Privacy Policy for the PLAIER Bot via WhatsApp

Welcome to the PLAIER Bot of KCJJ Sports GmbH, Leipoldstieg 5, 22605 Hamburg, Germany, which you can use via WhatsApp.

The protection of your privacy is our top priority. We collect and use your personal data exclusively in accordance with the applicable data protection regulations. Our employees and representatives are obliged to comply with data protection regulations in accordance with the statutory provisions.

In the following, we inform you about the type, scope and purpose of the collection and use of personal data. Personal data is all data that can be related to you personally, e.g. your telephone number or your user behavior.

You can access this information at any time on the PLAIER website. This information relates to the use of the service via WhatsApp.

1. Contact Details of the Responsible Person when using the PLAIER Bot

KCJJ Sports GmbH
Leipoldstieg 5
22605 Hamburg
Germany
(hereinafter„PLAIER“)

Legal Representative: Tim Schröder, Geschäftsführer

In order to use the PLAIER Bot, it is necessary to have WhatsApp installed. The provider WhatsApp, Inc. is solely responsible for the provision and data protection of WhatsApp. The purpose and scope of data collection by WhatsApp, Inc. and the further processing and use of personal data by WhatsApp, Inc. as well as your rights in this regard and setting options for protecting your privacy can be found in the privacy policy of WhatsApp, Inc. If you use WhatsApp, you agree to the privacy policy of WhatsApp, Inc. In this case, WhatsApp, Inc. is solely responsible for data protection.

If you use the PLAIER Bot via WhatsApp, PLAIER processes your personal data and is the data controller in this case.

2. General Information on Data Processing

PLAIER collects and uses your personal data only to the extent necessary to provide our content and services. The collection and use of your personal data is voluntary. An exception applies in cases where the processing of data is permitted by law.

3. Overview of the Scope of Data Collection and Processing

3.1. Purpose of the Data Processing

PLAIER provides you with the PLAIER Bot via WhatsApp of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, a chatbot that automatically answers your questions about soccer matches and soccer teams through data-driven analysis and predictions. In order to use the PLAIER Bot, it is necessary that WhatsApp is installed on your device.

3.2. Processing of Personal Data

If you use the PLAIER Bot via WhatsApp, PLAIER processes your personal data and is the controller for personal data processed via the PLAIER Bot. The following personal data is collected and processed: Your telephone number, conversation content and analytics data. The data is stored in a contact profile so that we can assign whether we have already had contact with you within the PLAIER bot.

3.3. Categories of Personal Data Processed

Personal data is processed as described below: Your telephone number, conversation content and analytics data. The data is stored in a contact profile so that we can assign whether we have already had contact with you within the PLAIER bot.

3.4. Exercising the Rights to Object and Erasure

If you no longer wish to use the PLAIER Bot, you can request the deletion of your personal data collected in the PLAIER Bot using the "/stop" command and delete the PLAIER Bot's telephone number from your end device at any time.

3.5. Legal Basis

The operation of the PLAIER Bot is based on our legitimate interest (Art. 6 para. 1 lit. f) GDPR) in answering the questions you ask the PLAIER Bot. In addition, we only process your personal data if the processing is necessary to comply with our legal and regulatory obligations.

3.6. Service Providers

We share your personal data with our service providers within and outside the European Economic Area who are involved in the provision of the PLAIER Bot on our behalf. All our service providers are contractually obliged to process the personal data provided to them only for the purpose of providing the specific service to us and to take appropriate security measures to protect your personal data.

We only use service providers outside the European Economic Area if they operate in a location that is considered by the European Commission to provide adequate protection for your personal data or if we have taken appropriate precautions to protect your personal data (for example, if both parties involved in the transfer have agreed standard data protection clauses that are recognized by the European Commission).

When you communicate with the PLAIER Bot, the questions you submit to the PLAIER Bot and the metadata of the communication (your telephone number, your WhatsApp username and the date and time of your question) are processed by the following service providers:

  • Supabase, Inc., 970 Toa Payoh North #07-04, Singapore 318992, Singapore, purpose of processing: database

  • OpenAI OpCo, LLC, 3180 18th Street, San Francisco, California, USA, purpose of processing: generating responses

  • LangChain Inc., Apt. 629 2660 3rd Street San Francisco, CA 94107, USA, purpose of processing: analysis

  • LLM Studios GmbH, c/o Factory Works GmbH Rheinsberger Str. 76/77, 10115 Berlin, Germany, purpose of processing: data management

  • Twilio Inc., Fifth Floor, 101 Spear Street, San Francisco, California, 94105, USA, purpose of processing: connection of messenger services

  • Vercel Inc., 340 S Lemon Ave 4133Walnut, California, 91789, USA, purpose of processing: Hosting

4. Rights of Data Subjects

4.1. Right to Information

You have the right to be informed in a clear, transparent and easily understandable way about your rights and how we use your personal data. We therefore inform you about this in this privacy policy.

4.2. Right of Access

You can request information about your personal data processed by PLAIER in accordance with Art. 15 GDPR.

4.3. Right to Object Pursuant to Art. 21 para. 1 GDPR

You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on point (f) of Article 6(1) GDPR. The controller will then no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims. The collection of data for the provision of the services is absolutely necessary for the operation of these services.

4.4. Right to Rectification and Completion

If your personal data is not (or is no longer) accurate, you can request rectification in accordance with Art. 16 GDPR. If your personal data is incomplete, you can request that it be completed.

4.5. Right to Erasure

You can request the erasure of your personal data in accordance with Art. 17 GDPR.

4.6. Right to Restriction of Processing

In accordance with Art. 18 GDPR, you have the right to request that the processing of your personal data be restricted.

4.7. Right to Lodge a Complaint

If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a data protection supervisory authority in accordance with Art. 77 (1) GDPR. This also includes the data protection supervisory authority responsible for the controller:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Straße 22
20459 Hamburg
E-Mail: mailbox@datenschutz.hamburg.de
Phone: 040-42854-4040
Website: https://datenschutz-hamburg.de

4.8. Right to Data Portability

In the event that the requirements of Art. 20 para. 1 GDPR are met, you have the right to have your personal data processed by PLAIER handed over to you or to third parties.