Privacy Policy — Elevator Matrix

DRAFT for review by a lawyer. Version 0.2 — October 2026.

1. Who we are

This Policy explains how the provider of Elevator Matrix (“we”), based in Thessaloniki, Greece, collects and processes personal data in the course of the service (app for iPhone, Android, computer and web). We act in accordance with Regulation (EU) 2016/679 (GDPR) and Greek Law 4624/2019. Contact for personal data matters: privacy@elevatormatrix.com.

2. Two roles: Controller and Processor

• For the account data of users of the service (name, email, phone, role, lift technician licence, company details, subscription and billing) we are the Controller.
• For the business data entered by each customer company (its customers, building managers, contacts, elevators, work reports, photos, signatures, calls, invoices and receipts, payments, bank transactions, supplier invoices, change history) we are a Processor on behalf of the customer company, which is the Controller. These matters are governed by the Data Processing Agreement (DPA). If, for example, you are a building manager and your details are in the app, please contact the maintenance company that serves you first.

3. Data we collect as Controller

• Company registration details: name, tax number, country, address, phone, email.
• User details: name, email, phone, role, lift technician licence number/grade and its expiry date.
• Subscription: plan, status, payment history. Card payments are handled by Stripe; we never see or store your card number.
• Technical data: IP address, device type and app version, device identifier for push notifications, logs for security and troubleshooting, sync times.
• Aggregated usage data (number of users, elevators, work reports per month, last activity) for subscription management and support. Platform administration has no access to the business data of customer companies.
• Support and sales communications (emails, notes).

The elevatormatrix.com website uses no tracking or advertising cookies; it only remembers your language choice in your browser.

4. Purposes and legal bases

• Providing the service, creating and managing accounts, synchronisation, notifications: performance of a contract (Art. 6(1)(b) GDPR).
• Billing and tax obligations: legal obligation (Art. 6(1)(c)).
• Security, abuse prevention, usage limits, backups, change history: legitimate interest (Art. 6(1)(f)).
• Notices about changes to the service and price list: performance of a contract / legitimate interest. Marketing only with your consent, which you may withdraw.

5. Location (GPS)

• The “GPS on” feature is optional and is switched on by the user in Settings. It recognises when a technician is at one of the company’s elevators or sites and reminds them to record materials. It works only while the app is open; location is not used in the background.
• Only visits are recorded (who, at which elevator or site, arrival and departure time), visible to the company’s office. No route is tracked.
• When a work report is completed, the device position may be used to correct the position of the elevator on the map (not of the technician).
• For maps, address lookup and daily routes, elevator addresses and coordinates are sent to Amazon Location Service (EU).
• The feature can be switched off at any time in the app or device settings.

6. Artificial intelligence

For AI features (voice work reports, fault diagnosis, part recognition from a photo, reading supplier invoices and bank statements, the in-app assistant) the relevant content is sent to Anthropic (Claude models) as a sub-processor, solely to produce the response:

• Speech recognition runs on the device; only the text is sent to the server, never audio.
• To answer, the assistant searches your company’s data and sends only the relevant results (e.g. balances, schedule, elevator details).
• This data is not used to train models. Anything that changes data is proposed first and saved only after the user confirms.

7. Recipients and sub-processors

• Amazon Web Services (Frankfurt, EU): hosting of servers and database, backups, email delivery (Amazon SES), maps (Amazon Location Service).
• Anthropic (USA): artificial intelligence features.
• Stripe: subscription payments.
• Apple (Apple Push Notification service): delivery of notifications to iPhone.
• Only if the customer company enables them: the tax authority of its country (e.g. AADE / myDATA in Greece) for transmitting invoices and receipts, an e-invoicing provider, a bank connection provider (Enable Banking, read-only transactions), the company’s own email server (to read invoices/statements) and a VoIP telephony provider.
• When a user chooses to send something via WhatsApp, Viber, SMS or their device’s email app, it is sent from their own app.

We do not sell personal data and do not use it for advertising. We may disclose data to public authorities where required by law. The detailed list of sub-processors is in the DPA.

8. Transfers outside the EEA

Data is stored in the EU. Where a sub-processor is outside the EEA (Anthropic, Stripe), transfers rely on the EU–US Data Privacy Framework or the European Commission’s Standard Contractual Clauses.

9. Retention

• Account and company data: for the duration of the contract and up to 30 days after a deletion request.
• Subscription billing records: as required by tax law (generally 5 years).
• Change history (who changed what, for undo): 90 days on the server, 30 days on the device.
• Security logs: up to 12 months.
• Server backups: daily, rolling, deleted automatically after 14 days.

10. Your rights

You have the right of access, rectification, erasure, restriction, data portability and objection, and to withdraw consent.

• Portability: the company owner can download the whole company at any time as a ZIP file (Settings → Backup): all data in JSON, tables for Excel and, optionally, photos and attachments.
• Deletion: from the app (Settings → Delete account) or as described on the Delete account page.
• Requests to privacy@elevatormatrix.com; we reply within 30 days. You may lodge a complaint with your data protection authority (in Greece: www.dpa.gr).

11. Security

Encryption in transit (TLS); encrypted storage on the server (AES-256-GCM) of credentials entered by the company (e.g. email, myDATA, e-invoicing provider); access rules per company and role on the server; daily backups; change history with undo. In the event of a breach we notify the authority and those affected as required by the GDPR.

12. Children

The service is intended for businesses and not for persons under 18.

13. Changes

We will notify material changes in the app or by email. The date of the current version is shown at the top.