Effective date: 2026-03-04

Data Controller

Tryghedsappen ApS
Suomivej 4
1927 København F
Denmark

CVR: 45 73 31 22

Email: gdpr@tryghedsappen.dk

1. Data Controller

Tryghedsappen ApS is the data controller responsible for personal data processed through the Tryghedsappen mobile application (also marketed as FeelingSafe) and related support services.

UK users: because Tryghedsappen ApS has no UK establishment, you may need to appoint a UK representative under Article 27 UK GDPR. If applicable, the representative’s name and contact details will be published here: [UK Representative – Name, Address, Email].

2. Scope of this Privacy Policy

This policy applies to the Tryghedsappen mobile application, related safety and alarm services, and customer support communications. Subscription management and payments are handled through Apple App Store and Google Play under their separate terms and policies.

3. Categories of Personal Data

We process only the personal data necessary to provide the safety service. This may include account identifiers, email relay address (if provided), emergency contacts entered by you, alarm event data, location data during an active alarm, device/app information, security/authentication data, and customer support communications.

4. Purposes and Legal Basis for Processing

We process personal data for: (A) providing the service – Contract (Art. 6(1)(b) UK GDPR); (B) security and fraud prevention – Legitimate interests (Art. 6(1)(f)); and (C) legal obligations (e.g., accounting) – Legal obligation (Art. 6(1)(c)). We limit logging to what is necessary and do not use analytics or advertising tracking.

5. Location Data

Location data is processed only when you actively trigger an alarm. We do not perform continuous or background location tracking. Location is shared with your selected contacts and may be stored in alarm history for a limited period.

6. Data Retention

Account data while active + up to 24 months after last activity; alarm history up to 6 months; security logs up to 12 months; support communications up to 36 months; accounting/subscription records typically 5 years. Data is deleted or irreversibly anonymised after the retention period unless retention is required by law or for legal claims/defence.

7. Recipients and Data Processors

We use selected service providers under written agreements, including hosting/infrastructure on Google Cloud in EU regions. Apple and Google may act as independent controllers for authentication and payment processing. We do not sell personal data and we do not use analytics or advertising tracking.

8. International Data Transfers

We host data in the EU/EEA. If personal data is transferred outside the UK and/or EU/EEA, we apply appropriate safeguards such as EU SCCs and the UK International Data Transfer Addendum, and assess transfer risks where required.

9. Children

The app is intended for adults only (18+). We do not knowingly collect personal data from children.

10. Your Rights

You have the right to access, rectification, erasure, restriction, objection, and data portability (where applicable). You can exercise your rights by contacting gdpr@tryghedsappen.dk.

11. Security Measures

We implement appropriate technical and organisational measures including encryption in transit (TLS), access control and logging, monitoring and incident response procedures, regular security updates, and confidentiality obligations.

12. Complaints

You may lodge a complaint with the ICO and/or the competent authority where you live, work, or where the alleged infringement occurred.

13. Language Interpretation

This policy may be provided in multiple languages. Each version is intended to convey the same information. In the event of any discrepancy, the version that best reflects the meaning and intent under UK law will prevail.