Vigilo App Privacy Policy
Last updated: 5 October 2026.
1. Who processes your data
The data controller is Udruženje CRTA (Center for Research, Transparency and Accountability), Bulevar kralja Aleksandra 70, 11000 Belgrade, Serbia, registration number 17414054, tax ID (PIB) 102211181.
CRTA has appointed a data protection officer. For questions about the processing of your data and to exercise your rights, write to [email protected] with the note “for the Data Protection Officer”.
This policy covers the Vigilo app. CRTA’s other activities are covered by the Privacy Policy and Personal Data Processing Notice.
2. What Vigilo is
Vigilo is the app for the election observers organised by CRTA. It exists as a web app (vigilo.crta.rs) and as the mobile app “Vigilo Crta” for iOS and Android, which shows the same content. It is used by CRTA’s observers and associates during preparations and on election day. Accounts are created by CRTA; there is no sign-up in the app.
3. What data we process
- Account: first and last name, email address, phone number and password (stored only in protected form).
- Observer questionnaire: data needed for accreditation and payment of the observer fee: personal identification number (JMBG), ID card number, permanent and current address with coordinates, municipality, bank account number and bank, travel details, accreditation photo and consents. Entered once, in the questionnaire.
- Engagement: the elections you observe, assigned polling station, shift, colleague at the polling station, training and accreditation status, unique observer code and notes of conversations with coordinators.
- Training: progress through lessons and quizzes, test answers, time spent watching video lessons and messages you send to training support (with a screenshot, if you attach one).
- Polling station reports: answers in the election forms, incident reports with a description and the photos you attach (for example a photo of the polling station record). Photos are kept in private storage and are available only to authorised persons at CRTA.
- Location, also in the background: the app sends your location to CRTA’s security team (1) during an SOS alarm, from pressing the button until the alarm is closed, also when the phone is locked; (2) once, when the team asks “where are you now”; (3) on observation days, while the security team keeps tracking switched on, also when the app is closed. While the location is sent in the background, an Android phone shows a persistent notification and an iPhone shows the location indicator at the top of the screen. The location is sent with its accuracy, time of measurement and battery level. Only CRTA’s security team sees it, and it is used for nothing else.
- SOS: time and location of the SOS call, the path during the alarm, your name, phone number and municipality, so that CRTA’s team can call you and, when needed, alert the police. During an alarm the app records sound, and on Android phones also video, also when the screen is locked (an iPhone records video only while the app is open on screen), for at most 10 minutes, and sends the recording to the team in parts every 10 seconds, as evidence. Without internet, the app opens an SMS with your code and location to CRTA’s short number 3344; you send that message yourself, through your operator, and CRTA may reply by SMS.
- Phone and permissions: phone model, system and app version, app installation identifier, the state of the permissions SOS uses (location, camera, microphone, notifications, background activity, battery) and the battery level, so that support knows what is missing and how to help you.
- Messages: notifications from coordinators and CRTA that you receive in the app and as push notifications.
- Technical data: the device identifier for push notifications, IP address and time of access in server logs, and a record of your actions in the system (change log), for security and to track changes.
The app shows no ads, uses no analytics tools and does not track you across other apps and websites.
4. Why and on what legal basis
- Organising election observation (schedule, training, reporting, communication): performance of the observer engagement contract and CRTA’s legitimate interest in organising election observation as an activity in the public interest.
- Payment of the observer fee and accreditation with the election authorities: performance of the contract and legal obligations.
- SOS, location and recordings: protection of the vital interests of observers and your consent, given through the permissions on your phone, which you can withdraw in the phone settings.
- Push notifications: your consent (device permission), which you can withdraw in the phone settings.
Processing complies with the Law on Personal Data Protection of the Republic of Serbia (Official Gazette RS no. 87/2018, ZZPL) and, where applicable, the General Data Protection Regulation (EU) 2016/679 (GDPR).
5. Who has access to the data
CRTA staff and associates see data according to their role and only as far as their work requires: coordinators see their own observers, and data such as the personal identification number, documents and bank account are visible only to persons with special authorisation. Location, SOS records and recordings are seen only by CRTA’s security team.
We use service providers that process data on our instructions:
- Hetzner Online GmbH: application servers, in a data centre in the European Union;
- Cloudflare, Inc.: traffic protection, the SOS system, its database and SOS alarm recordings;
- Amazon Web Services: private storage of photos and materials, Frankfurt region (Germany);
- Twilio SendGrid: email delivery;
- Apple and Google: delivery of push notifications to your device;
- Google: YouTube video lessons in the training and address search in the questionnaire;
- Akton d.o.o.: SMS messages to CRTA’s short number and replies to them.
We give the election authorities only the data the law requires for observer accreditation. We also disclose data when a competent authority lawfully requests it. Data is not sold and is not shared with third parties for marketing.
6. Transfers to other countries
Some of these providers are based in the United States or also process data outside Serbia. Transfers comply with Chapter V of the ZZPL: to countries with an adequate level of protection or under standard contractual clauses.
7. How long we keep data
- Account, questionnaire and engagement data: three years from the last elections in which you were engaged, unless you ask for deletion earlier.
- Fee payment data: as long as accounting and tax regulations require.
- Polling station reports, incident reports and photos: three years from the elections, as documentation of the observation mission.
- SOS records, recordings and location: 30 days after the end of the elections, except records needed for a report or proceedings before the competent authorities, which are kept while the proceedings last.
- Server logs: 90 days.
8. Your rights
You have the right of access, rectification, erasure and restriction of processing, the right to object and to data portability, and the right to withdraw consent at any time; withdrawal does not affect the lawfulness of processing before it. Send your request, including a request to delete your account, to [email protected] with the note “for the Data Protection Officer”; we reply within 30 days at the latest. You can lodge a complaint with the Commissioner for Information of Public Importance and Personal Data Protection (www.poverenik.rs).
9. Permissions the app asks for
- Location, including “Always” (background), precise: SOS alarm, the team’s “where are you now” request and tracking on observation days, as described in section 3.
- Microphone: recording sound during an SOS alarm, also when the screen is locked.
- Camera: video during an SOS alarm, scanning the QR code on the materials package and photographing the polling station record for a report.
- Notifications: messages from coordinators and CRTA.
- Background activity (Background App Refresh on iPhone, unrestricted battery use on Android): so that SOS and location sharing work when the app is not open.
You can refuse any permission or switch it off later in the phone settings. The app then works without that feature, but SOS cannot work reliably without location, microphone, camera and notifications; this is why CRTA’s observers are instructed to grant all permissions, and the app shows what is missing.
10. Children
The app is intended for adults. Only persons aged 18 or over can be observers.
11. Security
Data is transmitted encrypted (TLS). Access is protected by password and roles, and photos, materials and recordings are kept in private storage and open only through time-limited links. Changes to data are recorded in a change log.
12. Changes
We update this policy when the app changes. The current version is always on this page, with the date of the last change at the top.
