Privacy Policy

Preamble

With the following privacy policy, we would like to inform you which types of your personal data (hereinafter also referred to in short as "data") we process, for which purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the "online services").

The terms used are not gender-specific.

Last updated: August 20, 2026

Table of contents

• Preamble
• Controller
• Overview of processing activities
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• General information on data storage and deletion
• Rights of data subjects
• Business services
• Use of online platforms for offering and sales purposes
• Payment procedures
• Distribution via the Apple App Store
• Subscription management (RevenueCat)
• Provision of the online services and web hosting
• Registration, login and user account
• Email delivery (Resend)
• Single sign-on login
• AI-assisted betting slip recognition
• AI-assisted analyses and recaps
• Functional and quality data
• Reminders (local notifications)
• Contact and inquiry management
• Presences in social networks (social media)
• Changes and updates
• Definitions of terms

Controller

Lasse Julian Pöhls
Kieler Straße 7
24589 Nortorf, Germany

Email address: support@betinsight.app

Imprint: https://betinsight.app/en/imprint

Overview of processing activities

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of data processed

• Inventory data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and process data.
• Log data.

Categories of data subjects

• Service recipients and clients.
• Prospective customers.
• Communication partners.
• Users.
• Business and contractual partners.

Purposes of processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Office and organizational procedures.
• Organizational and administrative procedures.
• Feedback.
• Marketing.
• Login procedures.
• Provision of our online services and usability.
• Information technology infrastructure.
• Public relations.
• Business processes and management procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in this privacy policy.

• Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual German federal states may apply.

Security measures

In accordance with the legal requirements and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of threats to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry of and disclosure of the data, and safeguarding its availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to threats to the data. We also take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by privacy-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services against unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transmission of personal data

In the course of our processing of personal data, it may occur that such data is transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies (which can be recognized by the postal address of the respective provider or where the privacy policy expressly refers to a data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission of July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This twofold safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should any changes occur within the framework of the DPF, the standard contractual clauses step in as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, express consent or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are withdrawn or no further legal bases for the processing exist. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where statutory obligations or special interests require a longer retention or archiving of the data.

In particular, data that must be retained for reasons of commercial or tax law, or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing operations.

Where several retention periods or deletion deadlines apply to a piece of data, the longest period is always decisive. Data that is no longer retained for its originally intended purpose, but on the basis of legal requirements or for other reasons, is processed by us exclusively for the reasons justifying its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

• 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO (German Fiscal Code), § 14b para. 1 UStG (German VAT Act), § 257 para. 1 no. 1 in conjunction with para. 4 HGB (German Commercial Code)).
• 8 years - accounting records, such as invoices and cost receipts (§ 147 para. 1 nos. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
• 6 years - other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operational accounting sheets, costing documents, price labels, but also payroll accounting documents insofar as they are not already accounting records, and cash register receipts (§ 147 para. 1 nos. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 nos. 2 and 3 in conjunction with para. 4 HGB).
• 3 years - data required to take into account potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB (German Civil Code)).

Commencement of the period at the end of the year: If a period does not expressly begin on a specific date and amounts to at least one year, it automatically commences at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the date on which the termination or other ending of the legal relationship takes effect.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
• Right of access: You have the right to request confirmation as to whether the data in question is being processed, and to obtain access to this data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, to request restriction of the processing of the data in accordance with the legal requirements.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Business services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively referred to as "contractual partners"), for the purpose of initiating, performing and settling contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular the fulfillment of our primary and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the handling of warranty cases and other disruptions of performance, the processing of withdrawals, terminations of continuing obligations, reversals and refunds, as well as the handling of other contract-related declarations and inquiries. Both one-off contracts and ongoing contractual relationships are covered.

The data processed includes in particular master data such as name, address and, where applicable, company name, contact data such as email address and telephone number, contract and service data such as the subject matter of the contract, contract term, order or transaction number, usage and performance data, payment and billing data, as well as communication content and histories. Where necessary, we also process data disclosed or transmitted to us in the course of performing an order.

In addition, we process the data to safeguard our rights and to fulfill legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations and, where applicable, verification and accountability obligations. Processing is also carried out on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners against misuse and against threats to data, secrets and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for the performance of the contract or to fulfill legal obligations.

Personal data is passed on to third parties only insofar as this is necessary for the performance of the contract, for the implementation of pre-contractual measures, to safeguard legitimate interests or to fulfill legal obligations. We provide separate information about processing beyond this, in particular for marketing purposes, within this privacy policy.

We inform the contractual partners which data is required in each individual case as part of the data collection, for example in online forms by means of appropriate labeling or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations stand in the way. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific order is deleted after completion of the order and expiry of any retention periods, provided there are no further statutory or contractual obligations to store it.

The legal basis for the processing is Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures and the performance of the respective contractual relationship, as well as Art. 6 para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6 para. 1 lit. f GDPR. Insofar as the processing is based on Art. 6 para. 1 lit. f GDPR, it is carried out to safeguard our legitimate interests in a proper and efficient business organization, the internal administration and documentation of business transactions, the assertion and defense of legal claims, ensuring IT and data security, the prevention of misuse and fraud, as well as the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in maintaining our entrepreneurial capacity to act.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
• Data subjects: Service recipients and clients; prospective customers. Business and contractual partners.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and management procedures.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of online platforms for offering and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the privacy notices of the respective platforms apply in addition to our privacy notices. This applies in particular with regard to the processing of the payment transaction and the procedures used on the platforms for reach measurement and interest-based marketing.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
• Data subjects: Service recipients and clients. Business and contractual partners.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; marketing. Business processes and management procedures.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Payment procedures

All payments in connection with our app (subscriptions and in-app purchases) are processed exclusively via the Apple App Store. We do not receive any payment data such as credit card or account information, but only pseudonymized transaction information. Details can be found in the sections "Distribution via the Apple App Store" and "Subscription management (RevenueCat)".

Distribution via the Apple App Store

Our app is distributed via the App Store of Apple Inc. (or, for users in the EEA: Apple Distribution International Ltd., Ireland). When the app is downloaded and when subscriptions and in-app purchases are concluded, Apple processes personal data as an independent controller (e.g. Apple ID, payment information, purchase history). Payment data such as credit card information is processed exclusively by Apple and is at no time transmitted to us; we only receive pseudonymized transaction information from Apple for the provision of the purchased services. Further information on data processing by Apple: https://www.apple.com/legal/privacy/

Subscription management (RevenueCat)

For the management of subscriptions and in-app purchases, we use RevenueCat Inc. (USA) as a processor. In this context, pseudonymous user IDs, purchase history and subscription status are processed; payment data (e.g. credit card data) is processed exclusively by Apple and is not transmitted to us. The transfer to the USA takes place on the basis of the standard contractual clauses of the EU Commission. The legal basis is Art. 6 para. 1 lit. b GDPR (performance of a contract).

Provision of the online services and web hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

• Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times.).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online services and usability; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

• Provision of the online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a "web host"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, transferred data volumes, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid server overload (particularly in the event of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log files are stored only for as long as is necessary for the aforementioned purposes and are then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.

Hosting of the website and app infrastructure

Our website is hosted by Vercel Inc. (USA). When the website is accessed, Vercel automatically processes access data (including IP address, date and time of access, page accessed, browser information) in server log files for the provision and protection of the service (Art. 6 para. 1 lit. f GDPR – legitimate interest in secure and efficient operation).

The data of our app (account data, recorded bets including notes and markings, bankroll details, settings made in the app – including voluntarily set player protection limits such as stake limits –, uploaded betting slip images, as well as technical functional data) is stored in a database operated by Supabase Inc. Storage takes place on servers in the European Union (Ireland region). The data is stored for as long as the user account exists; when the account is deleted, it is irreversibly removed. Data processing agreements are in place with both providers; insofar as data is transferred to the USA, this takes place on the basis of the standard contractual clauses of the EU Commission or the EU-US Data Privacy Framework.

Registration, login and user account

Users can create a user account. As part of the registration process, users are informed of the required mandatory data, which is processed for the purpose of providing the user account on the basis of the fulfillment of contractual obligations. The data processed includes, in particular, the login information (email address and password).

When our registration and login functions are used, as well as when the user account is used, we store the IP address and the time of the respective user action. This storage is based on our legitimate interests, as well as those of the users, in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so.

Users may be informed by email about events that are relevant to their user account, such as technical changes.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions, as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files concerning logins or the retrieval of data or access times.).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online services and usability.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion". Deletion after termination.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

• Users' profiles are not public: Users' profiles are not publicly visible and not publicly accessible.
• Deletion of the user account in the app: Users can permanently delete their account themselves at any time in the app under "Settings → Account → Delete account". In doing so, the user account and the associated data – in particular recorded bets, bankroll details, settings and uploaded betting slip images – are irreversibly removed. A subscription concluded via the App Store is not ended by the deletion of the account; it must be canceled in the respective App Store account; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• No obligation to retain data: It is the users' responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Email delivery (Resend)

For sending account-related emails (e.g. confirmation codes during registration and codes for resetting the password), we use Resend, Inc. (USA) as a processor. In this context, the recipient's email address and the content of the respective message are processed. The transfer to the USA takes place on the basis of the standard contractual clauses of the EU Commission. The legal basis is Art. 6 para. 1 lit. b GDPR (performance of a contract).

Single sign-on login

"Single sign-on" or "single sign-on login or authentication" refers to procedures that allow users to log in to our online services using a user account held with a provider of single sign-on procedures (e.g. a social network). A prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access credentials in the online form provided for this purpose, or are already logged in with the single sign-on provider and confirm the single sign-on login via a button.

Authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in with the respective single sign-on provider under this user ID, and an ID that cannot be used by us for any other purposes (a so-called "user handle"). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of the authentication, and also on which data the users have released in the privacy or other settings of their user account with the single sign-on provider. Depending on the single sign-on provider and the users' choice, this can be various data; as a rule, it is the email address and the user name. The password entered with the single sign-on provider as part of the single sign-on procedure is neither visible to us nor stored by us.

Users are asked to note that the information about them stored with us can be automatically matched with their user account with the single sign-on provider, but that this is not always possible or does not always actually take place. If, for example, users' email addresses change, they must change them manually in their user account with us.

We may use single sign-on login, if agreed with the users, in the context of or prior to the performance of a contract, insofar as the users have been asked to do so, process it as part of a consent, and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure login system.

Should users ever decide that they no longer wish to use the link between their user account with the single sign-on provider for the single sign-on procedure, they must cancel this connection within their user account with the single sign-on provider. If users wish to have their data deleted by us, they must terminate their registration with us.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; login procedures. Provision of our online services and usability.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion". Deletion after termination.
• Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

• Apple Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
• Google Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/; Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: Settings for the display of advertisements: https://myadcenter.google.com/.

AI-assisted betting slip recognition

For the automatic recording of betting slips, users can upload photos or screenshots of their betting slips. These images are transmitted to Anthropic PBC (USA) for automated text recognition and data extraction and are processed there. The transfer to the USA takes place on the basis of the standard contractual clauses of the EU Commission or the EU-US Data Privacy Framework. The processing is carried out for the performance of the contract (Art. 6 para. 1 lit. b GDPR) – the scan feature is a core component of the app. The images are not used by Anthropic to train AI models.

AI-assisted analyses and recaps

To create personal analyses (e.g. weekly and monthly recaps, insights into your own betting behavior), we transmit betting metrics of the user to Anthropic PBC (USA), which uses them to automatically generate text summaries. This includes aggregated values (e.g. balance, hit rate, distribution by sport) as well as details of individual bets in the period being analyzed (e.g. odds, stake, win/loss, sport, and the market or tip designation recorded by the user – even if it was entered as free text). Name, email address, user identifier and betting operator are not transmitted in this process. The results are stored in the user account. The legal basis is Art. 6 para. 1 lit. b GDPR (performance of a contract); the transfer to the USA takes place on the basis of the standard contractual clauses of the EU Commission or the EU-US Data Privacy Framework. The data is not used by Anthropic to train AI models.

Functional and quality data

To ensure and improve the scan feature, we store technical metrics on scans performed (e.g. success/failure, processing time), linked to the user account. No third-party analytics or tracking services are used. The legal basis is Art. 6 para. 1 lit. f GDPR (legitimate interest in functionality and troubleshooting).

Reminders (local notifications)

Our app can display reminders, e.g. about open bets. These notifications are scheduled and displayed exclusively locally on the device; no data is transmitted to us or to third parties for this purpose and no device token is generated. Reminders are only displayed if the user has granted the app permission for notifications; this permission can be revoked at any time in the system settings (iOS or Android).

Contact and inquiry management

When contacting us (e.g. by post, email, telephone or via social media), as well as in the context of existing user and business relationships, the details of the inquiring persons are processed insofar as this is necessary to respond to the contact inquiries and any requested measures.

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as the information relating to them, such as details of authorship or time of creation).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback. Provision of our online services and usability.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, process user data in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created on the basis of users' usage behavior and the interests resulting from it. These usage profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions, as well as the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Communication; feedback. Public relations.
• Retention and deletion: Deletion in accordance with the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing operations, procedures and services:

• Instagram: Social network, allows the sharing of photos and videos, commenting on and favoriting posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
• YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/.
• TikTok: We maintain a profile on the TikTok platform of TikTok Technology Limited (Ireland) and TikTok Pte. Ltd. (Singapore), respectively. If you interact with our profile (e.g. comments, direct messages, following), we process the data arising in this context in order to communicate with you (Art. 6 para. 1 lit. f GDPR – legitimate interest in public relations and user communication). In doing so, TikTok processes your data under its own responsibility, including outside the EU; a transfer to third countries (including Singapore, the USA and China) may take place. For details, please refer to TikTok's privacy policy: https://www.tiktok.com/legal/privacy-policy TikTok provides us with aggregated statistics on the use of our profile ("analytics"); for this, we may be jointly responsible with TikTok.

Changes and updates

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and please verify the information before contacting them.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Inventory data: Inventory data comprises essential information required for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unambiguous assignment and communication.
• Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
• Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication and process data: Meta, communication and process data are categories containing information about the way in which data is processed, transmitted and managed. Metadata, also known as data about data, comprises information that describes the context, origin and structure of other data. It may include details on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used for tracking and verifying operations.
• Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data comprises a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages and via which paths they navigate through an application. Usage data may also include the frequency of use, time stamps of activities, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for the analysis of system problems, for security monitoring or for the creation of performance reports.
• Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or erasure.
• Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and comprises both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
• Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information on payment status, chargebacks, authorizations and fees.

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