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# Privacy Policy of the EKKIOS App

**Last updated: August 22, 2026**

This Privacy Policy applies to the EKKIOS web application ("the App") and describes how your personal data is processed when you use it.

## 1. Controller

**Ekkios e.V.**
Lurgiallee 6-8
60439 Frankfurt, Germany
Phone: +49 71412990101
Email: info@ekkios.com

## 2. Data processed when you visit the App without logging in

When you open the App, we process the following data to deliver and secure it:
- the pages and resources you request
- date and time of access
- the amount of data transferred
- the referring URL from which you reached the App
- your browser type and version, operating system and device type
- your IP address

This data is processed by us and our service providers (see Sections 3-9) to provide and protect the App. The App does not use advertising or marketing cookies, analytics pixels, or fingerprinting.

## 3. Hosting and app platform

The App and its database are operated by our cloud hosting and application infrastructure provider, which acts as our processor. Account data and content you submit through the App are stored with this provider and may be processed in the United States. International transfers are carried out under appropriate safeguards, including Standard Contractual Clauses.

## 4. Content delivery and security

Some App resources are delivered through external content delivery and security infrastructure. When these resources are loaded, technical data such as the IP address and requested resource may be processed for delivery, availability and security purposes. Where processing takes place outside the EEA, appropriate safeguards are used in accordance with applicable data-protection law.

## 5. Account, authentication and browser storage

If you create an account or sign in, we process your email address and authentication data. To operate the App, your browser stores:
- an authentication session, necessary to keep you signed in
- your language preference, when you choose one
- a local offline cache, so the App can be installed and used offline

No analytics or marketing storage is created.

## 6. PHOS AI assistant

The App includes "PHOS", an AI-powered spiritual assistant. When you send a message to PHOS, your message — together with the recent conversation context — is transmitted to our external AI processing provider (United States) for processing, and the generated reply is returned to you.

Before you can send your first message to PHOS, the App asks for your explicit consent through a dedicated consent screen; PHOS cannot be used until you have actively agreed. Because PHOS conversations may concern your religious beliefs, your spiritual life, health, or other sensitive matters, this is especially important: **your PHOS messages are sent to the external AI provider and processed there.** The App does not store your PHOS conversation history; your messages are sent to generate a response and are not retained in your account.

If you are signed in, your PHOS consent is linked to your account. If you use PHOS without signing in, your consent is recorded without creating an account. No PHOS message content is stored as part of the consent record.

The legal basis for processing any special-category data you choose to share with PHOS is your explicit consent (Art. 9(2)(a) GDPR). Transfers to the AI provider are based on appropriate safeguards (Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework). You can withdraw your PHOS consent at any time from within the PHOS interface; after withdrawal, no further messages are sent for processing, and you will be asked to consent again if you wish to use PHOS later. Withdrawing PHOS consent does not delete your EKKIOS account. Further information is available in the AI provider's privacy policy.

Some other content shown in the App (for example daily reflections and newsletter translations) is generated using AI services; this generation does not involve your personal data.

## 7. Newsletter subscription

You can subscribe to the EKKIOS newsletter through a subscription form provided by our email service provider, **Brevo**. The form is hosted by the provider and reached via a link from the App; the App itself does not embed the provider's tracking or scripts. When you subscribe, the provider collects your email address and (if provided) your name and uses a double opt-in process to confirm your consent. You can unsubscribe at any time using the link in any newsletter email. The provider processes subscriber data in the EU.

## 8. Prayer requests

The App's Prayer page offers a prayer request form provided by a third-party form provider, **Tally**. The form is loaded only after you give explicit consent using the checkbox on that page. When you submit it, your name, email and prayer request are sent directly to that provider as a separate processor. You can request deletion of your prayer request by contacting info@ekkios.com.

## 9. Donations

Donations are made through **TrustBridge**. The App only links to TrustBridge; no donation processing takes place inside the App. When you follow the donation link, TrustBridge collects and processes the donor data you provide (for example name, email and payment information) on its own platform, subject to TrustBridge's terms and privacy policy.

## 10. Contact

If you contact us by email (info@ekkios.com), we process the information you provide (name, email, message content) to respond to your request.

## 11. Legal basis

We process personal data on the following legal bases: (a) for the provision of the App and our legitimate interests (Art. 6(1)(f) GDPR), such as security and delivery; (b) for the performance of a contract or to provide an account you request (Art. 6(1)(b)); (c) with your consent where applicable (Art. 6(1)(a)), for example when you subscribe to the newsletter, consent to the prayer form, or consent to PHOS; (d) to comply with legal obligations (Art. 6(1)(c)). Where you provide special-category data (for example religious beliefs) to PHOS, this is collected through an explicit, affirmative consent mechanism before the first message is sent and is based on your explicit consent (Art. 9(2)(a)); you can withdraw this consent at any time from within PHOS.

## 12. Retention

We keep your account data for as long as your account exists. You can delete your account at any time (see Section 13). Technical log data is retained by our service providers according to their respective retention policies.

## 13. Your rights

Under the GDPR you have the right to: access, rectification, erasure, restriction of processing, data portability, objection to processing, and withdrawal of consent at any time without affecting the lawfulness of processing carried out before withdrawal. To exercise your rights, contact info@ekkios.com. You can delete your EKKIOS account directly in the App (Account → Delete Account) or by requesting it via email.

## 14. Security

The App is served over HTTPS (TLS) to protect data in transit.

## 15. Children

The App is not directed at children under 16, and we do not knowingly collect data from them.

## 16. Changes to this Privacy Policy

We may update this Privacy Policy. The "Last updated" date above indicates the latest revision.