Privacy Policy and Personal Data Processing

Revision date: 16.06.2026

This Policy defines the procedure for processing and protecting personal data of users of the esim.bar website, personal account, API, Telegram bot, and other related services of LLC "SISTEMA".

The Policy has been prepared taking into account the model for providing information and technical services for interaction with the platform of the foreign supplier of eSIM packages (hereinafter referred to as "ITV services") and is applied in conjunction with the public offer of the Operator for the provision of ITV services.

1. Personal Data Operator

1.1. The personal data operator is LLC "SISTEMA", OGRN 1186658072094, INN 6677012280, KPP 667701001.

1.2. Contact for inquiries regarding personal data: support@esim.bar.

1.3. The address of the Operator's location is to be posted on the Site in the "Contacts" section and/or in this section before the publication of the Policy.

1.4. The Operator processes personal data in accordance with the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", the Civil Code of the Russian Federation, the Law of the Russian Federation "On Consumer Rights Protection" in the applicable part, and other applicable acts of legislation of the Russian Federation.

2. Terms

2.1. Personal data - any information relating to a directly or indirectly identified or identifiable individual.

2.2. Processing of personal data - any action or set of actions with personal data, including collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, anonymization, blocking, deletion, and destruction.

2.3. User - visitor of the Site, Customer, representative of a Commercial Customer, owner of a personal account, API user, Telegram bot user, or other related service of the Operator.

2.4. Customer - an individual placing an Order, registering a personal account, using the API, or otherwise accepting the Operator's offer.

2.5. Commercial Customer - a Customer using the Site, personal account, API, or ITV services for entrepreneurial, professional, partnership, agency, resale, corporate, or other commercial activities.

2.6. eSIM package supplier - a foreign operator, provider, aggregator, platform, or other supplier that provides the technical capability to use an eSIM package in the networks of foreign partner operators on its terms.

2.7. eSIM parameters - QR code, LPA code, SM-DP+ address, activation code, link, instructions, order identifier, application status, or other digital data set obtained from the eSIM package Supplier's platform or technical platform and necessary for the installation or use of the eSIM package on the terms of such supplier.

3. Data Processed

3.1. The Operator processes only the data necessary for the operation of the Site, personal account, API, Telegram bot, order placement and support, provision of ITV services, user support, security, and compliance with legal requirements.

3.2. The Operator may process the following categories of personal data:

  • contact details: email, first name, last name, phone number, if the User provided them during registration, order placement, support inquiries, or bot usage;
  • account data: account identifier, email status, registration date, login date, account settings, technical session information;
  • data of the Commercial Customer and its representatives: organization or individual entrepreneur name, INN, contact persons, position, corporate email, information about powers, if such data is provided by the User;
  • order data: selected eSIM package, country or region, quantity, price, currency, order number, payment status, application processing status, status of receiving or sending eSIM parameters;
  • eSIM parameters data: identifiers of the eSIM package, QR code, LPA code, SM-DP+ address, activation code, link, instructions, application status, installation, activation, or usage status, if such data is available to the Operator and necessary for providing ITV services, displaying in the personal account, diagnostics, cancellation, or refund;
  • support inquiry data: inquiry text, attachments, screenshots, communication history, problem details, device model, country of use, date and time of installation, activation, or usage attempt;
  • Telegram bot and other messenger data: username, user ID, profile name, message text, attachments, dialogue history, selected actions, and technical statuses, if the User contacts through the respective channel;
  • technical data: IP address, request date and time, URL, interface language, user-agent, browser and device information, cookies, local storage, similar identifiers, security logs;
  • API data: API keys and tokens in the technically necessary volume, request identifiers, API methods, request parameters, response statuses, error logs, IP addresses, request times, limits, and signs of technical abuse;
  • balance and transaction data: top-up amount, balance remaining, deductions, currency, account, act, payment status, payment identifier, payment provider, payment method;
  • limited payment data: payment status, payment identifier, payment provider, amount, currency, last digits or mask of the payment instrument, if such data is transmitted by the payment provider. The full details of bank cards are not stored by the Operator.

3.3. The Operator does not request special categories of personal data and biometric personal data. The User should not transmit such data through the Site, personal account, API, Telegram bot, or support.

4. Purposes of Processing

4.1. Personal data is processed for the following purposes:

  • registration, servicing, and protection of the personal account;
  • providing technical access to the API, issuing and servicing API keys;
  • order placement, payment, execution, and support;
  • provision of ITV services, including displaying technical information about eSIM packages, processing technical requests, transmitting minimally necessary data to the eSIM package Supplier's platform or technical platform, receiving and sending eSIM parameters to the User;
  • displaying orders, statuses, eSIM parameters, operation history, and balance in the personal account;
  • customer support, diagnosing installation, activation, or usage errors of the eSIM package, checking the possibility of cancellation, replacement, or refund of expenses;
  • email confirmation, access recovery, and communication with the User;
  • servicing the Telegram bot and other support channels, including selecting eSIM packages, placing orders, and assisting with installation;
  • fulfilling obligations under accounting, tax, claims, consumer, and other applicable legislation;
  • ensuring the security of the Site, personal account, API, and payments, preventing abuse, fraud, and unauthorized access;
  • reviewing inquiries, claims, chargebacks, banking, and payment disputes;
  • analyzing the quality of the Site, personal account, API, support, and bot operations in anonymized or aggregated form;
  • sending informational, service, and marketing messages when there is a legal basis and separate consent, if such consent is required by law.

5. Legal Grounds for Processing

5.1. The Operator processes personal data on the following grounds:

  • conclusion and execution of a contract with the User or taking actions at the User's request before concluding the contract;
  • the User's consent to the processing of personal data;
  • fulfillment of obligations imposed by the legislation of the Russian Federation;
  • exercising the rights and legitimate interests of the Operator, provided that the rights and freedoms of the User are not violated.

5.2. Consent to the processing of personal data is provided separately from the acceptance of the offer, user agreement, and other documents, if separate consent is required by law or the chosen processing scenario.

5.3. The User may withdraw consent by sending a request to support@esim.bar. The withdrawal of consent does not affect the legality of processing carried out before the withdrawal and does not terminate processing that the Operator is obliged or entitled to continue by law, contract, or for the protection of its rights.

6. Consent to the Processing of Personal Data

6.1. By confirming a separate consent checkbox on the Site, in the personal account, Telegram bot, or other interface, the User gives the Operator consent to process the personal data specified in this Policy for the respective processing purposes.

6.2. Permitted actions with personal data: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer to authorized recipients, anonymization, blocking, deletion, and destruction.

6.3. Consent is valid until the purposes of processing are achieved, the storage periods expire, the account is terminated, or consent is withdrawn, unless a longer period is required by law, contract, or for the protection of the Operator's rights.

7. Data Storage and Localization

7.1. When collecting personal data from citizens of the Russian Federation through the Site, personal account, API, Telegram bot, or other services, the Operator ensures the recording, systematization, accumulation, storage, clarification, and extraction of such data using databases located in the territory of the Russian Federation, unless applicable legislation allows for an exception.

7.2. Storage periods are determined by the purposes of processing:

  • account data is stored until the account is deleted or until there is no longer a need for its servicing;
  • order, payment, balance, invoice, act, and accounting documents are stored for the periods established by the legislation of the Russian Federation;
  • eSIM parameters data is stored for the time necessary to display to the User, support the Order, perform diagnostics, handle returns, claims, and protect rights;
  • correspondence with support and the bot is stored until the inquiry is resolved and for the time necessary to protect rights, review claims, and fulfill legal requirements;
  • technical security logs, API logs, and anti-fraud data are stored for a limited time necessary to protect the service, investigate incidents, and prevent abuse.

7.3. After achieving the purposes of processing, the Operator ceases processing and destroys personal data or ensures their destruction within the timeframes established by the legislation of the Russian Federation, unless further storage is required by law, contract, or for the protection of the Operator's rights.

8. Transfer to Third Parties

8.1. The Operator may transfer personal data only to the extent necessary for the purposes of processing:

  • to payment providers, banks, and payment systems - for receiving and confirming payments, refunds, chargebacks, and payment security;
  • to eSIM package Suppliers, foreign platforms, and technical providers - for processing technical requests, obtaining eSIM parameters, checking order status, diagnostics, cancellation, replacement, or refund of expenses;
  • to hosting providers, database providers, security services, anti-fraud services, CDN, and technical infrastructure - for the operation and protection of the Site, personal account, and API;
  • to email providers, notification services, messengers, Telegram, and support services - for delivering messages, supporting Users, and processing inquiries;
  • to contractors for accounting, legal, technical, and customer support - to the extent necessary for the performance of their functions;
  • to government authorities, courts, banks, payment systems, and other authorized persons - in cases and procedures provided by the legislation of the Russian Federation or necessary for the protection of the Operator's rights.

8.2. Persons receiving personal data on behalf of the Operator are obliged to maintain confidentiality and ensure data protection in accordance with applicable legislation and the contract with the Operator.

9. Cross-Border Transfer

9.1. Since ITV services are related to platforms of foreign eSIM package Suppliers, in certain cases, for the execution of an Order, obtaining eSIM parameters, diagnostics, cancellation, replacement, or refund of expenses, a cross-border transfer of a limited set of personal data to a foreign eSIM package Supplier, foreign platform, technical provider, payment provider, or support service may be required.

9.2. Before the start of the cross-border transfer, the Operator fulfills the requirements of Article 12 of the Federal Law No. 152-FZ, including assessing the conditions of the transfer and sending a notification to Roskomnadzor, if such notification is required.

9.3. The cross-border transfer is carried out only to the extent necessary for providing ITV services, executing the Order, technical support, diagnostics, security, refunds, or fulfilling legal requirements.

10. Telegram Bot, AI, and Automated Processing

10.1. If the User interacts with the Telegram bot, AI consultant, or other automated assistant of esim.bar, the Operator may process Telegram profile data, message text, selected actions, attachments, dialogue history, technical statuses, and information necessary for selecting an eSIM package, placing an Order, sending eSIM parameters, or providing support.

10.2. Automated tools may be used for selecting eSIM packages, answering standard questions, routing inquiries, assisting with installation, diagnostics, and improving support quality.

10.3. The User should not transmit excessive personal data, document data, special categories of personal data, biometric data, payment card details, or other information not necessary for placing an Order or diagnostics through the Telegram bot, AI consultant, or support.

10.4. If a decision requires individual verification, financial refund, claims review, or other legally significant actions, the Operator has the right to forward the inquiry to a support employee.

11. Cookies and Analytics

11.1. The Site uses mandatory cookies and similar technologies for the operation of the cart, checkout, session, personal account, API interfaces, security, and language selection.

11.2. Analytical and marketing cookies are used in accordance with the Cookies policy and applicable consent settings.

11.3. The User can limit cookies in the browser, but this may affect the operation of the Site, order placement, personal account, API, and certain functions.

12. User Rights

12.1. The User has the right to:

  • receive information about the processing of their personal data;
  • request clarification, blocking, or destruction of data if they are incomplete, outdated, inaccurate, illegally obtained, or not needed for the stated purpose;
  • withdraw consent to the processing of personal data;
  • object to processing in cases provided by law;
  • appeal the actions or inaction of the Operator to Roskomnadzor or court.

12.2. To exercise their rights, the User sends a request to support@esim.bar.

12.3. The Operator has the right to request information necessary to confirm the identity of the applicant and verify the legitimacy of the request.

13. Protection of Personal Data

13.1. The Operator takes necessary legal, organizational, and technical measures to protect personal data from unauthorized access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions.

13.2. Measures include access restriction, user rights management, logging, backup, using secure channels, contractor control, internal rules for processing personal data, anti-fraud checks, and other measures considering the nature of the processed data.

13.3. The User is responsible for ensuring the security of their login, password, API keys, tokens, and other access means to the personal account, API, and related services.

14. Policy Changes

14.1. The Operator may update the Policy when the Site, personal account, API, Telegram bot, processing procedures, contractor composition, legislation, or service provision model changes.

14.2. The current version of the Policy is published on the Site and is available without restrictions.

15. Contacts

Support email: support@esim.bar
Website: esim.bar