Eurosky Personal Data Server (PDS) – Privacy Notice

Last updated: 4 February 2026

This Privacy Notice explains how personal data is processed when you use the Eurosky Personal Data Server (PDS). It applies specifically to the PDS and is separate from the Privacy Policy that applies to the Eurosky websites, mailing lists, and general communications.

1. Who we are

The Eurosky PDS is operated by Stichting Modal (“Modal”, “we”, “us”), a non-profit foundation established in the Netherlands.

For the purposes of the EU General Data Protection Regulation (GDPR), Stichting Modal is the data controller for personal data processed in connection with the operation of the Eurosky PDS.

Contact (privacy): privacy@eurosky.tech

2. What the Eurosky PDS is

The Eurosky PDS provides personal data storage and identity hosting services for the AT Protocol. It allows you to:

  • create and manage an AT Protocol identity;

  • store personal data and content associated with that identity; and

  • connect your identity to compatible applications and services of your choosing.

The Eurosky PDS is infrastructure. We do not operate social media feeds, recommend content, or curate speech.

3. What personal data is processed via the PDS

Depending on how you use the service, we may process the following categories of personal data:

  • account identifiers and handles;

  • profile information you choose to provide;

  • content you post, upload, or store via your PDS;

  • social graph data (such as follows and connections);

  • technical and operational data required to operate the PDS (for example, IP addresses, timestamps, and logs);

  • security and abuse-prevention signals.

We do not intentionally process special category (sensitive) personal data.

4. Why we process PDS data

We process personal data via the PDS in order to:

  • provide and operate identity hosting and personal data storage services;

  • enable interoperability with AT Protocol applications chosen by you;

  • maintain the security, stability, and integrity of the service;

  • detect and prevent abuse or misuse of the PDS; and

  • comply with applicable legal obligations.

5. Legal bases for processing

Under the EU GDPR, we rely on the following legal bases when processing PDS data:

  • Performance of a contract – to provide the PDS services to you;

  • Legitimate interests – to operate, secure, and improve the PDS, and to prevent abuse, where those interests are not overridden by your fundamental rights and freedoms;

  • Legal obligation – where processing is required to comply with EU or national law.

6. Where PDS data is hosted and processed

Personal data stored on the Eurosky PDS is hosted on infrastructure located within the European Union.

To operate and secure the service, we may use service providers acting on our behalf as data processors (for example, for cloud infrastructure, monitoring, or security). Where such providers process personal data, they do so under contractual safeguards and in accordance with EU data protection law.

7. Sharing of PDS data

Your PDS data may be shared in the following circumstances:

  • with applications and services you choose to connect to your PDS, in accordance with the AT Protocol;

  • with infrastructure or security service providers acting as data processors on our behalf;

  • with public authorities, where we are legally required to do so.

We do not sell PDS data.

8. International data transfers

We aim to host and process PDS data within the European Union.

Where limited personal data related to the operation or security of the service is processed outside the European Union (for example, by certain security or monitoring providers), appropriate safeguards are in place in accordance with EU data protection law, including Standard Contractual Clauses approved by the European Commission.

9. Data retention

We retain PDS data for as long as your account is active.

If you delete your account or migrate your identity to another compatible provider, we will handle your data in accordance with the AT Protocol and applicable law. Certain limited data may be retained where required for legal, security, or operational purposes.

10. Your rights

You have the right to:

  • access your personal data;

  • correct inaccurate or incomplete data;

  • request deletion of your data;

  • restrict or object to certain processing;

  • request data portability.

You can exercise these rights by contacting us at privacy@eurosky.tech.

You also have the right to lodge a complaint with your local data protection authority.

11. Data security

We use appropriate technical and organisational measures to protect PDS data against unauthorised access, loss, or misuse.

12. Changes to this notice

We may update this Privacy Notice from time to time to reflect changes to the Eurosky PDS or to applicable law. The most recent version will always be published, with the date of the latest update indicated above.

This Privacy Notice should be read together with the Eurosky PDS Terms of Service.