PRIVACY POLICY

We ask that you carefully read this Privacy Policy, which describes how we use the data you provide us, always in accordance with the requirements of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR), Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights, and other applicable regulations.

Our goal is maximum transparency in the information provided so that you, as the user, can easily understand it. However, if you still have any questions after reading it, you can contact us through the communication channels provided, and we will clarify them for you.

I. RESPONSIBLE FOR THE TREATMENT

The owner responsible for the website “safetroop.com”, as well as the mobile applications developed by Safetroop Technologies, S.L. (among others, the Apps “Connectpol”, “Proximity” and “HORUS”), is the entity:

SAFETROOP TECHNOLOGIES, S.L.
CIF: B44925204
Registered office: Carrer d’Espinoi 8-10 local.1, CP 08023, Barcelona (Spain)
Registered in the Mercantile Registry of Barcelona on June 19, 2023 (T 48829, F 199, S 8, H B 597776, I/A 1)
Contact email: info@safetroop.com

(hereinafter, “SafeTroop”).

II. PRINCIPLES IN ACCORDANCE WITH THE EUROPEAN DATA PROTECTION REGULATION

SafeTroop is committed to processing personal data in accordance with the principles set out in Article 5 of the GDPR:

  • Legality, loyalty and transparency

  • Limitation of purpose

  • Data minimization

  • Accuracy

  • Limitation of the retention period

  • Integrity and confidentiality

  • Proactive responsibility

Personal data will be processed only for specific, explicit and legitimate purposes, and will not be processed in a manner incompatible with those purposes.

III. USER CONSENT

Completing the registration forms, as well as using any of the SafeTroop applications, after express acceptance of this Privacy Policy, implies the user’s unequivocal consent to the automated processing of their personal data in accordance with the conditions described herein.

The consent may be revoked at any time by the interested party, without retroactive effect, through the means made available to him.

In applications that manage emergency services or personal alerts, the processing of certain data will only be activated when the user performs a voluntary and conscious action to activate the alert service.

IV. PURPOSES OF DATA PROCESSING

The personal data provided will be processed for the following purposes:

  • To handle information requests made through the website.

  • Manage the registration, use and maintenance of SafeTroop applications.

  • Manage the contractual, administrative, economic and billing relationship.

  • To guarantee the correct provision of the services offered.

  • To comply with legal obligations and attend to requirements of competent authorities.

  • Improve the quality, safety and operation of services.

Types of data processed

SafeTroop collects two types of information:

a) Non-identifying information:
Technical and statistical data on the use of the website or applications (type of device, operating system, language, date and time of access, browsing, etc.).

b) Personally identifiable information:
Includes, among others:

  • Name and surname

  • Postal address

  • Email address

  • Phone number

  • Geolocation data

  • IP address and device identifiers

  • Data required for the provision of the contracted services

V. SPECIFIC TREATMENTS OF THE HORUS SERVICE (PERSONAL EMERGENCY ALERTS)

The HORUS service is a specific personal alert functionality designed for emergency situations, aimed at users who voluntarily and consciously activate a distress signal from their mobile device.

1. Data specifically processed in HORUS

The following data may only be processed when the user manually activates a HORUS alert:

  • Identifying information: name, surname, address, telephone number and email address.

  • Real-time geolocation data.

  • Audio and video data captured by the microphone and camera of the user’s device.

  • Technical data associated with the communication of the alert.

The activation of these treatments does not occur automatically in any case, nor by the mere use of the application, but only through an express action of the user.

2. Specific purpose of the processing in HORUS

The data will be processed exclusively for:

  • Manage the emergency situation reported by the user.

  • Facilitate the intervention of emergency services, security forces, civil protection or other competent bodies.

  • To allow the immediate location of the user during a risk situation.

  • To guarantee the safety and physical integrity of the user.

3. Legal basis for processing in HORUS

The processing of personal data in the HORUS service is based on:

  • The user’s explicit consent (art. 6.1.a GDPR), manifested by consciously activating the alert.

  • La protección de intereses vitales del interesado o de otras personas físicas (art. 6.1.d RGPD).

  • Where appropriate, the performance of a task carried out in the public interest or the exercise of public powers by the intervening authorities (Art. 6.1.e GDPR).

4. Processing of third-party data

During the activation of a HORUS alert, images or sounds of third parties in the user’s vicinity may be incidentally captured. This processing will be strictly necessary for managing the emergency and will be limited to that purpose.

5. HORUS Data Preservation

Data generated during a HORUS alert will be kept only for the time strictly necessary for the management of the emergency and, where applicable, for the legal retention periods applicable to address legal responsibilities or requirements of competent authorities, subsequently being blocked or deleted in accordance with current regulations.

6. Enhanced security measures and impact assessment

Given the particularly sensitive nature of the data processed in HORUS, SafeTroop has adopted enhanced technical and organizational measures, and has assessed the risks associated with the processing, applying the principles of privacy by design and by default, in accordance with Article 25 of the GDPR.

VI. DATA RETENTION PERIOD

Personal data will be kept for the time necessary to fulfill the purpose for which it was collected and, subsequently, for the applicable legal limitation periods, remaining blocked where appropriate.

VII. LEGITIMATION

The legal basis for processing the data is the user’s consent, without prejudice to other applicable legal bases under the GDPR when processing is necessary to protect vital interests, comply with legal obligations or carry out tasks in the public interest.

VIII. RECIPIENTS

The data will not be transferred to third parties except when legally required or when necessary for the provision of the service, including its communication to State Security Forces and Corps, competent judicial or administrative authorities.

Suppliers acting as data processors will do so under contract in accordance with Article 28 of the GDPR.

IX. DATA PROTECTION RIGHTS

The user may exercise the rights of access, rectification, erasure, objection, limitation and portability by contacting:

info@safetroop.com

You may also file a complaint with the Spanish Data Protection Agency.

X. MINORS

The services are not intended for individuals under 18 years of age. Only those over 14 years of age may give consent, without prejudice to cases where the intervention of legal representatives is legally required.

XI. LEVEL OF SECURITY, CONFIDENTIALITY AND BROKENNESSES

SafeTroop will apply the appropriate technical and organizational security measures to the risk, committing to report any security breach in accordance with current regulations.

XII. VIDEO COMMUNICATIONS AND RECORDINGS (HORUS)

The audio and video communications of the HORUS service are carried out by Zoom Video Communications, Inc., which acts as the data processor, in accordance with its Data Processing Addendum (DPA) and the guarantees required by the GDPR.

International transfers of personal data that may arise from the use of third-party technological platforms, such as Zoom Video Communications, Inc., are carried out in accordance with the provisions of Articles 44 et seq. of Regulation (EU) 2016/679 (GDPR), being covered by the Standard Contractual Clauses approved by the European Commission and, where applicable, by the provider’s adherence to the EU-US Data Privacy Framework, guaranteeing at all times a level of protection essentially equivalent to that required in the European Union.

SafeTroop remains responsible for the processing of personal data derived from the use of the service, with Zoom limited to the technical provision of the communication service.

XIII. INTERNATIONAL DATA TRANSFERS

In the event of transfers outside the European Economic Area, appropriate safeguards will be adopted in accordance with the GDPR.

XIV. RESPONSIBILITY

The user will be responsible for the accuracy of the data provided.

XV. MODIFICATION OF THE PRIVACY POLICY

SafeTroop reserves the right to modify this Privacy Policy in accordance with legal, technical or service changes.