Privacy Policy
1. Two roles
For a team's data (members, shifts, incidents, equipment, finances), the controller is the team (κλιμάκιο), that is the association that runs it. We process that data as processor, only on its behalf and under the Data Processing Agreement. For this data, members turn to their team, and we help the team answer.
For accounts and contact with us (sign-in email, password, support messages, billing details where there are any), we are the controller: DANIAS EVANGELOS LP, hello@pharosapp.com.
2. What data
Account
- Email, password (stored only in hashed form by the sign-in service), name, language.
- Sign-in times, and for push notifications the address of the device that receives them: in the iPhone and Android app, the identifier Google's Firebase gives it, only once you switch notifications on.
Team members (on the team's behalf)
- Identity: full name, father's name, codename, photo, date of birth, identity card or passport number, tax number (ΑΦΜ), social security number (ΑΜΚΑ), insurance, registry number, ΜΕΟΠΠ number, and scans of the identity card.
- Contact: address, phones, email, emergency contact.
- Health data (special category, GDPR Article 9): blood type, medical notes, medical certificates (cardiologist, pathologist, psychologist).
- Degrees, licences and certifications, with their scans, and training.
- Activity in the team: shifts and attendance, vehicle crews, vehicle checks, equipment issued, incidents, the log book, events, protocols, dues and expenses, reports.
- Incidents may also name third parties (places, people who were helped). The team enters only what it needs.
- An activity log: who changed or deleted what and when, with whatever was deleted as it was (a shift or a degree, for example). It does not record the values of members' identity, contact and health details.
Technical
- IP addresses in server logs and request limits, for security.
- Error reports: when something fails in the app or on the server, a report goes to Sentry with the error, the page or request where it happened and what came before it (pages, taps, requests to the server), the type of device, operating system and browser, and, from the server, the ids of the request, the team and the member. A report holds no IP address, no email addresses and no content of the requests.
- On the device we keep only what the app needs: the session and your choices in it, such as the theme (light or dark) and the language. We use no advertising cookies, analytics or trackers.
3. Why, and on what basis
- Accounts and the service: performance of a contract (Art. 6(1)(b)).
- Security, fixing errors and preventing abuse: legitimate interest (Art. 6(1)(f)).
- Invoices and accounting records: legal obligation (Art. 6(1)(c)).
- Members' data: the legal basis is set by the team as controller, and for health data the Art. 9(2) exception that applies to it.
4. Where it is kept: subprocessors
| Provider | What it does | Region |
|---|---|---|
| DigitalOcean | Database, account sign-in, the app's server (API) | EU (Frankfurt, Germany) |
| Cloudflare (R2) | File storage | EU |
| Vercel | Hosting of the app's web pages | Global network, USA |
| Resend (Amazon SES) | Sending email | Sent from the EU (Ireland); sending logs in the USA |
| ImprovMX | Forwarding the email we receive at hello@ | USA and EU |
| Google (Gmail) | The mailbox where email to hello@ arrives | Global network, USA |
| Stripe | Subscription payments, once switched on | EU (Ireland) and USA |
| OpenFreeMap | Map tiles | EU (Hungary) |
| OpenStreetMap Foundation (Nominatim) | Address search on the map | United Kingdom and EU (Netherlands) |
| Sentry | Error reports from the app and the server | EU (Frankfurt, Germany) |
| Google (Firebase Cloud Messaging) and Apple (APNs) | Delivering push notifications to the iPhone and Android app: their title and text | Global network, USA |
The address search and the map tiles are requested straight from your device, so OpenStreetMap and OpenFreeMap receive its IP address. OpenStreetMap also receives the address you type or the point you pick on the map.
For providers that transfer data outside the EEA, the transfer rests on the EU-US Data Privacy Framework or the Standard Contractual Clauses, and for the United Kingdom on the European Commission's adequacy decision.
5. How long we keep it
- While the team uses the service, its data stays for as long as the team keeps it.
- When a member leaves the team, because the team removed them, they left, or they deleted their account, these are deleted at once: their photo, identity card scans, medical certificates and the other documents filed under their name, address, insurance, blood type, medical notes, emergency contact, ΑΜΚΑ, ΑΦΜ, ID number, date of birth and roles. The sign-in account is deleted with them, except when they left, when it stays so they can join another team.
- The team keeps their full name, father's name, codename, email, phones, registry number, ΜΕΟΠΠ number and joining date, so its records still show who did what. When the member deletes their own account, the phones are deleted too.
- Scans of degrees, licences and certifications, and signed equipment-issue papers, are deleted 5 years after the member leaves the team, or sooner by the team's decision.
- A deleted file waits in a recovery bin for up to 30 days and is then deleted for good.
- Backups are kept encrypted, until newer ones replace them. Whatever is deleted stays in the backups taken before the deletion, until they are deleted too.
- An account with no team (it never created or joined one, or it left its team) is deleted after 30 days without a sign-in.
- When a team leaves, the deadlines of the Data Processing Agreement apply.
6. Your rights
You have the right of access, rectification, erasure, restriction, portability and objection. For a team's data, turn to your team. For your account, write to hello@pharosapp.com. You may also complain to the Hellenic Data Protection Authority (www.dpa.gr).
You delete your account in the app, under «Το προφίλ μου» (My profile) → «Λογαριασμός» (Account) → «Κλιμάκιο και λογαριασμός» → «Διαγραφή λογαριασμού» (Delete account), or by email to hello@pharosapp.com, in which case we delete it within 30 days. The steps, and what is kept: Delete your account.
7. Age
Accounts are for people aged 16 and over. A team that registers members under 18 is responsible, as controller of their data, for the consents that the rules governing it require.
8. Security
Each team sees only its own data, enforced in the database itself. Access within a team follows the roles it sets. Every connection is encrypted, and the providers encrypt data where it is stored. Files are served only through the app, to whoever may see them.
9. Changes
Each new version is published here with a new date.