As of August 2023
I. Identity and contact details of the data controller
II. Contact details of the data protection officer
III. General information on data processing
IV. Rights of the data subject
V. Provision of app and creation of log files
VI. Creating a profile and alerting
VII. Feedback form
VIII. Participation in the app tester program
X. Location data processing
XI. Creation of aggregated statistics and analyses
XII. Content delivery networks
XIII. Use of software development kits (SDK)
XIV. Telemetry data
The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:
+49 89 413294691
The designated data protection officer is:
Dachauer Str. 65
+49 89 7400 45840
The responsibility of SafeNow GmbH for the data processing results from the following aspects:
SafeNow allows customers to use the following functionalities:
The provision of functionalities corresponds to the purposes of the processing. In addition, personal data is processed to ensure error-free functionality of the App.
We only process personal data of our users to the extent that this is necessary for the provisioning of a function, our content or services. The processing of our users’ personal data is only carried out after the user has given consent, if there is a legitimate interest of the processing, or a processing of personal data is necessary for the fulfilment of a contractual relationship.
Within the app, the following data is collected for the purpose of registration:
If we obtain the consent of the data subject for processing their personal data, Art. 6 (1) (a) GDPR acts as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) (f) GDPR serves as the legal basis for the processing.
Depending on the App modules used, different processors may be recipients of personal data, if they provide a partial service of the processing process. Categories of recipients of personal data are in particular:
In addition, data can be transmitted to third parties, e.g. operators of SafeNow Zones. This is specifically the case when a user triggers an alarm in a public SafeNow Zone. Operators can be organisations, authorities, companies, or associations that offer a public SafeNow Zone on a site where they are responsible for security. In a public SafeNow Zone, guests can use the App to reach the operator's security staff.
The logo of the SafeNow Zone or the Operator is displayed in the user's app when he or she is in the relevant area. This always gives users full transparency as to who alarm data is being forwarded to.
If recipients of personal data are located outside the EU or the EEA, SafeNow GmbH ensures that appropriate guarantees for legally compliant data transfers to third countries are in place, e.g., by concluding standard data protection clauses in accordance with Art. 46 (2) (c) GDPR.
The personal data of the data subject is deleted or anonymized as soon as the purpose of storage ceases to apply. Storage of data can exceed these circumstances, if this has been provided for by the European or national legislator in Union regulations, laws, or other provisions to which the controller is subject. The data will be anonymized or erased the latest after a period of 6 months, if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.
Users can update profile information independently within the app or delete their account at any time so that this data is no longer processed. In addition, users can withdraw their consent to data processing at any time by sending an informal e-mail to firstname.lastname@example.org. All other rights for you as a data subject can also be addressed to this e-mail address.
When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:
We are not responsible for the further processing of your data by the respective operator after they have received an alarm via the app.
You may request the data controller to confirm whether your personal data is processed by them.
If such processing occurs, you can request the following information from the data controller:
You have the right to request information on whether your personal data will be transmitted to a third country or an international organization. In this context, you can then request for the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.
You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay
You may request the restriction of the processing of your personal data under the following conditions:
If the processing of personal data concerning you has been restricted, this data may – with the exception of data storage – only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
If the processing has been restricted according to the aforementioned conditions, you will be informed by the data controller before the restriction is lifted.
a) Obligation to erase
If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:
b) Information to third parties
If the data controller has made your personal data public and must delete the data pursuant to Art. 17 (1) GDPR, they shall take appropriate measures, including technical means, to inform data processors who process the personal data, that a request has been made to delete all links to such personal data or copies or replications of the personal data, taking into account available technology and implementation costs to execute the process.
The right to deletion does not exist if the processing is necessary
If you have the right of rectification, erasure or restriction of processing over the data controller, they are obliged to notify all recipients to whom your personal data have been disclosed of the correction or erasure of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort.
You reserve the right to be informed about the recipients of your data by the data controller.
You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:
In exercising this right, you also have the right to transmit your personal data directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons shall not be affected.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the data controller.
For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) GDPR; this also applies to profiling based on these provisions.
The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, exercising or defending legal claims.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes. SafeNow does not use personal data for the purpose of direct marketing.
Regardless of Directive 2002/58/EG, you have the option, in the context of the use of our services, to exercise your right to object to automated decisions that use technical specifications.
You have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of the processing carried out on the basis of the consent until the withdrawal.
You have the right to not be subject to a decision based solely on automated processing – including profiling – that will have a legal effect or substantially affect you in a similar manner. This does not apply if the decision:
However, these decisions must not be based on special categories of personal data under Art. 9 (1) GDPR, unless Art. 9 (2) (a) or Art. 9 (2) (b) GDPR applies and reasonable measures have been taken to protect your rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to uphold your rights and freedoms as well as your legitimate interests, including the right to obtain assistance from the data controller or his representative, to express your opinion on the matter, and to contest the decision.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in the Member State of your residence, or your place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the GDPR.
The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
Each time our app is accessed, our system automatically collects data and relevant information from the system of the calling device.
The following data is collected:
This data is stored in the log files of our system. This does not include IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.
The storage in logfiles is done to ensure the functionality of the app. The data is also used to optimize the app and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.
For the aforementioned purposes, our legitimate interest lies in the processing of data in compliance with Art. 6 (1) (f) GDPR.
The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (f) GDPR.
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. In the case of the collection of data for the provision of the app, this is the case when the respective alarm has ended. Additionally, certain location data is stored as part of the alarm history see X. Location data processing for more information.
The collection of data for the provision of the app as well as the storage of data in log files are essential for the operation of the app. Therefore, the user may not object to the aforementioned processes.
After downloading the app, we offer users the option of creating a profile by providing personal data. The data is entered in an input mask and transmitted to us and stored. The data is only passed on to third parties like SafeNow Zone Providers to make it easier for helpers to find the user in the event of an alarm. Users of the SafeNow app have the option of notifying helpers by activating the alarm function. In the event of an alarm, information about the location, profile picture (optional), name, phone number is shared with the helpers (recipients). Additionally, users have the option to further qualify the alarm by selecting from a set of predefined alarm categories like fire, crime, medical emergency or feeling unsafe. This information is shared with helpers. Further, users can provide more context about the alarm through a free text field
The following data can be provided by the user on a voluntary basis as part of the process:
As part of the onboarding process, the user's consent to the processing of this data is obtained.
The user's registration is required for the provision of certain content and services on our app as well as triggering alarms The alarm qualification and free text entry are used to provide better immediate help in case of an alarm and analyze the types of emergencies in any given SafeNow Zone.
Furthermore, the phone number identification of the user is required to help the alerted helpers find the user in case of an alarm or contact him or her directly.
The legal basis for the processing of the data is Art. 6 (1) (a) GDPR, if the user has given his or her consent.
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In addition, the user has the option of deleting the surname and profile picture in the app at any time and changing the telephone number and first name. If the account is deleted by the user, all data will be irrevocably deleted or anonymized. Further processing, e.g. to restore the account, does not take place and is not possible.
As a user, you have the option to cancel the registration at any time. You can have the data stored about you changed at any time. Users can request the deletion or modification of their data at any time via e-mail to email@example.com or delete or modify the personal data in the user profile.
If the data is required for the performance of a contract or for the implementation of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.
Our app contains a feedback form that can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask is transmitted to us and stored.
At the time the message is sent, the following data is stored:
Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.
There is in connection with the data processing through the contact form for the transmission of user feedback a processing of data by the tool:
Google Forms of Google Ireland Limited, Gordon House, Barrow Street, 4, Dublin, Ireland (hereinafter referred to as: Google).
In particular, the following personal data is processed by Google as a result:
By using Google Forms, your personal data may be processed by Google on servers located in the United States. To ensure appropriate safeguards to protect the transfer and processing of personal data outside the EU, the transfer of data to and processing of data by Google is carried out on the basis of appropriate safeguards pursuant to Art. 46 et seq. DSGVO, in particular by concluding so-called standard data protection clauses pursuant to Art. 46 (2) (c) GDPR. A copy of the standard data protection clauses can be requested by sending us an informal email.
Further information on the processing of data by Google can be found here: https://policies.google.com/privacy
The processing of personal data from the input mask allows us to contact and to take note of the user feedback. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
The legal basis for the processing of data is Art. 6 (1) (a) GDPR, if the user has given his or her consent.
The legal basis for the processing of data transmitted while sending an e-mail is Art. 6 (1) (f) GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.
The data will be deleted as soon as they are no longer required to fulfil the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when the circumstances indicate that the matter in question (e.g., feedback on functionality) has been conclusively clarified.
The user has the possibility to withdraw his or her consent to the processing of personal data at any time. If the user contacts us by e-mail to firstname.lastname@example.org, he or she can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
All personal data stored in the course of contacting us will be deleted in this case.
Users can participate in the SafeNow app tester program. The goal of this program is to proactively gather feedback on the app to improve it. Testers are sent questionnaires in which they are asked about topics related to the app and its use. We collect and process the following data as part of the tester program:
For the processing of the data, your consent is obtained during the submission process and reference is made to this privacy statement.
The processing of personal data from the input mask serves us to improve the app functionalities, descriptions, explanations, and the user experience.
The legal basis for the processing of data is Art. 6 (1) (a) GDPR, if the user has given his or her consent.
The data from the input mask is aggregated and anonymized as soon as it is no longer required to fulfil the purpose for which it was collected. For the personal data from the input mask of the questionnaires, this is the case when all queries regarding the feedback have been clarified. Queries are clarified when it can be inferred from the circumstances that the matter in question has been conclusively clarified. Contact information will be deleted as soon as the user unsubscribes from the tester program by emailing email@example.com. From this point on, we will no longer ask any further questions about the feedback.
The user has the option to withdraw his or her consent to the processing of personal data at any time. If the user contacts us by e-mail at firstname.lastname@example.org, he or she can object to the storage of his or her personal data at any time.
All personal data stored during the App Tester program will be deleted in this case.
The app is hosted on servers of a service provider commissioned by us in the EU.
Our service provider is:
Amazon Web Services Inc.,
410 Terry Avenue North,
Seattle WA 98109
The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the app. The stored information is:
This data will not be merged with other data sources. The data is collected based on Art. 6 (1) (f) GDPR. The app operator has a legitimate interest in the technically error-free presentation and optimization of his app - and server log files are therefore recorded.
The service provider may obtain access to the above-mentioned data. For data protection-compliant use and legally compliant data transfer to third countries, appropriate data processing agreements and appropriate guarantees, e.g., standard data protection clauses in accordance with Art. 46 (2) (c) GDPR, have been concluded.
The server location of the service providers is in Germany and/or in the European Union.
Users of the App have the option of notifying helpers by activating the alarm function. In the event of an alarm, information about the location, profile picture (optional), name and phone number are shared with the recipients (helpers). Helpers can accept or reject the alarm to report their availability to the alarming person. The person who raised the alarm, as well as the helpers themselves, see the position of the helpers who have accepted the alarm. Here, the location information (including beacon information) of the alarm and the helpers are recorded.
Location data is processed by us in 3 situations:
The app regularly collects the location when it is open and running and sends it to us. With this location we can determine if the user is in a SafeNow Zone, which private groups should be alerted and display this information in the app. This location data is not used for any other purpose and is not shared with helpers, SafeNow Zone Operators or other parties. The location data is stored by us for a maximum period of 5 minutes and then automatically deleted. Once the app is closed, location data will no longer be collected. It may happen that a few seconds after closing the app, data is still being transferred until the corresponding app services are completely terminated.
Furthermore, the app regularly collects the location when a user has activated an alarm or has accepted an alarm as a helper. While the alarm is running, location data is shared with helpers regardless of whether the app is in the foreground or background. This means that those seeking help can, for example, make a call or use their mobile phone in other ways and helpers can still see where the person seeking help is. The location data during an alarm is sent directly to the helpers or person seeking help and is only cached by us for a few seconds for technical reasons.
After an alarm has ended, it appears in the alarm history of the person seeking help and the alerted helpers. Here you can see where the alarm was triggered and ended. This helps the person seeking help to remember the incident better afterwards and gives helpers an indication of where the person is if the alarm was accidentally canceled. This location data will be stored by us until the user deletes his or her account. As soon as the alarm has ended or you indicate as a helper that you cannot help, the respective location is no longer shared.
Push notifications are sent to alert the helpers via the App. The push notifications are sent via the Google Firebase service from Google Ireland Limited, Gordon House, Barrow Street, 4, Dublin, Ireland. However, no Firebase analytics functionalities are activated. The data can be transmitted to Google servers in the USA. Part of the data processing agreement with Google are so-called EU standard data protection clauses (Art. 46 Para. 2 S. 1 lit. c GDPR). These are classified as an appropriate guarantee to protect the transfer and processing of personal data outside the EU. A copy of the standard data protection clauses can be requested by sending an informal email to us.
After canceling an alarm, the helpers who were alarmed and the person who raised the alarm can follow the course of the alarm in the alarm history. The place where the alarm was triggered and the place where it was canceled are saved and displayed.
Further information on the processing of data by Google can be found here: https://policies.google.com/privacy
By processing the location data, we find out in which public Zones or private groups a user is currently located and can forward the alarm to the appropriate helpers at the user's location.
The legal basis for processing the data is Article 6 Paragraph 1 Clause 1 Letter a GDPR if the user has given his consent.
Location data is generally, automatically deleted after 5 minutes. Location data in the alarm history is stored untilthey are no longer required to achieve the purpose for which they were collected or the user deletes their account.
The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by email at email@example.com, he can object to the storage of his personal data at any time. Within the app, the user can also withdraw authorization for location access at any time. An objection can result in the services of the app not being able to be carried out further if the processing of personal data is necessary for the provision of services.
We process pseudonymized usage data of our app for analysis and statistical purposes. The aim is to improve the user-friendliness of our app as well as the safety of all people. For these statistical evaluations and analyses, we aggregate various data sets that we collect as part of the app deployment. We create dashboards or heat maps that show, for example, how many users are active in our app each month or at which locations users often press the attention button or trigger an alarm.
It is only possible to draw conclusions about individual users by consulting another database. This data is not merged with other data sources for this purpose.
In addition, we process pseudonymized data to optimize the creation of a profile process (after downloading the app) and ensure its functionality. This may result in the processing of pseudonymized data of those users who have downloaded our app but have not necessarily completed the profile creation process.
In detail, this concerns the following data:
The purpose of data processing is to improve our app and to improve the security of all users.
The legal basis for processing the data is our legitimate interest according to Art. 6 (1) (f) GDPR.
The data will be deleted as soon as they are no longer required to fulfil the purpose for which they were collected.
If the user contacts us by e-mail via firstname.lastname@example.org, he or she can object to the storage of his or her personal data at any time.
We use functions of the Amazon CloudFront content delivery network of Amazon Web Service Inc, 410 Terry Avenue North, Seattle WA 98109, USA (hereinafter referred to as Amazon CloudFront). A Content Delivery Network (CDN) is a network of regionally distributed servers connected via the Internet to deliver content, especially large media files such as videos. Amazon CloudFront provides web optimization and security services that we use to improve the load times of our website and protect it from misuse. When you visit our website, a connection will be established to Amazon CloudFront's servers to retrieve content, for example. This allows personal data to be stored and evaluated in server log files, the user's activity (in particular which pages have been visited) and device and browser information (in particular the IP address and the operating system). For more information on Amazon CloudFront's collection and storage of data, please visit: https://aws.amazon.com/privacy/?nc1=h_ls
Amazon CloudFront features are used to deliver and accelerate online applications and content.
The data is collected based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - and server log files are therefore recorded.
Information about objection and removal options regarding Amazon CloudFront can be found at: https://aws.amazon.com/privacy/?nc1=h_ls
We use third-party SDKs in our apps as well as in the backend.
For information, please visit: https://app.safenow.live/licenses_de.html
To provide specific functionalities, device permissions for your device are requested during the use of the app. Without these, we cannot provide certain services, such as our location services. Device permissions always require your explicit consent.
The following permissions are requested to implement the features in the app:
Permission assignment is necessary to use certain functionalities of our app. Before explicit permission assignment by the user, the app will not get access to device functionalities. You can change the permissions at any time on your device. In addition, meta information can be collected to monitor our app and identify errors.
The processing of photos and camera data is necessary for uploading profile or group images. Location services are used to determine available groups and public SafeNow Zones and to share location with helpers. Movement activity information is needed for turning off location services when the phone is not moving and to save battery. Push notifications, critical alerts, and access to do not disturb, respectively, are necessary to alert users when one of their contacts triggers an alarm, even if the phone is silent or on do not disturb.
The meta-information is collected on the basis of Art. 6 (1) (f) GDPR. The app operator has a legitimate interest in the technically error-free presentation and optimization of its app. The permission assignment and processing of internal data of the device is done by your explicit release and thus by your consent according to Art. 6 (1) (a) GDPR.
You can object to the processing or withdraw your consent at any time by sending an informal e-mail to email@example.com. You can prevent the use of device functions yourself at any time by making the appropriate settings on your terminal device.
We collect telemetry data on our app in order to ensure a technically error-free presentation. Here, the user ID of an app user can be processed. We implement this with the following tools:
The data is processed for the following purposes:
The collection of this data is based on Art. 6 (1) (f) GDPR. The app operator has a legitimate interest in the technically error-free presentation and optimization of its app.
Your personal information will be stored for as long as necessary to fulfil the purposes they were collected for. General log data in Grafana, Loki and Prometheus are automatically deleted after 90 days. Bug- and crashlogs in Sentry are stored up to 90 days after the error has been resolved. Data in PostHog is stored for as long as necessary to fulfil the purposes of the respective analysis.
You can object to the processing of your data at any time by sending an informal e-mail to firstname.lastname@example.org. You can also address all other rights as a data subject to this e-mail address.