim ve Yazılım Teknolojileri Ltd. Şti. is the information and technology partner. The partner processes personal data to develop and operate the website, application and product interface: on the seller's instructions, and, where the partner independently determines the purposes and means, for example for platform security, under its own responsibility. The partner is not the seller.
2. Data we process
We may process your email address, order number, product and destination selected, price, currency, payment status and payment-reference data. We may also process the eSIM profile identifier, activation and expiry status, available balance, top-up history, device-compatibility and installation diagnostics, support correspondence, fraud and security signals, and technical website/app logs such as IP address, browser, device type and timestamps.
We do not receive or store full payment-card numbers. Do not send passports, identity documents, bank statements, payment-card images, health data or other sensitive personal data to support unless we expressly and lawfully request a strictly necessary item.
3. Why we process it and our legal grounds
We process data to create and deliver the order, provide the eSIM profile, show your product status and balance, process top-ups, answer support requests, prevent fraud and abuse, protect our systems, meet accounting and legal obligations, and establish, exercise or defend legal claims. Depending on the activity, the basis is performance of a contract, compliance with a legal obligation, our legitimate interests where they do not override your rights, or your explicit consent where it is required.
4. Recipients and international transfers
By continuing to use the Raqoon website, by placing an order and by using the Raqoon mobile application, you agree to the cross-border transfer of your personal data. We share only the data needed for the stated purpose with the information and technology partner, E7 Access and its relevant connectivity partners, payment providers, hosting and security vendors, customer-support tools, professional advisers and public authorities when legally required. Order, account and support data are stored by the information and technology partner, Qat Bilişim ve Yazılım Teknolojileri Ltd. Şti., on the territory of the Republic of Türkiye. Processing and storage by the partner are subject to Turkish Law No. 6698 on the Protection of Personal Data (KVKK). Other recipients may process data outside your country of residence. We use the transfer mechanism and safeguards required by applicable law, including the Law of the Republic of Armenia on Protection of Personal Data where it applies, and KVKK where the partner processes the data.
5. Retention
We retain order, payment and tax records for the period required by applicable law. We retain eSIM delivery, activation, balance and support records for as long as reasonably needed to provide the product, resolve a dispute, prevent fraud or meet legal obligations. We delete or anonymise data when these purposes no longer apply, unless a longer period is legally required.
6. Security
We use appropriate technical and organisational measures designed to protect personal data, including access controls, encryption in transit where appropriate, logging, least-privilege access and vendor controls. No internet transmission or storage system is completely secure. Please keep your email account, device and QR code confidential and contact us promptly if you believe they have been compromised.
7. Your rights and requests
Subject to applicable law, including the Law of the Republic of Armenia on Protection of Personal Data and Turkish Law No. 6698 (KVKK) where the technology partner processes your data, you may request information about the processing, access, correction, and deletion or destruction of your personal data, object to processing where the law provides that right, and withdraw consent for future processing where consent is the basis. You may apply to the Personal Data Protection Agency of the Republic of Armenia and, for processing in Türkiye, to the Turkish Personal Data Protection Authority. To use these rights, send a request in free form from the email used for the order to [email protected]. We may ask for proportionate information needed to verify the request and protect your data.
8. Children, third parties and updates
Raqoon provides the website, the mobile application and eSIM services only to adults who are 18 years of age or older. Persons under 18 may not create an account, place an order or use a plan. Third-party websites, payment services and network providers have their own privacy terms. We may update this policy when the product, providers or law changes; the effective date will be updated and material changes will be communicated where required.
9. How we process data and where it is stored
We process personal data by collecting, recording, organising, storing, updating, retrieving and using it to take an order, deliver the eSIM, show status and balance, handle top-ups, answer support requests and meet legal duties. We disclose data to payment providers and connectivity partners only to the extent needed to perform the order. When a purpose no longer applies, we delete or anonymise the data, unless the law requires us to keep it.
Order, account and support data are stored by the information and technology partner, Qat Bilişim ve Yazılım Teknolojileri Ltd. Şti., on access-controlled servers and cloud infrastructure located in the Republic of Türkiye. Session and account records are kept in protected databases. Data is transmitted over encrypted TLS channels. Access is limited to people and suppliers who need it for the purposes in this policy.
10. App analytics (Google Analytics for Firebase)
We use Google Analytics for Firebase, a Google service, to understand how Raqoon eSIM works, which features are used and where users run into difficulty. This information helps us improve the app and assess checkout and payment.
In the app settings you can control detailed analytics. For new installations it is on by default. When detailed analytics is on, the app may send information about screens shown and actions, for example choosing a destination and plan, going to payment, installing an eSIM, topping up, working with trips and changing settings. We may also receive information about the results of those actions that are known to the app.
If you turn detailed analytics off, the app stops collecting new detailed events. Minimal information about the payment result and about a change to the analytics setting continues to be sent. Firebase also automatically collects some service events, such as app launch and session, and technical data about the device and the app. When the setting changes, we record the selected mode, including the fact that detailed analytics was turned off.
If you had already turned off the previous analytics setting before an app update, we keep that choice: analytics stays fully off until you change the setting yourself.
We do not include entered names, email addresses and messages, search-query text, payment details, eSIM activation codes, QR-code contents, invitation links or payment links in app analytics events. Events may be linked to the technical app-instance identifier that Firebase uses, so this data should not be treated as fully anonymised.
Changing the setting affects new events and does not automatically delete information sent earlier. Events collected before the switch may wait to be sent in the Firebase queue.