Effective from 16 October 2026.
1. Who handles your data
The controller is DataYield, s.r.o., company number 11942649, registered office Příčná 1892/4, 110 00 Praha 1, Czech Republic, entered in the Commercial Register kept by the Municipal Court in Prague, section C, insert 356047.
Write to support@semperonline.com — the same address handles the requests in section 6.
We have no data protection officer and are not required to appoint one: the duty arises from systematic monitoring on a large scale, or large-scale processing of special categories, and neither describes us. We record how much data our own customers used, not what people do online. If the scale changes materially, we will look at it again.
2. What we know about you
When you buy an eSIM
- your e-mail address — without it there is nowhere to send the QR code,
- your name, if you fill it in,
- what you bought, for how much, in which currency and when,
- payment identifiers from Stripe — we never hold your card number, only a payment id, the fee, and an opaque fingerprint of the card (section 5),
- the invoice, or rather its id at Stripe.
When you use the eSIM
- technical identifiers of the profile (ICCID, the supplier's profile number, sometimes IMSI, MSISDN, EID),
- the profile's state and how much data has gone through it, which the supplier reports to us one to three hours late,
- how long the plan is valid and when it was activated.
We do not track where you travel or what you do online. We cannot see the sites you visit, the content of anything, or your location. We do see the volume of data and the country the plan is for — without that we could not show you what is left.
When you buy VPN
- the same as for an eSIM: your e-mail, what you bought, for how much and when, the payment identifiers,
- for a subscription, its state, when it renews and how far it is paid up.
When you use VPN
- the account name we generated (it is derived from nothing of yours), its password stored encrypted, and the date the access runs to.
We cannot see what you do over the VPN — no visited sites, no DNS queries, no traffic content, no addresses you connect from. We have no access to it and the network operator does not send it to us. What they say about their own logging is in section 5.
When you have an account
- e-mail, password (stored as a hash, never readable), whether the address is confirmed, when you last signed in,
- sign-in tokens, of which we keep only a hash.
When you write to us — your message and the address it came from.
When you use the support chat
- we store the whole conversation — your messages and the assistant's,
- the e-mail we identify you by in the chat, or the order number you quote,
- and a language model answers you, not a person. So that it can answer a question about your order, the model is given your order and eSIM details — what you bought, where the plan works, how much data is left, its status.
That model runs at Anthropic in the United States (see section 5). We send it nothing you do not type into the chat and nothing unrelated to your order, and it changes nothing — the assistant cannot refund you or cancel a profile; that stays with you or with a person. If you would rather your message did not go to a model, write to support@semperonline.com instead.
Operational data — IP address and the technical records that running a website and servers produces.
3. Why, and on what basis
| Purpose | What it involves | Legal basis |
|---|---|---|
| Delivering the eSIM and supporting it | order, profile, usage, order e-mails | performance of a contract (Art. 6(1)(b)) |
| Delivering VPN and supporting it | order, creating the access, how long it lasts, e-mails about it | performance of a contract (Art. 6(1)(b)) |
| VPN subscriptions | the recurring payment, the subscription state, the link to manage it | performance of a contract (Art. 6(1)(b)) |
| Accounting and tax | payment records | legal obligation (Art. 6(1)(c)) |
| Preventing abuse | return limits, card fingerprint, rate limiting, the human check at checkout | legitimate interests (Art. 6(1)(f)) — protecting ourselves against buy-and-return cycles, stolen-card testing and attacks on accounts |
| Complaints and disputes | the record of an order | contract and legitimate interests |
| Support chat | the conversation, and your order details passed to a language model | performance of a contract (Art. 6(1)(b)) for questions about an order; legitimate interests (Art. 6(1)(f)) for general ones — answering quickly without waiting for a person |
| Audience measurement | aggregate statistics, no cookies, no identifier | legitimate interests (Art. 6(1)(f)) |
| Marketing e-mail | we send none — we only write about what you ordered | — |
4. How long we keep it
We keep them for as long as we need them, and after that for no longer than the law requires:
| What | How long |
|---|---|
| Tax documents (invoices issued and received) | 10 years from the end of the tax period in which the supply took place — § 35 of the Czech VAT Act; the longer of the two statutory periods, so the one that governs |
| Other accounting records | 5 years (Czech Accounting Act) |
| Financial statements and annual reports | 10 years (Czech Accounting Act) |
| Your account, orders, eSIMs and VPN access | while you have an account; after you close it, only as far as the periods above require |
| Server logs (including IP address) | 30 days — the default retention in Google Cloud Logging |
| Support chat conversations | 24 months from the last message |
Deletion is done by hand, not by machine, once those periods run out. We do not put shorter periods here that nobody would keep to — promising erasure in ninety days and not doing it is worse than saying plainly how it works.
If you want your data deleted sooner, write to us (section 6). Whatever we are not required to keep, we delete.
5. Who else sees it
We do not sell your data. It reaches only the companies the service cannot run without:
| Recipient | For what | Where | Basis for transfer outside the EU |
|---|---|---|---|
| Our eSIM supplier | issuing and managing the profile, usage | Hong Kong, Singapore, China | Art. 49(1)(b) GDPR — transfer necessary to perform the contract; no standard contractual clauses in place, detail below |
| Our VPN supplier | creating and managing the VPN access | Seychelles | Art. 49(1)(b) GDPR — transfer necessary to perform the contract; no standard contractual clauses in place, detail below |
| Stripe | payments, invoices, refunds | EU / USA | our contracting entity is Stripe Payments Europe (Ireland); the US leg rests on both the EU‑US Data Privacy Framework and standard contractual clauses |
| Resend | sending e-mail (QR code, confirmations) | USA | standard contractual clauses and the EU‑US Data Privacy Framework |
| Cloudflare | checking that an order comes from a person (Turnstile) | global network | EU‑US Data Privacy Framework and standard contractual clauses |
| Anthropic | the language model that answers in the support chat | USA | standard contractual clauses (module 2) in the data processing addendum, and participation in the EU‑US Data Privacy Framework; our account is on commercial terms, so your messages are not used to train models |
| Google Cloud | hosting, europe-west1 (Belgium) | EU | within the EU |
| Neon | database, eu-central-1 (Frankfurt) | EU | within the EU |
| Upstash | cache, eu-central-1 (Frankfurt) | EU | within the EU |
| Plausible | audience measurement | EU (Germany) | within the EU |
| accountants, lawyers, public authorities | where the law requires it | Czech Republic | — |
With Stripe, Resend, Cloudflare, Anthropic, Google Cloud, Neon and Upstash we have a data processing agreement in place; in each case it forms part of the terms we accept by using the service.
We describe the eSIM and VPN suppliers by category rather than by name: the law asks for categories of recipients, not a list of them, and who supplies us is commercially confidential. What you do need to know — and what matters for your data — is the country it goes to and on what basis.
Our eSIM supplier
We do not send them your name, your e-mail or your payment details. What goes out are the technical identifiers an eSIM cannot be issued without: our order number, the package code and the number of profiles, and for a top-up or a cancellation the profile number. Back comes the ICCID, the activation code and how much data has gone through. From where they stand it is an order for a plan, not a customer.
Because they operate the profile, they also see when it attached to a network and how much data passed through it. Your name is nowhere near it — we are the only ones who can tie it back to you. That is why we treat it as personal data and write it down here, rather than claiming nothing is passed on.
The contracting party is a company in Hong Kong, for which the European Commission has issued no adequacy decision. The data does not stay there, though — the supplier has told us where it is processed and from where it is reached:
- hosting in Singapore,
- the database, operational monitoring and the customer-support system in China,
- their staff may access it from China, Malaysia, Indonesia, Singapore, the United Arab Emirates, the Netherlands and the United States.
It is still the same technical identifiers as in the first paragraph; your name, your e-mail and your payment details enter no part of that chain. The supplier has not named those further processors to us — we know what they are used for and in which country, not what they are called.
We have no standard contractual clauses with them and they have told us they do not enter into them. The transfer rests on being necessary to perform the contract you entered into with us — Art. 49(1)(b) GDPR. Their commercial terms bind them to confidentiality, to notifying security incidents, and to deleting or returning data when the relationship ends.
The local mobile operator whose network the eSIM attaches to processes the data about that connection as a controller in its own right, under the law of its own country. It is neither our processor nor the supplier's, and we have no say in it — the same thing happens on ordinary roaming with a plastic SIM.
Our VPN supplier
We do not send them your name, your e-mail or your payment details — exactly as with the eSIM supplier. What goes out is the account name we generated, its password, and the date the account should run to. From where they stand it is an anonymous account, not a customer.
They do run the network your connection goes through, so your traffic technically passes through it. What they say they do not keep: browsing history, DNS queries, traffic content, source IP addresses, connection times and session lengths; the servers run in memory only. We write it down here because it matters to your decision — but it is their statement, not our promise: we cannot verify it and we cannot guarantee it on their behalf.
The contracting party is a company in the Seychelles, for which the European Commission has issued no adequacy decision, and we have no standard contractual clauses with them. The transfer rests on being necessary to perform the contract you entered into with us — Art. 49(1)(b) GDPR.
The app you connect to the VPN with is published by another company, based in Hong Kong. You download it yourself, its terms and its privacy policy are its own rather than ours, and we pass it nothing. You can also connect without it, with a QR code in a tool of your own choosing.
6. What you can do about it
You have the right to:
- know what we hold and get a copy,
- have anything inaccurate corrected,
- have your data deleted, unless we must keep it for the law or an order in progress,
- restrict processing, and object to processing based on legitimate interests (the rows above),
- receive your data in a machine-readable form,
- withdraw consent at any time where processing rests on it.
Write to support@semperonline.com. We answer within a month.
If you think we are handling your data badly, you can complain to the Czech Data Protection Authority (Úřad pro ochranu osobních údajů, Pplk. Sochora 27, 170 00 Prague 7, <https://uoou.gov.cz>). We would rather you told us first.
7. Cookies and what runs in your browser
There is no consent banner because there is nothing to consent to. We use only what the site cannot work without:
| What | For | How long |
|---|---|---|
| sign-in | keeping you signed in | until you sign out |
| chosen currency | so the site does not offer you a different currency each time | 1 year |
| chosen appearance | so the bar stays light or dark the way you picked it | 1 year, only if you pick |
| chosen language | so the site does not switch you back to your browser's language | 1 year, only if you pick |
| animation turned off | so the site does not start an animation you switched off | 1 year, only if you switch it off |
| Stripe | processing the payment and fraud prevention | as set by Stripe |
| Cloudflare Turnstile | checking you are a person | sets no tracking cookies |
We do not measure you with cookies. Plausible counts visits without cookies and without an identifier that would recognise you on another site; we only ever see totals.
There are no advertising or tracking scripts on this site.
8. Security
Passwords are stored only as hashes, and so are sign-in tokens. Traffic is over HTTPS. Administration is reachable only with the right role, and irreversible actions are recorded — who did what, and how it ended.
If there were a breach that put you at high risk, we would tell you.
9. Children
The service is not meant for children under 16, and we do not knowingly collect their data.
10. Changes
We reserve the right to change this policy. When we do, we publish the new version and change the effective date; if the change is significant, we will write to you.