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SafeCircle Legal Information

Terms

Privacy Policy

Data Controller

Safe Circle ApS, CVR no. 46438302, Bredager 22, 2670 Greve, Denmark.
Contact: privacy@safecircle.dk

What SafeCircle Is

SafeCircle is a digital safety app that helps users activate assistance, share their location, and document incidents via audio and video recordings in unsafe situations. SafeCircle is not a replacement for emergency services. In case of immediate danger, always call 112. Call 112 in an emergency — use 114 to report afterwards with your SafeCircle documentation.

1. Identity and Contact Information

Data: Name, email address, phone number and login credentials.

Purpose: Creating and managing user accounts, verification and communication.

Legal basis: Performance of a contract, cf. GDPR Art. 6(1)(b).

Retention: For the duration of the active account plus 30 days after deletion.

2. Profile Information

Data: Profile photo, emergency contacts and safety settings.

Purpose: Personalisation and correct functioning of SafeCircle, including enabling emergency contacts to receive alerts and location.

Legal basis: Performance of a contract, cf. GDPR Art. 6(1)(b).

Retention: For the duration of the active account.

3. Location Data

Data: (a) Your approximate last known position, updated periodically while the app is open. (b) Your precise GPS position during an active alarm or an active Walk Home journey.

Purpose:

(a) Your last known position is stored so SafeCircle can identify verified members nearby when someone triggers an alarm. The position is used solely to determine who should receive an alarm notification. It is never shown to other users and never displayed on a map.

(b) During an active alarm, your precise position is sent to your own approved emergency contacts, to nearby verified helpers who have been called to your specific alarm, and to the friends you have chosen to be notified. During a Walk Home journey, your position is shared with the people you have chosen as watchers until the journey ends. Your position is only visible to people you have personally selected as recipients for that alarm or journey — not to all your friends.

Legal basis: Performance of contract, cf. GDPR Art. 6(1)(b). Location sharing is the core function of the service and processing is necessary to deliver it. You may stop processing at any time by ending the alarm or journey, by denying location access in your device settings, or by deleting your account.

Retention: Last known position is continuously overwritten and is not stored as history. Live location during an alarm or journey is deleted no later than 24 hours after the alarm or journey ends.

Note: All display of your position to other users is user-initiated and time-limited. It begins when you hold the SOS button for 3 seconds or start a Walk Home journey yourself, and ends automatically when the alarm or journey is closed. The destination address of a Walk Home journey is no longer visible to your watchers once the journey ends. SafeCircle has no function that automatically or continuously shows your position to other users. Location data is shared exclusively with your own pre-approved emergency contacts, friends you have selected, and called SafeCircle helpers. Data is not shared with third parties for marketing or commercial purposes.

4. Audio and Video Recordings

Data: Audio and video material recorded during an active alarm.

Purpose: Documentation of incidents initiated by the user, for their own use and potential use as evidence.

Legal basis: Consent, cf. GDPR Art. 6(1)(a). Recording is actively initiated by the user via the alarm function.

Retention: Stored on an approved, encrypted server and automatically deleted after 48 hours, unless the user actively chooses to retain them.

Access: Recordings are accessible exclusively to the registered user. Recordings are encrypted on your own device before being transmitted, and Safe Circle ApS does not hold any key to decrypt them. Law enforcement may requisition recordings via a lawful authority request in accordance with applicable Danish law.

Server location: Recordings are stored on servers in the EU (Ireland) in accordance with GDPR requirements.

4a. Recording third parties without consent

When SafeCircle activates audio and video recording during an alarm, the recordings may capture the image and voice of persons who are not SafeCircle users and who have not given consent. This section sets out the legal basis for each scenario.

Scenario 1: The user activates an alarm — a perpetrator is recorded

When a user activates an alarm in a situation that constitutes or may constitute a criminal act against them, a situation arises in which a potential perpetrator's interest in not being recorded must be weighed against the user's fundamental right to personal safety and the ability to produce evidence.

Legal basis:

  • Vital interests, cf. GDPR Art. 6(1)(d): Processing is lawful when necessary to protect the vital interests of the data subject or another natural person. A person's physical safety and life are the most fundamental vital interests. This legal basis applies regardless of whether the perpetrator consents.
  • Legitimate interests, cf. GDPR Art. 6(1)(f): The user's (and by extension SafeCircle's) legitimate interest in documenting a criminal act for the purposes of reporting to law enforcement, producing evidence, and legal proceedings clearly outweighs the perpetrator's interest in not being recorded while committing a criminal act. A perpetrator has a significantly reduced expectation of privacy in relation to the specific offence being committed.
  • Legal claims, cf. GDPR Art. 9(2)(f): If the recording contains special categories of data (for example, health-related information visible during a violent incident), processing is permitted when necessary to establish, exercise, or defend a legal claim.
  • Danish Criminal Code §§ 13–14 (self-defence and necessity): Acts that would under normal circumstances constitute an infringement are not punishable when performed in self-defence or out of necessity. Recording a person who is committing a criminal act against one is in principle lawful under the doctrines of self-defence and necessity, as the recording's purpose is to avert harm and secure evidence — not to violate privacy.

Proportionality: Recordings are encrypted, inaccessible to anyone other than the user, automatically deleted after 48 hours, and can only be requisitioned by law enforcement via a lawful authority request. These measures ensure that recordings are not processed beyond what is necessary.

Scenario 2: A helper confirms and arrives on the scene

When a SafeCircle helper chooses to respond to an alarm and arrives at the scene, the helper's activation of their own alarm function may result in the recording of those present — including possible perpetrators, the person in distress, and other witnesses.

Legal basis:

  • Consent from the helper, cf. Art. 6(1)(a): The helper voluntarily activates the alarm and thereby the recording. The helper is the data subject in respect of their own recording.
  • Legitimate interests, cf. Art. 6(1)(f): The helper's and the victim's shared interest in documenting the incident for reporting to law enforcement and use as evidence constitutes a legitimate interest. This interest outweighs third parties' (including the perpetrator's) interest in not being recorded at the scene of a crime.
  • Vital interests, cf. Art. 6(1)(d): The helper has entered a situation that potentially poses a risk to the victim's life. The recording serves to protect vital interests.
  • Danish Criminal Code §§ 13–14: As with the victim scenario, recording an ongoing criminal act is in principle covered by the doctrines of self-defence and necessity, also for a helper who voluntarily and knowingly enters the situation to provide assistance.

Scenario 3: Incidental third parties captured in the background

Audio and video recordings made during an alarm may unintentionally capture incidental third parties — passers-by, witnesses, or others in the vicinity — who have no connection to the incident and are neither perpetrators nor the person in distress.

Legal basis: Legitimate interests, cf. GDPR Art. 6(1)(f), read together with the proportionality assessment. The primary purpose of the recording is to document a safety incident. The presence of incidental background individuals is unintentional and unavoidable in an acute emergency. SafeCircle minimises the risk to these individuals' privacy by encrypting recordings, restricting access to the user alone, and automatically deleting after 48 hours.

Common principles across all recording scenarios

  • Recordings are end-to-end encrypted and accessible only via the user's personal secure link.
  • SafeCircle employees can never access the content of recordings.
  • Recordings are automatically deleted after 48 hours unless the user actively saves them.
  • Law enforcement may only access recordings via a special secure link upon a lawful authority request in accordance with the Danish Administration of Justice Act.
  • Recordings are not used for commercial purposes, marketing, profiling, or disclosure to third parties.

5. Payment Information

Data: Subscription status and transaction confirmations. SafeCircle does not receive or store your card details — payment is processed by Apple (App Store) or Google (Google Play), who act as the legal seller and are responsible for the payment transaction.

Purpose: Subscription administration and payment verification.

Legal basis: Performance of a contract, cf. Art. 6(1)(b), and legal obligation, cf. Art. 6(1)(c) (Danish Bookkeeping Act, § 10).

Retention: 7 years in accordance with section 10 of the Danish Bookkeeping Act.

Note: SafeCircle currently offers 3 months of free access for new users. After this period, the user automatically transitions to a paid subscription (personal or family), unless cancelled before the free period ends. Payment is processed via the App Store or Google Play.

6. Technical Operational Data

Data: Log files, error reports and device data.

Purpose: Security, debugging and improvement of the app.

Legal basis: Legitimate interests, cf. GDPR Art. 6(1)(f).

Retention: Up to 90 days.

Recipients and data processors

We do not share your data with third parties for marketing purposes. Data may be shared with technical sub-processors under a data processing agreement, and with public authorities including law enforcement upon a lawful request.

Key data processors include:

  • Supabase — database, account login, file storage and server functions. Your data is stored in the EU (Ireland).
  • Idura — MitID login broker (identity broker). We receive only a pseudonymous identifier and your name. We do not request or store your CPR number.
  • Mapbox — map display, route calculation and address search.
  • Expo — technical delivery of push notifications to Apple's notification service. Notifications do not contain GPS coordinates.
  • Sentry — error and crash reporting. Only an anonymous user ID is sent — never name, contact details or location. Data is processed in the EU (Germany).
  • Apple Inc. — delivery of push notifications and, if paid subscriptions are introduced, payment processing as legal seller.

Transfers to countries outside the EU/EEA are made on the basis of the European Commission's Standard Contractual Clauses (SCCs), cf. GDPR Art. 46(2)(c).

Your Rights

You have the right to access, rectify, erase, restrict, transfer and object to the processing of your personal data. Contact us at privacy@safecircle.dk.
You may lodge a complaint with the Danish Data Protection Agency, Carl Jacobsens Vej 35, 2500 Valby, Denmark, dt@datatilsynet.dk.