DPIA (Data Protection Impact
Assessment)

1. DPIA Overview

DPIA Reference Number: DPIA-SOS-001

Last Updated: 16 June 2026

Prepared By: Sentrivo OÜ

Controller: Sentrivo OÜ

Registered Address of the Controller: Harju maakond, Tallinn, Kesklinna linnaosa, Tuukri tn 19, 10120, Estonia

Contact Details of the Controller: info@buttonsos.com

Product / Service Covered by this DPIA: SOS Button App and the Services provided through the App

Jurisdictions Covered by this DPIA: European Union, including, where applicable, Estonia and other jurisdictions in which the Services are offered or used

Categories of Data Subjects Covered by this DPIA: Users, Child Users, Parent / Legal Guardians, Respondents, and other persons whose Personal Data may be processed through the App in connection with the Services

Main Processing Activities Covered by this DPIA: registration and account administration; creation, activation, administration, cancellation, closure, and history of SOS Alerts and SOS Events; processing of SOS Event Data; delivery and attempted delivery of Critical Alerts where available and authorized; sending, delivery, and attempted delivery of Fallback Notifications; geolocation and location data processing, including location updates during an active SOS Event; processing of media files shared through the App, including in connection with an SOS Event; notification-related processing, including sending status, delivery status, failure status, acknowledgement or response information; event logs, technical logs, and diagnostic records; communication flows between Users, Initiators, Respondents, Child Users, and Parent / Legal Guardians; child-related service functionality; and parental consent, parental authority, and permission management.

Related Documents: Privacy Policy; Children’s Privacy Notice; Terms of Use; Children’s Terms / Kids Rules; internal security and data protection documentation, where applicable

2. Definitions

2.1. Account means the personal account created by the User and/or, where applicable, in relation to a Child User in the App for accessing and using the Services, managing profile information, sending or receiving alerts, and using other available functionality.

2.2. Personal Data means any information relating to an identified or identifiable User, Child User, Parent / Legal Guardian, or other natural person whose data may be processed in connection with the Services, including any information that directly or indirectly allows the identification of such person, including, where applicable, a name or nickname, email address, phone number, profile photo, geolocation data, media files, and event logs.

2.3. Services means the functionality and services made available by the Company through the SOS Button App, including communication between Users and/or in relation to Child Users, the sending and receiving of alerts, notifications, geolocation data, media, and related event information.

2.4. Initiator means a User and/or, where applicable, a Child User who initiates and sends an alert, emergency signal, notification, and/or other request for attention, assistance, or response by using the functionality of the App.

2.5. Respondent means a User designated by the Initiator to receive an alert, emergency signal, notification, and/or other request for attention, assistance, or response by using the functionality of the App, and who may review, acknowledge, and/or react to such communication by using the functionality of the SOS Button.

2.6. User means the general term used to refer to a person using the App and/or the Services, including, where applicable, a person acting as an Initiator or Respondent.

2.7. Child User means a natural person under the age of 18 who uses the App and/or in relation to whom Personal Data is processed in connection with the Services.

2.8. SOS Button App (hereinafter referred to as "App" or "SOS Button") means the mobile application operated by the Company through which the User and/or, where applicable, the Child User accesses and uses the Services.

2.9. Company Sentrivo OÜ (hereinafter referred to as "Company") means Sentrivo OÜ, registry code 17511615, legal address: Harju maakond, Tallinn, Kesklinna, linnaosa, Tuukri tn 19, 10120, a legal entity that provides the Services to Users through the SOS Button App and processes Personal Data in accordance with this Privacy Policy and applicable law.

2.10. Third Party means any natural person, legal entity, public authority, agency, or body other than the Company, the User, the Child User, and/or the Parent / Legal Guardian.

2.11. Controller means a natural person, legal entity, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing of Personal Data.

2.12. Processor means a natural person, legal entity, public authority, agency, or other body which processes Personal Data on behalf of the Controller.

2.13. Parent / Legal Guardian means a natural person who is the parent, legal guardian, or other lawful representative of a Child User and who is authorized under applicable law to act on behalf of such Child User in connection with the use of the Services, the provision of permissions, consents, confirmations, and requests, and, where applicable, the processing of Personal Data relating to such Child User.

2.14. Consent means a freely given, specific, informed, and unambiguous indication of the wishes of the relevant data subject, or, where applicable, of the relevant User, by which such person, by a statement and/or clear affirmative action, signifies agreement to the relevant processing of Personal Data and/or acceptance of relevant actions, conditions, or practices through the applicable document, interface, or functionality of the Services.

2.15. Parental Consent means any freely given, specific, informed, and unambiguous indication of wishes by a Parent / Legal Guardian, given by statement and/or clear affirmative action, by which such Parent / Legal Guardian authorizes the processing of Personal Data of a Child User and/or the use of the Services by or in relation to a Child User, where such authorization is required under applicable law.

2.16. Privacy Policy means the general privacy policy of the Company governing the collection, use, storage, disclosure, and other processing of Personal Data in connection with the App and the Services.

2.17. Children’s Privacy Notice means the child-focused privacy notice of the Company intended to explain, in a simplified and child-appropriate manner, how Personal Data of a Child User may be processed in connection with the App and the Services.

2.18. Terms of Use means the terms and conditions governing access to and use of the App and the Services, including the rights, obligations, restrictions, and responsibilities of Users and, where applicable, Parent / Legal Guardians.

2.19. Children’s Terms / Kids Rules means the simplified rules of use intended for Child Users, setting out in clear and age-appropriate language the main rules, limitations, and expectations applicable to the use of the App and the Services.

2.20. SOS Alert means a user-initiated alert, emergency signal, or request for attention, assistance, or response created by the Initiator through the App by using the SOS functionality and intended to be sent to one or more Respondents in accordance with the functionality of the Services.

2.21. Critical Alert means a notification related to an SOS Alert that may be delivered with a critical interruption level or similar system-level priority on supported devices and operating systems, where such functionality is available, enabled, permitted by the relevant device settings, and authorized for the App.

2.22. SOS Event means the event created in the App when an SOS Alert is activated by the Initiator and registered by the Services, including the creation, sending, delivery, display, acknowledgement, cancellation, closure, history, geolocation sharing, media sharing, and other actions or records related to such SOS Alert until the relevant SOS Event is cancelled, closed, or otherwise completed in accordance with the functionality of the App.

2.23. SOS Event Data means Personal Data and technical data relating to an SOS Event, including, where applicable, the SOS event identifier, Initiator identifier, Respondent identifiers, date and time of activation, SOS status, notification status, sending and delivery information, acknowledgement or response information, cancellation or closure information, geolocation data shared during the SOS Event, media files attached to or shared during the SOS Event, fallback notification information, technical diagnostic information, and records necessary for security, support, abuse prevention, compliance, and protection of rights and safety.

2.24. Fallback Notification means an SMS message, email notification, or other alternative notification sent or attempted to be sent to a Respondent in connection with an SOS Alert where the primary push notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective, in accordance with the functionality of the Services.

2.25. Website means the website operated by the Company at: https//buttonsos.com, including its webpages, subdomains, legal document pages, support or contact pages, informational materials, download links, and other website sections made available by the Company in connection with the App and the Services.

3. Purpose of DPIA

3.1. The purpose of this DPIA is to identify, assess, and document the risks to the rights and freedoms of natural persons arising from the processing of Personal Data in connection with the SOS Button App and the Services, and to determine whether such processing is necessary, proportionate, and compliant with applicable law.

3.2. This DPIA is carried out in view of the nature of the Services, including the use of the App by and/or in relation to Child Users, the processing of SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, geolocation and location data, media files, event logs, notification-related data, and other Personal Data, as well as the involvement of Parent / Legal Guardians, Respondents, and Third Party service providers.

3.3. This DPIA also specifically takes into account the processing activities and risks connected with SOS Alert delivery, the possible delivery of SOS Alerts as Critical Alerts, background delivery of SOS Alerts where applicable, Fallback Notifications, notification delivery status, acknowledgement or response information, cancellation or closure information, abuse-prevention records, and the technical dependency of such functionality on device settings, permissions, operating systems, communication channels, notification delivery providers, SMS providers, email delivery providers, and other Third Party services.

3.4. This DPIA is intended to:

1. 3.4.1. describe the relevant processing activities carried out through the App and the Services;
2. 3.4.2. identify the categories of Personal Data, data subjects, recipients, and data flows relevant to the Services;
3. 3.4.3. assess the necessity and proportionality of the relevant processing operations;
4. 3.4.4. identify and evaluate risks to the rights and freedoms of Users, Child Users, Parent / Legal Guardians, and other natural persons whose Personal Data may be processed in connection with the Services;
5. 3.4.5. identify and evaluate specific risks connected with SOS Alerts, SOS Events, Critical Alerts, Fallback Notifications, SOS Event Data, geolocation sharing, media sharing, notification delivery, delayed delivery, non-delivery, misdelivery, false alerts, repeated false SOS activations, misuse, and over-reliance on the App or the Services in safety-related situations;
6. 3.4.6. identify and describe the technical, organizational, contractual, and other measures applied or proposed in order to prevent, mitigate, and manage such risks;
7. 3.4.7. support the Company’s compliance with applicable data protection law, including the requirements applicable to the processing of Personal Data of Child Users.

3.5. This DPIA also serves as an internal compliance and risk assessment document intended to support the lawful design, launch, operation, review, and ongoing development of the App and the Services.

3.6. The scope of this DPIA covers the processing of Personal Data carried out by the Company in connection with the App, the Website, and the Services, including processing relating to account administration, SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, notification-related data, geolocation and location data, location updates during an active SOS Event, media files, event logs, and other Personal Data.

3.7. This DPIA does not replace the Privacy Policy, the Children’s Privacy Notice, the Terms of Use, the Children’s Terms / Kids Rules, or other applicable legal or compliance documents, but is intended to complement such documents as part of the Company’s overall data protection and risk management framework.

4. Description of SOS Button App

4.1. SOS Button is a mobile application designed to support the creation, sending, receipt, display, acknowledgement, cancellation, closure, and history of SOS Alerts and SOS Events through the functionality made available in the App. The App is intended to facilitate safety-related communication between Users and, where applicable, in relation to Child Users, including communication involving an Initiator, one or more Respondents, and/or a Parent / Legal Guardian.

4.2. Depending on the configuration of the App and the functionality used, SOS Button may enable a User and/or, where applicable, a Child User to create and send an SOS Alert, share geolocation or location-related information, transmit media files, and generate SOS Event Data within the App. The App may also allow a Respondent and/or, where applicable, a Parent / Legal Guardian to receive, review, acknowledge, respond to, cancel, close, or otherwise react to SOS Alerts, notifications, geolocation data, location updates, media files, SOS Event Data, and related information.

4.3. Where supported by the relevant device, operating system, permissions, and authorization granted for the App, an SOS Alert may be delivered as a Critical Alert. Where the primary push notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective, the App may use Fallback Notifications in accordance with the functionality of the Services.

4.4. During an active SOS Event, the App may process and transmit geolocation data, location updates, media files, notification-related information, acknowledgement or response information, cancellation or closure information, and other SOS Event Data to the relevant Respondent and/or other persons made available through the functionality of the App, where applicable.

4.5. The App operates through mobile devices, technical infrastructure, notification services, communication channels, cloud or hosting infrastructure, and related service providers necessary for the provision of the Services. The scope and functioning of the App may depend on device settings, permissions, notification permissions, Critical Alert permissions where available, geolocation permissions, media access permissions, subscription status, connectivity, operating system limitations, communication channels, Third Party service providers, and other technical or legal conditions relevant to the lawful operation of the Services.

4.6. The App and the Services are intended to support safety-related communication through the App but do not themselves constitute emergency response, rescue, medical, law enforcement, dispatching, monitoring, or professional response services.

4.7. The Company may also operate the Website in connection with the App and the Services. The Website may be used to publish information about the App and the Services, legal documents, contact details, support information, download links, informational materials, and other materials related to the App and the Services. Unless otherwise expressly provided by the Company, the Website is informational in nature and does not itself provide SOS Alert functionality, Critical Alerts, Fallback Notifications, geolocation sharing, media sharing, account functionality, subscription functionality, or other core functionality of the Services.

5. Roles of User / Child User / Parent / Legal Guardian / Respondent

5.1. For the purposes of this DPIA, the User is the general category of a person using the App and/or the Services. Depending on the relevant functionality, the User may act in different roles within the SOS Button App, including, where applicable, as an Initiator and/or a Respondent. The User may create or use an Account, interact with the functionality of the App, create, send, receive, acknowledge, cancel, close, or otherwise manage SOS Alerts and SOS Events, and otherwise use the Services in accordance with the configuration of the App, the applicable permissions, and applicable law.

5.2. A Child User is a natural person under the age of 18 who uses the App and/or in relation to whom Personal Data is processed in connection with the Services. In the context of this DPIA, the Child User is a particularly sensitive category of data subject because the App may process data relating to SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, geolocation and location data, location updates, media files, notification-related data, event logs, and other information connected with the use of the Services by or in relation to the Child User.

5.3. A Parent / Legal Guardian is a natural person authorized under applicable law to act on behalf of a Child User in connection with the use of the Services, the provision of permissions, consents, confirmations, requests, and, where applicable, the processing of Personal Data relating to the Child User. In practical terms, the Parent / Legal Guardian may be involved in registration, subscription management, child-related permissions, notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation and/or location-related permissions, media access permissions, child-related requests, and the lawful use of the App by or in relation to the Child User.

5.4. An Initiator is the User and/or, where applicable, the Child User who creates or activates an SOS Alert through the functionality of the App. In connection with such role, the Initiator may cause the creation of an SOS Event and the processing of SOS Event Data, including, where applicable, geolocation data, location updates, media files, notification-related data, cancellation or closure information, and other information made available through the App.

5.5. A Respondent is a User designated to receive an SOS Alert and related SOS Event Data through the functionality of the App. Depending on the functionality used, the permissions granted, and the settings applied within the App, the Respondent may receive, review, acknowledge, respond to, or otherwise react to SOS Alerts, Critical Alerts where available and authorized, Fallback Notifications, geolocation data, location updates, media files, notification-related information, and other SOS Event Data transmitted or made available through the App.

5.6. For the purposes of this DPIA, the Respondent is assessed as a recipient and user-side participant in the SOS communication flow. The Respondent is not an emergency responder, rescue service, medical provider, law enforcement authority, monitoring service, dispatcher, or professional response service acting on behalf of the Company. This role allocation is relevant to the assessment of risks connected with response delay, non-response, inadequate response, recipient behavior, and reliance on information transmitted through the App.

6. Categories of Personal Data

6.1. For the purposes of this DPIA, the Company may process the following categories of Personal Data in connection with the App and the Services:

1. 6.1.1. Account and Registration Data: data used for registration, account creation, authentication, account administration, and access to the Services, including name, nickname, email address, phone number, login-related data, profile photo, and other data associated with the creation and use of an Account.
2. 6.1.2. Child User Data: Personal Data relating to a Child User processed in connection with the Services, including full name, nickname, profile photo, geolocation data, location data, location updates, media files, SOS Alerts, SOS Events, SOS Event Data, notifications, notification-related data, response-related information, event logs, activity data, and other Personal Data relating to the Child User that is processed through the App.
3. 6.1.3. Parent / Legal Guardian Data: Personal Data relating to a Parent / Legal Guardian, including full name, email address, phone number, account and profile data, data relating to permissions, consents, confirmations, authorizations, requests, subscription-related actions, support communications, child-related settings, notification permissions, geolocation and/or location-related permissions, media access permissions, and other data processed in connection with the lawful use of the Services by or in relation to a Child User.
4. 6.1.4. SOS Event Data: Personal Data and technical data relating to an SOS Event, including, where applicable, the SOS event identifier, Initiator identifier, Respondent identifiers, date and time of activation, SOS status, notification status, sending and delivery information, acknowledgement or response information, cancellation or closure information, geolocation data shared during the SOS Event, location updates, media files attached to or shared during the SOS Event, Fallback Notification information, technical diagnostic information, and records necessary for security, support, abuse prevention, and compliance.
5. 6.1.5. Alert and Notification Data: data relating to the creation, sending, attempted sending, receipt, display, acknowledgement, review, response, cancellation, closure, and other handling of SOS Alerts, Critical Alerts where available and authorized, Fallback Notifications, push notifications, SMS messages, email notifications, and other service-related communications. This may include notification event type, recipient information, sending status, delivery status, failure status, acknowledgement or non-acknowledgement information, response-related activity, fallback delivery information, and other notification-related records.
6. 6.1.6. Geolocation and Location Data: geolocation data, location data, location updates, location accuracy data, location timestamps, and other location-related information processed through the App in connection with SOS Alerts, SOS Events, child-related functionality, enabled location-related functionality, and other Services features that involve location sharing or location-related communication flows.
7. 6.1.7. Media Files and Related Content: photos, video recordings, audio recordings, and other files uploaded, recorded, transmitted, attached, or otherwise made available through the App, including media files shared in connection with an SOS Event, as well as any Personal Data contained in such files.
8. 6.1.8. Event Logs and Activity Data: data concerning actions performed within the App, including who initiated an SOS Alert, when an SOS Alert was activated, who received it, delivery status, acknowledgement or response activity, cancellation or closure information, access-related events, permission-related events, fallback delivery attempts, abuse-prevention records, and other event information generated through the use of the Services.
9. 6.1.9. Technical and Device Data: IP address, device type, operating system, application version, device identifiers, push notification tokens, notification-related identifiers, time zone, language settings, notification-related data, device settings relevant to notification delivery, notification permissions, Critical Alert permissions where available, geolocation permissions, media access permissions, log data, diagnostic data, crash data, and other technical data relating to the operation of the App and the Services.
10. 6.1.10. Consent, Permission, and Authorization Data: data relating to User Consent, Parental Consent, permissions, confirmations, authorizations, requests, withdrawal-related information, device-level permissions, notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation and/or location-related permissions, media access permissions, parental authority-related records, and other records necessary to evidence, manage, or verify the lawful use of the Services and the lawful processing of Personal Data, including in relation to a Child User.
11. 6.1.11. Payment and Subscription Data: subscription status, payment status, transaction identifiers, billing-related data, renewal-related information, refund-related information, chargeback-related information, app marketplace payment data, subscription management data, and other payment-related data received from payment providers, app marketplaces, banks, and/or other financial institutions to the extent necessary for the operation of the Services.
12. 6.1.12. Support, Communication, and Complaint Data: support requests, complaints, correspondence, communications with the Company, technical issue reports, SOS Alert delivery issue reports, safeguarding-related concerns, parental authority-related communications, and other messages submitted in connection with the App, the Services, a Child User, a Parent / Legal Guardian, an SOS Alert, an SOS Event, or related functionality.
13. 6.1.13. Compliance and Legal Data: data necessary for compliance with applicable law, lawful requests of competent authorities, dispute resolution, fraud prevention, abuse prevention, incident handling, repeated false SOS activation handling, safeguarding-related review, security review, protection of rights and safety, internal compliance documentation, and the establishment, exercise, or defense of legal claims.
14. 6.1.14. Potential Special Category Data: although the Services are not designed to intentionally request special categories of Personal Data as a standard feature, certain special category data may nonetheless arise in practice through SOS Alerts, SOS Events, media files, support communications, or other content transmitted through the App, including, where applicable, data relating to health, physical safety, distress, injury, emergency-style circumstances, or other particularly sensitive circumstances of a Child User or another person. For the purposes of this DPIA, such possibility is taken into account as part of the risk assessment and safeguards.
15. 6.1.15. Website Data: Personal Data and technical data relating to access to or use of the Website, including IP address, browser type and version, device type, operating system, time zone and language settings, pages viewed, date and time of access, referring pages, cookie identifiers, analytics data, diagnostic data, security logs, and data submitted through Website contact forms, support forms, or other Website functionality, where applicable.

7. Processing Operations

7.1. For the purposes of this DPIA, the processing operations carried out in connection with the App and the Services may include the collection, receipt, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, transmission, disclosure, sharing, restriction, deletion, and other handling of Personal Data necessary for the operation of the SOS Button App and the provision of the Services.

7.2. Such processing operations may take place in connection with the creation and administration of Accounts, the use of the App by Users and/or in relation to Child Users, the designation and management of Initiators and Respondents, the creation, activation, registration, sending, receipt, display, acknowledgement, response, cancellation, closure, and history of SOS Alerts and SOS Events, and the generation, maintenance, and review of SOS Event Data.

7.3. The processing operations may include the processing of geolocation data, location data, location updates, media files, notification-related data, SOS Event Data, acknowledgement or response information, cancellation or closure information, Fallback Notification information, and other data generated or transmitted through the App in connection with an SOS Event or other functionality of the Services.

7.4. Where supported by the relevant device, operating system, permissions, and authorization granted for the App, the processing operations may include the sending or attempted sending of an SOS Alert as a Critical Alert. Where the primary push notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective, the processing operations may include the sending or attempted sending of Fallback Notifications.

7.5. The processing operations may also include the receipt, recording, verification, management, update, withdrawal, and retention of permissions, consents, confirmations, authorizations, device-level permissions, notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation and/or location-related permissions, media access permissions, and related requests provided by Users and/or Parent / Legal Guardians, including in connection with the use of the Services by or in relation to a Child User.

7.6. In addition, the Company may carry out processing operations necessary for technical operation, maintenance, support, security, troubleshooting, abuse prevention, compliance, improvement, and lawful administration of the App and the Services, including the use of cloud infrastructure, notification services, communication channels, analytics and diagnostic tools, payment-related systems, and other service providers involved in the provision of the Services.

7.7. The processing operations may also include Website-related processing where the User or another person accesses or uses the Website, views legal documents or informational materials, follows download links, uses contact or support forms, submits a request, communicates with the Company, or otherwise interacts with the Website.

7.8. The processing operations may further include the review and handling of technical failures, non-delivery, misdelivery, delayed delivery, failed delivery, acknowledgement or non-acknowledgement, cancellation patterns, repeated false SOS activations, misuse of SOS Alerts, abuse of Critical Alerts, misuse of geolocation data or media files, safeguarding-related concerns, security incidents, support requests, and complaints.

7.9. For the purposes of this DPIA, the processing operations covered by this assessment include both routine operational processing and higher-risk processing connected with Child Users, SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, geolocation and location data, location updates, media files, notification-related data, event logs, technical records, and permissions.

8. Purposes of Processing

8.1. For the purposes of this DPIA, the Personal Data processed through the App and the Services may be processed for one or more of the following purposes:

1. 8.1.1. Provision of the Services: Personal Data may be processed in order to provide the functionality of the App and the Services, including registration and account administration, access to the App, communication flows between Users, and the use of the App by and/or in relation to a Child User.
2. 8.1.2. SOS Alerts, Critical Alerts, Fallback Notifications, and Response Functionality: Personal Data may be processed in order to enable the creation, activation, sending, attempted sending, receipt, display, review, acknowledgement, response, cancellation, closure, documentation, and history of SOS Alerts and SOS Events, including the processing of SOS Event Data, delivery of Critical Alerts where available and authorized, and Fallback Notifications.
3. 8.1.3. Geolocation and Location-Related Functionality: Personal Data may be processed in order to enable geolocation and location-related functionality of the App, including location sharing, location updates during an active SOS Event, location-related information shared with the relevant Respondent, location-based alerts where applicable, and related communication flows between relevant persons using the Services.
4. 8.1.4. Media Transmission and Related Communication: Personal Data may be processed in order to enable the upload, recording, transmission, receipt, display, review, and other handling of photos, video recordings, audio recordings, and other media files made available through the App.
5. 8.1.5. Child-Related Use of the Services: Personal Data may be processed in order to enable the use of the Services by and/or in relation to a Child User, including child-related functionality, child-related permissions, parental involvement, and the lawful operation of the App where a Child User is involved.
6. 8.1.6. Parent / Legal Guardian Involvement: Personal Data may be processed in order to receive, record, manage, verify, and otherwise handle permissions, consents, confirmations, authorizations, requests, and other actions of a Parent / Legal Guardian in connection with the use of the Services by or in relation to a Child User.
7. 8.1.7. Operation, Maintenance, and Technical Administration of the App: Personal Data may be processed in order to ensure the operation, maintenance, technical administration, availability, support, troubleshooting, and improvement of the App and the Services.
8. 8.1.8. Operation, Maintenance, and Technical Administration of the Website: Personal Data may be processed in order to operate, maintain, secure, administer, analyze, diagnose, and improve the Website, publish legal documents and informational materials, provide contact and support information, make download links available, respond to Website-based inquiries, and ensure the technical availability and security of the Website.
9. 8.1.9. Security, Abuse Prevention, and Incident Handling: Personal Data may be processed in order to detect, prevent, investigate, mitigate, and respond to unauthorized use, misuse of SOS Alerts, abuse of Critical Alerts, misuse of Fallback Notifications, false alerts, repeated false SOS activations, abusive conduct, suspicious activity, security incidents, unlawful uploads, fraud, misuse of geolocation data or media files, and other risks.
10. 8.1.10. Event Logging and Service Monitoring: Personal Data may be processed in order to generate, maintain, review, and use SOS Event Data, event logs, activity data, technical records, diagnostic records, notification-related records, delivery and failure records, acknowledgement or response records, cancellation or closure records, fallback delivery records, abuse-prevention records, and related operational information necessary for the Services.
11. 8.1.11. Support, Complaints, and Communications: Personal Data may be processed in order to receive, review, and respond to support requests, complaints, technical issues, user communications, safeguarding-related concerns, and other matters directly connected with the operation of the App and the Services.
12. 8.1.12. Subscription, Payment, and Related Administration: Personal Data may be processed in order to administer subscriptions, tariffs, payments, renewals, refunds, billing-related actions, and other payment-related processes connected with the Services.
13. 8.1.13. Compliance with Applicable Law: Personal Data may be processed in order to comply with applicable law, regulatory requirements, lawful requests of competent authorities, safeguarding-related obligations, child-related legal requirements, and other legal obligations applicable to the Company.
14. 8.1.14. Protection of Rights, Safety, and Legitimate Interests: Personal Data may be processed in order to protect the rights, safety, property, and legitimate interests of the Company, Users, Child Users, Parent / Legal Guardians, Respondents, and/or Third Parties, including in connection with incidents, disputes, safeguarding-related concerns, and threat-to-life situations.
15. 8.1.15. Establishment, Exercise, and Defense of Legal Claims: Personal Data may be processed in order to establish, exercise, defend, and otherwise manage legal claims, disputes, investigations, and related legal processes arising out of or in connection with the App and the Services.
16. 8.1.16. Internal Compliance and Risk Management: Personal Data may be processed in order to support internal compliance, accountability, risk assessment, incident review, safeguarding-related review, and other internal governance processes connected with the lawful operation of the App and the Services.

9. Legal Bases

9.1. For the purposes of this DPIA, the Company may rely on one or more legal bases for the processing of Personal Data, depending on the relevant category of Personal Data, the category of data subject, the specific functionality of the App, and the purpose of the relevant processing activity. Under the GDPR, processing must rely on a valid legal basis, and children’s data requires specific safeguards where consent is used for information society services offered directly to a child.

1. 9.1.1. Consent: The Company may rely on Consent where the relevant processing activity requires a freely given, specific, informed, and unambiguous indication of wishes by the relevant data subject. For the purposes of the App and the Services, Consent may be relevant, in particular, in relation to optional permissions, optional features, notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation and/or location-related permissions, media access permissions, certain forms of communication, and other processing activities where Consent is the appropriate legal basis under applicable law.
2. 9.1.2. Parental Consent in relation to Child Users: Where the App and/or the Services are used by or in relation to a Child User, and where the relevant processing is based on consent in connection with information society services offered directly to a child, the Company may rely on Parental Consent where required under applicable law. Parental Consent may be relevant, in particular, in relation to child-related functionality, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation and/or location-related permissions, media access permissions, Fallback Notifications, and other functionality involving the processing of Personal Data of a Child User.
3. 9.1.3. Necessity for the Provision of the Services: The Company may rely on the necessity to provide the Services and operate the App in connection with the relevant user relationship, including account administration, access to functionality, creation, activation, sending, receipt, display, acknowledgement, cancellation, closure, and history of SOS Alerts and SOS Events, processing of SOS Event Data, and delivery of Critical Alerts where available and authorized.
4. 9.1.4. Compliance with Applicable Law: The Company may rely on processing that is necessary for compliance with applicable law, including regulatory requirements, lawful requests of competent authorities, child-related legal requirements, safeguarding-related obligations, payment-related compliance, data protection obligations, recordkeeping duties, and other legal obligations applicable to the Company.
5. 9.1.5. Protection of Vital Interests, Rights, and Safety: Where applicable, the Company may rely on processing that is necessary to protect the vital interests, rights, safety, and legitimate interests of the Company, Users, Child Users, Parent / Legal Guardians, Respondents, and/or Third Parties, including in connection with SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, and Fallback Notifications.
6. 9.1.6. Legitimate Interests: The Company may rely on legitimate interests where such processing is necessary for operating, securing, maintaining, administering, improving, and reviewing the App and the Services, ensuring the reliability and security of SOS Alert delivery, troubleshooting Critical Alert delivery where available and authorized, supporting Fallback Notifications, and preventing abuse, fraud, misuse of SOS Alerts, and abuse of Critical Alerts.
7. 9.1.7. Establishment, Exercise, and Defense of Legal Claims: The Company may rely on processing that is necessary for the establishment, exercise, and defense of legal claims, including processing connected with disputes, complaints, investigations, enforcement actions, safeguarding-related cases, security incidents, and other matters arising out of or in connection with the App and the Services.
8. 9.1.8. Processing of Potential Special Category Data: Although the App and the Services are not designed to intentionally request special categories of Personal Data as a standard feature, this DPIA takes into account the possibility that such data may arise in practice through SOS Alerts, SOS Events, media files, support communications, or other content transmitted through the App.
9. 9.1.9. Combination of Legal Bases: For the purposes of this DPIA, different processing operations carried out through the App may rely on different legal bases. The applicable legal basis must therefore be assessed by reference to the specific processing activity, the relevant data subject, the role of the relevant person within the App, the nature of the Personal Data concerned, and the specific purpose of processing.
10. 9.1.10. Relevance to this DPIA: This DPIA proceeds on the basis that the processing activities covered by the App involve a mixed legal-basis model, including, as applicable, Consent, Parental Consent, necessity for the provision of the Services, compliance with applicable law, protection of rights and safety, legitimate interests, and the establishment, exercise, or defense of legal claims.

10. Need for this Assessment

10.1. This assessment is required due to the nature, scope, context, and purposes of the processing carried out through the SOS Button App and the Services. In particular, the processing covered by this DPIA involves the use of the App by and/or in relation to Child Users, the processing of SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, geolocation and location data, media files, notification-related data, event logs, and other Personal Data.

10.2. This assessment is also necessary because the processing includes factors that require enhanced scrutiny and documented safeguards, including the involvement of Child Users as a vulnerable category of data subjects, the possible processing of highly sensitive contextual information through SOS Alerts, SOS Events, media files, support communications, or related records, the use of geolocation-related functionality, and the potential delivery of SOS Alerts as Critical Alerts or through Fallback Notifications.

10.3. The assessment is further required because the proper operation of SOS Alert delivery, Critical Alerts where available and authorized, Fallback Notifications, geolocation sharing, media sharing, and related safety functionality may depend on device settings, notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation permissions, media access permissions, and other technical conditions outside the Company’s full control.

10.4. For these reasons, the Company considers it necessary to carry out and maintain this assessment as part of its data protection, risk management, safeguarding, security, and accountability framework in relation to the App and the Services, including the processing of Personal Data of Child Users, SOS Event Data, geolocation and location data, media files, notification-related data, event logs, technical records, and other Personal Data.

11. Necessity and Proportionality

11.1. The processing covered by this DPIA is considered necessary for the operation of the SOS Button App and the provision of the Services because the core functionality of the App depends on the collection, use, transmission, storage, and other handling of Personal Data necessary to create, send, deliver, display, acknowledge, respond to, cancel, close, document, and maintain the history of SOS Alerts and SOS Events.

11.2. The processing of SOS Event Data, geolocation and location data, media files, notification-related data, event logs, technical records, consent-related records, and permission-related records is considered necessary because such data is required to enable the relevant SOS communication flow, identify the Initiator and Respondent, support the delivery and attempted delivery of SOS Alerts, and document notification status, sending and delivery information, and related response activity through the App.

11.3. The processing connected with Critical Alerts is considered necessary only to the extent such functionality is available, enabled, permitted by the relevant device settings, and authorized for the App, and only in connection with SOS Alerts and SOS Events. The use of Critical Alerts is intended to support the delivery and visibility of SOS Alerts in safety-related situations where ordinary notification delivery may be insufficient.

11.4. The processing connected with Fallback Notifications is considered necessary where the primary push notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective, because such alternative notification attempts may support the delivery of an SOS Alert to the relevant Respondent. Such processing is limited to the data necessary to send or attempt to send the relevant Fallback Notification and document the relevant delivery status.

11.5. The processing is considered proportionate because it is limited to categories of Personal Data that are relevant to the specific functions of the App and the specific purposes identified in this DPIA. In assessing proportionality, particular weight is given to the involvement of Child Users, and the sensitivity of geolocation data, location updates, media files, SOS Event Data, notification-related data, and related records.

11.6. The processing is further considered proportionate because SOS Alert-related processing, Critical Alert-related processing, Fallback Notification-related processing, geolocation sharing, media sharing, and related event logging are tied to the functionality of the App and the relevant SOS Event or enabled service feature. The Company does not design the App to process more Personal Data than is reasonably necessary for the relevant purpose.

12. Specific Risks for Child Users

12.1. The processing covered by this DPIA creates specific risks for Child Users due to the nature of the App and the types of Personal Data involved. In particular, the processing of geolocation and location data, alerts, notifications, media files, and related event information may create increased risks of unauthorized access, excessive disclosure, misuse of location-related information, and misdelivery of alerts or child-related information.

12.2. Further risks arise from the fact that Child Users are a vulnerable category of data subjects and may be less able to understand the consequences of data sharing, location-related processing, alerts, or media transmission through the App. The use of the Services by or in relation to a Child User may also involve risks connected with disputed parental authority, invalid or insufficient permissions, and unauthorized instructions.

12.3. Specific risks may also arise where SOS Alerts relating to a Child User are delivered or attempted to be delivered as Critical Alerts or through Fallback Notifications. Such risks may include accidental SOS activation by a Child User, repeated false SOS activations, distress caused by urgent or high-priority notifications, and over-reliance by the Child User, Parent / Legal Guardian, Respondent, or other recipient on the App.

13. Risk Factors Relating to Core App Functionality

13.1. The processing covered by this DPIA gives rise to specific risks in connection with the core functionality of the App, in particular where the Services involve SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, geolocation and location data, location updates, media files, notification-related data, event logs, and technical records.

13.2. Geolocation and location-related functionality may create risks of overexposure of a person’s whereabouts, unauthorized access to location information, delayed, inaccurate, incomplete, or outdated location data, and inappropriate reliance on such data by Respondents or other recipients. These risks may be increased during an active SOS Event where location data or location updates may be shared in a safety-related context.

13.3. SOS Alerts and related notification functionality may create risks of false activation, accidental SOS activation, repeated false SOS activations, misuse of SOS Alerts, misdelivery, delayed delivery, non-delivery, incomplete delivery, inadequate acknowledgement, delayed response, non-response, or reliance on incomplete, inaccurate, outdated, or misleading information.

13.4. Fallback Notifications may create additional risks where SMS, email, or other alternative notification channels are delayed, unavailable, misdelivered, not acknowledged, or received by a person who is no longer the appropriate recipient. Such risks may be intensified where the relevant Fallback Notification concerns a Child User, geolocation data, media files, or other sensitive contextual information connected with an SOS Event.

13.5. Media files may create risks of excessive disclosure, unlawful sharing, unauthorized copying, storage, forwarding, or reuse of sensitive or highly personal content, including content relating to a Child User, a safety-related situation, distress, injury, or other emergency-style circumstances. Such risks may be increased where media files are attached to or shared during an SOS Event and are made available to Respondents.

13.6. SOS Event Data, event logs, notification-related records, and technical records may create risks where records of SOS Alerts, communications, response activity, delivery status, acknowledgement status, cancellation or closure information, timing, location, media sharing, fallback delivery attempts, or related operational data are accessed, retained, linked, or used more broadly than necessary. Such data may reveal patterns relating to a person.

13.7. These risks are increased by the operational characteristics of the App, including reliance on device settings, notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation permissions, media access permissions, mobile operating systems, internet connectivity, mobile networks, notification infrastructure, SMS providers, email delivery providers, and other Third Party services.

13.8. In the case of Child Users, such risks may be further intensified because the relevant data may concern safety-related events, movements, communications, media, parental permissions, Respondent selection, or other child-related circumstances requiring a heightened level of protection. For these reasons, the processing of these categories of data requires specific scrutiny and safeguards relating to access limitation, transfer limitation, retention, and security.

14. Third Parties and Transfers

14.1. The processing covered by this DPIA involves the disclosure and transfer of Personal Data to Third Parties to the extent necessary for the operation of the App, the Website, the provision of the Services, the support of SOS Alerts and SOS Events, the processing of SOS Event Data, the delivery or attempted delivery of Critical Alerts where available and authorized, and the sending or attempted sending of Fallback Notifications.

14.2. The processing covered by this DPIA involves the disclosure and transfer of Personal Data to Third Parties to the extent necessary for the operation of the App, the provision of the Services, the support of SOS Alerts and SOS Events, the processing of SOS Event Data, the delivery or attempted delivery of Critical Alerts where available and authorized, the sending or attempted sending of Fallback Notifications, and related functionality.

14.3. Such Third Parties may include cloud and hosting providers, notification delivery providers, SMS providers, email delivery providers, analytics, diagnostics, and performance providers, payment service providers, app marketplace or subscription management providers, contractors and service providers supporting technical operation, security, support, abuse prevention, compliance, safeguarding-related review, and child-related service administration.

14.4. Depending on the functionality used, transfers may also occur between Users within the App. In particular, a Respondent may receive SOS Alerts, SOS Event Data, geolocation data, location updates, media files, notification-related information, acknowledgement or response information, cancellation or closure information, and other information made available through the functionality of the App.

14.5. Transfers to notification delivery providers, SMS providers, email delivery providers, and other communication providers may be necessary to send, attempt to send, deliver, document, troubleshoot, or support SOS Alerts, Critical Alerts where available and authorized, Fallback Notifications, push notifications, SMS messages, email notifications, and other service-related communications.

14.6. Transfers to cloud, hosting, storage, and infrastructure providers may be necessary for the hosting, storage, transmission, backup, protection, and technical processing of Account Data, SOS Event Data, geolocation data, location updates, media files, event logs, technical records, diagnostic records, consent-related records, and other data necessary for the operation, security, support, and lawful administration of the App.

14.7. Transfers to analytics, diagnostics, performance, or crash reporting providers create additional sensitivity where the App processes SOS Event Data, geolocation data, media files, Child User data, or other sensitive contextual data. The Company should limit such transfers to what is strictly necessary for the relevant technical, diagnostic, security, performance, or improvement purpose, and use aggregated, minimized, or pseudonymized data where possible and appropriate.

14.8. These transfers create specific risks because Personal Data may be disclosed beyond the immediate control of the Company, including risks of over-sharing, unauthorized access, excessive recipient access, insufficient recipient limitation, insufficient transfer restrictions, differing technical and organizational standards among recipients, onward disclosure, and limitations arising from the involvement of external providers.

14.9. The transfer context therefore requires particular attention to necessity, proportionality, recipient limitation, role-based access, need-to-know access, contractual safeguards, technical and organizational security measures, logging and monitoring, restrictions on onward processing, and vendor-specific controls. Where a Third Party processes Personal Data on behalf of the Company, the relevant relationship should be governed by an appropriate data processing arrangement.

14.10. Where Personal Data is transferred outside the country in which it was collected and/or outside the European Economic Area, the relevant processing also creates transfer-related risks connected with cross-border access, differing legal regimes, enforcement limitations, government access risks, onward transfer risks, and reduced practical control over onward processing.

14.11. Transfers involving Child User data, SOS Event Data, geolocation data, media files, Critical Alerts, Fallback Notifications, notification-related records, or other sensitive contextual data should be subject to heightened scrutiny. Such transfers should be limited to what is necessary for the relevant functionality or lawful purpose and should be assessed together with the safeguards described in this DPIA.

15. Safeguards and Measures

15.1. In order to reduce the risks identified in this DPIA, the Company applies and/or plans to apply a combination of legal, technical, organizational, contractual, and operational safeguards in connection with the App and the Services. Such safeguards are intended to address the specific risks connected with Child Users, SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, and related processing.

15.2. The Company applies and/or plans to apply role-based access restrictions, need-to-know access limitations, authentication and account protection measures, permission and consent management, parental consent and parental authority-related controls where applicable, technical and organizational security measures, retention limits, deletion and anonymization practices, and contractual obligations imposed on relevant service providers.

15.3. Particular attention is given to the processing of Personal Data of Child Users, SOS Event Data, geolocation data, location updates, media files, notification-related data, event logs, and other data that may create elevated risks due to the safety-related context in which the App may be used. Where the Services are used by or in relation to a Child User, the Company applies and/or plans to apply child-specific safeguards.

15.4. The Company applies and/or plans to apply safeguards relating to SOS Alerts and Critical Alerts, including limiting the use of Critical Alerts to SOS Alerts and SOS Events, preventing the use of Critical Alerts for marketing, advertising, onboarding, subscription reminders, ordinary service messages, general communications, or other non-SOS purposes, and maintaining internal controls intended to ensure that notification classification is applied correctly.

15.5. The Company applies and/or plans to apply server-side controls for notification classification, centralized notification routing, and event type validation in order to reduce the risk of incorrect or unauthorized use of Critical Alerts. The App should not independently assign a Critical Alert level without the relevant server-side validation, where such architecture is implemented.

15.6. The Company applies and/or plans to apply safeguards relating to Fallback Notifications, including limiting such notifications to circumstances where the primary push notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective in accordance with the functionality of the Services. Fallback Notification processing should be limited to data necessary for the relevant delivery attempt and delivery status.

15.7. The Company applies and/or plans to apply logging, monitoring, and audit measures in relation to SOS Alerts, SOS Events, Critical Alerts, Fallback Notifications, and related processing. Such measures may include records of SOS Alert activation, date and time of activation, Initiator and Respondent identifiers, notification status, sending and delivery information, failure information, and acknowledgement or response information.

15.8. The Company applies and/or plans to apply abuse-prevention measures intended to reduce misuse of the App and the Services, including measures relating to false alerts, repeated false SOS activations, misuse of SOS Alerts, abuse of Critical Alerts, misuse of Fallback Notifications, misuse of geolocation data or media files, unauthorized access, suspicious activity, and other conduct affecting the lawful and secure operation of the Services.

15.9. The Company applies and/or plans to apply safeguards relating to geolocation data, location updates, and media files, including limiting access to relevant Users and recipients through the functionality of the App, reducing unnecessary disclosure, applying access controls, limiting retention where appropriate, and ensuring that such data is processed only to the extent necessary for the relevant SOS Event or enabled functionality.

15.10. The Company applies and/or plans to apply safeguards relating to Third Party providers and transfers, including recipient limitation, vendor review, contractual safeguards, confidentiality obligations, processing limitations, security obligations, incident notification obligations, restrictions on onward processing, and deletion or return obligations where applicable.

15.11. The Company also applies and/or plans to apply safeguards relating to the Website, including technical security measures, access controls, Website hosting safeguards, protection of Website forms where applicable, limitation of Website-related analytics and diagnostic data, cookie-related controls where required by applicable law, and measures intended to reduce unauthorized access, excessive collection, or misuse.

15.12. The safeguards and measures described in this DPIA are intended to ensure that the relevant processing remains limited to what is necessary for the lawful operation of the App and the provision of the Services, and that the risks to the rights and freedoms of Users, Child Users, Parent / Legal Guardians, Respondents, and other relevant persons are reduced to the extent reasonably possible. The adequacy of these safeguards is subject to ongoing review.

16. Residual risk and conclusion

16.1. Following the assessment set out in this DPIA, the processing covered by the SOS Button App and the Services remains associated with a heightened level of risk due to the nature of the App, the involvement of Child Users, the processing of SOS Alerts, SOS Events, SOS Event Data, Critical Alerts where available and authorized, Fallback Notifications, geolocation and location data, location updates, media files, and notification-related data.

16.2. Even where appropriate legal, technical, organizational, contractual, and operational safeguards are implemented, certain residual risks cannot be eliminated in full. Such residual risks may include delayed delivery, failed delivery, misdelivery, or non-delivery of SOS Alerts, Critical Alerts, Fallback Notifications, or other notifications; inaccurate, incomplete, delayed, or unavailable location-related information; and misuse of the Services.

16.3. In relation to Child Users, residual risks remain heightened because the relevant processing may involve geolocation data, location updates, media files, urgent or safety-related communications, parental permissions, Respondent selection, notification delivery, and other child-related contextual information. Such risks may be increased where a Child User accidentally activates an SOS Alert or where false or repeated SOS Alerts occur.

16.4. At the same time, taking into account the purposes of the processing, the functionality of the App, the safeguards and measures identified in this DPIA, and the necessity of the relevant processing operations for the provision of the Services, the Company considers that the processing may proceed provided that the safeguards described in this DPIA are implemented, maintained, reviewed, and updated on an ongoing basis.

16.5. In particular, continued attention is required in relation to the processing of Personal Data of Child Users, SOS Event Data, geolocation and location data, media files, notification-related records, consent and parental authority management, permission management, retention controls, vendor management, incident response, abuse prevention, repeated false SOS activation handling, and restrictions on the use of Critical Alerts.

16.6. This DPIA therefore concludes that the processing should remain subject to continuing review as part of the Company’s compliance, security, safeguarding, data protection, and risk management framework. Any material change to the functionality of the App, the functionality or data processing role of the Website, the categories of Personal Data processed, the use of Child User data, the use of Critical Alerts, or the use of Fallback Notifications should prompt a review and, where necessary, an update of this DPIA.

17. Company details

Sentrivo OÜ
Register code: 17511615
Address: Harju maakond, Tallinn, Kesklinna, linnaosa, Tuukri tn 19, 10120
E-mail: info@buttonsos.com