Terms and Conditions for the eSIMiles Bonus Points and Loyalty Program

Date: 01.07.2026

A. Program Terms and Conditions

Section 1 Operator, program and scope

The operator of the bonus points and loyalty program is
HD Solutions GmbH
Danckelmannstr. 9, 14059 Berlin
Managing directors: Holger Zimmermann, Diana Bohlinth
Register court: Charlottenburg Local Court (Berlin)
Commercial register: HRB 250803
VAT ID: DE291049963.
The bonus points and loyalty program is operated under the working title “eSIMiles”.
The program is offered within the “eSIMony” mobile app for iOS and Android. The app is used for the sale, installation, management and top-up of travel eSIMs.
These Terms and Conditions govern only participation in the eSIMiles bonus points and loyalty program. They do not govern:

purchase contracts for eSIMs, data packages, top-ups or other paid services,
the use of the app software,
payment processing, cancellation rights, refunds or purchase-related warranty rights,
the general processing of personal data outside the program.

Separate purchase terms apply to the purchase of eSIMs, data packages and top-ups. Separate app terms of use apply to the use of the app. The Privacy Policy applies additionally to the processing of personal data.
The planned program start date is the launch of the eSIMony app.

Section 2 Eligibility and start of participation

Participation in the eSIMiles program is free of charge.
Only registered users of the eSIMony app with an active customer account are eligible to participate.
Participation requires that you accept these Terms and Conditions and that the program data required for participation may be processed.
Participation is only available to consumers within the meaning of Section 13 of the German Civil Code.
Only one customer account and one program participation are permitted per person. Multiple accounts, false identities or third-party accounts may not be used to obtain points, status benefits, referral rewards or other benefits improperly.
The operator may refuse, restrict or terminate participation if there are specific indications of misuse, manipulation, multiple accounts, false information or other breaches of these Terms and Conditions.

Section 3 Earning points through in-app purchases

Points are credited exclusively for purchases made within the eSIMony app.
Purchases made via the website, external shops, third-party platforms or other sales channels do not participate in the eSIMiles program and do not result in points being credited.
The basis for calculating points is the gross purchase amount that you actually paid for the respective purchase. The relevant amount is the amount including VAT after deduction of any discounts, vouchers, credits or points used, to the extent such deductions were applied at checkout.
The base earning rate is 5% of the gross purchase amount actually paid.
The conversion rate is: 100 points = EUR 1.00 credit value.
Points are calculated by converting the relevant percentage of the gross purchase amount actually paid into points based on the corresponding credit value. Example: For a purchase amount of EUR 10.00 and an earning rate of 5%, the credit value is EUR 0.50. This corresponds to 50 points.
Fractions of points are rounded down to whole points.
Points are generally credited after successful completion of the purchase. The operator may delay the credit until technical checks, fraud checks, payment confirmation or other appropriate security checks have been completed.
No points are granted for purchases that are canceled, refunded, charged back or not fully paid. Points already credited for such purchases will be reversed in accordance with Section 7.

Section 4 Status levels and increased earning rates

The eSIMiles program includes the status levels Bronze, Silver and Gold.
The status level is based on the total points you have collected during your entire participation. The relevant criterion is the total points collected (including referral rewards).
There is no annual reset and no rolling assessment period.
The status levels are:

Bronze: from 0 points collected, the earning rate is 5%,
Silver: from 500 points collected (equivalent to approx. EUR 100 in revenue), earning rate is 6% of amount spent,
Gold: from 1,700 points collected (equivalent to approx. EUR 300 in revenue), earning rate is 7% of amount spent.

The increased earning rate applies to purchases made after the respective status level has been reached. There is no retroactive increase for purchases already completed.
Only confirmed point entries that have not been permanently canceled, refunded or charged back count towards the points collected.
If a purchase is subsequently canceled, refunded or charged back and the basis for a status level is therefore removed, the operator may correct the points balance accordingly. A status level already reached will be recalculated accordingly and may be downgraded.

Section 5 Redeeming points

Points can be redeemed from a minimum balance of 200 points. 200 points correspond to a credit value of EUR 2.00.
There is no maximum discount for redemption, unless otherwise provided for technical or legal reasons in the respective checkout.
Only one points redemption may be used per order.
To redeem points, the selected points are converted into a one-time discount code.
The discount code has a validity period of 60 minutes and can be applied to the next qualifying purchase in the app.
The discount code can be used only once. After successful use, the discount code is deemed used.
If a generated discount code is not used within its validity period, the points used for it will be automatically re-credited.
Points have no cash value. They cannot be paid out, do not bear interest, are not transferable, are not inheritable and cannot be used outside the eSIMiles program.
Points cannot be combined with points or benefits from other programs unless expressly permitted by the operator.
The operator may refuse redemption if there are specific indications of misuse, manipulation, technical errors, multiple accounts, unauthorized transfer or other breaches of these Terms and Conditions.

Section 6 Referral program

Each participant receives a personal invitation code.
A new user may enter the invitation code when registering in the eSIMony app.
A referral reward is triggered only when the invited user successfully completes their first paid purchase within the app after entering the invitation code.
Purchases made by the invited user via the website or other sales channels do not trigger a referral reward.
After the invited user’s first paid purchase, the invited user receives 200 points.
The inviting participant receives the following reward depending on their own status level at the time the referral reward is triggered:

Bronze: 200 points,
Silver: 300 points,
Gold: 400 points.

Self-referrals are excluded. In particular, referrals to one’s own secondary accounts, household accounts or fictitious accounts, artificially created user accounts, accounts without genuine independent use or other circumvention arrangements are prohibited.
Abusive multiple accounts, manipulated registrations, fictitious purchases, automated account creation or other circumventions of the referral program are prohibited.
The operator may withhold, refuse or reverse referral rewards if there are specific indications of misuse, manipulation, cancellation, refund, chargeback or other breaches.
The operator may use technical protection measures to prevent misuse and verify proper use of the referral program.

Section 7 Points expiry, inactivity, cancellation, refunds and chargebacks

Unredeemed points expire if there has been no activity on the customer account for 24 months.
Activity within the meaning of this rule means any customer-side points transaction, in particular:

a purchase within the eSIMony app,
a top-up within the eSIMony app,
a redemption of points,
a confirmed referral under the referral program.

Each activity resets the 24-month period for the entire existing points balance. As long as activity takes place within the respective 24-month period, unredeemed points do not expire.
Pure system postings do not count as activity. These include, in particular, cancellations, refunds, reversals, chargebacks, technical corrections, misuse-related corrections and the expiry of points itself.
The operator may inform you in an appropriate manner about upcoming points expiry, for example in the app, by email or by push notification. A separate reminder is required only where legally mandatory.
If a purchase is canceled, fully or partially refunded or charged back, the points credited for that purchase will be reversed in full or proportionately.
This also applies in cases of chargebacks, payment errors, suspected fraud or subsequent reversal of a transaction.
If the points to be reversed have already been redeemed or are no longer fully available in the points account, the points balance may become negative.
A negative points balance will be offset against future points credits.
The operator may block further redemptions as long as there is a negative points balance or as long as there are specific indications of misuse, manipulation or open reversals.

Section 8 Misuse, suspension and exclusion

The operator is entitled to withdraw points in whole or in part, refuse redemptions, deactivate discount codes, refuse referral rewards or temporarily or permanently terminate participation in the program if there are specific indications of a breach of these Terms and Conditions.
Misuse includes in particular:

multiple accounts to obtain additional benefits,
self-referrals,
fictitious or coordinated referrals,
manipulated purchases, cancellations or chargebacks,
automated registrations or automated access,
false or third-party information,
transfer, sale or passing on of points, discount codes or invitation codes,
technical manipulation of the program, the app or connected systems,
any other unlawful or bad-faith use.

Before permanently terminating participation, the operator will appropriately take your legitimate interests into account. Prior warning is not required if there is a serious breach or if continued participation is unreasonable.
Statutory rights, purchase-related claims and mandatory consumer rights remain unaffected.

Section 9 Changes and termination of the program

The operator may change the eSIMiles program, individual functions, status levels, earning rates, redemption rules, referral rewards or other program conditions if there is an objective reason and the change is reasonable for participants.
Objective reasons may include in particular:

technical development of the app,
changes in economic conditions,
prevention of misuse,
legal or regulatory requirements,
changes relating to Shopify, payment service providers, app stores or technical partners,
security requirements,
editorial clarifications.

The operator will inform participants of material changes with reasonable prior notice in an appropriate manner, for example by email, in-app notice or push notification.
The operator may discontinue the program as a whole. In this case, the operator will inform participants with reasonable notice and provide a reasonable opportunity to redeem existing points, unless legal, technical or misuse-related reasons prevent this.
Changes that are exclusively beneficial, purely editorial or required due to mandatory legal requirements may become effective without a separate notice period to the extent legally permissible.
Points already earned generally remain unaffected by changes, unless reversal, expiry, misuse or program closure applies under these Terms and Conditions.

B. Data Protection Section for the eSIMiles Program

Section 10 Data protection in the eSIMiles program

HD Solutions GmbH processes personal data of participants for the operation of the eSIMiles program.
The controller within the meaning of the General Data Protection Regulation is:
HD Solutions GmbH
Danckelmannstr. 9, 14059 Berlin
Email: hello@esimony.com
A data protection officer has not been appointed.
In the context of the program, the following personal data in particular is processed:

customer account and identification data, such as name, email address, customer ID and app account,
purchase and order history within the app, to the extent required for points calculation, status levels, redemption, reversal and misuse checks,
gross purchase amounts actually paid within the app,
points balance,
points movements, in particular credits, redemptions, reversals, expiry and corrections,
status level, namely Bronze, Silver or Gold,
redemption data, discount codes and their use,
referral data, in particular personal invitation code, invitation code used and the allocation of which participant invited which new user,
technical log data and security features, to the extent required for prevention of misuse and program security.

The processing is carried out for the following purposes:

setting up and managing participation in the eSIMiles program,
calculating and crediting points,
calculating the status level,
creating and managing discount codes,
operating the referral program,
reversing points in the event of cancellation, refund or chargeback,
displaying the points balance and points history in the app,
communicating program-specific matters, for example points credit, redemption, expiry or changes,
preventing and investigating misuse, manipulation and multiple accounts,
complying with statutory retention and documentation obligations.

The legal basis for processing for the performance of program participation is Art. 6(1)(b) GDPR. The processing is necessary to enable participation in the eSIMiles program and to provide the associated services.
The legal basis for processing for misuse prevention, fraud prevention, system security and enforcement of these Terms and Conditions is Art. 6(1)(f) GDPR. The operator’s legitimate interest is to protect the program against manipulation, multiple accounts, unlawful use, financial damage and technical attacks.
Where personal data is processed to comply with commercial, tax or other statutory retention obligations, the processing is based on Art. 6(1)(c) GDPR.
Payment and ordering are processed via Shopify or through payment service providers integrated there. Within the scope of the eSIMiles program, the operator does not process full payment data such as full credit card numbers or comparable payment information.
Personal data may be transferred to service providers and technical partners to the extent necessary for the operation of the program, app provision, order processing, discount code creation, communication, IT security or prevention of misuse. This may include hosting, app, analytics, support, email, push notification, Shopify or technical infrastructure service providers. Details are described in the Privacy Policy.
Transfers to countries outside the European Union or the European Economic Area may take place if service providers used are based there or data is processed there. In such cases, the required data protection safeguards will be provided, for example EU Standard Contractual Clauses, adequacy decisions or other suitable safeguards under the GDPR. Details are described in the Privacy Policy.
Points and program histories are stored for as long as this is necessary for operating the program. Under these Terms and Conditions, unredeemed points generally expire if there has been no activity on the customer account for 24 months. Activity includes, in particular, a purchase, top-up, redemption or confirmed referral. Each such activity resets the 24-month period for the entire points balance. Pure system postings, in particular cancellations, refunds, technical corrections or the expiry of points itself, do not count as activity.
The underlying points movements and program data may be stored beyond the expiry of individual points or beyond the end of program participation to the extent this is necessary for traceability, misuse prevention, accounting, defense or enforcement of claims or compliance with statutory retention obligations.
Purchase and order data may be stored for a longer period due to commercial and tax retention obligations. The specific storage period depends on the applicable statutory requirements and the Privacy Policy.
After termination of participation, program-specific data will be deleted or anonymized as soon as it is no longer required for the stated purposes and no statutory retention obligations or legitimate interests prevent deletion or anonymization.
Subject to the statutory requirements, you have in particular the following rights:
right of access,
right to rectification,
right to erasure,
right to restriction of processing,
right to data portability,
right to object to processing based on legitimate interests,
right to lodge a complaint with a data protection supervisory authority.
To exercise your data protection rights, you can contact:
Email: hello@esimony.com.
Additional information on the processing of personal data, service providers, recipients, third-country transfers and data subject rights is available in the Privacy Policy:
https://www.esimony.com/policies/privacy-policy.

Section 11 Final provisions

The law of the Federal Republic of Germany applies, excluding the UN Convention on Contracts for the International Sale of Goods.
In relation to consumers, this choice of law applies only to the extent that it does not deprive the consumer of the protection of mandatory provisions of the law of the country in which the consumer has their habitual residence.
The contract language is German. This English version is provided for convenience. In the event of discrepancies, the German version prevails, unless mandatory law provides otherwise.
The statutory places of jurisdiction apply to consumers. These Terms and Conditions do not establish an exclusive place of jurisdiction to the detriment of consumers.
The operator is neither obliged nor willing to participate in dispute resolution proceedings before a consumer arbitration board, unless there is a statutory obligation to do so.
If individual provisions of these Terms and Conditions are or become invalid in whole or in part, the validity of the remaining provisions remains unaffected.
The statutory provisions apply in place of any invalid provision.
Headings are for readability only and have no independent regulatory effect.
Current version: 01.07.2026, version 1.0.