How we process your data

I. Introduction

This document outlines the personal data processing of user data from the Záchranka mobile application. This data processing is governed by legislation, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council, referred to as the GDPR – the General Data Protection Regulation, and Act No. 110/2019 Coll., on the processing of personal data, as amended.

II. The Personal Data Controller

The Operator of the Záchranka app system (hereinafter referred to as the ‘app’) and Personal Data Controller is the non-profit organisation Aplikace Záchranka, z.ú. (the Záchranka application), registered address: Vachova 43/5, Brno, 60200, Czech Republic, Company Reg. No.: 05435773 (hereinafter referred to as the ‘controller’). The key partner for the operation of this system is the Zdravotnická záchranná služba Jihomoravského kraje (South Moravian Regional Emergency Medical Service) organisation, Company Reg. No.: 00346292 (hereinafter referred to as ‘EMS South Moravia’). EMS South Moravia is, within the meaning of GDPR, the personal data processor of personal data sent via the app in an emergency situation in combination with the call to the 155 emergency line.

III. Personal data processed and purpose of processing

The Operator shall process users’ personal data entered into the app by users during the registration process and in the app’s ‘My Profile’ section and data automatically collected by the app.

Mandatory registration constitutes the submission of a mobile phone number and full name. This data is then used to generate the registration code that is sent to the aforementioned mobile phone number submitted. By entering the registration code in the app, the app is then activated, and in the event of an emergency, the system’s own emergency messages are then able to be sent to the units of the integrated rescue systems in the Czech Republic, Austria, Hungary, and in areas covered by the Slovak Mountain Rescue Service.

The Emergency application allows to send and share the location of your device to an emergency service. This function is activated by pressing the emergency button in the "ALARM" module. When pressed, an emergency message will be sent, via data or SMS. The message is sent to the rescue service and is used only for the purposes of the rescue operation. In case the user disables the application the possibility to use position data, only the emergency line 155 is called after pressing the emergency button.

All entered data is stored solely in the Záchranka mobile app on the user’s own device and is not passed on to a third party or the controller (except for the registration data – mobile phone number and full name). Data is only ever transferred when users deliberately press the emergency button in the ‘Alarm’ module. By pressing and holding the red button for 3 seconds, an emergency message is sent. It contains all data that users have entered in their ‘My Profile’ section. The emergency message always contains the user’s GPS location at the time the emergency button is pressed, along with details of their mobile’s language settings, battery and signal statuses, internet connection, and the version of the app currently installed.

Among the types of Personal Data that this Application collects and are described bellow there are: Read Contacts permission; Camera permission; Call phone permission; Coarse location permission, Fine location permission; Background location permission, Write external settings permission.

Users also have the option to add and edit the following additional health/personal information in the ‘My Profile’ section:

Email address
Year of birth
Permanent address
Social Security/Health Insurance number
Native language
2 next-of-kin contacts (phone numbers)
Health details by selecting YES/NO (diabetic, heart problems, lung problems, deaf, blind)
Add editable text further describing the user’s health details (e.g. prescribed medications, allergies etc.)
Add editable text describing the user’s current health details or temporary illnesses, current location, or further identification data, with the option to set a time limit for automatic deletion of this data

Users also have the option to create a scheduled event in the app’s ‘My Trips’ section, where the following information may be entered:

The event’s start time and location
The event’s transit point times and locations
The event’s destination arrival time and location
Next-of-kin contact details: names and telephone numbers
Contact details for event participants accompanying the user: names and telephone numbers

The data is sent either by secure data transmission or by SMS to the Information System of South Moravia EMS. Based on the GPS location contained in the emergency message, this information is then forwarded to the respective regional emergency rescue service tasked to handle that rescue operation. By sending data from a mobile phone to the South Moravia EMS system, the user data becomes part of medical documentation and is thus subject to the rules governing these purposes, as set out by law. Sending data in an emergency message is the equivalent to providing such information during a voice call to the 155 emergency line. The 155 emergency call is still, however, an integral part of activating the ‘Alarm’ button.

Social Security/Health Insurance numbers are used by the rescue services to retrieve user information that users may have stored in the ZDRAVEL electronic medical records system.

All transferred data is considered part of the medical documentation and may only be used in the context of a rescue operation or for the subsequent processing of anonymized data analysis and statistics within the rescue service system.

Personal information and data stored in the My Trips module is stored for the exact time deemed as necessary. When users activate an event within the module, this data is forwarded to a third party – the Mountain Rescue Service.

The controller shall not be responsible for the accuracy of personal data entered by users that is processed by the app. In the event that the controller shall be demonstrably aware of the inaccuracy or incompleteness of the processed data hitherto provided by the user, they shall be obliged to correct, supplement or delete such data in the prescribed manner.

IV. Location in the background

The Emergency application can regularly update the user's location in the background after pressing the emergency button in an emergency, even when the application is closed. This feature allows to clarify the location and better guide rescuers to the scene. In such a case, an emergency message containing position information is sent to the rescue services at regular intervals. This feature is active only if the user has more than 20% of the battery and is connected to the Internet. Updating the location in the background is important for better navigation of rescue services to the scene. The user must enable the use of collecting background location after installing the application in the setup wizard or in the application settings. Without the user's permission and consent, the location of the position after pressing the emergency button in the background is not used.

V. Device permissions for personal data access

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below. By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner The exact procedure for controlling app permissions may be dependent on the User's device and software. Please note that the revoking of such permissions might impact the proper functioning of this Application. If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Read Contacts permission

Is used to read contacts and upload telephone number, name and email address into the users profile in the app.

Camera permission

Is used during the video call with the emergency services.

Call phone permission

Is used for direct call of national emergency number after pressing the emergency button.

Coarse location permission and fine location permissions

Is used for accessing the User's device location. This Application may collect, use, and share User location Data in order to provide location-based services. The location based services are used in the Emergency application to send and share the location of users device to an emergency service. This function is activated by pressing the emergency button in the "ALARM" module. When pressed, an emergency message will be sent, via data or SMS. The message is sent to the rescue service and is used only for the purposes of the rescue operation. In case the user disables the application the possibility to use position data, only the emergency line 155 is called after pressing the emergency button. Location services are also used in other modules within the app to provide specific location based content.

Background location permission

Write external settings permission

Is used to control device settings for example scree brightness level in case of an emergency and during the CPR metronome.

Send SMS permission

This permission is strictly used to send an SMS to emergency services, including your exact location and battery status, ensuring a swift and accurate response to your emergency.

VI. Legal titles of processing

The controller shall process personal data on the basis of the user’s acceptance of the conditions of use during the installation of the app – by consenting to the processing of personal data.

The controller shall process a specific category of personal data (primarily data on the user’s state of health) only when this is entered by the user – by consenting to the processing of personal data.

VII. Duration of processing

South Moravia EMS shall store the data on the app’s central server for a maximum of two years. This shall be only user data that was transmitted to South Moravia EMS, i.e. the Záchranka app data of those users who have used the app to call for help.

Regarding personal data processed through the My Trips module – all data entered when creating an event shall be deleted 2 months after creation.

VIII. Personal data security

The controller has taken appropriate technical and organisational measures with regard to the technology, financial costs, nature, and purpose of processing. The controller has ensured an adequate level of security for personal data transferred as part of an emergency call to the central server at South Moravia EMS, taking into account the risks of accidental or unlawful destruction, loss, alteration, unauthorized access or other forms of unauthorized data processing.

The controller shall undertake to comply with the above measures with regard to the development of new technologies and to eliminate possible future threats to the system.

Employees of the controller, other persons who process personal data on the basis of a contract with the controller, and other persons who come into contact with personal data in the performance of their rights and obligations are obliged to maintain the confidentiality of personal data and security measures, the disclosure of which would jeopardize the security of personal data. The obligation to maintain confidentiality does not apply to the legal obligation to provide information under specific laws.

IX. Processing methods

Personal data is processed exclusively in automated electronic form.

X. Recipients of personal data

Recipients of personal data include EMS rescue operations centres and the operations centres of other units of the integrated rescue service system participating in the rescue operation (the Water Rescue Services, Mountain Rescue Services, etc.)

XI. Your data subject rights:

You have the right to request access to personal data concerning you as a data subject from the controller, and you have the right to correct this data.

Where applicable, you have the right to restrict processing in the following cases:

a) if you dispute the accuracy of personal data, for a period enabling for the controller to verify the accuracy of this personal data

b) the processing is unlawful, and you as the data subject oppose the deletion of the personal data and request the restriction of its use instead

c) the controller no longer needs the personal data for processing purposes, but you as the data subject require this to establish, exercise or defend legal claims

d) if you have already objected to processing in the case of processing in the legitimate interest of the controller or third parties, pending verification whether the legitimate grounds of the controller outweigh the legitimate grounds of the data subject.

You have the right to object to the processing if:

a) the processing is necessary for the completion of a task carried out in the public interest or in the exercise of official authority, or

b) if the processing is carried out in the legitimate interest of the controller or a third party, as well as to the right of data portability.

The right to delete personal data, including, inter alia, if the legal obligation to process them no longer applies or other statutory exemptions do not apply.

XII. You have the right to lodge a complaint with the supervisory authority if you believe that the processing of personal data violates the GDPR. You can lodge a complaint with the supervisory authority:

a) in the country of your place of habitual residence,

b) at your place of employment or

c) at the place where the alleged infringement took place.

XIII. Contacting the Data Protection Officer

The Data Protection Officer can be contacted by email at: poverenec@zachrankaapp.cz

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