PRIVACY POLICY
LAST UPDATED
19 January 2026
CONTROLLER
Kofi Schulz
Leopold Gattringer-Straße 42/1
2345 Brunn am Gebirge
Austria
Email: info@kofifootball.com
SCOPE
This policy applies when you:
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visit the website
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create an account
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use the member area
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take the Elite Standards Test
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subscribe to emails
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contact us
Personal data means any information that can identify you.
DATA WE PROCESS
Account data
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name
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email address
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encrypted or hashed password
Profile data
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profile picture, if uploaded
Training and performance data
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training progress
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performance records created by you
Test data
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email address for report delivery
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answers to the Elite Standards Test
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generated report
Technical data
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IP address
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device and browser information
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log data such as time, page, and referrer
Marketing and analytics data
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cookie identifiers
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interaction events, only after consent
PURPOSES AND LEGAL BASES
Website operation and security
Purpose: delivery, stability, abuse prevention
Legal basis: legitimate interest (Art. 6(1)(f) GDPR)
Account and member access
Purpose: account creation, access, progress display
Legal basis: contract (Art. 6(1)(b) GDPR)
Elite Standards Test
Purpose: process answers, generate and deliver report
Legal basis: contract (Art. 6(1)(b) GDPR)
Marketing follow-up only with consent (Art. 6(1)(a) GDPR)
Newsletter and marketing
Purpose: send updates and offers
Legal basis: consent (Art. 6(1)(a) GDPR)
You can withdraw consent at any time via the unsubscribe link or by contacting us.
Legal duties
Purpose: tax, accounting, legal defence
Legal basis: legal obligation (Art. 6(1)(c) GDPR) and legitimate interest (Art. 6(1)(f) GDPR)
Retention: 7 years under Austrian law
MANDATORY OR OPTIONAL DATA
Providing personal data is required to create an account, use member features, or receive reports. If the required data is not provided, we may not be able to deliver the service.
COOKIES
We use:
Essential cookies
Required for:
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login
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security
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core site functions
These cookies cannot be disabled.
Optional cookies
Used for:
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analytics
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advertising
They are set only after your consent via the cookie banner.
You can change your cookie preferences at any time via the banner or browser settings.
GOOGLE ANALYTICS
Used to analyse website usage.
Data processed:
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visited pages
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time on site
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interactions
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approximate location
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device data
Legal basis: consent (Art. 6(1)(a) GDPR)
Runs only after consent.
META PIXEL
Used for advertising measurement and targeting.
Data processed:
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page views
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actions
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cookie or device identifiers
Legal basis: consent (Art. 6(1)(a) GDPR)
Runs only after consent.
EMBEDDED CONTENT
We embed content from:
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YouTube
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Instagram
When loaded, these providers may receive your IP address and device data and may set cookies.
Embeds that require cookies load only after consent.
EMAIL SERVICES (BREVO)
Used for:
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account-related emails
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test report delivery
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newsletters
Data processed:
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email address
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delivery status
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interaction data, if enabled
Legal basis:
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contract for account and report emails
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consent for newsletters
PAYMENTS
Used for:
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account-related emails
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test report delivery
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newsletters
Data processed:
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email address
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delivery status
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interaction data, if enabled
Legal basis:
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contract for account and report emails
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consent for newsletters
PROCESSORS
We use GDPR-compliant processors with Art. 28 agreements, including:
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Wix (hosting, accounts, CMS, payments)
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Brevo (email services)
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Google (Analytics, if enabled)
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Meta (Pixel, if enabled)
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YouTube and Instagram (embedded content)
Only data necessary for each service is shared.
TRANSFERS OUTSIDE THE EU OR EEA
Some providers may process data in third countries, such as the United States.
Safeguards include:
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EU Standard Contractual Clauses
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adequacy decisions, where available
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additional technical measures
RETENTION
We store personal data only as long as necessary:
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Account data: while active, then up to 3 years
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Training data: while active, then up to 12 months
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Test data for non-members: up to 12 months
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Newsletter data: until unsubscribe, then up to 3 years
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Invoices: 7 years
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Logs: up to 30 days unless required for security
YOUR RIGHTS
You have the right to:
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access (Art. 15 GDPR)
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rectification (Art. 16 GDPR)
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erasure (Art. 17 GDPR)
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restriction (Art. 18 GDPR)
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data portability (Art. 20 GDPR)
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objection (Art. 21 GDPR)
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withdraw consent (Art. 7 GDPR)
Requests can be sent to: info@kofifootball.com
COMPLAINTS AUTHORITY
SECURITY
We use appropriate technical and organisational measures to protect personal data.
No system can be guaranteed to be fully secure.
AUTOMATED DECISION-MAKING
We do not use automated decision-making or profiling within the meaning of Art. 22 GDPR.
CHILDREN
Our services are intended for users aged 16 and above.
We do not knowingly collect personal data from children under 16.
UPDATES
This privacy policy may be updated.
The current version is always published on this website.