Privacy Policy

1. Introduction

This Privacy Policy governs the collection, use, storage, disclosure, and other processing of Personal Data by the Company in connection with the provision of the Services through the SOS Button mobile application.

This Privacy Policy sets out the categories of Personal Data processed by the Company, the purposes and legal grounds for such processing, the manner in which such Personal Data may be used, stored, and disclosed, as well as the rights of the User in relation to such processing.

For the purposes of this Privacy Policy, references to “we”, “our”, or “us” (or similar words) shall mean the Company.

For the purposes of this Privacy Policy, references to “you”, “your”, or the “User” (or similar words) shall mean any individual who accesses, registers with, or uses the Services through the SOS Button mobile application and/or, where applicable, accesses or uses the Website.

Unless the context requires otherwise, words importing the singular include the plural and vice versa, and words importing one gender include all genders.

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, or Legal Guardian, including any information that directly or indirectly allows the identification of such person, including, where applicable, the User’s 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, 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 both the Initiator and the 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/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, Child User, the Controller, or the Processor.

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 and the exercise of rights, permissions, consents, confirmations, and requests under this Privacy Policy, the Terms of Use, and applicable law.

2.14. Cookies means small text files and/or similar technologies placed on, stored on, or accessed from the User’s device for the purposes of ensuring the operation, functionality, security, performance, and analytics of the Services, where applicable.

2.15. User’s Consent (hereinafter “Consent”) means a freely given, specific, informed, and unambiguous indication of the User’s wishes by which the User, by a statement and/or clear affirmative action, signifies agreement to the processing of Personal Data and/or acceptance of other actions, conditions, or practices as provided by the applicable document, interface, or functionality of the Services.

2.16. 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 Child User’s use of the Services, where such authorization is required under applicable law.

2.17. DPIA (Data Protection Impact Assessment) means an assessment carried out by the Company, where required by applicable law, in order to identify, evaluate, and mitigate risks to the rights and freedoms of natural persons arising from the processing of Personal Data, including, where applicable, risks related to the processing of Personal Data of Child Users.

2.18. 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.

2.19. 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.

2.20. 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.

2.21. 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.

2.22. 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.

2.23. 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. General provisions

3.1. The Company provides the Services through the SOS Button App to Users, Child Users, and, where applicable, Parents / Legal Guardians, who may access and use the SOS Button from different countries and jurisdictions. In connection with the provision of the Services, the Company may process Personal Data in accordance with the laws and regulatory requirements applicable to the relevant jurisdiction, including, where applicable, the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the “GDPR”).

3.2. The Company processes Personal Data in connection with the provision of the Services, including to enable communication between Users, the sending and receiving of alerts, notifications, geolocation data, media, and related event information, as well as to ensure the operation, security, support, and improvement of the App. Where the Services are used in connection with a Child User, the Company may also process Personal Data of the Child User and the Parent / Legal Guardian to the extent necessary for the provision of the Services, compliance with applicable law, and implementation of applicable safeguards relating to children’s Personal Data.

3.3. The Services may include SOS Alert functionality that allows the Initiator to create an SOS Alert and transmit it to one or more Respondents through the App. In connection with such functionality, the Company may process Personal Data and technical data related to the creation, sending, delivery, display, acknowledgement, cancellation, closure, history, and support of the relevant SOS Event, including SOS Event Data, notification-related data, geolocation data shared during the SOS Event, media files shared during the SOS Event, and Fallback Notification data, where applicable.

3.4. 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. Critical Alerts are used only in connection with SOS Alerts and are not used for marketing, advertising, subscription reminders, onboarding, general messaging, or other non-SOS communications. If Critical Alerts are unavailable, disabled, not permitted, or not authorized, the Services may use other available notification methods in accordance with the functionality of the App, including standard or priority push notifications and/or Fallback Notifications, where applicable.

3.5. For the purposes of Regulation (EU) 2016/679 (General Data Protection Regulation) and, where applicable, other data protection laws, the Company acts as the Controller in relation to the Personal Data processed for the purposes of registration, account administration, provision of the Services, technical support, subscription management, security, analytics, and compliance with applicable law.

3.6. To the extent the Company processes Personal Data in the course of enabling communication, alerts, notifications, geolocation data, media, and related event information between Users through the App, such processing shall be carried out by the Company in accordance with this Privacy Policy, the functionality of the Services, and applicable law.

3.7. This Privacy Policy governs the collection, use, storage, disclosure, and other processing of Personal Data by the Company in connection with the provision of the Services through the SOS Button mobile application and, where applicable, the operation and use of the Website.

4. Personal data

4.1. The Company may receive the following Personal Data about the Users:

1. 4.1.1. full name;
2. 4.1.2. nickname;
3. 4.1.3. email address;
4. 4.1.4. phone number;
5. 4.1.5. profile photo;
6. 4.1.6. geolocation data;
7. 4.1.7. location data;
8. 4.1.8. SOS Event Data;
9. 4.1.9. notification-related data, including data related to push notifications, Critical Alerts, and Fallback Notifications;
10. 4.1.10. media files uploaded, recorded, transmitted, or otherwise shared through the App in connection with an SOS Event or other functionality of the Services;
11. 4.1.11. login and password data required for the creation and use of the Account;

4.2. The Company may receive and process the following Personal Data relating to a Child User:

1. 4.2.1. full name;
2. 4.2.2. nickname;
3. 4.2.3. profile photo;
4. 4.2.4. geolocation data and location data transmitted through the App;
5. 4.2.5. SOS Event Data, including data relating to SOS Alerts created by or in relation to a Child User;
6. 4.2.6. media files uploaded, recorded, transmitted, or otherwise shared through the App;
7. 4.2.7. event logs and other information related to alerts, notifications, delivery status, and response activity within the App;
8. 4.2.8. other Personal Data strictly necessary for the provision of the Services, operation of the App, compliance with applicable law, and protection of the rights, safety, and legitimate interests of the Company, Users, and/or Third Parties;

4.3. The Company may receive and process the following Personal Data relating to a Parent / Legal Guardian:

1. 4.3.1. full name;
2. 4.3.2. email address;
3. 4.3.3. phone number;
4. 4.3.4. account and profile data;
5. 4.3.5. data confirming or relating to parental authority, consents, permissions, and requests submitted in connection with a Child User;
6. 4.3.6. communication, support, subscription, and payment-related data;
7. 4.3.7. other Personal Data strictly necessary for the provision of the Services, compliance with applicable law, and protection of the rights, safety, and legitimate interests of the Company, Users, and/or Third Parties;

4.4. Through the Website: when the User 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 provides information through the Website. In such cases, the Company may process Website-related technical data, usage data, cookie-related data, analytics data, support and communication data, and other Personal Data submitted through the Website.

4.5. The Company does not intentionally collect or store full banking card details of the User. Payment card and other banking data required to complete payments are processed by the relevant Third Party payment service provider. The Company may receive and process limited payment-related data, transaction identifiers, subscription status, billing status, and other payment information to the extent necessary for subscription administration, renewals, refunds, dispute resolution, fraud prevention, compliance with applicable law, and protection of the Company’s rights and legitimate interests.

4.6. The Company does not intentionally collect Personal Data through photos, video recordings, audio recordings, and/or other media files uploaded, submitted, recorded, transmitted, and/or otherwise shared by the User through the App. However, the Company may receive such Personal Data where this is necessary for the operation of the SOS Button, provision of the Services, technical support, security, and/or compliance with applicable law. In such case, any Personal Data contained in such media files shall be processed in accordance with this Privacy Policy.

4.7. The Company does not intentionally request or seek to collect special categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data processed for the purpose of uniquely identifying a person, health data, or data concerning a person’s sex life or sexual orientation, unless such processing is required, permitted, or otherwise justified under applicable law. However, due to the nature of the Services, certain special categories of Personal Data may be contained in alerts, media files, support communications, or other information provided through the App. Where this occurs, the Company shall process such data only to the extent permitted or required by applicable law and subject to applicable safeguards.

4.8. In connection with the SOS Alert functionality, the Company may receive and process SOS Event Data, notification-related data, and technical data necessary to create, send, deliver, display, acknowledge, cancel, close, support, and document an SOS Event. Such data may include information about the Initiator, Respondent, date and time of SOS Alert activation, SOS Event 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, and technical diagnostic information related to the operation and delivery of the SOS Alert.

4.9. Where an SOS Alert is delivered or attempted to be delivered as a Critical Alert, the Company may process data relating to the relevant notification event type, notification status, sending and delivery information, device and operating system settings relevant to notification delivery, and other technical information necessary to support, troubleshoot, document, and secure such notification. Critical Alerts are processed only in connection with SOS Alerts and are not used for marketing, advertising, subscription reminders, onboarding, general messaging, or other non-SOS communications.

4.10. Where the primary push notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective, the Company may process Personal Data and technical data necessary to send or attempt to send Fallback Notifications, including SMS messages, email notifications, or other alternative notifications, to the relevant Respondent in accordance with the functionality of the Services.

4.11. When using the App or receiving the Services, the Company may automatically collect certain Personal Data and technical information, including:

1. 4.11.1. IP address;
2. 4.11.2. time zone and language settings;
3. 4.11.3. device type and operating system;
4. 4.11.4. application version;
5. 4.11.5. geolocation data and location data, where enabled by the User and/or permitted by the device settings;
6. 4.11.6. event logs, including data about who initiated an alert, when such alert was sent, who received it, delivery status, and response time;
7. 4.11.7. data related to the sending and delivery of push notifications, SMS messages, and email notifications;
8. 4.11.8. SOS Event Data, including technical records relating to SOS Alert activation, delivery, acknowledgement, cancellation, closure, history, and related actions within the App;
9. 4.11.9. data related to Critical Alerts and Fallback Notifications, including notification event type, sending status, delivery status, failure status, acknowledgement status, and fallback delivery attempts, where applicable;
10. 4.11.10. log, diagnostic, and technical data related to the operation of the App;

4.12. The Company has the right to collect and receive Personal Data as follows:

1. 4.12.1. During registration and creation of the Account: when the User and/or Parent / Legal Guardian registers in the App, creates an Account, confirms the email address, logs in to the Account, and/or provides data necessary for access to and use of the Services, including where such registration or Account relates to a Child User.
2. 4.12.2. Directly from the User, Child User, and/or Parent / Legal Guardian: when such person completes or updates a profile, adds, designates, or manages an Initiator and/or Respondent, creates, sends, receives, cancels, closes, or otherwise manages an SOS Alert or SOS Event, uploads, records, transmits, or otherwise shares media files, communicates through the App, contacts support, subscribes to the Services, submits feedback, provides consents or permissions, and/or otherwise provides information while using the SOS Button and the Services.
3. 4.12.3. Automatically: when the User, Child User, and/or Parent / Legal Guardian accesses or uses the App, including through log files and similar technologies, to collect device and technical data, IP address, time zone and language settings, geolocation data, location data, notification-related data, SOS Event Data, event logs, and technical records relating to alerts, SOS Alerts, Critical Alerts, Fallback Notifications, sending status, delivery status, failure status, acknowledgement or response status, cancellation or closure status, and related actions within the App.
4. 4.12.4. From Third Parties: from the Company’s service providers and partners involved in the operation of the App and provision of the Services, including push notification providers, SMS providers, email delivery providers, cloud storage providers, analytics providers, payment service providers, banks, and/or other financial institutions, to the extent such data is provided to the Company in connection with the User’s use of the App, payment for the Services, and/or provision of the Services, including data relating to the sending, delivery, failure, acknowledgement, or fallback delivery of alerts, SOS Alerts, Critical Alerts, Fallback Notifications, and other service-related communications.
5. 4.12.5. Through media files: the Company may receive and process Personal Data contained in photos, video recordings, audio recordings, and/or other media files uploaded, submitted, recorded, transmitted, or otherwise shared through the App, including in connection with an SOS Event, to the extent necessary for the provision of the Services, operation of the App, technical support, security, compliance with applicable law, and protection of the rights, safety, and legitimate interests of the Company, Users, and/or Third Parties.
6. 4.12.6. Operation of the Website: to operate, maintain, secure, administer, analyze, 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.

4.13. The Company has the right to use Personal Data for the following purposes:

1. 4.13.1. Provision of the Services: to register the User, create and administer the Account, provide access to and use of the App, enable communication between the Initiator and the Respondent, enable the sending, delivery, receipt, and display of alerts, notifications, geolocation data, media files, and related event information, and otherwise provide the Services.
2. 4.13.2. Operation of the App: to ensure the proper functioning, availability, maintenance, administration, and technical operation of the SOS Button and its functionality.
3. 4.13.3. Notifications and Communications: to send push notifications, SMS messages, email notifications, service communications, technical notices, security alerts, and other communications related to the App and the Services.
4. 4.13.4. Payments and Subscriptions: to process subscriptions, payments, renewals, refunds, payment confirmations, and related financial and transactional operations connected with the provision of the Services.
5. 4.13.5. Support and User Requests: to respond to inquiries, requests, complaints, and support messages, and to provide technical and customer support to Users.
6. 4.13.6. Security and Abuse Prevention: to protect the App and the Services, detect, prevent, investigate, and respond to suspicious, unauthorized, abusive, fraudulent, misleading, false, and/or unlawful activity, including misuse of alerts, spam, repeated false activations, and other violations related to the use of the SOS Button.
7. 4.13.7. Analytics and Improvement: to analyze the use of the App and the Services, including event logs, technical data, and usage patterns, to troubleshoot issues, improve functionality, develop new features, and enhance the performance and user experience of the App.
8. 4.13.8. Compliance with Law: to comply with applicable law, lawful requests of public authorities, court orders, legal process, and regulatory requirements.
9. 4.13.9. Legal Protection: to establish, exercise, protect, and/or defend the rights, legitimate interests, property, safety, and legal claims of the Company, Users, and/or Third Parties, including in connection with disputes, investigations, and threat-to-life situations where applicable.
10. 4.13.10. Enforcement of Documents and Policies: to enforce this Privacy Policy, the Terms, subscription terms, internal rules, and other applicable documents governing the use of the App and the Services.
11. 4.13.11. SOS Alerts, Critical Alerts, and Fallback Notifications: to create, send, deliver, display, acknowledge, cancel, close, support, troubleshoot, and document SOS Alerts and SOS Events, including, where applicable, the processing of SOS Event Data, geolocation data shared during an SOS Event, media files shared during an SOS Event, notification-related data, Critical Alert data, Fallback Notification data, delivery information, acknowledgement or response information, and related technical records.

4.14. Child Safety and Child-Related Service Administration: to enable the use of the Services in connection with a Child User, including account administration where applicable, parental permissions and confirmations, child-related settings, communication flows, SOS Alert functionality, SOS Event administration, and implementation of safeguards applicable to children’s Personal Data.

4.15. Risk Assessment and Data Protection Compliance: to carry out and document assessments, reviews, and compliance measures required under applicable law, including, where applicable, a DPIA (Data Protection Impact Assessment), security reviews, safeguarding measures, and records related to the lawful processing of Personal Data of Child Users.

4.16. The Company may receive, verify, and process information and documents relating to parental authority, parental consent, permissions, confirmations, and related requests to the extent necessary to verify the lawful use of the Services by or in relation to a Child User, comply with applicable law, and implement safeguards applicable to children’s Personal Data.

4.17. The Company may receive, record, store, and otherwise process data relating to consents, permissions, confirmations, and withdrawals of consent provided by the User and/or Parent / Legal Guardian, including the date, time, scope, method, and status of such consent or withdrawal, to the extent necessary for compliance with applicable law, operation of the Services, and protection of the Company’s rights and legitimate interests.

4.18. The Company may receive and process data necessary to verify the identity of the User and/or Parent / Legal Guardian, confirm control over the Account, detect suspicious or unauthorized activity, and protect the security, integrity, and lawful operation of the App and the Services, where such processing is necessary and permitted under applicable law.

4.19. The Company may receive and process requests, communications, declarations, and related data submitted by a Parent / Legal Guardian in connection with a Child User, including requests relating to access, correction, deletion, restriction, objections, permissions, and other actions concerning the Child User’s Personal Data and use of the Services.

4.20. In particular, our application may collect and process the following categories of data:

5. Transfer of Personal data

5.1. The Company may transfer Personal Data to entities with which the Company cooperates in the implementation and provision of the Services, including in connection with the provision of the Services to or in relation to a User, Child User, and/or Parent / Legal Guardian, and only to the extent necessary for the relevant purpose and permitted by applicable law:

1. 5.1.1. Other Users. Personal Data may be transferred between Users within the App in accordance with its functionality. In particular, the Respondent may receive the Initiator’s geolocation data, location data, alerts, notifications, SOS Event Data, media files, and related event information where such transfer is initiated and/or enabled through the SOS Button. Such data may be made available to the Respondent to the extent necessary to receive, view, acknowledge, respond to, cancel, close, or otherwise manage the relevant SOS Alert or SOS Event in accordance with the functionality of the Services.
2. 5.1.2. Notification Delivery Providers. The Company may transfer Personal Data to providers that support the delivery of notifications and communications through the App, including push notification providers, SMS providers, and email delivery providers, such as Apple Push Notification service, Google Firebase Cloud Messaging, OneSignal, Twilio, Resend, and/or other providers used by the Company for such purposes, to the extent necessary for the sending, delivery, administration, troubleshooting, and support of alerts, SOS Alerts, Critical Alerts, Fallback Notifications, and other service-related communications.
3. 5.1.3. Cloud Storage Providers. The Company may transfer Personal Data to cloud and hosting providers, including AWS S3 and/or other cloud, hosting, storage, infrastructure, or backend providers used by the Company, to the extent necessary for the storage, hosting, transmission, backup, protection, and technical processing of media files, SOS Event Data, SOS Event history, geolocation data shared during an SOS Event, event logs, notification-related records, and other data related to the operation of the App and provision of the Services. Such transfers may also include child-related data, alert-related content, SOS Event records, media files, event logs, and data relating to parental permissions and child-related service administration, where applicable and necessary for the operation of the App and the provision of the Services.
4. 5.1.4. Analytics Providers. The Company may transfer Personal Data and technical data to analytics, diagnostics, and performance providers, including PostHog, Firebase, and/or other providers used by the Company for such purposes, to the extent necessary to analyze the use of the App, monitor performance, troubleshoot issues, improve functionality, and develop the SOS Button and the Services.
5. 5.1.5. Payment Service Providers, Banks, and Financial Institutions. Where payment for the Services is made through the App and/or in connection with the Services, the Company may transfer Personal Data to payment service providers, banks, app store payment systems, subscription management providers, and/or other financial institutions to the extent necessary for payment processing, subscription management, renewals, refunds, transaction administration, and related financial operations. Such transfers may also include limited data necessary for billing verification, fraud prevention, payment-related security measures, chargeback handling, and compliance with applicable financial and legal obligations.
6. 5.1.6. Contractors and Service Providers. The Company may transfer Personal Data to contractors, consultants, advisors, and other service providers engaged by the Company to support the operation of the App, provision of the Services, technical support, infrastructure, security, incident investigation, troubleshooting of SOS Alert delivery issues, abuse prevention, legal compliance, accounting, audit, and other related business functions, to the extent such transfer is necessary and permitted by applicable law. This may include contractors and service providers supporting child-related service administration, parental consent or authorization management, data protection compliance, safeguarding-related measures, and the lawful administration and support of SOS Alerts, SOS Events, Critical Alerts, and Fallback Notifications.
7. 5.1.7. Corporate Transactions. The Company may disclose and/or transfer Personal Data in connection with an actual or potential merger, acquisition, reorganization, restructuring, financing transaction, sale of assets, transfer of business, joint venture, bankruptcy, or similar corporate transaction, subject to applicable law. Any such disclosure and/or transfer shall be subject to appropriate confidentiality, security, and data protection measures applicable to the relevant transaction.
8. 5.1.8. Courts, Authorities, and Law Enforcement. The Company may disclose and/or transfer Personal Data, including SOS Event Data where applicable, to courts, law enforcement authorities, regulatory authorities, public bodies, and/or other competent authorities where such disclosure is required by applicable law, court order, legal process, lawful request, and/or where necessary for the establishment, exercise, or defense of legal claims, protection of rights, investigation of violations, or response to threat-to-life situations. Such disclosure may also include disclosure relating to the protection of a Child User, compliance with legal obligations relating to children’s data, or safeguarding-related matters, where permitted or required by applicable law.
9. 5.1.9. Protection of Rights, Safety, and Legitimate Interests. The Company may disclose and/or transfer Personal Data where such disclosure is necessary to protect the rights, property, safety, and legitimate interests of the Company, Users, and/or Third Parties, including in situations involving fraud, abuse of the App, security incidents, false alerts, repeated false SOS activations, misuse of SOS Alerts, abuse of Critical Alerts, unauthorized use of geolocation data or media files, repeated violations, and/or other misuse of the Services. This may also include situations involving child safety, safeguarding concerns, emergency-related circumstances, or the protection of a Child User and/or Parent / Legal Guardian, to the extent permitted by applicable law.

5.2. Where the Company uses service providers, contractors, or other recipients located outside the country from which Personal Data is accessed or processed, including where relevant outside the European Economic Area, the Company may transfer Personal Data relating to a User, Child User, and/or Parent / Legal Guardian only to the extent necessary for the operation of the App and the specific functionality concerned, including notifications, SOS Alerts, Critical Alerts, Fallback Notifications, cloud hosting or storage, analytics, diagnostics, technical support, payment processing, fraud prevention, security, abuse prevention, and child-related service administration. In such cases, the Company shall ensure that the relevant transfer is based on a lawful transfer mechanism under applicable law and that safeguards appropriate to the nature of the data are applied.

5.3. The Company seeks to ensure that recipients of Personal Data process only the categories of Personal Data that are necessary for the relevant service or function and do not access or use such data beyond what is required for the provision, support, security, compliance, or lawful administration of the Services. In particular, where the transferred data relates to a Child User and/or Parent / Legal Guardian, the Company applies a need-to-know approach, role-based access limitations, and safeguards appropriate to the sensitivity and context of such data, including in connection with SOS Alerts, SOS Events, location-related functionality, media content, parental permissions, child-related requests, and safeguarding-related matters.

6. User consent

6.1. Where the processing of Personal Data is based on Consent, the User provides voluntary, informed, specific, and unambiguous Consent to such processing by performing one or more of the following actions through the App:

1. 6.1.1. creating an Account and confirming acceptance of this Privacy Policy through the relevant checkbox and/or other equivalent technical method made available in the App during registration;
2. 6.1.2. providing Personal Data, completing or updating profile information, uploading media files, enabling geolocation and/or location-related permissions, enabling notification permissions, including permissions necessary for the background delivery of SOS Alerts where applicable, and/or otherwise using functionality of the App where the relevant processing is based on Consent;
3. 6.1.3. enabling optional features, settings, permissions, and/or communications in the App that require Consent, including, where applicable, marketing communications and/or other non-mandatory processing;
4. 6.1.4. confirming Consent through another technical method made available by the Company, including through in-app notifications, interface controls, device permissions, system permission prompts, email confirmation, and/or other equivalent affirmative action, where applicable.

6.2. The App may request access to notifications, including permissions necessary for the background delivery of SOS Alerts, for the User’s safety and for the purpose of enabling SOS Alerts to be sent, received, displayed, and acted upon in connection with the Services. Such permissions are intended to support the delivery of SOS Alerts even where the App is not actively open on the device, subject to the relevant device settings, operating system limitations, permissions granted by the User, and the technical availability of the relevant functionality.

6.3. The Company may request that the User renew, update, and/or reconfirm Consent where required by applicable law, where the scope or purpose of processing materially changes, where new functionality is introduced, and/or where such reconfirmation is otherwise necessary for the lawful provision of the Services.

6.4. If the Company updates this Privacy Policy, the Company may notify the User in the App and/or by other available means. Continued use of the SOS Button and the Services after such update may constitute acknowledgement of the updated Privacy Policy to the extent permitted by applicable law. Where Consent is required by applicable law, the Company shall request such Consent through a separate affirmative action before the relevant processing is carried out.

7. Parental consent

7.1. Where the processing of Personal Data relating to a Child User is based on Consent and/or where authorization from a Parent / Legal Guardian is required under applicable law, such Consent and/or authorization shall be provided by the Parent / Legal Guardian in a voluntary, informed, specific, and unambiguous manner by performing one or more of the following actions through the App and/or by other means made available by the Company:

1. 7.1.1. creating, registering, managing, confirming, and/or maintaining an Account in connection with a Child User;
2. 7.1.2. confirming acceptance of this Privacy Policy, the Terms, and/or other applicable documents through the relevant checkbox, confirmation field, interface control, and/or other equivalent technical method made available by the Company during registration, onboarding, activation of child-related functionality, and/or subsequent use of the Services;
3. 7.1.3. providing, confirming, updating, and/or submitting Personal Data, permissions, settings, requests, declarations, and/or other information relating to the Child User, including where such actions are necessary for the use of child-related features, SOS Alerts, notifications, geolocation and/or location-related functionality, notification permissions necessary for the background delivery of SOS Alerts where applicable, media sharing, response activity, and/or other functionality of the App;
4. 7.1.4. granting, enabling, confirming, and/or maintaining permissions, device settings, geolocation and/or location-related permissions, notification permissions, including permissions necessary for the background delivery of SOS Alerts and, where available, Critical Alerts, communication options, and/or other child-related or parent-controlled functionality made available through the App;
5. 7.1.5. confirming Parental Consent through another technical or organizational method made available by the Company, including through in-app notifications, interface controls, device permissions, system permission prompts, email confirmation, identity and/or authority verification steps, support communications, and/or other equivalent affirmative action, where applicable.

7.2. The App may request access to notifications, including permissions necessary for the background delivery of SOS Alerts and, where available, Critical Alerts, for the safety of the Child User and for the purpose of enabling SOS Alerts relating to the Child User to be sent, received, displayed, and acted upon in connection with the Services. Such permissions are intended to support the delivery of SOS Alerts even where the App is not actively open on the relevant device, subject to the relevant device settings, operating system limitations, permissions granted or managed by the Parent / Legal Guardian and/or the User, and the technical availability of the relevant functionality.

7.3. The Company may request that the Parent / Legal Guardian provide, renew, update, reconfirm, and/or verify Parental Consent and/or parental authority where required by applicable law, where the scope, purpose, or functionality of the relevant processing materially changes, where new child-related functionality is introduced, where there is reason to verify the validity of previously provided Consent or authority, and/or where such reconfirmation or verification is otherwise necessary for the lawful provision of the Services.

7.4. The Company may also request information, declarations, and/or documents reasonably necessary to confirm that the person providing Parental Consent has the legal right to act on behalf of the Child User under applicable law. Where the Company is unable to verify Parental Consent, parental authority, and/or the lawfulness of the relevant use of the Services in relation to a Child User, the Company may restrict, suspend, or refuse access to the relevant child-related functionality and/or the relevant part of the Services until the required confirmation is provided.

7.5. If the Company updates this Privacy Policy, the Company may notify the Parent / Legal Guardian in the App and/or by other available means. Continued use of the SOS Button and the Services in relation to a Child User after such update may constitute acknowledgement of the updated Privacy Policy to the extent permitted by applicable law. Where Parental Consent is required by applicable law for the relevant processing, the Company shall request such Parental Consent through a separate affirmative action before the relevant processing is carried out.

8. Personal data storage and Protection

8.1. The Company uses appropriate technical and organizational measures to protect Personal Data, ensure its confidentiality, and prevent loss, unauthorized access, or unlawful disclosure, including with due regard to the nature of the Services and the risks associated with the processing of Personal Data of Child Users.

8.2. The Company protects Personal Data against: loss; unauthorized access or use; unlawful transfer or disclosure; alteration; deletion; and destruction.

8.3. The Company may use, in particular, the following measures (including those aligned with Article 32 GDPR, where applicable):

1. 8.3.1. pseudonymization and, where appropriate, encryption of Personal Data;
2. 8.3.2. measures to ensure ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
3. 8.3.3. regular testing, assessment, and evaluation of the effectiveness of technical and organizational security measures;
4. 8.3.4. access controls and role-based access restrictions;
5. 8.3.5. logging and monitoring of access to systems and Personal Data, where applicable;
6. 8.3.6. measures designed to minimize the amount of Personal Data processed and retained;
7. 8.3.7. additional safeguards applicable to the processing of Personal Data of Child Users, where required or appropriate under applicable law.

8.4. Storage Location: the Company stores and processes Personal Data using servers and infrastructure providers located in Germany, including Hetzner and DigitalOcean. Where Personal Data is stored or otherwise processed using service providers or infrastructure located in other jurisdictions, the Company shall ensure that such storage and processing are carried out in accordance with applicable law and subject to appropriate safeguards, where required.

8.5. Deletion Requests: where the User, Child User, and/or Parent / Legal Guardian, as applicable, exercises the right to erasure under applicable law (including Article 17 GDPR, where applicable), the Company will delete the relevant Personal Data unless retention is required or permitted by law (for example, for legal compliance, security, fraud prevention, or the establishment, exercise, or defense of legal claims).

8.6. Retention Period: the Company may retain Personal Data for up to 3 (three) years after termination of the relationship with the User, or, where applicable, after the end of the relevant relationship with the Child User and/or Parent / Legal Guardian, to the extent necessary:

1. 8.6.1. to comply with applicable legal obligations;
2. 8.6.2. to ensure security, prevent fraud and abuse, and enforce the Company’s terms and policies;
3. 8.6.3. to investigate incidents, prevent misuse of the Services, repeated false alerts, unauthorized use, or other suspicious activity;
4. 8.6.4. to establish, exercise, or defend legal claims;
5. 8.6.5. to maintain business records and internal accounting;
6. 8.6.6. to create aggregated and/or anonymized statistics, where applicable.

8.7. The Company may retain different categories of Personal Data for different periods depending on the category of the relevant Personal Data, the role of the relevant data subject, including a User, Child User, and/or Parent / Legal Guardian, the nature of the Services used, including alerts, SOS Alerts, SOS Events, notifications, geolocation data, media files, event logs, and SOS Event Data, as well as the necessity to ensure the operation and security of the App, investigate incidents, prevent abuse, verify parental authority and consents where applicable, carry out and document compliance measures, including, where applicable, a DPIA (Data Protection Impact Assessment), comply with applicable law, and establish, exercise, or defend legal claims.

8.8. SOS Event Data, including SOS Alert records, Critical Alert-related records, notification status, sending and delivery information, acknowledgement or response information, cancellation or closure information, Fallback Notification information, geolocation data shared during the SOS Event, media files attached to or shared during the SOS Event, technical diagnostic information, and abuse-prevention records, may be retained for the period necessary to provide the Services, maintain SOS Event history, support and troubleshoot SOS Alert delivery, investigate incidents, prevent misuse, document delivery attempts, comply with applicable law, carry out and document compliance measures, including, where applicable, a DPIA (Data Protection Impact Assessment), and establish, exercise, or defend legal claims.

8.9. Where SOS Event Data relates to a Child User, the Company applies appropriate safeguards and retention limitations taking into account the nature of the data, the purposes of processing, the rights and interests of the Child User, the rights and lawful requests of the Parent / Legal Guardian, the necessity to provide the Services, child safety considerations, applicable legal requirements, and the need to carry out and document compliance measures, including, where applicable, a DPIA (Data Protection Impact Assessment).

8.10. The Company may retain records relating to consents, permissions, parental authority, parental confirmations, withdrawals of consent, access requests, deletion requests, restriction requests, objections, and other compliance-related records for the period necessary to demonstrate compliance with applicable law, verify the lawfulness of the relevant processing, carry out and document compliance measures, including, where applicable, a DPIA (Data Protection Impact Assessment), and establish, exercise, or defend legal claims.

8.11. Upon expiry of the applicable retention period, the Company shall delete, anonymize, or otherwise securely dispose of the relevant Personal Data, unless continued retention is necessary in connection with the provision of the Services, unresolved incidents, fraud prevention, abuse prevention, security, protection of the rights and safety of the Company, Users, Child Users, Parent / Legal Guardians, and/or Third Parties, compliance with applicable law, documentation of compliance measures, including, where applicable, a DPIA (Data Protection Impact Assessment), or the establishment, exercise, or defense of legal claims.

9. Grounds for personal data processing

9.1. The Company processes Personal Data based on one or more legal grounds, as applicable:

1. 9.1.1. the User’s Consent, where such Consent is required under applicable law for specific processing activities, including, where applicable, enabling optional features, communications, geolocation or location-related functionality, media access, notification permissions, Critical Alerts, background delivery of SOS Alerts, marketing communications, or other processing that requires Consent;
2. 9.1.2. necessity to provide the Services and administer the Account, including registration, authentication, account administration, profile management, communication between Users, designation and management of Initiators and Respondents, creation and administration of SOS Alerts and SOS Events, sending and receiving of alerts and notifications, processing of SOS Event Data, display of SOS Event history, transmission of geolocation data and media files through the App, and performance of the Company’s obligations to the User;
3. 9.1.3. necessity to provide SOS Alert functionality and related safety functionality of the Services, including creating, sending, delivering, displaying, acknowledging, cancelling, closing, supporting, troubleshooting, and documenting SOS Alerts and SOS Events, processing notification-related data, enabling Critical Alerts where available and authorized, enabling background delivery of SOS Alerts where applicable, and using Fallback Notifications where the primary notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective;
4. 9.1.4. necessity to process geolocation data and location-related data for the provision of the Services, including transmitting the Initiator’s location to the Respondent, providing location updates during an active SOS Event, displaying location-related information within the App, maintaining SOS Event history where applicable, and supporting safety-related functionality enabled by the User;
5. 9.1.5. necessity to process media files uploaded, recorded, transmitted, or otherwise shared through the App, including media files shared in connection with an SOS Event, for the purposes of providing the Services, transmitting such media files to the relevant Respondent, maintaining SOS Event history where applicable, providing technical support, ensuring security, and protecting rights and safety;
6. 9.1.6. the Company’s legitimate interests, including operating, maintaining, securing, supporting, troubleshooting, and improving the App and the Services, ensuring the reliability and security of SOS Alert delivery, preventing fraud, abuse, misuse of alerts, spam, repeated false activations, unauthorized use, security incidents, and other violations, enforcing the Company’s policies, maintaining audit and technical records, conducting internal analytics and diagnostics, and protecting the Company’s rights and legitimate interests, provided that such interests are not overridden by the User’s rights and freedoms;
7. 9.1.7. necessity to protect the vital interests, rights, safety, property, and legitimate interests of the User, other Users, Respondents, Child Users where applicable, Parent / Legal Guardians where applicable, and/or Third Parties, including in connection with SOS Alerts, SOS Events, threat-to-life situations, safety-related communications, security incidents, misuse of the Services, and other circumstances where processing may be necessary for safety-related or child-protection purposes;
8. 9.1.8. compliance with applicable law, including responding to lawful requests from competent authorities, complying with regulatory requirements, data protection requirements, accounting and tax obligations, consumer protection requirements, payment-related obligations, and other legal obligations of the Company;
9. 9.1.9. necessity to establish, exercise, or defend legal claims, protect the rights, safety, property, and legitimate interests of the Company, Users, Respondents, Child Users where applicable, Parent / Legal Guardians where applicable, and/or Third Parties, including in connection with investigations, disputes, complaints, security incidents, abuse prevention, false alerts, misuse of SOS Alerts, payment disputes, and threat-to-life situations;
10. 9.1.10. necessity for the Company’s legitimate business needs in connection with subscription administration, payments, renewals, refunds, billing verification, fraud prevention, chargebacks, corporate transactions, including a merger, acquisition, financing, reorganization, sale of assets, transfer of business, or bankruptcy, subject to applicable law and appropriate safeguards.

9.2. Where processing is based on the User’s Consent, the User may withdraw such Consent at any time by emailing: info@buttonsos.com. Withdrawal of Consent does not affect the lawfulness of processing carried out before the withdrawal. If the User withdraws Consent for processing that is strictly necessary to provide the Services, the Company may be unable to continue providing the Services and may terminate or restrict access to the Services. The Company will stop the relevant processing without undue delay and, in any case, within 15 (fifteen) business days from the date the Company verifies and records the withdrawal request, unless a longer period is permitted or required by applicable law.

10. Grounds for processing personal data of child users

10.1. The Company processes Personal Data of Child Users based on one or more legal grounds, as applicable:

1. 10.1.1. the Parent / Legal Guardian’s Consent, where such Consent is required under applicable law for specific processing activities relating to a Child User, including, where applicable, enabling child-related functionality, geolocation or location-related functionality, notification permissions, Critical Alerts, permissions necessary for the background delivery of SOS Alerts, media access, communication options, and other processing that requires Consent or authorization of the Parent / Legal Guardian;
2. 10.1.2. the Child User’s Consent, where permitted under applicable law and where the Child User has reached the minimum age required under applicable law for providing such Consent in connection with the Services;
3. 10.1.3. necessity to provide the Services and administer child-related functionality of the App, including registration, authentication, account administration, communication between Users, designation and management of Initiators and Respondents, creation and administration of SOS Alerts and SOS Events in connection with a Child User, sending and receiving of alerts and notifications, processing of SOS Event Data, display of SOS Event history, transmission of geolocation data and media files through the App, and performance of the Company’s obligations in relation to the Services;
4. 10.1.4. necessity to provide SOS Alert functionality and related safety functionality in connection with a Child User, including creating, sending, delivering, displaying, acknowledging, cancelling, closing, supporting, troubleshooting, and documenting SOS Alerts and SOS Events, processing notification-related data, enabling Critical Alerts where available and authorized, enabling background delivery of SOS Alerts where applicable, and using Fallback Notifications where the primary notification channel is unavailable, delayed, not acknowledged, or otherwise ineffective;
5. 10.1.5. necessity to process geolocation data and location-related data in connection with a Child User for the provision of the Services, including transmitting the Child User’s or relevant Initiator’s location to the Respondent, providing location updates during an active SOS Event, displaying location-related information within the App, maintaining SOS Event history where applicable, and supporting safety-related functionality enabled or authorized in accordance with the functionality of the Services;
6. 10.1.6. necessity to process media files uploaded, recorded, transmitted, or otherwise shared through the App in connection with a Child User, including media files shared in connection with an SOS Event, for the purposes of providing the Services, transmitting such media files to the relevant Respondent, maintaining SOS Event history where applicable, providing technical support, ensuring security, and protecting rights and safety;
7. 10.1.7. the Company’s legitimate interests, including operating, maintaining, securing, supporting, troubleshooting, and improving the App and the Services, ensuring the reliability and security of SOS Alert delivery, preventing fraud, abuse, misuse of alerts, spam, repeated false activations, unauthorized use, security incidents, and other violations, enforcing the Company’s policies, maintaining audit and technical records, conducting internal analytics and diagnostics, implementing child-related safeguards, and protecting the Company’s rights and legitimate interests, provided that such interests are not overridden by the rights and freedoms of the Child User;
8. 10.1.8. necessity to protect the vital interests, rights, safety, property, and legitimate interests of the Child User, Users, Respondents, Parent / Legal Guardians, and/or Third Parties, including in connection with SOS Alerts, SOS Events, threat-to-life situations, safety-related communications, safeguarding concerns, security incidents, misuse of the Services, false alerts, and other circumstances where processing may be necessary for safety-related or child-protection purposes;
9. 10.1.9. compliance with applicable law, including responding to lawful requests from competent authorities, complying with regulatory, child-protection, safeguarding, data protection, accounting, tax, consumer protection, payment-related, and other legal obligations of the Company;
10. 10.1.10. necessity to verify, document, and manage parental authority, Parental Consent, permissions, confirmations, withdrawals of consent, child-related requests, access requests, deletion requests, restriction requests, objections, and other actions relating to the Child User’s Personal Data and use of the Services;
11. 10.1.11. necessity to carry out and document data protection, child-safety, safeguarding, and compliance measures, including, where applicable, a DPIA (Data Protection Impact Assessment), security reviews, internal accountability records, and other measures relating to the lawful processing of Personal Data of Child Users;
12. 10.1.12. necessity to establish, exercise, or defend legal claims, protect the rights, safety, property, and legitimate interests of the Company, Child Users, Users, Respondents, Parent / Legal Guardians, and/or Third Parties, including in connection with investigations, disputes, complaints, security incidents, abuse prevention, false alerts, misuse of SOS Alerts, parental authority disputes, child-related requests, payment disputes, and threat-to-life situations.

10.2. Where the App requests device-level permissions in connection with a Child User, including notification permissions, permissions necessary for the background delivery of SOS Alerts, Critical Alert permissions where available, geolocation or location-related permissions, media access permissions, or other system permissions, such permissions are requested to enable the relevant functionality of the App and do not limit the Company’s obligation to rely on an appropriate legal ground for the processing of Personal Data under applicable law. If the Parent / Legal Guardian, Child User where applicable, or relevant User does not grant, withdraws, disables, or limits such permissions, the Company may be unable to provide the relevant functionality of the Services in full, including SOS Alert delivery.

10.2. Where processing is based on the Consent of the Parent / Legal Guardian and/or, where permitted under applicable law, the Child User, such Consent may be withdrawn at any time by emailing: info@buttonsos.com. Withdrawal of Consent does not affect the lawfulness of processing carried out before the withdrawal. After withdrawal of Consent, the Company will stop the relevant Consent-based processing without undue delay and, in any case, within 15 (fifteen) business days from the date the Company verifies and records the withdrawal request, unless a longer period is permitted or required by applicable law.

10.2. Withdrawal of Consent does not prevent the Company from continuing to process Personal Data of a Child User where such processing is based on another applicable legal ground, including necessity to provide the Services, compliance with applicable law, legitimate interests, protection of rights and safety, child-safety or safeguarding purposes, fraud and abuse prevention, security, verification or documentation of parental authority, or the establishment, exercise, or defense of legal claims.

10.2. If the Parent / Legal Guardian and/or, where permitted under applicable law, the Child User withdraws Consent, disables device-level permissions, or otherwise limits access to data or functionality that is necessary for certain features of the Services, the Company may be unable to provide the relevant functionality in full, including SOS Alert delivery, Critical Alert delivery where available, background delivery of SOS Alerts, geolocation sharing, media sharing, Fallback Notifications, child-related functionality, or other safety-related functionality of the App.

11. User Rights

11.1. This section of the Privacy Policy governs the processing of Personal Data belonging to Users, Child Users, and, where applicable, Parents / Legal Guardians in connection with the Services, who are residents of the member states of the European Economic Area (EEA), in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR). The processing of such Personal Data is carried out on lawful grounds and in compliance with the principles of lawfulness, transparency, proportionality, purpose limitation, and data minimization as set forth by the GDPR.

11.2. When processing Personal Data, the Company recognizes and facilitates the exercise of the following rights of the User and, where applicable, the Child User and/or Parent / Legal Guardian in relation to the Personal Data processed through the App:

1. 11.2.1. Right of access (Article 15 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right to obtain access to the Personal Data processed by the Company, as well as to receive the information provided for in Article 15 GDPR.
2. 11.2.2. Right to rectification (Article 16 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right to request the correction, update, or completion of inaccurate or incomplete Personal Data in accordance with Article 16 GDPR.
3. 11.2.3. Right to erasure (Article 17 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right to request the deletion of the relevant Personal Data. In such a case, the Data will be permanently deleted in accordance with Article 17 GDPR, unless legal exceptions apply.
4. 11.2.4. Right to restriction of processing (Article 18 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right to request restriction of the processing of the relevant Personal Data in the cases provided for by Article 18 GDPR.
5. 11.2.5. Right to data portability (Article 20 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right to receive the relevant Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another controller or request its direct transmission to a third party, where technically feasible, pursuant to Article 20 GDPR.
6. 11.2.6. Right to object (Article 21 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right to object at any time to the processing of the relevant Personal Data on grounds relating to the relevant person’s particular situation, pursuant to Article 21 GDPR.
7. 11.2.7. Automated individual decision-making, including profiling (Article 22 GDPR). The User and, where applicable, the Child User and/or Parent / Legal Guardian acting in relation to the Child User, has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning the relevant person or similarly significantly affects such person, as set forth in Article 22 GDPR.

11.3. Where Personal Data of a Child User is processed, the rights relating to such Personal Data may be exercised by the Parent / Legal Guardian on behalf of the Child User to the extent permitted under applicable law. The Company has the right to request information and/or documents necessary to verify the identity of the requesting person, the existence of parental authority or other lawful authority, and the relationship to the Child User before taking action on such request.

11.4. Where permitted under applicable law and taking into account the age, status, and rights of the Child User, the Company may also consider requests submitted directly by the Child User in relation to such Child User’s Personal Data.

11.5. The Company may refuse, limit, or defer action on a request to the extent such refusal, limitation, or deferral is permitted or required under applicable law, including where the Company is unable to verify the identity or authority of the requesting person, where retention of the relevant Personal Data is required for compliance with applicable law, protection of rights and safety, fraud prevention, security, safeguarding-related purposes, or the establishment, exercise, or defense of legal claims.

12. User Rights (USA)

12.1. This section of the Privacy Policy regulates the procedure for processing personal data of Users, Child Users, and, where applicable, Parents / Legal Guardians acting in relation to a Child User, who are residents of the United States of America, taking into account the requirements of the legislation of individual U.S. states on the protection of personal information, including, where applicable, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).

12.2. This section applies to Users, Child Users, and, where applicable, Parents / Legal Guardians acting in relation to a Child User, who are residents of the United States of America. Within the framework of applicable legislation, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), the following rights may be exercised in relation to the relevant Personal Data:

1. 12.2.1. Right of access. The User, Child User, and/or Parent / Legal Guardian, as applicable, has the right to request information regarding which Personal Data about the relevant person is stored by the Service, as well as to learn about the purpose of its processing, its source, and the categories of third parties to whom it may have been disclosed.
2. 12.2.2. Right to deletion. The User, Child User, and/or Parent / Legal Guardian, as applicable, has the right to request deletion of the relevant Personal Data, except in cases where its retention is necessary under applicable law.
3. 12.2.3. Right to rectification. The User, Child User, and/or Parent / Legal Guardian, as applicable, has the right to update, change, or supplement inaccurate or incomplete Personal Data stored by the Service.
4. 12.2.4. Right to data portability. The User, Child User, and/or Parent / Legal Guardian, as applicable, has the right to receive a copy of the relevant Personal Data in a commonly used machine-readable format and to transfer this data to another service provider upon request, where applicable under relevant law.
5. 12.2.5. Right to object. The User, Child User, and/or Parent / Legal Guardian, as applicable, may object at any time to the processing of the relevant Personal Data, including for marketing or analytical purposes, to the extent such right is provided under applicable law.
6. 12.2.6. Right to withdraw Consent. The User and/or Parent / Legal Guardian, as applicable, has the right to withdraw previously given consent to the processing of Personal Data. In such a case, the Services reserves the right to discontinue the provision of Services to the extent the relevant processing is necessary for such Services.
7. 12.2.7. Right to opt out of sale or sharing of Personal Data. Where applicable under the relevant U.S. state privacy law, the User, Child User, and/or Parent / Legal Guardian, as applicable, may have the right to opt out of the sale or sharing of the relevant Personal Data.
8. 12.2.8. Right to limit the use of sensitive personal information. Where applicable under the relevant U.S. state privacy law, the User, Child User, and/or Parent / Legal Guardian, as applicable, may have the right to request limitation of the use and disclosure of sensitive personal information to the extent provided by applicable law.
9. 12.2.9. Right to opt out of sale or sharing of Personal Data. The User, Child User, and/or Parent / Legal Guardian, as applicable, has the right not to be unlawfully discriminated against for exercising privacy rights provided by applicable U.S. state privacy laws.

12.3. Where Personal Data of a Child User is processed, the rights relating to such Personal Data may be exercised by the Parent / Legal Guardian on behalf of the Child User to the extent permitted under applicable law. The Company may request information and/or documents necessary to verify the identity of the requesting person, the existence of parental authority or other lawful authority, and the relationship to the Child User before taking action on such request.

12.4. The Company may refuse, limit, or defer action on a request to the extent such refusal, limitation, or deferral is permitted or required under applicable law, including where the Company is unable to verify the identity or authority of the requesting person, where retention of the relevant Personal Data is required for compliance with applicable law, protection of rights and safety, fraud prevention, security, safeguarding-related purposes, or the establishment, exercise, or defense of legal claims.

13. Submission of Request

13.1. A User, Child User, and/or Parent / Legal Guardian, as applicable, in any jurisdiction has the right to submit a request to the Company if such person believes that his, her, or the Child User’s rights have been violated, by sending a written request to the Company’s support service at: info@buttonsos.com

13.2. The request must contain sufficient and accurate information regarding the identity of the requesting person, the nature of the request, the Personal Data concerned, and the action requested from the Company. If the request does not contain sufficient or accurate information, the Company has the right to request clarification and/or additional information reasonably necessary to process the request.

13.3. The Company will not be able to respond to a request or provide access to Personal Data unless it is able to verify the identity of the requesting person and, where applicable, confirm that such person is authorized to act in relation to the relevant Personal Data, including in relation to a Child User. In the event of inaccurate information, inability to verify identity, inability to verify parental authority or other lawful authority, or failure to provide the information reasonably requested for verification, the Company has the right not to process the request until the relevant deficiencies are remedied.

13.4. Where a request concerns the Personal Data of a Child User, the Company has the right to request information and/or documents reasonably necessary to verify the identity of the requesting person, the existence of parental authority or other lawful authority, and the relationship to the Child User before taking action on such request.

13.5. Where a request concerns SOS Event Data, geolocation data, media files, notification-related data, response activity, Fallback Notification data, or other Personal Data that may also relate to another User, Respondent, Child User, Parent / Legal Guardian, or Third Party, the Company may limit, redact, refuse, or defer disclosure or other action to the extent necessary to protect the rights, freedoms, privacy, safety, and legitimate interests of such other persons, or where retention of the relevant Personal Data is required or permitted for the provision of the Services, unresolved SOS Events, security, fraud prevention, abuse prevention, safeguarding-related purposes, compliance with applicable law, documentation of compliance measures, or the establishment, exercise, or defense of legal claims.

13.6. If the Company requests clarification or additional information in relation to a request, the requesting person must provide a corrected or updated request, or otherwise provide the requested clarification or information necessary for the Company to process the request.

13.7. The Company shall respond to the request and/or take the action required under applicable law without undue delay and, in any event, within the period required by applicable law, provided that the Company has received sufficient information to process the request and, where applicable, completed the necessary verification of identity and authority.

14. Reponsibility

14.1. The Company takes reasonable technical, organizational, and administrative measures to protect Personal Data against unauthorized or unlawful access, collection, use, disclosure, alteration, loss, destruction, and/or other unlawful processing, taking into account the nature of the Personal Data and the risks associated with its processing, including the risks associated with the processing of Personal Data of Child Users.

14.2. The User and, where applicable, the Child User and/or Parent / Legal Guardian, is responsible for the accuracy, completeness, and lawfulness of the Personal Data, media files, geolocation data, location data, alerts, notifications, SOS Alerts, SOS Event Data, consents, permissions, confirmations, and/or other information provided, uploaded, transmitted, and/or otherwise shared through the App.

14.3. The User and, where applicable, the Parent / Legal Guardian, is solely responsible for ensuring that any Personal Data relating to another User, Child User, Parent / Legal Guardian, and/or any Third Party, including contact details, geolocation data, location data, media files, SOS Event Data, and/or other information, is provided, uploaded, transmitted, and/or otherwise shared through the App on a lawful basis and in accordance with applicable law, including where such data is provided in relation to a Child User or where the use of the Services requires parental authority, consent, permission, or other lawful basis.

14.4. The Company does not verify the identity, background, qualifications, reliability, availability, reaction, and/or actions of any Initiator, Respondent, Parent / Legal Guardian, and/or other User and does not guarantee that any alert, SOS Alert, Critical Alert, Fallback Notification, notification, geolocation data, location data, media file, SOS Event Data, and/or other communication will be sent, delivered, displayed, received, viewed, acknowledged, responded to, or acted upon by the relevant User, Respondent, or other recipient.

14.5. The Respondent is not an employee, contractor, representative, agent, emergency responder, rescue service, medical provider, law enforcement authority, and/or other controlled person of the Company. The Company does not appoint, engage, train, supervise, monitor, and/or control the Respondent and does not assume responsibility for the actions, omissions, failure to respond, delayed response, inadequate response, and/or any consequences of the Respondent’s behavior.

14.6. The App and the Services are not an emergency response, rescue, medical, law enforcement, dispatching, monitoring, or professional response service and do not replace emergency services, emergency numbers, hotlines, rescue services, medical services, law enforcement authorities, or other competent emergency or public safety authorities. The Company does not provide emergency intervention, rescue, medical assistance, law enforcement response, dispatching, monitoring, or professional response services through the App.

14.7. Where the Services are used in connection with a Child User, the Company does not assume responsibility for supervising family relations, verifying the actual relationship between the Child User and the Parent / Legal Guardian in every case, assessing the appropriateness of any parental instruction, permission, consent, confirmation, or request, or determining whether a specific person should be designated as an Initiator, Respondent, Parent / Legal Guardian, or other contact, except to the extent such verification or action is expressly required under applicable law.

14.8. The Company is not responsible for disputes, conflicts, misunderstandings, claims, damages, losses, and/or other consequences arising between Users, Child Users, Parent / Legal Guardians, and/or Third Parties in connection with the use of the App, including in connection with alerts, SOS Alerts, SOS Events, Critical Alerts, Fallback Notifications, notifications, SOS Event Data, geolocation data, location data, media files, response time, delivery status, acknowledgement status, failure to respond, and/or the interpretation or use of any information transmitted through the SOS Button, as well as any dispute concerning parental authority, child-related permissions, consent, access to a Child User’s data, or the use of the Services in relation to a Child User.

14.9. The Company is not responsible for interruptions, delays, errors, failures, unavailability, and/or incomplete operation of the App or the Services caused by mobile devices, operating systems, internet connectivity, telecommunications networks, geolocation services, cloud infrastructure, notification delivery services, payment service providers, and/or other Third Parties, including cases where the proper operation of the App or the Services depends on such Third Parties or external factors beyond the Company’s reasonable control.

14.10. The Company does not guarantee uninterrupted, error-free, or fully secure operation of the App or the Services and does not guarantee that any alert, SOS Alert, Critical Alert, Fallback Notification, notification, geolocation data, location data, media file, SOS Event Data, or other communication transmitted through the App will be sent, delivered, displayed, received, reviewed, acknowledged, responded to, or acted upon without delay, interruption, technical failure, interference, inaccurate location data, provider failure, device limitation, operating system limitation, disabled permission, or other circumstances beyond the Company’s reasonable control.

14.11. The Company shall not be responsible for any indirect, incidental, consequential, special, punitive, and/or exemplary damages, including loss of data, loss of profit, loss of opportunity, emotional distress, personal injury, and/or other damage arising out of or in connection with the use of the App, the Services, and/or any failure, delay, omission, or inability of any User, Child User, Parent / Legal Guardian, Respondent, and/or other relevant person to send, receive, review, acknowledge, respond to, and/or react to an alert, SOS Alert, SOS Event, Critical Alert, Fallback Notification, or related communication.

14.12. The Company shall not be responsible for unlawful, unauthorized, inaccurate, misleading, incomplete, abusive, fraudulent, or otherwise improper use of the App or the Services by any User, Child User, Parent / Legal Guardian, Respondent, and/or Third Party, including misuse of alerts, misuse of SOS Alerts, abuse of Critical Alerts, repeated false alerts, repeated false SOS activations, misuse of SOS Event Data, misuse of geolocation data, misuse of media files, submission of inaccurate information, use of another person’s data without lawful basis, or use of the Services without the permissions, consents, or authority required under applicable law.

14.13. Nothing in this Privacy Policy shall exclude or limit the Company’s responsibility to the extent such exclusion or limitation is not permitted under applicable law.

14.14. Unfortunately, the transmission of information through the Internet, mobile networks, and/or the App cannot be completely secure. Although the Company makes every effort to protect Personal Data, the Company cannot guarantee the security of the transfer of Personal Data to or through the SOS Button. In this regard, the User, Child User, and/or Parent / Legal Guardian, as applicable, acknowledges and accepts the risks associated with such transmission.

15. Cookies and Similar technologies

15.1. The Company may use Cookies and/or similar technologies in connection with the operation of the App and provision of the Services.

15.2. Since the Services are provided through the App, the Company may use not only Cookies in the traditional browser-based sense, where applicable, but also similar mobile application and device technologies, including device identifiers, local storage, SDKs, push notification tokens, notification-related identifiers, analytics tools, diagnostic tools, crash reporting tools, and other technical identifiers necessary for the operation, security, support, and improvement of the App and the Services.

15.3. Such Cookies and/or similar technologies may be used for the following purposes:

1. 15.3.1. ensuring the operation, stability, security, and technical functionality of the App;
2. 15.3.2. authentication of the User, support of login sessions, and administration of the Account;
3. 15.3.3. enabling, supporting, administering, and troubleshooting the sending, delivery, background delivery, and technical operation of alerts, SOS Alerts, Critical Alerts where available and authorized, Fallback Notifications, push notifications, SMS messages, email notifications, and other service-related communications;
4. 15.3.4. supporting SOS Event functionality, including technical records relating to notification delivery attempts, sending status, delivery status, failure status, acknowledgement or response status, fallback delivery attempts, cancellation or closure status, and other technical events necessary for the operation and support of SOS Alerts and SOS Events;
5. 15.3.5. saving technical settings, language settings, notification settings, permission-related settings, and other User preferences, where applicable;
6. 15.3.6. collecting analytics, performance, diagnostic, crash, and technical usage data in order to analyze the use of the App, troubleshoot technical issues, monitor performance, improve functionality, and develop the SOS Button and the Services, subject to data minimization and applicable safeguards;
7. 15.3.7. protecting the App and the Services against unauthorized access, abuse, misuse, suspicious activity, spam, false activations, repeated false SOS activations, misuse of SOS Alerts, abuse of Critical Alerts, and other security risks;
8. 15.3.8. supporting child-related functionality of the App, including, where applicable, features used in connection with a Child User, Parent / Legal Guardian settings, child-related SOS Alert functionality, and child-related safety and safeguarding measures.

15.4. The use of certain Cookies, SDKs, and/or similar technologies may involve the collection and processing of technical data, device-related data, notification-related data, analytics data, diagnostic data, crash data, IP address, time zone and language settings, push notification tokens, permission-related settings, SOS Event technical records, and other data described in this Privacy Policy, including data relating to the use of the App by or in relation to a Child User and/or Parent / Legal Guardian, where applicable.

15.5. Where such technologies are used for analytics, diagnostics, performance monitoring, or improvement of the App, the Company seeks to limit the processing of SOS Event Data, geolocation data, media files, Child User Data, and other sensitive contextual data to what is strictly necessary for the relevant purpose. Where possible and appropriate, the Company uses aggregated, minimized, pseudonymized, or non-content technical data for analytics and performance purposes. Where such processing involves data relating to a Child User, the Company shall apply appropriate safeguards, data minimisation measures, and access limitations appropriate to the nature of the relevant data and the purposes of the processing.

15.6. Where required by applicable law, the Company shall request the User’s Consent and/or, where applicable, the Consent or authorization of the Parent / Legal Guardian for the use of Cookies, SDKs, and/or similar technologies that are not strictly necessary for the operation of the App, provision of the Services, security of the App, delivery of SOS Alerts, or other essential functionality of the Services.

15.7. The User may manage certain permissions, technical settings, notification settings, device-level controls, and/or operating system controls related to the use of Cookies, SDKs, push notification tokens, device identifiers, local storage, and/or similar technologies through the App, device settings, and/or operating system settings, where such controls are available.

15.8. To the extent Cookies, SDKs, and/or similar technologies are operated by Third Parties, such Third Parties may process relevant data in accordance with their own policies and applicable law, subject to the requirements, safeguards, and restrictions applicable to the relevant Personal Data, including where such data relates to a Child User. The Company seeks to ensure that Third Party SDKs and similar technologies used in connection with the App process only the data necessary for the relevant technical, notification, analytics, diagnostic, security, payment, or service-related purpose.

15.9. In connection with the Website, the Company may use browser-based Cookies and similar technologies to ensure the operation, security, functionality, analytics, diagnostics, performance monitoring, and improvement of the Website, including to make legal documents, informational materials, contact information, support pages, and download links available to Users.

16. Confirm Policy

16.1. The use of certain functionality of the Services may require Consent, permission, confirmation, authorization, or device-level permission from the User and/or, where applicable, the Parent / Legal Guardian. This may include, where applicable, permissions relating to notifications, background delivery of SOS Alerts, Critical Alerts, geolocation and/or location-related functionality, media sharing, communication options, SOS Alert functionality, and other functionality of the App.

16.2. The Services may be used in connection with a Child User, subject to the conditions of this Privacy Policy, the Terms of Use, and applicable law.

16.3. Where the use of the Services by or in relation to a Child User requires the Consent, permission, confirmation, or authorization of a Parent / Legal Guardian under applicable law, such use shall be permitted only where such Consent, permission, confirmation, or authorization has been duly provided.

16.4. The Company may request information and/or documents reasonably necessary to verify the age of the relevant person, the existence of parental authority or other lawful authority, and the lawfulness of the use of the Services by or in relation to a Child User, where such verification is required or permitted under applicable law.

16.5. If the Company becomes aware or has reasonable grounds to believe that the Services are being used by or in relation to a Child User in breach of applicable law, without the required Consent, permission, confirmation, or authorization of a Parent / Legal Guardian, or otherwise in violation of this Privacy Policy or other applicable documents of the Company, the Company has the right to restrict, suspend, or terminate access to the Services, delete the relevant Account, and/or delete the relevant Personal Data, to the extent permitted or required under applicable law.

16.6. If you believe that the Services are being used by or in relation to a Child User in violation of applicable law, without the required parental authority, consent, permission, or other lawful basis, please contact the Company at: info@buttonsos.com

17. Privacy Policy Changes

17.1. The Company has the right to amend, supplement, update, and/or otherwise modify this Privacy Policy from time to time in connection with changes to the Services, the functionality of the App, the operation or functionality of the Website, the categories of Personal Data processed, the purposes or legal grounds for processing, the use of Cookies and similar technologies, data protection practices, security measures, child-related safeguards, applicable law, and/or other circumstances relevant to the provision of the Services.

17.2. Where required by applicable law, the Company shall notify the User, Child User, and/or Parent / Legal Guardian, as applicable, of the updated version of this Privacy Policy through the App and/or by other available means before the relevant changes become effective.

17.3. The User and, where applicable, the Parent / Legal Guardian shall independently review the current version of this Privacy Policy and familiarize themselves with any amendments thereto. The Company shall not be responsible for the failure of the User and/or Parent / Legal Guardian to review the updated version of this Privacy Policy.

17.4. The Company shall indicate the date of the latest update of this Privacy Policy in the relevant line at the top of the document.

17.5. Where required by applicable law, or where the relevant changes affect the lawful basis, scope, or conditions of processing of Personal Data, including the processing of Personal Data of a Child User, the Company may request a renewed Consent, Parental Consent, permission, or confirmation before the relevant changes become applicable.

17.6. The electronic, digital, and/or other version of this Privacy Policy stored by the Company shall be deemed the valid, complete, and enforceable version of this Privacy Policy in effect at the relevant time.

18. Contacts

The User has the right to contact the Company support service at: info@buttonsos.com to ensure his rights, in accordance with the terms of this Privacy Policy, or in case of violation of his rights, or to leave feedback or ask a question.