Privacy policy

TWIM Advisors SL, operating under its trade name TurTrip (www.turtrip.com ), is fully committed to protecting your privacy and the security of your personal data. This Privacy Policy aims to clearly and transparently detail how we collect, use, share, and protect the personal information we collect through your interaction with our services.

In this document, we also inform you of your rights regarding your personal data, as well as the options available for exercising those rights. You will also find information on how to contact us with any questions, requests, or concerns regarding the processing of your personal information.

1. Introduction

At TurTrip, operated by TWIM Advisors SL, we recognize the importance of privacy and the protection of your personal data. This Privacy Policy explains how we collect, use, process, and protect your personal information (hereinafter, “Personal Data”), in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection regulations.

By creating an account, accessing, or using our services through our website, mobile application, products, software, tools, data sources, and/or any other service provided by TurTrip (hereinafter, the “Service”), you expressly consent to the collection and processing of your Personal Data in accordance with the terms of this Privacy Policy. If you do not agree with any of the provisions set out in this policy, we recommend that you do not use our services.

This policy applies to all interactions with TurTrip users, both online and offline, and includes the use of our mobile applications, website, and any other digital or physical platform linked to our services. It also extends to relationships with our employees, job applicants, partners, and any third party interacting with TurTrip in the context of providing services or products.

1.1. Scope of Application

This Privacy Policy applies to:

• End users: individuals who use TurTrip services on a personal basis, through their individual accounts, for the purpose of purchasing or using our products and services, including eSIMs and data plans.
• Corporate clients: companies or entities that purchase our services to provide connectivity to their employees or customers.
• Job applicants: individuals who apply to join our team and whose personal data is processed during the recruitment and selection process.
• Proveedores y socios: terceros que colaboran o proporcionan servicios a TurTrip y que pueden, en el transcurso de esa relación, proporcionar o ser expuestos a datos personales.

1.2. Purpose of this Policy

The purpose of this Privacy Policy is to ensure that users and all stakeholders clearly understand how TurTrip collects, uses, discloses, and protects Personal Data, as well as the rights they have regarding such information. We are committed to:

• Ensure the confidentiality and security of your data.
• Use Personal Data only for the legitimate and lawful purposes indicated.
• Provide you with appropriate control over the processing of your data, respecting your rights in accordance with the GDPR and other applicable regulations.

1.3. Consent and Acceptance

By using TurTrip’s services, you agree to the terms set out in this Privacy Policy. Your consent is required for the processing of your Personal Data, and you may withdraw it at any time, without affecting the lawfulness of the processing based on consent prior to its withdrawal. However, withdrawing consent may affect your ability to use some of our services or features.

If TurTrip makes significant changes to this policy, we will notify you promptly through our communication channels, such as email or a notice on our website, so that you are aware of the changes and can make informed decisions regarding your continued use of our services.

2. TurTrip as the Data Controller and Data Processor

TWIM Advisors SL, operating under its trade name TurTrip (www.turtrip.com ), acts as the Data Controller by determining the purposes and means for processing personal data. This means that TurTrip is responsible for ensuring that personal data is processed in accordance with applicable regulations, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and any other relevant data protection legislation.

2.1. TurTrip’s Activities as Data Controller

As the Data Controller, TurTrip manages personal data directly in the following scenarios:

• Direct Records: When users register directly for our services, TurTrip assumes the role of data controller for the personal data of end users who purchase eSIMs and use the services provided.

2.1.1. Key Activities as Data Controller

In its capacity as Data Controller, TurTrip carries out the following essential activities related to personal data:

• Service provision: We process personal data to facilitate the purchase, activation, and management of eSIMs and other contracted services, ensuring an efficient and personalized experience for the user.
• Fraud prevention: We monitor and analyze activities and transactions to detect and prevent fraud or improper activities that may compromise the security of our services.
• Legal and regulatory compliance: We use personal data to comply with our legal and regulatory obligations, such as billing, tax reporting, and data storage in accordance with applicable regulations.
• Service improvement: We analyze usage data to improve, develop, and optimize our products and services in order to provide a more satisfying and efficient experience for our users.
• Processing of job applications: We manage the personal data of candidates applying to work at TurTrip, ensuring proper handling during the recruitment and hiring processes.

2.2. Compliance and Confidentiality Guarantee

TurTrip is committed to protecting personal data and complies with the principles of lawfulness, fairness, and transparency in its processing. We ensure that the data:

• Are processed only for the legitimate purposes previously defined and communicated to the user.
• Are adequate, relevant, and limited to what is strictly necessary for the purposes for which they are collected.
• Are kept up to date and are deleted or anonymized when no longer necessary for the purposes of processing or in accordance with legal retention periods.
• Are protected through appropriate security measures, in order to prevent unauthorized access, loss, alteration, or improper disclosure.

TurTrip is committed to ensuring the confidentiality of the personal data of all users, employees, and involved third parties, strictly complying with applicable data protection regulations.

3. Personal Information We Collect

We may collect and process different types of Personal Data when you interact with us or use our services, including but not limited to the following:

• Identification Data: First name, last name, date of birth, etc.
• Contact Data: Email address, phone number, postal address, etc.
• Payment Data: Credit/debit card information or other payment methods to process your transactions.
• Usage Data: Information about how you interact with our services, including details of your browsing on the website, the application, and the use of TurTrip products or services.
• Location Data: Geolocation information collected through mobile devices or other technological means.

Below are examples of the types of information we collect in various contexts and how we use that information.

Data Category	Compiled Information	Main Purpose
Website usage and device data: when you visit our website.	Details about your visits and interactions, including pages visited, date and time of access, clicks made, IP address, location data, device type, language, browser type, and any website from which you access ours.	This data is primarily collected through cookies. We use this information to improve website functionality, perform internal analysis, and enhance your user experience. Please refer to our Cookies Policy for more details.
Customer information: when you purchase an eSIM or data plan.	Full name, address, current location, phone number, payment information, email address, and device type (brand and model).	We use this information to process your purchase, manage and activate your eSIM, and fulfill our contractual and legal obligations.
Account Registration	Name, contact information, and actions taken within your account while you are logged in.	We use this information to manage your account, enable you to make purchases, and save your preferences. We have a legitimate interest in providing these features and fulfilling our contract with you.
Biometric information	Biometric identifiers (selfies or photo ID).	We process this information with your explicit consent to verify your identity in compliance with applicable legal regulations.
Required online tracking technologies	Information about browser type, operating system, IP address, domain name, and click activity collected via cookies and clear GIFs.	We use these technologies to ensure that our website functions properly and to enhance the user experience.
Non-essential tracking technologies	Information about your browser, operating system, IP address, and activity on our website, which may be collected for statistical purposes or for behavioral advertising.	We collect this data to perform analyses and improve targeted advertising. We rely on your consent to use this data when required by law.
Demographic information	Personal information such as age and location.	We use this data to provide personalized services and improve the user experience. We have a legitimate interest in better understanding our users.
Job seekers	Contact information, employment history, and educational background provided by job applicants.	We use this information to manage recruitment processes and comply with our legal obligations in the workplace.
Comments/Help	Name, email address, and other information you provide when you contact us for support or to leave feedback.	We use this information to respond to your support requests or feedback. We have a legitimate interest in addressing your needs and improving our services.
Mobile devices	A unique identifier generated by your device when you visit our website.	We use this information to identify unique visitors and track traffic on our website.
Place an order	Name, billing address, shipping address, email address, phone number, and payment details when making a purchase.	We use this information to process and fulfill orders in accordance with our contractual obligations.
Employee Promotion	Information provided as part of a joint brand promotion.	We use this data to manage brand promotions, and we have a legitimate interest in carrying out these activities.
Surveys	Information provided when participating in surveys. If the survey is conducted by a third party, that party’s privacy policy will apply.	We use this information to gather feedback and improve our services. We have a legitimate interest in understanding our users' opinions.

4. How We Use Personal Information

At TurTrip, we are committed to using your Personal Data responsibly and in compliance with applicable regulations, including the General Data Protection Regulation (EU) 2016/679 (GDPR). In addition to the specific purposes previously described, we use your personal information for the following purposes:

4.1. Provision of Services

• Identification: We use your Personal Data to identify you when you access or browse our website or use our services.
• Transaction processing: We process your data to provide products and services, manage orders, and handle returns of eSIMs and other purchased products
• Payment process optimization: We use your information to facilitate and optimize payment processing, ensuring secure and fast transactions.

4.2. Improving Services and Products

• Product development and improvement: We analyze your interactions with our services and products to improve and optimize our offerings, aiming to provide a better user experience.
• Conducting analytical studies: We use the data to carry out statistical and analytical studies that help us better understand our users’ preferences and improve our services.

4.3. Communications and Support

• User communication: We use your information to respond to your requests, questions, issues, or feedback, whether via email, online chat, or any other available communication channel.
• Sending promotional materials: With your consent, we send you promotional and marketing communications related to products, services, sales, or promotions from TurTrip or our business partners.

4.4. Safety and Security

• Prevention of fraudulent or illegal activities: We use your Personal Data to detect, prevent, and protect you against malicious, deceptive, fraudulent, or illegal activities, as well as against violations of our policies and terms and conditions. This includes detecting security incidents and protecting the rights, property, and safety of our company, our users, or other individuals.
• Website functionality troubleshooting and maintenance: We process personal information to identify and fix errors that may affect the proper functioning of our website and services, ensuring their stability and operability.

4.5. Legal Compliance and Regulatory Obligations

• Regulatory compliance: We use your Personal Data to comply with our legal and regulatory obligations, including the retention of tax information, reporting to competent authorities, and compliance with local and European regulations.
• Establishment and defense of legal rights: We process your personal information to establish, exercise, or defend ourselves against potential legal claims, both in judicial proceedings and administrative procedures.

4.6. Internal Administrative Purposes

• Business relationship management: We use your Personal Data to manage our business relationships with you, including maintaining records of purchases, transactions, and user preferences.
• Internal management: We use information from our employees, candidates, and suppliers to carry out the internal administration of the company and personnel management.

4.7. Other Permitted Purposes

• Specific consent: In some cases, we may process your Personal Data for other specific purposes if we have previously obtained your explicit consent for such processing. These purposes may vary depending on the circumstances, and you will be informed in each case about the use of your data.

4.8. Legal Basis for Processing

The processing of your Personal Data by TurTrip may be based on different legal grounds, depending on the context in which we collect and use the information:

• Performance of a contract: We process your Personal Data when necessary to perform a contract to which you are a party, such as when you purchase an eSIM or use our services.
• Compliance with legal obligations: We process your information to comply with our legal obligations, such as retaining records to meet tax regulations.
• Legitimate interest: We process your Personal Data when we have a legitimate interest in doing so, for example, to improve our services, prevent fraud, or ensure the security of our systems. In these cases, we always ensure that your privacy is protected and that our interests do not override your rights and freedoms.
• Consent: In cases where your explicit consent is required for the processing of certain data, such as for sending promotional communications, you will always have the option to withdraw it at any time, without affecting the lawfulness of prior processing.

4.9. Multiple Purposes

In many cases, your Personal Data is collected and processed for multiple purposes simultaneously. For example, if you make an online purchase, your data will be used both to fulfill the contract and for administrative and security purposes. This means that your data is processed in different contexts and under various legal bases, such as your consent, the need to fulfill a contract, our legal obligations, and/or our legitimate interest in efficiently managing our business.

5. How We Share Your Personal Data

TurTrip is committed to protecting the confidentiality of your Personal Data. However, in certain circumstances, it may be necessary to share your information with third parties. These third parties will only have access to your Personal Data when it is essential for providing our services and always under strict confidentiality and security guarantees, in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR). Below, we outline the situations in which we share your Personal Data:

5.1. External Service Providers

TurTrip may share your Personal Data with third-party providers to facilitate the provision of our services. These third parties act as data processors and are bound by confidentiality agreements that ensure the security of your information. Some examples include:

• Payment service providers: To securely manage and process your financial transactions.
• Telecommunications service providers: For the delivery, activation, and operation of purchased eSIMs.
• Technical support and maintenance providers: To ensure the operability of our platform and provide technical assistance when necessary.
• Administrative and back-office service providers: To carry out administrative tasks related to billing, accounting, and record management.

5.2. Legal and Regulatory Authorities

We may share your Personal Data with legal authorities, regulatory bodies, and other government entities in the following cases:

• Compliance with legal or regulatory obligations: If required by law, court order, or at the request of a competent authority. This includes, but is not limited to, requests from tax authorities, courts, data protection regulatory bodies, and law enforcement agencies such as the police.
• Protection of our rights: When necessary to protect the rights, property, or safety of TurTrip, our users, or third parties, including the detection and prevention of fraud or any other illegal activity.

5.3. International Data Transfers

If your Personal Data needs to be transferred outside the European Economic Area (EEA), TurTrip ensures that such transfers are carried out with appropriate safeguards, in compliance with the GDPR. These measures may include:

• Standard contractual clauses adopted by the European Commission that provide adequate data protection safeguards.
• Certifications or international agreements that ensure an adequate level of protection, such as the Privacy Shield between the EU and the U.S., where applicable.

5.4. Group Entities

If TurTrip is part of a corporate group, your Personal Data may be shared with other entities within the group for internal administrative purposes and for the development of our business activities, ensuring at all times the confidentiality and security of the data.

5.5. External Advisors and Professionals

We may share your Personal Data with external advisors, such as legal and tax consultants, auditors, or insurers, in the following cases:

• Legal advice: When necessary to obtain legal advice or to defend ourselves in legal proceedings.
• Financial and tax consultancy: To ensure compliance with our tax and financial obligations.

5.6. Other Service Providers

TurTrip may also share your Personal Data with external providers that offer other types of services essential for the operation of our company. These providers include:

• Advertising and communication services: For the management of marketing and communication campaigns.
• Physical and technological security services: To ensure the protection of our facilities and the security of our systems.
• Servicios de archivo, custodia, almacenamiento y destrucción de documentos: Para garantizar una adecuada gestión de los datos físicos y electrónicos de acuerdo con la normativa vigente.
• Other services: Any other service that, at TurTrip’s discretion, may be of commercial interest.

6. Data Retention

TurTrip will retain your Personal Data only for as long as strictly necessary to fulfill the purposes set out in this Privacy Policy, including compliance with our legal, accounting, and reporting obligations. In some cases, we may retain your Personal Data for a longer period if required or permitted by law.

6.1. Criteria for Determining the Retention Period

To determine the appropriate retention period for your Personal Data, TurTrip relies on the following criteria:

• Duration of the contractual relationship: We will retain your data for the duration of our relationship with you, as a client or user of our services, and for an additional period of 7.5 years after the end of that relationship. This additional period is based on our legitimate interests in protecting ourselves against potential legal disputes or complying with regulatory obligations.
• Legal and regulatory requirements: We retain information in accordance with applicable laws, including those related to tax, accounting, and financial reporting. If we are subject to specific legal obligations requiring data retention for a longer period, we will comply with those timelines.
• Potential risk and nature of the data: We consider the amount, nature, and confidentiality of the Personal Data. We also assess the potential risk of harm that could arise from unauthorized use or disclosure of the data, as well as whether the purposes for which we collect the data can be achieved by other means.
• Legal position of TurTrip: If there is the possibility of a regulatory investigation, pending or potential litigation, or any other type of legal conflict, we may retain the data longer than initially planned to protect the interests of TurTrip.

6.2. Specific Retention Periods

Certain personal data may be retained for specific periods of time, depending on the nature of the data:

• Connection history and call recording: We will retain this data for up to 6 months, in accordance with the security and protection requirements of our systems, as well as to resolve inquiries or disputes that may arise related to the use of our services.
• Payment and transaction-related data: Information related to eSIM or data plan purchases, including billing and payment details, will be retained for as long as necessary to fulfill our contractual and regulatory obligations, and for the applicable legal retention period for financial documents.

6.3. Data Deletion or Anonymization

When Personal Data is no longer necessary for the purposes for which it was collected or processed, or when the retention period expires, we will take appropriate measures to securely delete it or anonymize the data so that it is no longer associated with you or capable of identifying you, unless we are required to retain it for a longer period to comply with a legal obligation.

7. Personal Information of Minors

At TurTrip, we recognize the importance of protecting the Personal Data of minors and are committed to complying with all applicable regulations, especially those governing the processing of data of minors. Under European regulations and other applicable laws, we consider minors to be individuals under 18 years of age, or the equivalent age according to local laws.

7.1. Prohibition on Use by Minors Under 16

Our services are intended exclusively for individuals over 16 years old. TurTrip does not allow or encourage the registration, use of accounts, or purchase of services by persons under 16 years of age. If you are under 16, we ask that you do not use our services, create an account, or provide us with any personal information under any circumstances.

7.2. No Intentional Collection of Children’s Data

TurTrip does not deliberately collect Personal Data from individuals under 16 years of age. We also do not knowingly authorize third parties to collect personal data from minors through our website, mobile application, or any other means related to our services.

7.3. Actions to Be Taken If Minors Under the Age of 16 Are Detected

If TurTrip detects that it has received personal information from a minor under 16 without proper consent, we will take the following measures immediately:

• Data deletion: We will delete the minor’s Personal Data from all our systems and databases as quickly as possible.
• Account closure: If the minor has created an account, we will proceed to close it, preventing access to our services.

If you are aware that a minor has provided Personal Data to TurTrip, please notify us immediately through the channels indicated in this Privacy Policy. We are committed to investigating and resolving the situation diligently and in accordance with applicable regulations.

7.4. Responsibility of Parents or Guardians

We strongly recommend that parents and legal guardians supervise the online activities of minors under their responsibility. If you believe that a minor under your care has provided Personal Data to TurTrip without your consent, please contact us immediately so that we can delete that information and take the necessary measures to prevent future incidents.

8. Your Data Protection Rights

At TurTrip, we respect your rights regarding the protection of your Personal Data and are committed to providing you with the appropriate mechanisms to exercise them, in accordance with the General Data Protection Regulation (GDPR) and other applicable regulations. Below, your rights and how to exercise them are detailed.

Law	Description
Right of Access	You have the right to request access to the Personal Data that TurTrip holds about you, as well as to receive a copy of the personal information we process.
Right to Rectification	You may request that we correct any inaccurate or incomplete Personal Data that TurTrip holds about you.
Right to Erasure	In certain cases, you have the right to request the deletion of your Personal Data, for example, if the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent and there is no other legal basis for processing.
Right to Object	You have the right to object at any time to the processing of your Personal Data when such processing is based on the legitimate interests of TurTrip or a third party. If we receive your objection, we will stop processing your data unless we can demonstrate compelling legitimate grounds for continuing the processing.
Right to Restriction of Processing	You may request the restriction of the processing of your Personal Data in certain circumstances, for example, if you contest the accuracy of the data or if you believe the processing is unlawful.
Right to Data Portability	You may request that the Personal Data you have provided to TurTrip be delivered to you in a structured, commonly used, and machine-readable format, or that it be transferred to another data controller, when technically feasible.
Right to Withdraw Consent	If you have given your consent to the processing of your data, you may withdraw it at any time. This will not affect the lawfulness of the processing based on your consent prior to its withdrawal.
Right to File a Complaint	You have the right to file a complaint with a supervisory authority, such as the Spanish Data Protection Agency (AEPD), if you believe your rights have been violated.
Right to Object to Automated Decisions	You have the right not to be subject to a decision based solely on the automated processing of your data, including profiling, that produces legal effects or significantly affects you.

8.1. Exercising Your Rights 

To exercise any of these rights, you can contact us via email at [email protected] or by using the contact forms available on our website. TurTrip is committed to processing your request without undue delay, and in any case, within a maximum period of one month from receipt of the request, unless exceptional circumstances justify an extension.

8.2. Identity Verification

Before processing your request, we may need to verify your identity to ensure that the Personal Data in question actually belongs to you. This verification may include questions related to your account or a request for additional documentation.

8.3. Limitations and Exceptions

Please note that some rights may not be absolute. In certain cases, TurTrip may not be able to fulfill your request, either due to legal obligations or because the law allows it. In any case, we will provide you with a clear and detailed explanation of the reason why we cannot fulfill your request.

8.4. Rights Regarding Marketing Emails

You can opt out of receiving marketing communications at any time. To do so, simply use the unsubscribe feature provided in the marketing emails we send or write to [email protected] .

8.5. How to delete your account

If you wish to delete your account, you can do so by accessing your profile settings on our website, or by contacting us through customer service channels. Once the request is received and verified, we will process the deletion of your account and your Personal Data in accordance with applicable regulations.

8.6. Exceptions to Data Deletion

In certain cases, TurTrip may be required to retain some of your Personal Data even after you have requested its deletion. This occurs, for example, when the law requires us to keep data to comply with our tax, legal, or security obligations, such as Know Your Customer (KYC) requirements or compliance with transaction retention rules.

9. Security

At TurTrip, we are committed to protecting your Personal Data and follow generally accepted security standards to safeguard the information we collect. We implement physical, electronic, and procedural security measures appropriate to the nature of the Personal Data processed to protect it against unauthorized access, alteration, disclosure, or improper destruction.

The measures implemented include:

• Data encryption: We apply encryption technology in sensitive communications and payment processes to protect your information.
• Access controls: We limit access to your Personal Data only to employees, contractors, and third parties who need this information to perform their duties.
• Monitoring and auditing: We conduct audits and monitor the use and access of the systems where Personal Data is stored to identify potential security threats.

Despite our efforts, no method of data transmission over the Internet or electronic storage is completely secure. Therefore, while we strive to protect your information to the fullest extent, we cannot guarantee the absolute security of your Personal Data.

9.1. User Responsibility

It is the responsibility of each TurTrip user to protect their access credentials, including their password. We recommend using strong passwords and changing them regularly to minimize the risk of unauthorized access.

If you have reason to believe that the security of your account or any interaction with TurTrip has been compromised, please notify us immediately through our customer service team at [email protected] . We will take the necessary measures to investigate and resolve any potential security breach as quickly as possible.

In the event of a security breach affecting your Personal Data, TurTrip will comply with applicable legal obligations, including notifications to the relevant authorities and affected users, as stipulated by the General Data Protection Regulation (EU) 2016/679 (GDPR) and other relevant regulations.

10. Contact Information for Exercising Your Data Protection Rights

For any inquiries regarding the information detailed in this Privacy Policy, or if you wish to exercise your rights under data protection regulations, you can contact our customer service team.

Email: [email protected].

We encourage you to contact us if you have any questions or concerns regarding the processing of your Personal Data. We will respond to your request diligently and within the timeframes established by applicable regulations.

We are committed to addressing your inquiry promptly and efficiently. If you are not satisfied with our response and are located within the European Union, you may file a complaint with the competent data protection supervisory authority, such as the Spanish Data Protection Agency (AEPD) if you are in Spain, or the corresponding authority in your jurisdiction.

11. Changes to this Privacy Policy

At TurTrip, we reserve the right to modify or update the terms of this Privacy Policy at any time, in accordance with applicable regulations. If we make substantial changes in the way we process or use your Personal Data, we will notify you appropriately. This may include posting a prominent notice on our homepage, in the app, or by sending a notification to your registered email address.

We recommend that you periodically review this Privacy Policy to stay informed about any updates. Modifications will take effect from the time of their publication, unless otherwise indicated. At the top of this policy, you will find both the effective date and the last updated date, so you can easily identify if any changes have been made since the last time you viewed it.

Effective date: This is the date from which the current version of the policy is considered effective.

Last updated date: Indicates when this policy was last reviewed or substantially modified.

If you have any questions or concerns regarding the changes made, or about how they may affect the processing of your Personal Data, you can contact us through the channels indicated in this Privacy Policy.

This Privacy Policy was reviewed and published on September 16, 2024.