Eurosky PDS and Portal – Privacy Notice

Last updated: 15 April 2026

This Privacy Notice explains how personal data is processed when you use the Eurosky Personal Data Server (PDS) and the Eurosky Portal (portal.eurosky.tech). Both products are operated by Stichting Modal as parts of the Eurosky service.

This Privacy Notice is separate from the Privacy Policy that applies to the Eurosky marketing websites, mailing lists, and general communications. It also does not cover the Eurosky migration tool EU-HAUL, which is offered as a separate product and has its own Terms of Service and Privacy Policy.

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 both the Eurosky PDS and the Eurosky Portal.

Contact (privacy): privacy@eurosky.tech

Part A — The Eurosky PDS

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. The Eurosky PDS is not an online platform.

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 cloud infrastructure provided by an EU-headquartered hosting provider, in data centres located within the European Union. At the time of writing, that provider is Hetzner Online GmbH (Germany). We may change our infrastructure provider from time to time, but we are committed to using only providers that are headquartered in the EU and that process personal data exclusively in data centres within the European Union.

To operate and secure the service, we may also use service providers acting on our behalf as data processors (for example, for 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 or use it for advertising, marketing or purposes other than providing you with the service.

Public nature of federated content. The Eurosky PDS is part of the AT Protocol federated network. Content you publish through your PDS, such as posts, profile information, follows, and likes, is, by design, publicly accessible. It can be read, indexed, and re-displayed by any service participating in the AT Protocol network (such as relays, AppViews, and feed generators), including services we do not operate or control. Once published, this data should be considered fully public and may be retained or cached by third parties beyond our control. If you delete content from your PDS, we propagate the deletion through the protocol (including tombstone events on the firehose), but we cannot guarantee that all third parties will honour the deletion.

Moderation. The Eurosky PDS is infrastructure, not an online platform. We do not proactively monitor, rank, or curate content. We do not use third-party moderation services. Moderation actions are taken in-house and only on a notice-and-action basis: we act on lawful notices we receive (for example, under the EU Digital Services Act) or where we are legally required to do so. Further information is set out in our Terms of Service.

8. International data transfers

Your PDS data is hosted and stored within the European Union, by an EU-headquartered hosting provider operating EU-based data centres (see Section 6).

In the course of operating, securing, and supporting the Eurosky PDS, we may also use internal systems and third-party service providers, such as monitoring, security, error tracking, communication, or customer support, some of which may be established outside the European Economic Area. Where personal data is transferred to a country outside the EEA as a result, we ensure that appropriate safeguards are in place in accordance with EU data protection law, such as Standard Contractual Clauses approved by the European Commission or an adequacy decision by the European Commission.

We do not transfer the primary contents of your PDS repository (your posts, profile data, and stored media) outside the European Union, except as a result of AT Protocol federation as described in Section 7.

9. Data retention

We retain PDS account data (such as your AT Protocol identity, profile, and content stored in your repository) for as long as your account is active.

Technical and operational data, including server logs, IP addresses, and security and abuse-prevention signals, is retained for 30 days, unless a longer retention period is required for legal, security, or operational purposes (for example, to investigate a specific incident, to comply with a legal obligation, or to defend legal claims).

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.

Part B — The Eurosky Portal

10. What the Eurosky Portal is

The Eurosky Portal (the "Portal") is a user-facing front-end available at portal.eurosky.tech. The Portal is currently available only to users of the Eurosky PDS; users whose AT Protocol identity is hosted on a different Personal Data Server cannot currently sign in to the Portal. This restriction may be relaxed in future versions as the Portal moves out of beta. The Portal allows Eurosky PDS users to:

  • create a Eurosky account on the Eurosky PDS;
  • sign in to their account using AT Protocol OAuth;
  • view a basic dashboard with their profile information (such as their handle, display name, avatar, and post and follower counts) as fetched from their PDS;
  • discover compatible third-party AT Protocol applications via a featured-apps directory;
  • use sign-in facilitation for selected third-party apps, where the Portal shares your handle with the app to streamline its sign-in flow;
  • browse and view data stored in their PDS, such as images, videos, and other media; and
  • access account management and support links.

The Portal is currently in beta. This means it is an early version that is not feature-complete, and that its features and behaviour may change. The Portal is not an online platform: it does not host user content, operate feeds, recommend content, or curate speech.

The Eurosky Portal is not the migration tool. The Eurosky migration tool, EU-HAUL, is a separate product offered by Stichting Modal with its own Terms of Service and Privacy Policy. This Privacy Notice does not apply to EU-HAUL.

11. What personal data is processed via the Portal

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

  • Account creation hand-off: when you create a Eurosky account from the Portal, account creation happens directly against the Eurosky PDS. The Portal does not collect or store your email address or your password. Those fields, where applicable, are submitted directly to the PDS and are governed by Part A of this notice.
  • Authentication data (OAuth): when you sign in, the Portal uses AT Protocol OAuth. You enter your handle, are redirected to your PDS to authorise the Portal, and the Portal receives an OAuth access token. The Portal holds this token server-side only (it is not exposed to your browser or to third-party applications) and uses it solely to retrieve your profile information from your PDS in order to populate your dashboard. As part of the OAuth handshake, the Portal also temporarily stores the OAuth flow state required for the sign-in to function.
  • Profile data fetched from your PDS: once authenticated, the Portal makes a server-side request to your PDS using the OAuth access token to retrieve profile information (handle, display name, avatar, post count, following count, follower count). Depending on how your PDS resolves the request, this may in turn involve a call to an AT Protocol AppView (such as the Bluesky AppView). The Portal does not independently store a copy of your profile data; it is fetched on demand and displayed to you.
  • Browsing and viewing your own data: the Portal may allow you to browse and view data stored in your PDS, such as images, videos, and other media (collectively referred to as "blobs" in the AT Protocol). This data is retrieved from your PDS using your existing OAuth access token and displayed to you within the Portal for your own use. The Portal does not independently store copies of this data and does not share it with any third party.
  • Server-side account state: the Portal stores a small amount of state on its servers in order to function, including a record of whether you have accepted our Terms of Service, whether you have dismissed the welcome banner shown to new users, your login-session state, and the OAuth flow state described above.
  • Sign-in facilitation for third-party apps: for selected third-party AT Protocol applications, the Portal may facilitate the sign-in process by sharing your handle with the destination app so that it can identify you and streamline its own sign-in flow. Before any data is shared, the Portal will clearly inform you of what will be transmitted. Only your handle (and, where applicable, a marker identifying Eurosky as the referring service) is shared. The Portal does not share your OAuth access token, your email address, your password, or any other profile or account data with third-party apps through this feature.
  • Technical and operational data: standard request data needed to operate the Portal, such as IP addresses, user-agent strings, timestamps, and server logs.
  • First-party cookies and local browser storage: the Portal sets:
    • First-party session cookies to maintain your authenticated login session.
    • A theme key in your browser's local storage to remember whether you have selected light or dark mode.
    • Language preferences stored in your browser's local storage to remember your preferred language.
    The Portal does not set any third-party cookies, tracking cookies, advertising cookies, or analytics cookies.

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

12. Why we process Portal data

We process personal data via the Portal in order to:

  • enable you to create and sign in to a Eurosky account;
  • display your profile information and account dashboard;
  • present a directory of compatible AT Protocol applications;
  • maintain the security, stability, and integrity of the Portal;
  • detect and prevent abuse or misuse of the Portal; and
  • comply with applicable legal obligations.

13. Legal bases for processing Portal data

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

  • Performance of a contract: to provide the Portal services to you, including account creation and sign-in;
  • Legitimate interests: to operate, secure, and improve the Portal, 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.

14. Where Portal data is hosted and processed

The Eurosky Portal is hosted on cloud infrastructure provided by an EU-headquartered hosting provider, in data centres located within the European Union. At the time of writing, that provider is Hetzner Online GmbH (Germany). As with the PDS, we may change our infrastructure provider from time to time, but we are committed to using only providers that are headquartered in the EU and that process personal data exclusively in data centres within the European Union. All personal data processed and stored by the Portal itself — including server-side session state, OAuth tokens, and Terms of Service / welcome-banner acknowledgements — is processed within the European Union.

When the Portal fetches your profile information from your PDS in order to display your dashboard, the request is made server-side from the Portal to your PDS. Depending on how your PDS resolves the request, the data flow may also involve a call to an AT Protocol AppView, such as the Bluesky AppView, which is operated by Bluesky PBC in the United States. Where this happens, only the minimum public data needed to populate your dashboard (such as your handle and aggregate post and follower counts) is involved in that fetch; your OAuth credentials are not shared with any AppView.

Quick-login destinations. Third-party apps offered via the Portal's Quick-login category may be hosted outside the European Economic Area. When you click a Quick-login app, your handle and a source=eurosky marker are transmitted directly from your browser to that third-party app, which acts as an independent data controller and processes your data under its own privacy policy, including any applicable international-transfer safeguards.

If, in the future, additional personal data is transferred to a country outside the European Economic Area, we will ensure that appropriate safeguards are in place in accordance with EU data protection law (such as Standard Contractual Clauses approved by the European Commission) and update this Privacy Notice accordingly.

15. Sharing of Portal data

Third-party applications listed in the Portal. The Portal includes a directory of third-party AT Protocol applications, organised into two categories:

  • Featured apps (plain links). Clicking a plain featured app simply opens the third-party application's website in a new browser tab. The Portal does not transmit your handle, your OAuth token, or any other personal data to these applications.
  • Sign-in facilitation. For selected apps, the Portal may facilitate the sign-in process by sharing your handle (and, where applicable, a marker identifying Eurosky as the referring service) with the destination app. Before any data is shared, the Portal will clearly inform you of what will be transmitted. No other personal data is shared: the Portal does not pass your OAuth access token, your email address, your password, or any other profile data to third-party apps through this feature.

In both cases, once you leave the Portal and visit a third-party application, that application is operated by a third party and is governed by its own terms and privacy policy. We are not responsible for the privacy practices of third-party applications.

Service providers. We may use service providers acting on our behalf as data processors (for example, for hosting). Where such providers process personal data, they do so under contractual safeguards and in accordance with EU data protection law.

Public authorities. We may share Portal data with public authorities where we are legally required to do so.

We do not sell PDS data or use it for advertising, marketing or purposes other than providing you with the service.

16. Analytics and tracking

The Eurosky Portal does not use any web analytics, tracking pixels, fingerprinting, or third-party advertising or marketing tags.

17. Data retention (Portal)

We retain technical and operational Portal data — including server logs, IP addresses, and security signals — for 30 days, unless a longer retention period is required for legal, security, or operational purposes.

OAuth tokens and login-session state are retained server-side for the duration of your session, and are deleted or invalidated when your session ends.

Server-side acknowledgements (such as your acceptance of our Terms of Service and your dismissal of the welcome banner) are retained for as long as your Eurosky account exists.

The Portal does not collect or store account-creation data such as email addresses or passwords; those fields, where applicable, are submitted directly to and stored by the PDS, and are governed by Part A of this notice.

Part C — Your rights and our obligations

18. 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. In the Netherlands, the supervisory authority is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).

19. Data security

We use appropriate technical and organisational measures to protect personal data processed via the Eurosky PDS and the Eurosky Portal against unauthorised access, loss, or misuse.

20. Personal data breaches

In the event of a personal data breach affecting Eurosky PDS or Eurosky Portal data, we will notify the competent supervisory authority (the Dutch Autoriteit Persoonsgegevens) without undue delay and, where feasible, no later than 72 hours after becoming aware of the breach, in line with Article 33 of the GDPR.

Where a breach is likely to result in a high risk to the rights and freedoms of affected users, we will also notify those users without undue delay, in line with Article 34 of the GDPR.

21. Changes to this notice

We may update this Privacy Notice from time to time to reflect changes to the Eurosky PDS, the Eurosky Portal, 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 and the Eurosky Portal Terms of Service. The Eurosky migration tool EU-HAUL is a separate product with its own Terms of Service and Privacy Policy.