GDPR Privacy Notice

Effective Date: April 2026

Introduction

This GDPR Privacy Notice supplements our main Privacy Policy and provides additional information specifically for individuals in the European Economic Area (EEA), United Kingdom, and Switzerland.

Ethos (operating as Ethos OÜ, registry code 16972881, located at Kursi tn 3, 10415 Tallinn, Estonia) is the data controller for the personal information we collect through our service.

Contact: hello@ethosbook.co

Lawful Basis for Processing

Under GDPR, we must have a lawful basis to process your personal data. Here's how we process different types of information:

Performance of Contract

We process the following data to fulfill our contract with you (creating your biography book):

Account information (name, email, phone) - To create and manage your account
Payment information - To process your order
Shipping information - To deliver physical books
Voice recordings and stories - To generate your personalized book
Support communications - To help you use our service

We process the following data only with your explicit consent:

Marketing emails - To send promotional content (you can withdraw consent anytime)
Analytics cookies (PostHog, Supabase) - To improve our service
Marketing cookies (Meta Pixel, Rewardful) - For advertising and affiliate tracking
Sensitive personal information in your stories (health, religion, etc.)

Legitimate Interest

We process the following data based on our legitimate business interests:

Technical and usage data - To maintain security and prevent fraud
Customer support interactions - To improve our service quality
Anonymized analytics - To understand how our service is used

You have the right to object to processing based on legitimate interest.

Legal Obligation

We process certain data to comply with legal requirements:

Tax and accounting records - Required by Estonian law (7 years)
Payment records - For anti-money laundering compliance
Data breach notifications - As required by GDPR

Right to Access (Article 15)

You can request:

A copy of all personal data we hold about you
Information about how we use your data
Who we share your data with
How long we keep your data

How to request: Email hello@ethosbook.co with "Access Request" in the subject line.

Right to Rectification (Article 16)

You can request corrections to inaccurate or incomplete information.

How to request: Email hello@ethosbook.co with the corrections you'd like to make.

Right to Erasure / "Right to be Forgotten" (Article 17)

You can request deletion of your personal data. We will delete your data unless we have a legal obligation to keep it.

Exceptions where we cannot delete:

Tax and accounting records (7 years under Estonian law)
Legal claims or disputes in progress
Legal obligations to retain certain data

How to request: Email hello@ethosbook.co with "Deletion Request" in the subject line.

What we delete:

Your account information
All voice recordings and stories
Payment history (after legal retention period)
All backups within 30 days

Right to Restrict Processing (Article 18)

You can limit how we use your data in certain circumstances:

While we verify accuracy of contested data
When processing is unlawful but you don't want deletion
When we no longer need the data but you need it for legal claims
While we verify legitimate grounds after you object to processing

How to request: Email hello@ethosbook.co explaining your restriction request.

Right to Data Portability (Article 20)

You can receive your personal data in a structured, commonly used, machine-readable format (JSON or CSV). This includes:

Your account information
Transcripts of your voice recordings
Audio files of your recordings
Generated book content

How to request: Email hello@ethosbook.co with "Data Portability Request" in the subject line.

Right to Object (Article 21)

You can object to:

Processing based on legitimate interests
Direct marketing (including profiling)
Processing for research or statistical purposes

How to request: Email hello@ethosbook.co with "Objection Notice" in the subject line.

We use AI to generate your book content, but you are not subject to fully automated decisions that have legal or significant effects on you. Human review and your input are always part of the process.

Where we process data based on your consent, you can withdraw it at any time:

Marketing emails: Click unsubscribe in any email or email hello@ethosbook.co
Analytics cookies: Adjust settings in our cookie banner
Sensitive data processing: Email hello@ethosbook.co

Withdrawing consent doesn't affect the lawfulness of processing before withdrawal.

How to Exercise Your Rights

Email: hello@ethosbook.co

Subject line: Include the type of request (e.g., "Access Request", "Deletion Request")

Response time: We will respond within 30 days (may extend by 2 months if complex)

Identity Verification:

We'll verify your identity before fulfilling requests to protect your data. We may ask for:

Your registered email address
Account details you provided
Answers to security questions

No Fee:

We don't charge for most requests. If requests are clearly unfounded or excessive, we may charge a reasonable fee or refuse the request.

International Data Transfers

Your data may be transferred outside the EEA to the United States and other countries. We protect these transfers using:

Standard Contractual Clauses (SCCs)

We use EU Commission-approved Standard Contractual Clauses with:

Supabase (US-based hosting)
Stripe (payment processing)
ElevenLabs (voice transcription)
Other US-based service providers

Adequacy Decisions

We transfer data to countries with EU adequacy decisions where applicable.

Additional Safeguards

For transfers to the US, we implement:

Encryption in transit and at rest
Access controls and authentication
Regular security audits
Data processing agreements
Transfer impact assessments

Request copies: Email hello@ethosbook.co to receive copies of our Standard Contractual Clauses or transfer safeguards.

Data Retention Periods

Data Type	Retention Period	Lawful Basis
Account information	While account active + 90 days	Performance of contract
Voice recordings	While account active + 90 days	Performance of contract
Payment records	7 years after transaction	Legal obligation (tax law)
Marketing consents	Until withdrawn + 30 days	Consent
Support tickets	3 years after resolution	Legitimate interest
Analytics data (anonymized)	Indefinitely	Legitimate interest
Deleted account backups	30 days maximum	Technical necessity

Supervisory Authority

If you're unhappy with how we handle your data, you have the right to lodge a complaint with a supervisory authority:

Estonia (Our Lead Supervisory Authority)

Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)

Website: www.aki.ee

Email: info@aki.ee

Address: Tatari 39, 10134 Tallinn, Estonia

Your Local Authority

You can also contact the data protection authority in your country of residence. Find your local authority at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

Special Categories of Personal Data

Your stories may contain "special category" data under GDPR Article 9:

Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Health information
Sexual orientation
Biometric data

Processing Basis: We process this data with your explicit consent and only to create your book. You can withdraw consent at any time by emailing hello@ethosbook.co.

Extra Protections:

Encrypted storage and transmission
Access restricted to essential personnel
Never used for profiling or automated decisions
Never shared with third parties except processors under strict contracts

Data Protection by Design and Default

We implement privacy-protective measures throughout our service:

Encryption: All data encrypted in transit (TLS/SSL) and at rest (AES-256)
Access controls: Role-based access with least privilege principle
Pseudonymization: Internal systems use IDs instead of names where possible
Data minimization: We only collect data necessary for our service
Regular audits: Quarterly security and privacy reviews
Staff training: All employees trained on GDPR compliance

Data Breach Notification

If we experience a personal data breach that risks your rights and freedoms:

To you: We'll notify you within 72 hours if high risk
To supervisory authority: We'll notify Estonian DPA within 72 hours
Information provided: Nature of breach, likely consequences, measures taken

Changes to This Notice

We may update this GDPR Privacy Notice to reflect changes in:

Our data processing practices
GDPR requirements or guidance
Supervisory authority recommendations

When we make significant changes:

We'll email you 30 days in advance
We'll post the updated notice on our website
We'll update the "Effective Date" at the top

Contact Our Data Protection Officer

For GDPR-specific questions or to exercise your rights: