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PRIVACY POLICY

LAST UPDATED

20 July 2026

CONTROLLER

Kofi Schulz

Leopold Gattringer-Straße 42/1
2345 Brunn am Gebirge

Austria
 

Email: info@kofifootball.com

SCOPE

This policy applies when you:

 

  • visit the website

  • create an account

  • use the member area

  • take the Elite Standards Test

  • purchase or use the Standards Reset

  • subscribe to PlayerZone

  • subscribe to emails

  • contact us

  • comment a keyword on our Instagram posts or reply to our Instagram Stories, and receive an automatic reply

 

Personal data means any information that can identify you.

DATA WE PROCESS

Account data:

  • name

  • email address

  • encrypted or hashed password

 

Profile data:

  • profile picture, if uploaded

 

Training and performance data:

  • training progress

  • performance records created by you

 

Test data:

  • age range, country, playing level, and training environment

  • answers to the Elite Standards Test

  • email address for report delivery

  • for players under 16, the email address of a parent or guardian, and a

  • record of the date and time permission was confirmed

  • generated report

 

Technical data​:

  • IP address

  • device and browser information

  • log data such as time, page, and referrer

 

Marketing and analytics data:​

  • cookie identifiers

  • interaction events, only after consent
     

Feedback data:
Your rating, your answers, the product and area you completed, and the date.

Testimonial data:
If you agree to a testimonial: your first name, the first letter of your last name, your feedback, and, if you choose to share them, your age range and playing level. We also keep a record of your consent: the date, time, and wording you agreed to.

Problem report data:
Your message, an optional screenshot, the page you were on, your device and browser type, the date, and your member ID if you are logged in. We do not collect your email address through this form.

Instagram reply data:

  • Instagram user ID and username

  • text of your comment or Story reply, and the post or Story it was on

  • the message we sent you and whether it was delivered

  • if you tap the link: a shortened code of your IP address, browser type and referring page

PURPOSES AND LEGAL BASES

Website operation and security:

  • Purpose: delivery, stability, abuse prevention

  • Legal basis: legitimate interest (Art. 6(1)(f) GDPR)

  • Legitimate interest pursued: ensuring the secure and stable operation of the website and preventing misuse

 

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 a report

  • Legal basis: contract (Art. 6(1)(b) GDPR). By submitting the test, you agree to the test terms: you provide your answers and email address, and we generate and deliver your report.

  • Marketing follow-up only with consent (Art. 6(1)(a) GDPR)

  • For players under 16, the report is delivered to a parent or guardian's email address instead of the player's own, and marketing consent is not requested.

 

Standards Reset:

  • Purpose: process purchase, deliver programme content, manage access

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

PlayerZone:

  • Purpose: process subscription, deliver content, manage access and subscription status

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

Feedback
To improve our products. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).

Testimonials
To publish your feedback on our website and social media, showing only your first name and the first letter of your last name, for example “John S.” Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time by emailing info@kofifootball.com. We then remove your testimonial from our website and our own social media accounts within 14 days.

Problem Reports
To find and fix problems on our website. Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in running a working website. Only add a screenshot if it does not show private information you do not want to share.
 

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.

​

Instagram automatic replies:
Purpose: when you comment a keyword on a post or Reel, or reply to a Story, we send you one private message with the link you asked for, and keep delivery records and link statistics.

Legal basis: contract (Art. 6(1)(b) GDPR) for sending you the link.
Legitimate interest (Art. 6(1)(f) GDPR) for the records and statistics.
Legitimate interest pursued: making sure the service works and seeing which posts help players

Details:
https://reply.kofifootball.com/legal/privacy

​

Legal duties:

  • Purpose: tax, accounting, legal defence

  • Legal basis: legal obligation (Art. 6(1)(c) GDPR) and legitimate interest (Art. 6(1)(f) GDPR)

  • Legitimate interest pursued: establishing, exercising, or defending legal claims

  • Retention: 7 years under Austrian law (§132 BAO)

MANDATORY OR OPTIONAL DATA

Providing personal data is required to create an account, use member features, take the Elite Standards Test, purchase the Standards Reset, subscribe to PlayerZone, or receive reports. If the required data is not provided, we may not be able to deliver the service.
 

Providing data for marketing purposes, feedback, testimonials and problem reports are optional. You can use the service without subscribing to marketing emails.

COOKIES

We use:

 

Essential cookies required for:

  • required for login

  • security

  • core site functions

  • These cookies cannot be disabled.

 

Optional cookies used for:

  • analytics

  • 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:

  • visited pages

  • time on site

  • interactions

  • approximate location

  • device data

 

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

Runs only after consent.

META PIXEL

Used for advertising measurement and targeting.
 

Data processed:

  • page views

  • actions

  • cookie or device identifiers

 

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

Runs only after consent.

EMBEDDED CONTENT

We embed content from:

  • YouTube

  • 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:

  • account-related emails

  • test report delivery

  • newsletters

 

Data processed:

  • email address

  • delivery status

  • interaction data, if enabled

 

Legal basis: contract (Art. 6(1)(b) GDPR) for account and report emails. Consent (Art. 6(1)(a) GDPR) for newsletters.

PAYMENTS

Payments are processed via Wix.

We do not receive or store full payment card details.

 

We may receive:

  • payment status

  • purchased product

  • billing details for invoices

PROCESSORS

We use GDPR-compliant processors with Art. 28 agreements, including:

  • Wix (hosting, accounts, CMS, payments)

  • Brevo (email services)

  • Google (Analytics, if enabled)

  • Meta (Pixel, if enabled)

  • YouTube and Instagram (embedded content)

  • Hetzner Online GmbH (server hosting in Germany, for Instagram automatic replies)


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:

  • The EU-US Data Privacy Framework, where the provider is certified

  • EU Standard Contractual Clauses

  • adequacy decisions, where available

  • additional technical measures where required

RETENTION

We store personal data only as long as necessary:

  • Account data: while active, then up to 3 years

  • Training and performance data: while active, then up to 12 months

  • Test data for non-members: up to 12 months

  • Purchase and subscription data: for the duration of the contract, then as required for invoicing (7 years under §132 BAO)

  • Newsletter data: until unsubscribe, then up to 3 years

  • Invoices: 7 years

  • Logs: up to 30 days unless required for security

  • Feedback: up to 12 months, then deleted or made anonymous.

  • Testimonials: until you withdraw consent. The consent record is kept for up to 3 years after that, to prove consent was given.

  • Problem reports: up to 12 months.

  • Screenshots in problem reports: up to 90 days.

  • Instagram reply data: raw notifications 30 days, message records and link statistics up to 12 months

YOUR RIGHTS

You have the right to:

  • access your personal data (Art. 15 GDPR)

  • rectification of inaccurate data (Art. 16 GDPR)

  • erasure of your data (Art. 17 GDPR)

  • restriction of processing (Art. 18 GDPR)

  • data portability (Art. 20 GDPR)

  • object to processing based on legitimate interest (Art. 21 GDPR)

  • withdraw consent at any time, without affecting the lawfulness of processing before withdrawal (Art. 7 GDPR)

 

Right to object to direct marketing:
You have the right to object at any time to the processing of your personal data for direct marketing purposes. If you object, your data will no longer be processed for that purpose. You can exercise this right by using the unsubscribe link in any email or by contacting us.
 

Requests can be sent to: info@kofifootball.com
 

We will respond to your request within one month. If your request is complex, we may extend this by up to two further months, but we will inform you within the first month.

COMPLAINTS AUTHORITY

Österreichische Datenschutzbehörde

Barichgasse 40–42

1030 Wien

Austria
 

Email: dsb@dsb.gv.at

SECURITY

We use appropriate technical and organisational measures to protect personal data.

No system can be guaranteed to be fully secure.

DATA BREACH

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with Art. 34 GDPR.

AUTOMATED DECISION-MAKING

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects within the meaning of Art. 22 GDPR.

The Elite Standards Test generates a report based on your answers. This is an informational tool and does not produce legal effects or restrict your access to any service.

CHILDREN

Under Austrian law (§4(4) DSG), users who have reached the age of 14 can consent independently to the processing of their personal data for online services. Users under 14 require parental or legal guardian consent.
 

We do not knowingly collect personal data from children under 14 without parental consent. If we become aware that we have collected data from a child under 14 without valid parental consent, we will delete that data.

If you are a parent or guardian and believe your child under 14 has provided personal data without your consent, please contact us at info@kofifootball.com.
 

Players under 16:

If you tell us you are under 16, we ask you to confirm that a parent or guardian has permitted you before the test continues. We record the date and time of that confirmation. We then send your report to a parent or guardian's email address rather than yours. You will not receive our marketing emails, and we will never add you to our mailing list. If you are a parent or guardian and did not give permission, or you want the report and answers deleted, contact us at info@kofifootball.com.
 

Note:
Other EU Member States may set different age thresholds (between 13 and 16). The threshold that applies to you depends on where you live.

UPDATES

This privacy policy may be updated. The current version is always published on this website.

WE USE COOKIES
This site uses cookies to see how it performs. Nothing is shared or sold. Read our Privacy Policy.
This site uses cookies to see how it performs.
Nothing is shared or sold. Read our Privacy Policy.
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