Privacy Policy

SOS-ID GmbH · As of: February 2026

The protection of your personal data is of utmost importance to us. We process your data exclusively on the basis of the General Data Protection Regulation (GDPR) and the German Telecommunications and Digital Services Data Protection Act (TDDDG).

1. Data Controller under the GDPR

Company: SOS-ID GmbH

Address: Cassellastrasse 30–32, 60386 Frankfurt am Main, Germany

Email: info@id-no.com

Represented by: Management

ID-No.com is the technical platform for using SOS-ID products. The operator and data controller within the meaning of the GDPR is SOS-ID GmbH. It determines the purposes and means of data processing and fulfils all data protection obligations. Users have no contractual or liability relationship with any other entity.

2. Data Protection Officer

Company: DataGAP GmbH

Address: Bessemerstraße 51, 1st Floor, 12103 Berlin

Email: info@datagap.de

3. Hosting, Server Location & Retention Periods

ID-No.com is operated exclusively on secured servers located in Germany. All processing of personal data takes place entirely within the European Union. No transfer to third countries takes place.

Contract & billing data: Statutory retention periods apply

Customer account: Until deletion by the user

Emergency & health data: Deletable by the user at any time

Once the purpose has ceased or statutory retention periods have expired, data will be deleted or anonymised.

3.1 Termination & Data Deletion

Users may request the deletion of their account at any time by emailing datenschutz@id-no.com. All data not subject to statutory retention obligations will be irrevocably deleted or anonymised within 30 days. Health and emergency data will be removed immediately upon account closure – restoration is not possible thereafter. Data subject to statutory retention requirements (e.g. invoices pursuant to § 147 of the German Fiscal Code) will be blocked until the relevant period expires and then deleted.

3.2 Use of Data Processors

To provide our services, we engage external service providers (e.g. hosting, payment processing, email delivery, IT services). These providers process personal data exclusively on the basis of data processing agreements pursuant to Art. 28 GDPR and only in accordance with our instructions.

4. Data Processing When Visiting the Website

When you access our website, the following data is processed automatically:

  • Truncated / anonymised IP address
  • Date and time
  • Pages accessed
  • Browser type and operating system
  • Referrer URL

Purpose: Ensuring stable operation, defending against security incidents, preventing misuse

Legal basis: Art. 6(1)(f) GDPR

Retention period: Maximum 30 days

5. Cookies & Consent Management

Technically necessary cookies: Legal basis: § 25(2) TDDDG, Art. 6(1)(f) GDPR – no consent required

Analytics & statistics cookies: Legal basis: § 25(1) TDDDG, Art. 6(1)(a) GDPR – only with explicit consent

Consent may be withdrawn at any time via the cookie banner.

6. Customer Account & Orders

In connection with account creation and order processing, we process the following data:

  • Name and address
  • Email address
  • Order and contract data

Legal basis: Art. 6(1)(b) GDPR

Contract data: Statutory retention periods apply

Customer account: Until deletion by the user

7. SOS-ID Emergency Data & Special Categories of Data

Users may voluntarily store particularly sensitive data within the SOS-ID emergency passport. These may constitute special categories of personal data within the meaning of Art. 9 GDPR.

7.1 Types of Data Processed

Users may store the following information in particular:

  • Health data
  • Medical notes
  • Allergies and intolerances
  • Medications
  • Emergency contacts
  • Additional voluntary information

7.2 Role of ID-No.com

ID-No.com serves exclusively as a technical platform for storing information entered by the user. SOS-ID GmbH operates the technical infrastructure but does not carry out any medical assessment, content review, or analysis of the data.

7.3 Legal Basis & Consent

Processing is carried out exclusively on the basis of explicit consent, which is obtained separately and in granular form – independently of accepting the Terms and Conditions (separate checkbox):

  • Art. 6(1)(a) GDPR
  • Art. 9(2)(a) GDPR

Consent may be withdrawn at any time with effect for the future. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

7.4 Encryption & Access Protection

Emergency data is stored in encrypted form and protected by extensive technical and organisational measures (TOMs). Employees do not have unrestricted access to stored content. Access is only granted where technically absolutely necessary – without any content analysis.

7.5 Access in an Emergency

Access to emergency data is only possible via:

  • The individual QR code or personal ID number
  • The password-protected user area

Without the appropriate authorisation, no access is possible. SOS-ID GmbH assumes no liability for the availability of the platform in an emergency. We recommend keeping analogue emergency information as a supplement.

7.6 Data Control & User Responsibility

Users retain full control over their data at all times. Independent modification, deletion, and withdrawal of consent are possible at any time. Once deleted, data can no longer be retrieved. Responsibility for the accuracy, currency, and completeness of the information lies with the user.

7.7 Event Notification upon QR Code Scan

When an SOS-ID QR code is accessed, an event (date and time) is recorded. The user automatically receives an email notification. The purpose is to inform about usage and to enhance the security of the user account. For misuse prevention purposes, the IP address of the accessing device is logged for a short period (max. 30 days) upon each scan.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest: security & misuse prevention)

8. Payment Processing

Service provider: Stripe Technology Company Limited, Dublin, Ireland (EU)

Data access: We do not receive access to complete payment data

Third-country transfer: Stripe may process data via US group companies. Legal basis: Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR

Stripe privacy policy:https://stripe.com/privacy

9. Newsletter

If you subscribe to our newsletter, we process your email address and the time of registration. Registration is carried out using a double opt-in procedure: after entering your email address, you will receive a confirmation email. Your address will only be activated for newsletter delivery after clicking the confirmation link.

Legal basis: Art. 6(1)(a) GDPR

Service provider: Brevo

Retention period: Until unsubscription; deletion within 30 days of unsubscription

Unsubscription: At any time via the link in each newsletter email or by emailing datenschutz@id-no.com

10. Your Rights

You have the following rights against us at any time:

  • Right of access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 17 GDPR)
  • Right to restriction of processing (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object (Art. 21 GDPR)
  • Right to lodge a complaint with a supervisory authority

Where we process data on the basis of legitimate interests, you may object at any time.

Competent supervisory authority: The Hessian Commissioner for Data Protection and Freedom of Information (HBDI), Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany

11. Data Security & Data Breaches

We deploy extensive technical and organisational measures to protect personal data to the greatest possible extent:

  • SSL/TLS encryption
  • Access restrictions
  • Role-based authorisation concepts
  • Regular security audits

In the event of a data breach, we will report the incident to the competent supervisory authority without undue delay, and at the latest within 72 hours (Art. 33 GDPR). Where there is a high risk to affected individuals, they will also be notified without undue delay (Art. 34 GDPR). Data breaches involving health data are generally considered to pose a high risk.

12. Contact and Support

If you contact us by email or via a contact form, we process your information exclusively for the purpose of handling your enquiry.

Legal basis: Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR

Retention period: Deletion after the enquiry is concluded, unless statutory retention obligations apply

13. No Automated Decision-Making or Profiling

No automated decision-making or profiling within the meaning of Art. 22 GDPR takes place.

14. Amendments to this Privacy Policy

We reserve the right to update this Privacy Policy in response to changes in our services or the legal framework. The current version is available at www.id-no.com/privacy. In the event of material changes, registered users will be informed by email.

Data Protection Contact: datenschutz@id-no.com · SOS-ID GmbH, Cassellastrasse 30–32, 60386 Frankfurt am Main, Germany