Privacy Policy
Privacy Policy
Updated: 22 October 2026
This English version is provided for convenience. The German version is authoritative.
Controller
LivaGoo, Muhammed Akbas, Bremsberg 12, 59229 Ahlen, Germany, support@livagoo.com.
LivaGoo and Gurbet eSIM are brands of the same German sole proprietorship owned by Muhammed Akbas. LivaGoo is not a separate legal entity. The contracting party and data controller is Muhammed Akbas, Bremsberg 12, 59229 Ahlen, Germany; LivaGoo contact: support@livagoo.com.
Hosting
Technical server logs such as IP address, time, browser and requested files are processed to operate the website securely.
Orders
We process name, email, order, payment, technical and support data to perform the contract and comply with legal duties.
Payments
We use Stripe for checkout payments under Article 6(1)(b) GDPR. Stripe is a separate controller in particular for its own payment-service obligations, regulatory checks and fraud prevention. Where it processes data solely on our instructions for technical payment processing, it acts as processor under the applicable agreements. Roles depend on the processing; Stripe is not universally our processor. Transfers outside the EEA additionally require Chapter V GDPR compliance.
Technical eSIM provision and international transfers
For the technical generation and provision of eSIM profiles, we use ESIM ACCESS LIMITED, Hong Kong (eSIMAccess), as our technical wholesale partner, together with the local mobile network operators in the selected destination country. In accordance with data minimisation, when retrieving a new eSIM profile through our API we transmit no customer names, postal addresses or email addresses to the wholesale partner, only technical package parameters and pseudonymised reference/profile identifiers (e.g. order ID, ICCID). Processing for contract performance is based on Article 6(1)(b) GDPR. Where technical connection, device or location data are processed outside the EU/EEA during profile provisioning or subsequent mobile network use in the non-EU destination country selected by the customer, transfers rely on appropriate safeguards under Article 46 GDPR (particularly Standard Contractual Clauses) or, where transfer to the booked destination’s network infrastructure is objectively and directly necessary to perform the customer contract, Article 49(1)(b) GDPR. The network operators act as separate controllers for technical network operation and statutory requirements in the destination country.
Email and WhatsApp
Messages are processed to answer enquiries. WhatsApp is optional; email is available as an alternative.
Cookies and local storage
Essential storage is used for language and settings. Non-essential technologies are used only with consent.
Your rights
Subject to the GDPR, you may have rights to access, correction, deletion, restriction, portability, objection and withdrawal of consent.
You may complain to LDI North Rhine-Westphalia. For telecommunications-specific processing under the TDDDG/TKG, the Federal Commissioner for Data Protection and Freedom of Information (BfDI) may be competent. Your right under Article 77 GDPR to complain to a competent authority remains unaffected.
Customer area, usage and service notices
For the protected customer area we process the order email address, short-lived one-time links, session data, order and eSIM details, status, validity and usage. Access uses a single-use link sent to the order email. Factual service emails may be sent at 50%, 80% and 90% usage to support the purchased service.
Optional feedback request
Only with voluntary consent, one honest-feedback request may be sent after the data is used or the plan ends, including contact options and the Google review page shared with Gurbet eSIM. Consent is optional and can be withdrawn.
Referral programme
We process the verified order email, a technical referral code, assignment and redemption data and pseudonymous Stripe metadata to run the programme, grant discounts and prevent abuse.
Marketing choice at checkout
If the optional newsletter choice is selected, a double-opt-in confirmation email is sent first. Marketing starts only after confirmation and can be stopped through the unsubscribe link.
Newsletter and 10% welcome code
For newsletter registration, we process your email address, language, registration, confirmation and unsubscribe timestamps, a pseudonymised IP record and the consent version used. Registration uses double opt-in. The legal basis is your consent under Art. 6(1)(a) GDPR. To create a personal one-time discount code, no plain-text email address is sent to Stripe; Stripe receives only a technical code and a hash as metadata. You may withdraw your consent at any time using the unsubscribe link in every newsletter email.
Withdraw from contract
For online withdrawal we process your name, contract identification, confirmation email, statement and receipt time to meet legal duties (Article 6(1)(c) GDPR, section 356a BGB). This information is not used for marketing or sent to eSIMAccess. After completion it is retained only for necessary proof and statutory retention periods.