Privacy Policy

Last updated: March 2026

1. Data Controller

The data controller responsible for this website is:

Turkey eSIM Tracker

Operated by: [Your Full Legal Name]

Address: [Your German Virtual Office Address]

Email: privacy@turkeyesimtracker.com

For details about our operator identity, please refer to our Impressum.

2. What Data We Collect

Turkey eSIM Tracker is a static website — we do not operate a database, user accounts, or login system. However, we do use the following services that may collect data:

2.1 Google Analytics 4 (GA4)

We use Google Analytics 4 to understand how visitors interact with our website. GA4 collects:

  • Pages visited, session duration, and scroll depth
  • Device type, browser, operating system, and screen resolution
  • Approximate geographic location (country/city level)
  • Referral source (how you found our site)
  • Custom events: BTK tool usage, affiliate link clicks

Important: GA4 does not collect your name, email address, or any personally identifiable information. Google Analytics cookies are only loaded after you provide consent via our cookie banner.

Data processor: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google's privacy policy: policies.google.com/privacy.

2.2 Affiliate Cookies

When you click an affiliate link on our site (e.g., links to Holafly, Airalo, or Nomad), the destination website may place its own tracking cookies on your device. These cookies allow the affiliate provider to attribute your purchase to our referral, enabling us to earn a commission at no additional cost to you.

We do not control these third-party cookies. Please review each provider's privacy policy:

2.3 Hosting Provider

This website is hosted on Vercel. Vercel may collect standard server log data including your IP address, browser type, and request timestamps for security and performance purposes. Vercel's privacy policy: vercel.com/legal/privacy-policy.

3. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your data based on the following legal grounds:

Data Processing Activity Legal Basis (GDPR Article)
Essential website hosting logs Art. 6(1)(f) — Legitimate Interest
Google Analytics 4 tracking Art. 6(1)(a) — Consent (via cookie banner)
Affiliate tracking cookies Art. 6(1)(a) — Consent (user-initiated click)

4. Cookie Categories

We categorize cookies used on this website into the following groups:

Category Purpose Requires Consent?
Necessary Cookie consent preferences, basic site functionality No
Analytics Google Analytics 4 — page views, tool usage, scroll depth Yes
Marketing Affiliate provider tracking cookies (set by third-party sites after link click) Yes (implicit via user click)

No analytics or marketing cookies are loaded until you provide explicit consent through our cookie banner. You can change your preferences at any time by clearing your browser cookies and revisiting the site.

5. Your Rights Under GDPR

If you are located in the European Economic Area (EEA) or the United Kingdom, you have the following rights:

  • Right of Access — Request a copy of any personal data we hold about you
  • Right to Rectification — Request correction of inaccurate data
  • Right to Erasure — Request deletion of your personal data ("right to be forgotten")
  • Right to Restrict Processing — Request limitation of how we use your data
  • Right to Data Portability — Receive your data in a structured, machine-readable format
  • Right to Object — Object to processing based on legitimate interest
  • Right to Withdraw Consent — Withdraw your cookie consent at any time

To exercise any of these rights, contact us at privacy@turkeyesimtracker.com. We will respond within 30 days.

6. Data Retention

Since we do not operate a database or store personal data directly, data retention is governed by our third-party service providers:

  • Google Analytics 4: Data retention set to 14 months (Google's default for GA4 properties)
  • Vercel hosting logs: Retained per Vercel's data retention policy

7. Data Transfers Outside the EEA

Google Analytics data may be processed in the United States. Google participates in the EU-US Data Privacy Framework and provides Standard Contractual Clauses (SCCs) as safeguards for international data transfers.

8. Children's Privacy

This website is not directed at children under the age of 16. We do not knowingly collect personal data from children.

9. Changes to This Policy

We may update this privacy policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Material changes will be communicated through a notice on the website.

10. Supervisory Authority

If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. For Germany, this is the relevant state data protection authority (Landesdatenschutzbeauftragter) for the federal state where our business is registered.

11. Contact

For any privacy-related questions or requests, please contact:

Turkey eSIM Tracker — Privacy Inquiries

Email: privacy@turkeyesimtracker.com