Last updated: March 2026.
1. Who We Are
CRTA — Center for Research, Transparency and Accountability
Bulevar kralja Aleksandra 70, 11000 Belgrade, Serbia
Email: [email protected]
Data Protection Officer: [email protected]
2. About the Application
SOS Poziv is a mobile application designed for election observers. The app enables observers to send urgent SOS alerts to CRTA coordinators in case of safety threats, as well as location tracking and communication during election monitoring.
3. What Data We Collect
3.1. Identity Data
- First and last name
- Phone number
- Access code (assigned by CRTA)
- Municipality and observation region
Purpose: Observer identification, emergency communication, observation coordination.
3.2. Location Data (GPS)
- Precise GPS location (foreground and background)
- Location history (timestamped coordinates)
Purpose: Allows coordinators to locate an observer during an emergency and monitor movement during election observation.
Background location: The app collects location data even when not actively open so that coordinators have up-to-date information about observer locations during election day. This is essential for observer safety.
Frequency: Location is sent periodically (every few minutes) while the observer is logged into the app.
3.3. Audio and Video Recordings
- Audio recording (up to 3 minutes) upon SOS signal activation
- Video recording (optional) upon SOS signal activation
Purpose: Documenting the situation in case of observer safety threats, serving as evidence of an incident.
Important: Recording is activated exclusively by user action (pressing the SOS button). The app never records without explicit activation by the user.
3.4. Push Notification Tokens
- Unique device identifier for sending notifications (APNS token for iOS, FCM token for Android)
Purpose: Receiving urgent notifications from coordinators, SOS signal status updates.
3.5. Device Data
- Operating system type (iOS/Android)
Purpose: Technical app functionality and push notification delivery.
4. Legal Basis for Processing
We process data based on:
- User consent (Article 12 ZZPL / Article 6(1)(a) GDPR) — for collecting location data, recordings, and push notifications. Consent is given when granting device permissions and logging into the app.
- Legitimate interest (Article 12 ZZPL / Article 6(1)(f) GDPR) — for processing identity data for election observation coordination and observer safety.
5. Who Has Access to Your Data
Your data is accessed exclusively by:
- CRTA coordinators (app administrators) — for coordination and responding to SOS alerts
- CRTA technical team — for app maintenance and operation
Your data is not shared with third parties, advertising networks, analytics services, or government authorities, unless required by court order or law.
Infrastructure
- Data is stored on Cloudflare Inc. servers (EU/US) in accordance with their privacy policy and standard contractual clauses for data transfers.
6. How Long We Keep Your Data
| Data Type | Retention Period |
|---|---|
| Identity data | Until end of election cycle + 6 months |
| Location history | 30 days from collection |
| Audio/video recordings | 90 days from creation |
| Push tokens | Until logout or account deletion |
| SOS alerts and logs | 1 year |
Data is automatically deleted after the specified retention periods.
7. Your Rights
Under the Serbian Personal Data Protection Act (ZZPL) and the GDPR, you have the right to:
- Access — request a copy of your data
- Rectification — correct inaccurate data
- Erasure — request deletion of your data
- Restriction — restrict how we use your data
- Portability — receive your data in a structured format
- Objection — object to data processing
- Withdraw consent — withdraw your consent at any time
To exercise your rights, contact us at: [email protected]
We will respond to your request within 30 days.
You have the right to lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection (www.poverenik.rs).
8. Data Security
We apply technical and organizational security measures:
- Encrypted communication (HTTPS/TLS) between the app and servers
- Access authentication via session tokens
- Restricted data access (authorized coordinators only)
- Audio/video recordings stored in encrypted storage
9. Account and Data Deletion
You can request complete deletion of all your data by sending a request to [email protected]. Upon receiving your request, all your data will be deleted within 30 days.
Additionally, logging out of the app stops location collection and push notifications.
10. Children
The application is not intended for persons under 18 years of age and we do not knowingly collect data from minors.
11. Changes to This Privacy Policy
You will be notified of any significant changes to this policy via the app or email. Continued use of the app after notification constitutes acceptance of the changes.
12. Contact
For any questions regarding your data:
- Email: [email protected]
- Address: CRTA, Bulevar kralja Aleksandra 70, 11000 Belgrade, Serbia
