Document

Personal Data Processing Policy

1. Personal Data Processing Policy (Privacy Policy)

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) defines the procedure for collecting, accumulating, storing, using, distributing, anonymizing, blocking, and deleting personal data of users of qusim.online (the “Website”).

1.2. The personal data operator is IE MAXUDEN (IIN/BIN 950820050382, legal address: Republic of Kazakhstan, Aktobe, 38/39 Almat-Samyrat Street, email: info@qusim.online) (the “Operator”).

1.3. This Policy was developed in accordance with Law No. 94-V of the Republic of Kazakhstan dated 21 May 2013 “On Personal Data and Its Protection”.

2. Personal data collected

2.1. The Operator may process the following personal data of the User:

• Identification data: email address and telephone number, if provided;

• Technical and system data: IP address, browser type and version, operating system, cookies, and device type and identifiers when an eSIM profile is downloaded;

• Order and transaction data: order history, details of purchased eSIM Data Plans, and identifiers of generated QR codes.

2.2. The Operator does not collect or store payment data (bank card numbers or CVC/CVV codes). All payments are processed by authorized payment organizations/acquirers.

3. Purposes of collection and processing

3.1. The User’s personal data is processed for the following purposes:

• Performing the User Agreement (Public Offer), including providing access to the Account, generated QR codes, and eSIM profiles;

• Providing technical support and handling User inquiries;

• Transferring data across borders to the Infrastructure Provider (esimaccess.com / ESIM ACCESS LIMITED, Hong Kong) to the extent necessary to activate eSIM and provide communication services in international roaming;

• Sending service notifications, including order confirmations and installation instructions;

• Complying with the laws of the Republic of Kazakhstan.

4. Processing procedure and cross-border transfer

4.1. Personal data is processed using automated tools.

4.2. Cross-border transfer: the User is hereby informed and agrees that, to provide communication services, some technical data (order identifiers and email) is transferred to the Infrastructure Provider, ESIM ACCESS LIMITED (Hong Kong).

4.3. The Operator takes all necessary technical and organizational measures to protect the User’s personal data from unauthorized or accidental access.

5. Storage and deletion periods

5.1. Personal data is stored for the duration of the User’s account on the Website and for the periods established by the laws of Kazakhstan for retaining tax and financial records.

5.2. Personal data is deleted or anonymized when the User deletes the account or withdraws consent in writing.

6. User rights

6.1. The User has the right to:

• Receive information about the processing of their personal data;

• Request clarification, blocking, or deletion of their personal data;

• Withdraw consent to data processing by sending a request to info@qusim.online. Withdrawal of consent makes further use of the Account and provision of eSIM services impossible.