EOS is a communication and safety app. That is why we designed it so that we know as little about you as possible: messages and calls are end-to-end encrypted, your address book is never uploaded, your location is never shown to strangers, and ads never use your messages, your contacts or your exact position.
This Policy explains what personal data we process when you use the EOS app and the business page (ads portal), for what purpose, on what legal basis, for how long, who we share it with, and what rights you have under the General Data Protection Regulation (EU) 2016/679 ("GDPR"), Cyprus Law 125(I)/2018 and, for users in Greece, Law 4624/2019.
1. Controller
- Controller: Evangelos Panatos, sole proprietorship "Eosalia"
- Address: 8os Dromos 2, 4620 Episkopi, Limassol, Cyprus
- Privacy email: privacy@eosalia.com
- Data Protection Officer (DPO): not appointed. For any data protection matter write to privacy@eosalia.com.
2. At a glance
| What | What applies |
|---|---|
| Messages, files, calls | End-to-end encrypted. We cannot read or listen to them. |
| Address book | Only fingerprints (hashes) of numbers leave the phone. We keep only which of them are already EOS users. |
| Location | Only with contacts who accepted sharing and members of your family. Never with strangers. |
| Stories | Only mutual contacts, for 24 hours. |
| Ads | Local ads only with consent; the phone sends only a rough area (about 20 km). No ads at all with EOS+. |
| Usage statistics | Off until you turn them on. |
| Selling data | We never sell personal data. |
| Deletion | In Settings, with one tap. |
3. What data we process and why
3.1 Account and profile
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Mobile number, one-time confirmation code | Creating the account and signing in | Performance of a contract (Article 6(1)(b) GDPR) | The number until the account is deleted; the code expires within minutes |
| Name, "about", profile photo, language | Showing your profile to other users | Performance of a contract | Until you change them or delete the account |
| Plan (free, EOS+) and its expiry | Providing the plan's features | Performance of a contract | Until the account is deleted |
| Date and version of acceptance of the Terms and this Policy | Proof of acceptance | Legitimate interest (Article 6(1)(f)) and legal obligation (6(1)(c)) | Until the account is deleted and 6 years afterwards |
Your profile photo is stored at a link that anyone who has it can open, so that it loads quickly for other users. Do not upload a photo you do not want visible outside EOS.
3.2 Finding friends from your address book
If you give access to your contacts, the app computes on your phone a cryptographic fingerprint (SHA-256) of each number and sends only those fingerprints to find who uses EOS. Names and numbers in clear text never leave your phone. Fingerprints of people who are not users are not stored. We store only the list of EOS account identifiers found, so we know who your mutual contacts are (for example for stories).
Transparency note: because the set of phone numbers is limited, a number fingerprint counts as pseudonymised, not anonymous, data. That is why we process it only for the comparison and do not keep it.
- Legal basis: your and our legitimate interest (Article 6(1)(f)) in letting you find people you know and, for people in your address book who are not users, minimal processing that is discarded immediately.
- Retention: the list of mutual contacts is refreshed at each sync and deleted with the account.
- You can withdraw contacts permission in your device settings at any time.
3.3 Messages, groups and calls
Messages, groups, attachments (photos, videos, files, voice notes, places) and calls are end-to-end encrypted using the Matrix protocol. The keys exist only on the participants' devices. The server only stores and relays encrypted content it cannot read.
To run the service we process the following metadata: who is a member of which conversation, when a message was sent and from which account, delivery and read indicators, the public keys of your devices, and, for calls, who takes part and when. Encrypted backups of your keys (key backup) are stored encrypted with the recovery key that only you hold.
In calls, audio and video pass through a relay server (SFU), encrypted per participant, so the server cannot see them. Call history is kept only on your device.
- Legal basis: performance of a contract (Article 6(1)(b)) and, for the confidentiality of communications, the relevant legislation.
- Retention: encrypted content stays on the server until delivered and deleted or until the account is deleted, and in any case for no more than 12 months. Metadata is deleted with the account.
3.4 Notifications (push)
To receive notifications, your device registers a push token with Apple (APNs) or Google (Firebase Cloud Messaging). Our server sends them only an event identifier, not the content of the message; your phone downloads and decrypts the message itself.
- Legal basis: performance of a contract. Retention: until you sign out on the device or delete the account.
3.5 Stories
| Data | Who sees it | Retention |
|---|---|---|
| Photo, video (up to 30 s) or text, caption, stickers, drawing | Only your mutual contacts who are not blocked | 24 hours; files are deleted automatically within the following hour |
| Tagging a contact | The same people, and the tagged contact gets a line in your chat | As long as the story |
| Place name (check-in) and weather | The same people | As long as the story |
| Who viewed the story | Only you | As long as the story |
If a story has been reported, we keep its files until the report and any appeal are closed. Replies to stories go to your chat, end-to-end encrypted.
For the place name, the phone uses the device's geocoding service (Apple or Google) and, for searching by name, the Photon service (komoot), which receives a rounded position. For the weather, a rounded position is sent to Open-Meteo. None of them receives your account details.
- Legal basis: performance of a contract.
3.6 Location and family
| Data | When | Who sees it | Retention |
|---|---|---|---|
| Live position (latitude, longitude, accuracy, time) | Only while someone is allowed to see it: an active share the other person accepted, or a family with sharing on | Only those people | The last position is deleted when sharing stops |
| Location history (one point every 2 minutes or 50 metres) | While you share your position | The same people, under the circle's rules | 24 hours on the free plan, 30 days with EOS+; deleted automatically every night |
| Family circles, members, invitations (codes valid 7 days) | When you create or join a circle | Circle members | Until you leave the circle or delete the account |
| Sharing requests with contacts | When you ask or accept | Both sides | Expire after 1 hour, 8 hours or when someone stops them |
The app may ask for location access including in the background, so that sharing continues while the app is closed. Access is used only while a share, SOS or Check-In is active.
- Legal basis: performance of a contract, based on your own active choice to share your position. For children in a family circle, the person with parental responsibility decides on their behalf.
3.7 Panic SOS
When you trigger Panic SOS:
- the SOS contacts you set (name and number, up to five) receive an alert with your name, your position updated every 15 seconds and, where available, the address;
- if you allow it, a 30-second audio clip is recorded and uploaded, which only you and the recipients of that alert can play;
- contacts who do not have EOS receive an SMS through our SMS provider with your name and a map link; without internet, the app opens your phone's SMS app so that you send it yourself;
- you see who opened the alert.
Audio, live location and SMS can each be turned off in the SOS settings.
- Legal basis: performance of a contract (Article 6(1)(b)) and, where you cannot act, protection of vital interests (Article 6(1)(d)). For your contacts' details: legitimate interest (Article 6(1)(f)) in alerting them in an emergency; please tell them.
- Retention: an alert counts as ended after one day at the latest. Alerts, positions and audio are kept for 30 days, so you can give them to the authorities if needed, and deleted earlier if you delete the account.
3.8 Safe Check-In
We process the destination, the arrival deadline, the contacts you chose, when they may see your position (until arrival, for 30 or 60 minutes, or only on alert), your position while the Check-In is open (at most once a minute or when you move 50 metres), and the status (reminder, "Are you OK?", alert, "Checked"). If you do not answer, the server alerts your contacts with your last known position, even if your phone is off.
- Legal basis: performance of a contract and, on alert, protection of vital interests.
- Retention: 30 days after the Check-In ends.
3.9 Local offers (ads)
Ads in EOS are designed so that we do not need to know where you are.
- Consent. We ask you once whether you want offers from your area and whether you are 18 or older. We store your answer and when you gave it. You can change it at any time under More › Local offers.
- With consent: the phone sends only a square of about 20 × 20 km (0.2 degrees). The server returns the offers for that square and the phone keeps only those whose circle contains your position. Your exact position never leaves the phone for ads and no position is stored. We only count how many people asked for offers in each square per day, without linking it to an account, so the business page can estimate reach; these totals are deleted after 30 days.
- Without consent: you see only general listings for the whole country. Your location is not used.
- Views and taps. To charge a business at most 3 views per person per ad per day and to count how many different people saw it, we record for each account how many times it saw or tapped each ad each day. These records are deleted after 2 days. Businesses see totals only, never names, numbers or positions.
- Hiding. Ads you hide are recorded only on your device.
- What we never use: messages, contacts, calls, stories, family, SOS, Check-In or special categories of data (health, religion, political opinions and so on). We do not build an advertising profile and do not give data to ad networks.
- Legal basis: for local offers, your consent (Article 6(1)(a) GDPR and the legislation on access to terminal equipment). For counting views for billing and fraud prevention, our legitimate interest (Article 6(1)(f)).
3.10 EOS+ and purchases
Purchases are made through the Apple App Store or Google Play, which act as independent controllers for the payment. We do not receive card details. Through RevenueCat we receive the product, the store, the purchase and expiry dates and transaction identifiers, linked to your account identifier.
- Legal basis: performance of a contract and legal obligation (tax records).
- Retention: for the duration of the subscription and afterwards for 7 years, as Cyprus tax law requires. When you delete the account we delete the subscriber from RevenueCat; data held by the stores is governed by their own policies.
3.11 Reports, moderation and blocking
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Report: who reported, what (user, message, group, story, ad), reason, comment, and the content the reporter's app sent | Reviewing reports and applying the DSA | Legal obligation (6(1)(c), DSA) and legitimate interest in user safety | 12 months after the case closes, or longer if needed for legal claims or by an authority |
| Decisions, statements of reasons, suspensions, appeals | The same, and evidence of the process | The same | The same |
| Blocked users | So that people you block cannot see you or write to you | Performance of a contract | Until you unblock or delete the account |
Because of encryption, we do not see conversation content unless a participant sends it to us with a report. Decisions are made by people; only the order of review is set automatically according to the report category.
3.12 Crash reports and usage statistics
- Crash reports (Sentry, EU region): when the app crashes it sends technical information (error type, stack trace, device model and operating system, app version). It does not send an account identifier, number, messages, positions or screenshots. They are on by default and you turn them off under Settings › Privacy. Legal basis: legitimate interest in the stability and security of the app. Retention: 90 days.
- Usage statistics (PostHog, EU region): off until you turn them on. If you turn them on, we send which screens you opened (only the type of screen, not which chat or person), without an account identifier. Legal basis: consent (Article 6(1)(a)), which you can withdraw at any time. Retention: 12 months.
3.13 Contacting support
If you write to us, we process your email, your message and anything you send us in order to reply. Legal basis: performance of a contract or legitimate interest. Retention: 24 months after the request is closed.
3.14 Business page (ads portal)
If you use the business page:
- Account: email, one-time sign-in links, your role in each business (owner, editor, viewer), invitations.
- Business: name, tax / VAT number, registered address, country and VAT zone, phone, email, reverse-charge flag.
- Ads: texts, photos, videos, call-to-action (phone, directions or website), area on the map, budget, dates and hours, review history.
- Payments: card payments are made through Stripe. We do not receive card details; we receive the amount, the date and the payment identifier. Invoices are issued by us, in our own accounting system.
- Cookies: the page uses only strictly necessary cookies for your sign-in and the selected business. It uses no advertising or analytics cookies.
- Maps: the page's maps load from CARTO and address search goes through OpenStreetMap Nominatim, which receive your IP address and what you search for.
- Legal basis: performance of the contract with the business, legal obligation (invoicing, tax, DSA) and legitimate interest (security, fraud prevention).
- Retention: while the account is active; accounting and tax records for 7 years under Cyprus tax law; ads and the Article 26 DSA information for 1 year after the ad stops running.
3.15 Data on your device
The app stores on your device, encrypted where applicable, messages and encryption keys, call history, settings (language, large text, auto-download, privacy choices) and the ads you hid. This storage is strictly necessary for the service you asked for, except usage statistics, for which we ask for consent. The app does not use cookies.
3.16 Nearby (Matching)
Nearby shows only your mutual contacts who are close by and have turned on their own visibility. It never shows you to strangers. Before connecting, others see only an approximate distance, not your exact position. If you send a connection request and the other person accepts it, you share your exact positions for the time you choose; sharing stops when it ends or when either of you stops it.
- Legal basis: performance of a contract, based on your own active choice to become visible and to accept a request.
- Retention: your position for Nearby is used only while visibility is on; requests and shared positions are deleted when they end, and in any case with the account.
- You can turn visibility off at any time from the Nearby screen.
4. Who sees your data
- Other users: only what each feature provides for (for example your profile, what you send to recipients, stories to mutual contacts, position to the people you chose, SOS and Check-In to your contacts).
- Our team: only authorised people, as far as needed for support, report moderation, ad review and security, with access logging.
- Processors: providers that process data on our behalf under a contract under Article 28 GDPR (see section 5).
- Authorities: when required by law or court order, or to protect someone's life.
- Successor: if EOS is transferred to a company (for example when the current provider incorporates a company), the data passes to it on the same terms, after we tell you.
We do not sell personal data and do not give it to advertisers or data brokers.
Requests from authorities
We give data to public authorities (for example police, prosecutors, courts) only where the law requires it: with a valid court or prosecutor's order, or a European Production or Preservation Order for electronic evidence (Regulation (EU) 2023/1543), concerning a specific account. We check every request for lawfulness, competence and scope, and provide only what is asked for and what we hold.
- What we cannot provide: the content of end-to-end encrypted messages, files and calls. We do not have the keys and cannot decrypt them.
- What may exist, for as long as we keep it under section 3: account details (number, name, sign-up date), technical connection logs (for example IP addresses and times), conversation metadata (which conversations the account takes part in and when), stories, location, SOS and Check-In data, reports, and subscription data.
- Preservation: when an authority asks us to preserve the data of a specific account, that data is not deleted automatically for as long as the order requires (usually up to 90 days, which can be extended), even after the periods in section 3. If deletion of the account is requested during that time, the account is locked and deletion is completed once preservation ends (Art. 17(3)(b) and (e) GDPR).
- Emergencies: where there is an imminent risk to someone's life or physical safety, we may give the necessary data without a prior order, as the law allows (Article 6(1)(d) GDPR, Article 18 DSA).
- Notice: we tell the user about the request, unless the law or the order forbids it, or it would endanger an investigation or people.
- Point of contact for authorities: legal@eosalia.com.
5. Providers we use
| Provider | What it does | Where | Safeguard |
|---|---|---|---|
| Supabase | Database, accounts, files for stories, profile photos, SOS audio and ads | EU (Frankfurt) | Data processing agreement (DPA) and SCCs |
| Hostinger, Hetzner Online | Our own messaging (Matrix), call (LiveKit), notification and map servers | EU | DPA |
| Cloudflare (R2) | Storage of encrypted attachments | EU | DPA, SCCs / EU-US Data Privacy Framework |
| Twilio | Sending confirmation codes and SOS and Check-In SMS | US / EU | DPA, SCCs / DPF |
| Google (Firebase Cloud Messaging), Apple (APNs) | Delivering notifications without content | US / EU | DPA, SCCs / DPF |
| RevenueCat | Managing EOS+ subscriptions | US | DPA, SCCs |
| Apple App Store, Google Play | Subscription payments | Worldwide | Independent controllers |
| Stripe | Card payments on the business page | EU (Ireland) / US | Independent controller for card data; DPA for the rest |
| Vercel | Hosting the business page and the admin panel | EU (Frankfurt) | DPA, SCCs / DPF |
| Sentry | Crash reports | EU | DPA |
| PostHog | Usage statistics (only with consent) | EU | DPA |
| Resend | Sending email (sign-in links and notices of the business portal) | EU / US | DPA, SCCs / DPF |
| komoot (Photon), Open-Meteo | Place search and weather for stories, with a rounded position | EU | No account data |
| Our own map server (OpenStreetMap data), CARTO, OpenStreetMap (Nominatim) | Map tiles: in the app from our own server; on the business page from the same server or CARTO; address search on the business page | EU (our server); EU / UK / US (CARTO, Nominatim) | Third parties receive only the IP address and the map area |
| KLIPY | Searching and showing GIFs in chats. The phone sends KLIPY the search words and a random device identifier directly, never the EOS account or message content. When you send a GIF, the recipient's phone loads it from KLIPY, which therefore sees their IP address | US | Independent controller; SCCs |
6. Transfers outside the EU/EEA
We store data mainly in the EU. Where a provider or its affiliates have access from a country outside the EEA (for example the US), the transfer relies on an adequacy decision (for example the EU-US Data Privacy Framework for certified companies) or on the European Commission's Standard Contractual Clauses with supplementary measures. You can ask for a copy of the safeguards at privacy@eosalia.com.
7. Automated decisions
We do not make decisions based solely on automated processing that produce legal effects for you (Article 22 GDPR). Local offers are selected on your phone based only on position, and moderation decisions are made by people.
8. How we protect data
End-to-end encryption for messages and calls, encryption in transit (TLS) and at rest, row-level access policies in the database, least privilege for the team, access logging, private files with temporary links, rate limits against abuse, and backups in the EU. No system is completely secure; if a breach affecting you occurs, we will notify the competent authority and you as Articles 33 and 34 GDPR provide.
9. Children
EOS is intended for people aged 16 and over. Local offers are shown only to people who confirm they are 18 or older, and we do not show profiling-based ads to minors (Article 28 DSA). If a child takes part in a family circle, the person with parental responsibility is responsible for the decision and for informing the child. If you believe a child has given us data without the required consent, contact us so that we delete it.
10. Your rights
You have the right to:
- access your data and receive a copy;
- rectification of inaccurate data (you can change your profile yourself);
- erasure: under Settings › Delete account. Deletion deactivates and erases the messaging account, the data in the database (profile, contacts, location, family, SOS, Check-In, stories, consents), SOS audio files, photos and the RevenueCat subscriber. We keep only what the law requires (for example tax records, DSA reports and decisions for the required period). Messages you already sent remain on the recipients' devices;
- restriction of processing;
- portability, meaning receiving the data you gave us in a structured format by a request to privacy@eosalia.com;
- object to processing based on legitimate interest;
- withdraw consent at any time, without affecting the lawfulness of processing before that (local offers, usage statistics, device permissions);
- lodge a complaint with a supervisory authority:
- Cyprus: Office of the Commissioner for Personal Data Protection, 1 Iasonos Street, 1082 Nicosia, www.dataprotection.gov.cy
- Greece: Hellenic Data Protection Authority, 1-3 Kifisias Avenue, 115 23 Athens, www.dpa.gr
To exercise your rights, write to privacy@eosalia.com from your account's number or email, or use the options in the app. We reply within one month. We may ask you to confirm your identity.
11. Device permissions
| Permission | Why | When |
|---|---|---|
| Contacts | Finding friends with number fingerprints, choosing SOS contacts | When you ask |
| Location (including background) | Location sharing, family, SOS, Check-In, local offers, places in messages and stories | Only when you use these features |
| Microphone | Calls, voice notes, videos, SOS audio | Only while in use |
| Camera, photos | Video calls, photos and videos in messages, stories, profile photo | Only while in use |
| Notifications | Messages, calls, SOS, Check-In | Always, if you allow it |
| Files | Sending and saving files | Only while in use |
12. Changes to this Policy
If we change this Policy materially, we will tell you in the app before the changes apply and, where the change concerns processing based on consent, ask for your consent again. The effective date is shown at the top.
13. Contact
For any privacy question: privacy@eosalia.com · 8os Dromos 2, 4620 Episkopi, Limassol, Cyprus.