Privacy Policy

Last updated: 2 April 2026

1. Who we are

The eurosky.social and eurosky.tech websites are operated by Stichting Modal ("we", "us", "our"), a non-profit foundation established in the Netherlands.

Stichting Modal is the data controller for personal data processed in connection with the Eurosky websites and related communications.

This Privacy Policy applies to:

  • visitors to the Eurosky websites;
  • subscribers to Eurosky mailing lists and updates; and
  • individuals who submit information via forms or other communications technologies operated by Eurosky.

This Privacy Policy does not apply to personal data processed by third-party applications or services that interact with the AT Protocol, except to the extent Stichting Modal processes personal data directly in operating Eurosky services.

If you have any questions about this policy or how we handle personal data, contact us at: privacy@eurosky.tech

2. Key points

This section summarises how we approach personal data protection under EU law. It is written to be clear and accessible, and reflects that we do not use advertising or profiling, and that appropriate safeguards apply where any processing takes place outside the European Union.

  • We collect and process only limited personal data, primarily when you choose to provide it.
  • We do not sell personal data.
  • We do not use advertising, profiling, or behavioural tracking.
  • Where personal data is processed outside the European Union, appropriate legal safeguards are in place.
  • You can exercise your data protection rights at any time (see "Your rights" below).

While Eurosky may link to or provide access to third-party websites or services, this Privacy Policy does not apply to the practices of those third parties, and we are not responsible for their privacy policies.

3. What personal data we collect

Information you provide directly

When you register your interest, sign up for updates, or contact us, we may collect:

  • first name;
  • last name;
  • email address;
  • country or region;
  • language preferences;
  • information about whether you have an existing Bluesky / AT Protocol account;
  • any additional information you voluntarily include in a form or message.

Technical information

When you visit the Eurosky websites, limited technical data may be collected automatically, including:

  • IP address;
  • device and browser type;
  • pages visited and interactions with the site.

This technical data is collected in aggregated form via IONOS SiteAnalytics, a server-side analytics tool provided by our hosting provider. IONOS SiteAnalytics processes data on infrastructure located within the European Union and does not use tracking cookies or client-side scripts.

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

4. How we collect data

We collect personal data through:

  • forms on the Eurosky website, processed via Bunny.net edge scripts and Mailjet;
  • standard server logs maintained by our hosting provider (IONOS).

Form submissions (contact and signup forms) are processed by serverless edge scripts hosted on Bunny.net infrastructure, which forward the data to Mailjet for email delivery and contact management.

To protect forms from automated abuse and spam, we use Cloudflare Turnstile, a privacy-focused CAPTCHA alternative. Turnstile operates in the background to assess whether interactions are likely to be automated, without requiring user interaction in most cases. Turnstile may collect limited technical information (such as IP address and browser characteristics) for verification purposes. This processing is subject to Cloudflare's privacy policy.

We do not use Turnstile for advertising, profiling, or marketing purposes.

5. Why we use your data

We use personal data to:

  • register and manage expressions of interest in eurosky.social accounts;
  • notify you when account registration, migration, or related services become available;
  • respond to enquiries or messages you send us;
  • plan and design future Eurosky services; and
  • meet applicable legal, regulatory, and accessibility requirements, including by understanding user location and language preferences where necessary;
  • understand aggregate website usage and improve the site.

Where you have explicitly consented, we may also send you updates related to eurosky.social or the Eurosky project more broadly.

We do not use personal data for advertising or commercial profiling.

6. Legal basis for processing

Under the EU General Data Protection Regulation (GDPR), we process personal data on the following legal bases:

  • Consent – where you opt in to receive updates or communications;
  • Contractual necessity – to respond to requests or administer pre-registration processes;
  • Legitimate interests – to operate, secure, and improve the website and communications, where such interests are not overridden by your fundamental rights and freedoms.

We do not rely on UK-specific data protection regimes for this processing. You may withdraw consent at any time.

7. Analytics and cookies

We use IONOS SiteAnalytics, a server-side analytics tool provided by our hosting provider, to understand how visitors use the website and to improve performance.

IONOS SiteAnalytics collects limited, aggregated information such as page views, device type, and general location from standard server logs. This data is processed on infrastructure within the European Union and is used only for operational and statistical purposes.

We do not use advertising, profiling, or cross-site tracking cookies.

We do not use any client-side analytics scripts (such as Google Analytics). The Eurosky website does not set any first-party or third-party tracking cookies.

Cloudflare Turnstile, where used on forms, is treated strictly as a security and abuse-prevention measure. It is not used for analytics, advertising, marketing, or behavioural profiling.

Technical third-party resources

Some pages on the Eurosky website may load technical resources from third-party providers to ensure proper functionality. Currently, this includes the Cloudflare Turnstile script (served from challenges.cloudflare.com) on pages with forms. These resources:

  • are used only to ensure proper functionality and form security;
  • do not set advertising or profiling cookies; and
  • do not involve marketing or behavioural tracking.

8. Data sharing and processors

We do not sell personal data.

We share personal data only with service providers acting on our behalf as data processors, including:

  • IONOS SE (Germany) – website hosting and server-side analytics;
  • Bunny.net (Slovenia) – serverless edge script hosting for form processing;
  • Mailjet / Sinch (France / Sweden) – email delivery and contact management for form submissions;
  • Cloudflare (United States) – Turnstile CAPTCHA, used solely for security, spam, and abuse prevention on forms.

We no longer use Squarespace, Google reCAPTCHA, or HubSpot as data processors.

These providers are contractually required to protect personal data and to process it in accordance with applicable data protection law.

9. International data transfers

The Eurosky Personal Data Server (PDS) itself is hosted exclusively on infrastructure located within the European Union.

The Eurosky website and the majority of its supporting services are hosted and operated within the European Union: IONOS (Germany) for website hosting and analytics, Bunny.net (Slovenia) for form processing, and Mailjet/Sinch (France/Sweden) for email delivery.

Cloudflare Turnstile, used for form security, is provided by Cloudflare, Inc. (United States). Limited technical data (such as IP address and browser characteristics) may be processed outside the European Union as part of the CAPTCHA verification process.

Where personal data is processed outside the European Union, appropriate safeguards are in place in accordance with EU data protection law, including Standard Contractual Clauses approved by the European Commission.

Further details are available on request.

10. Data retention

We retain personal data only for as long as necessary to fulfil the purposes described in this policy.

In practice:

  • pre-registration and contact data is retained until accounts are launched or you request deletion;
  • communications and mailing list data is retained until you unsubscribe or ask for removal.

11. 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 processing;
  • withdraw consent at any time;
  • request data portability.

To exercise these rights, contact us at privacy@eurosky.tech.

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

12. Data security

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

13. Changes to this policy

We may update this Privacy Policy from time to time. The most recent version will always be published on this page, with the date of the latest update indicated above.