Saily Terms of Service: 35 Mentions of ID Checks

edit Editorial team · updated 22 Aug 2026

This is not a review built from impressions. It is the same reading we give a statute, applied to a contract instead: the document a buyer accepts by clicking a button, reported back with the date it was read.

The source is Saily’s own Consumer Terms of Service. It is linked from Saily’s own site, not found by guessing a URL. Saily maintains seven separate agreements side by side, named together in a selector on the Terms page itself. They are the Consumer Terms of Service, the Business Terms of Service, the Airport Services Terms and Conditions, the Saily Voucher Terms and Conditions, the Third-Party Voucher Terms and Conditions, Saily’s Rewards Program and Saily’s Referral Program. This article reads one of them: the Consumer Terms of Service. It is the document that applies to a traveler buying a plan for personal use. The document itself is headed, plainly, "Saily Terms of Service,“ with ”Consumer Terms of Service" printed underneath as its specific subtitle.

The saved copy runs 93,052 characters. That makes it the longest of the four eSIM contracts we hold on file — longer than Holafly’s, Ubigi’s, or Nomad’s. It carries its own version marker too: “Last updated: 2026-07-15.” We read it on 22 August 2026, five weeks after that date. Nothing below is an opinion about Saily. It is what the text says, quoted, with the section it sits in named.

What the identity check actually gates

The Saily Terms of Service use the term “KYC” 35 times. That count is by word boundary — the regex \bKYC\b, not a plain substring search — against the full document text. Three separate counting methods agree here: word boundary, case-insensitive word boundary, and a bare substring match all return the same 35. That agreement is worth stating, not assumed. On other pages in this project the three methods have disagreed. The disagreement changed the published number there.

The check has nothing to do with the plain data eSIM that most Saily buyers purchase. It sits entirely inside one optional add-on: "Phone Number Functionality," which gives a buyer an actual phone number for calls and texts. The contract defines the term inside that same section:

'“KYC” or “Know Your Customer” means the identity verification procedure that you are required to complete, and that must be successfully verified by Saily, prior to (i) the disclosure to you of the specific Phone Number allocated under your Number Reservation, and (ii) the activation of such Phone Number for two-way communication, in each case in accordance with applicable telecommunications, electronic-communications, anti-money-laundering and consumer-protection laws and the rules of the relevant numbering authority and underlying carriers.'

The phrase that matters most is "prior to... the disclosure to you of the specific Phone Number." The check is not paperwork attached after purchase. It is a condition of finding out what the number is:

"Activation of the Phone Number for two-way communication... is conditional upon your successful completion of the KYC procedure and Saily’s successful verification of the information submitted. Until KYC has been so completed and verified: (i) the specific Phone Number allocated to your Account will not be disclosed to you; (ii) the Phone Number will remain inactive for two-way communication..."

The same section spells out what a buyer must keep supplying, on an ongoing basis, once that first check clears: "Provide proof of identity, if requested, including for the purposes of the KYC procedure and any periodic re-verification“, and ”Maintain accurate and up-to-date KYC information, and promptly notify Saily of any material change to such information." It also names what gets kept once the check runs: "retention and disclosure of call-detail records, SMS metadata, KYC documentation and traffic data, in accordance with applicable telecommunications and anti-money-laundering laws and the Privacy Policy."

The consequence of failing the check is not the same at every stage. Before a Phone Plan is ever activated, non-completion in time triggers the automatic cancellation-and-refund clause quoted later in this article. After activation, the contract treats a KYC failure differently: "Saily may, at any time and where reasonably necessary for compliance purposes, request additional information or documentation from you and re-perform or re-verify the KYC procedure. Where the KYC procedure cannot be successfully completed or verified within the timeframe specified... Saily may refuse, suspend or terminate the Phone Number Functionality and any associated Phone Plan. In any such case, no refund, extension, credit or compensation will be provided in respect of any elapsed reservation period or Phone Plan validity period." Two different moments, two different outcomes, inside the same defined procedure.

We spend a separate month of this project reading the laws that require a seller to identify a subscriber before activating service. That work lives in our rules coverage, not on this page. Here, no external regulator forced the clause onto the page in front of a reader. Saily wrote the identity-check condition into its own contract, for its own phone-number product, and a buyer accepts it by clicking through the Terms.

Three companies, one contract

“Saily,” as the contract defines the word, is not one company. The Terms name three. Which one actually binds a given buyer depends on the tax country tied to that buyer’s account:

The third row holds a detail worth reading closely. Saily Inc. is organized under the laws of Delaware. The contract’s own term for its Chicago, Illinois address is “principal business address” — not “registered address” or “registered office.” That is an ordinary feature of a Delaware corporation, not a mismatch: incorporating in Delaware while running the business somewhere else is standard practice for US companies. The governing-law clause is explicit about which law applies to everyone who lands in that third row:

"These Terms shall be governed by, and construed in accordance with, the laws of the state of Delaware, without reference to its choice of law rules."

The same clause carves out an exception for EU consumers. Their local mandatory consumer-protection law still applies, on top of the Delaware default. This is a description of how the contract is structured, not a judgment of it. Three entities, three principal business addresses, one governing-law default for the entity that covers most of the world. That is simply what the document sets up.

What happens to data you don’t use

On the plain eSIM data plan — the product most buyers actually purchase — the Saily Terms of Service are direct about what happens once the clock runs out:

"The Services will be available to you for the period specified at the time of purchase. When the mentioned period expires, any remaining Services will be lost, and no refund will be payable for those unused Services."

The Phone Number Functionality carries a separate, longer refund policy of its own, with partial-refund carve-outs tied to how much of a voice or SMS allowance went unused. That is a narrower question than the plain-eSIM clause above, and this page does not need to reproduce it in full.

We hold three other eSIM contracts on file. Reading each of them on this question, at the depth this page reads Saily’s, is separate work. It is not this page.

The clause that runs the other way

A page built only from the paragraph above would be one-sided. It would misstate what Saily’s Terms actually say. The same "Phone Number Functionality" section that makes the identity check a condition of activation also makes failing that check, on time, a trigger for getting the money back automatically:

"Where you have purchased a Phone Plan but have not, within specified amount of time from the date of purchase, successfully completed the KYC procedure so that Saily is able to verify it, Saily will: (i) automatically cancel the Phone Plan; (ii) initiate a refund; and (iii) notify you of such cancellation and refund through the App and/or by email."

The mechanism cuts both ways inside one clause. The number stays hidden until the check clears. If the check does not clear in time, the plan is cancelled and the refund runs on its own, not something a buyer has to request or chase. Both halves sit in the same section of the same document. A page quoting only one of them would not be describing this contract honestly.

Why this reads differently from other Saily reviews

Search for Saily and most results are impression-based. A star rating. A line inside someone else’s complaint about a different provider. A blog ranking Saily against a handful of competitors on price and coverage. None of that is wrong on its own terms. It just is not reading the same document this page reads. This page opened the Saily Terms of Service document itself. It counted a term across the full text, checked which section that term lives in, and quoted the one clause that cuts against a one-sided story. That is the whole method here: the contract, not an impression of it.

For the actual purchase — Turkey packages, coverage, and what the identity check does and does not touch on the ground — see our Turkey eSIM guide.