Verwerkersovereenkomst en Beveiligingsbeleid TablePlay Inclusief subverwerkerslijst, technische en organisatorische maatregelen, responsible disclosure en toegankelijkheidsverklaring
TablePlay by Jimani Jimani B.V. Albert Plesmanweg 122, 4462 GC Goes KvK 91644453 - Btw NL865722729B01 support@tableplay.online
Version 1.0 Last updated: 10 July 2026
Legal review note This document has been prepared for business use by TablePlay. Have the final publication, international application, current suppliers, technical set-up and country-specific rules periodically reviewed by legal counsel.
Table of Contents Part A - Data Processing Agreement Schedule 1 - Sub-processors Schedule 2 - Technical and organisational measures Part B - Security and Coordinated Vulnerability Disclosure Part C - Accessibility Statement
Data Processing Agreement and Security Policy TablePlay
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Part A - Data Processing Agreement Article 1 - Parties This Data Processing Agreement applies between the business customer of TablePlay as Controller and Jimani B.V., trading under the name TablePlay by Jimani, Albert Plesmanweg 122, 4462 GC Goes, KvK 91644453, as Processor. The parties are jointly referred to as the Parties.
Article 2 - Applicability and formation This agreement applies insofar as TablePlay processes personal data on behalf of and for the benefit of the Customer and forms an integral part of the principal agreement. It is formed by electronic acceptance, signature or actual use of the Service. For processing operations for which TablePlay independently determines the purposes and means, TablePlay is the controller and the Privacy Statement applies. In the event of a conflict regarding processing on behalf of the Customer, this Data Processing Agreement shall prevail over the General Terms and Conditions.
Article 3 - Subject matter, duration and nature TablePlay processes personal data for restaurant-related game, table, QR, score, leaderboard, dashboard and support functionalities. The processing continues for the duration of the principal agreement and a limited period thereafter for deletion, return, back-up rotation, statutory obligations and legal protection. The processing may include collecting, recording, organising, structuring, storing, consulting, calculating, combining within the restaurant context, displaying, transmitting, restricting, deleting and anonymising.
Article 4 - Purposes • Linking QR codes to restaurant and table. • Starting and conducting game sessions. • Processing temporary nicknames, game choices, answers, scores and results. • Facilitating table-versus-table games and temporary leaderboards. • Displaying restaurant-related statistics. • Preventing duplicate, fraudulent or technically invalid sessions. • Technical support, security, continuity and recovery. • Deletion or anonymisation after retention periods.
Article 5 - Categories of data subjects • Guests and players of the Customer. • Contact persons, users, employees and auxiliary persons of the Customer. • Persons referred to in a support report.
Article 6 - Categories of personal data • Temporary nickname, table number or unique table ID and restaurant or location ID. • Game session ID, chosen game, play mode, answers, actions, score, result and ranking. • Date, time and temporary language setting. • Technical session, IP, browser and device data insofar as present in security logs.
Data Processing Agreement and Security Policy TablePlay
Page 3 of 10 • Name and business email address of a contact person and content of support enquiries. • Other data entered within the agreed functionality. TablePlay is not intended for special categories of data, criminal, medical or biometric data, or extensive directly identifiable guest profiles. The Customer shall not instruct such processing without a prior written agreement.
Article 7 - Documented instructions The principal agreement, this Data Processing Agreement, customer portal settings and lawful support requests constitute instructions. TablePlay does not process data for other purposes, except for statutory obligations, its own independent security and legal protection purposes, or processing after adequate anonymisation. In the event of a suspected unlawful instruction, TablePlay shall inform the Customer, unless legally prohibited from doing so, and may suspend performance. Additional extensive instructions may be invoiced separately.
Article 8 - Obligations of the Client The Client warrants lawfulness, valid legal basis, information to Guests, lawful instructions, data minimisation, internal security and protection of login credentials. The Client is responsible for accuracy and quality, does not require real names from Guests and does not use Game Data for individual marketing or profiling without an independent legal basis. Security incidents and unlawful instructions shall be reported without delay.
Article 9 - Confidentiality Persons under the authority of TablePlay are given access only to the extent necessary, are bound by confidentiality and process only in accordance with instructions. This obligation shall remain in force after termination. Disclosure to third parties shall take place solely on the basis of this agreement, the principal agreement or the law.
Article 10 - Security TablePlay shall implement appropriate technical and organisational measures having regard to the state of the art, costs, nature, scope, context, purpose and risk. The measures are set out in Schedule 2 and may be amended provided the overall level of protection is not materially reduced. No system can guarantee absolute security.
Article 11 - Data breaches TablePlay shall inform the Client without undue delay after becoming aware of a breach of personal data processed on behalf of the Client. Where possible, the nature, systems, categories of data and data subjects, consequences, measures and contact information shall be provided. Information may be provided in phases. TablePlay shall investigate, contain, retain relevant evidence and carry out remediation. The Client shall assess the statutory notification obligation and TablePlay shall provide reasonable support. A notification does not constitute an admission of liability. Work required due to circumstances within the responsibility of the Client may be carried out at reasonable cost.
Article 12 - Requests from data subjects Direct requests concerning the Client's role shall in principle be forwarded. TablePlay shall only respond independently on instruction, in its own capacity or where legally required. TablePlay shall provide reasonable support with respect to access, rectification, erasure, restriction, portability and objection.
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Because Guests do not have an Account, identification may be limited. Restaurant, table, date, time, nickname and game context may be required. Data shall not be provided if it is not sufficiently established that it relates to the requester.
Article 13 - Support for compliance TablePlay shall provide reasonable support with respect to security, data breach assessments, data protection impact assessments, prior consultation and necessary documentation. Extensive support beyond the standard service may be invoiced, unless it results from a shortcoming on the part of TablePlay.
Article 14 - Sub-processors The Client grants general authorisation for the sub-processors named in Schedule 1. TablePlay may add, replace or remove such sub-processors and shall maintain an up-to-date electronic list. In the event of a new material sub-processor, TablePlay shall in principle provide thirty days' prior notice. The Client may, within that period, raise a reasoned objection on specific data protection grounds. The parties shall seek additional safeguards, limitation or a technical alternative. If no reasonable solution exists, the Client may terminate the directly affected part prior to deployment. TablePlay shall impose substantially equivalent obligations and shall remain responsible to the extent required by the GDPR.
Article 15 - International transfers Personal data shall, where possible, be processed within a European region. Sub-processors or group companies may be located outside the EEA or have access from outside the EEA. Where required, TablePlay shall use adequacy decisions, standard contractual clauses, supplementary measures or other valid mechanisms. Upon reasonable request, information shall be provided having regard to confidentiality.
Article 16 - Requests from authorities TablePlay shall disclose data solely to competent authorities where subject to a lawful obligation. Where permitted, the Client shall be informed in advance. TablePlay shall assess authority, scope and legal validity and shall limit disclosure where possible.
Artikel 17 - Audits and Information TablePlay makes reasonable information available, including security documentation, audits, certifications, questionnaires or assurance statements. If this is insufficient, the Customer may request an audit a maximum of once per calendar year with thirty days' notice, during business hours, by an independent expert bound by confidentiality, without damage to security, confidentiality or other customers. The Customer bears the costs unless a material attributable breach is established. TablePlay may withhold source code, other customer data, vulnerability details and commercially sensitive information where a sufficient alternative exists.
Artikel 18 - Return and Deletion After termination, TablePlay shall delete or return, at the Customer's choice and to the extent technically and legally possible, data that is processed solely on behalf of the Customer. The choice must be communicated no later than within thirty days. In the absence of a choice, TablePlay may delete or anonymise in accordance with the standard policy. Backups may contain data for a maximum of one month and shall be used solely for restoration purposes.
Data that is legally required, necessary for legal protection, or anonymised need not be deleted.
Artikel 19 - Liability The liability provisions from the General Terms and Conditions also apply. Each party is responsible for its own privacy obligations. The Customer indemnifies TablePlay against claims arising from unlawful instructions, absence of a legal basis, insufficient information, unlawful use of Game Data or the input of prohibited sensitive data, to the extent permitted by law.
Artikel 20 - Term and Termination This Data Processing Agreement ends when TablePlay no longer processes personal data on behalf of the Customer. Confidentiality, security, deletion, liability and audits shall continue to apply to the extent their nature so requires.
Artikel 21 - Governing Law and Disputes This Data Processing Agreement is governed by Dutch law. Disputes shall be dealt with in accordance with the General Terms and Conditions.
Bijlage 1 - Subprocessors Leverancier
Dienst
Mogelijke gegevens
Regio / rol
Supabase
Database, authentication, storage and backend Accounts, table data, nicknames, sessions, scores Primary and logs EU region where configured; core subprocessor
Vercel
Hosting, runtime, content delivery and IP address, logging request, browser, device and application data EEA and potentially US; hosting subprocessor
Twilio SendGrid
Transactional and operational email Name, email address, account information, content and International; delivery status email subprocessor
OpenAI / other AI provider Only when AI features are activated
Limited data necessary for the Depending function on configuration; potential subprocessor
Stripe
Business data, invoices, transactions and payment status International; role varies per processing
Payments, invoicing and fraud
Google / Meta / LinkedIn Analytics and marketing following consent Website, device, advertising and conversion data International; generally not a subprocessor for re
The current list is made available via the website or the customer portal. In the event of a material new subprocessor, the notification and objection procedure from artikel 14 shall apply. TablePlay shall not provide identifiable guest data to an AI provider for general model training, unless this is later expressly, lawfully and transparently arranged otherwise.
Bijlage 2 - Technical and Organisational Measures 1. Access Security • Unique user accounts and secure authentication. • Hashed passwords and restriction of administrative rights. • Access based on role and necessity. • Revocation of access when no longer required. • Additional authentication measures where appropriate.
2. Logical Data Segregation • Segregation between business Accounts and tenant-specific authorisation.
- Supabase Row Level Security where technically applicable.
- Restriction of access to other Customers' data.
- Unique table identifiers.
3. Transport and Storage • HTTPS and TLS secured connections. • Secure communication between browser, application, backend and APIs. • Storage at selected cloud providers. • Restricted staff access and contractual confidentiality. • No storage of passwords in directly readable form.
4. Availability, Logging and Recovery • Backups and recovery facilities where appropriate. • Monitoring of technical errors and relevant login attempts. • Detection and investigation of anomalous use. • Backups in principle for a maximum of one month. • Logs in principle for a maximum of one year, unless longer retention is required for an incident or dispute.
5. Secure development and supplier management • Version control, code review and controlled deployment where appropriate. • Restriction of secrets and keys in source code. • Timely updates of relevant components. • Assessment and remediation of reported vulnerabilities. • Selection of professional suppliers, contractual arrangements and transfer mechanisms.
6. Data minimisation and incident management • No mandatory real names, email or phone number for Guests. • Temporary nicknames and limited leaderboard visibility. • Deletion or anonymisation after retention periods. • Internal escalation process, investigation, registration, assessment of notification obligations and remediation measures.
Part B - Security and Coordinated Vulnerability Disclosure 1. Purpose and reporting address TablePlay values the security of the website, Platform, infrastructure and data. Possible technical vulnerabilities can be reported confidentially via support@tableplay.online with the subject Security report - confidential.
2. Contents of a report • Clear description of the vulnerability. • Domain, endpoint, screen or system involved.
Processor Agreement and Security Policy TablePlay
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3. Permitted actions • Only actions necessary to establish existence. • Keep impact and data access as limited as possible. • Do not change, delete or download data of third parties. • Do not affect availability and stop as soon as sufficient evidence exists. • Only investigate systems that are demonstrably under the control of TablePlay.
4. Prohibited actions • Social engineering, phishing, physical attacks, brute force and credential stuffing. • Account takeovers, denial-of-service, malware or persistent access. • Modifying, deleting, copying or disclosing data. • Actual manipulation of payments, invoices, coupons or scores. • Investigation of external suppliers without their consent. • Onerous automated scans. • Disclosure before a reasonable investigation and remediation period has been provided. • Extortion or coercing payment through threats.
5. Response and disclosure TablePlay aims to acknowledge receipt within five business days, assess the report, ask questions where necessary, keep the reporter informed on the main points and mitigate a verified vulnerability as soon as reasonably possible. The remediation time depends on severity, complexity, suppliers and necessary tests. TablePlay does not guarantee a fixed timeframe. Details will not be disclosed until TablePlay agrees, a reasonable date has been agreed, or at least ninety days have passed without a reasonable substantive response or remediation attempt. Personal data, authentication data and exploit code will not be published.
6. No general bug bounty and legal approach TablePlay does not operate a general bug bounty programme and a report does not give rise to any right to payment, an assignment or publicity. TablePlay may, at its own discretion, provide appreciation. TablePlay will in principle not take legal action against a researcher who acts in good faith, within this policy, without causing damage, confidentially and without extortion. This commitment does not apply in the case of evidently criminal, harmful, fraudulent or disproportionate actions and does not bind third parties or authorities.
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7. security.txt TablePlay may publish a technical file at /.well-known/security.txt with a reporting address, policy link, languages, expiry date and, where applicable, an encryption key. This file must be periodically checked and renewed.
Part C - Accessibility Statement 1. Ambition and reference framework TablePlay strives to make the website, registration, customer portal and guest games usable for a broad range of users, including persons with visual, auditory, motor or cognitive impairments. Where reasonably possible, the principles of WCAG 2.2 level AA are used as a technical and substantive reference framework. This does not constitute a guarantee that every component fully complies under all circumstances.
2. Current status The full environment has not yet been independently and comprehensively audited. TablePlay therefore does not currently claim full formal WCAG 2.2 AA conformity. Possible limitations concern real-time game components, time pressure, drag-and-drop, animations, external payment or authentication pages, translations, older colour displays and touch-oriented functions.
3. Measures • Semantic HTML and usable labels where appropriate. • Keyboard operability of essential functions and visible focus. • Sufficient contrast and scalable text. • Alternative text for informative images. • No essential information conveyed by colour alone. • Understandable error messages and consistent navigation. • Clear buttons and links. • Support for common browsers and screen sizes. • Limitation of unnecessary animation. • Understandable language in the guest environment. • Automated and manual testing where possible.
4. Games and time pressure Some games are inherently time-bound by nature. Where technically and content-wise possible, TablePlay may offer alternative play modes, extended time limits, less movement, visual alternatives for sound and text or symbols in addition to colour. Not every game mode is equally suitable for every user. Restaurants are encouraged to offer multiple game types.
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5. Responsibility of the business customer The Customer remains responsible for the physical and operational accessibility of the Venue, including placement of QR codes, legibility of printed materials, alternative assistance, accessibility of screens, support by staff and own content. QR codes shall be placed so as to be reachable and visible and, where reasonably possible, an alternative shall be offered to Guests who are unable to scan independently.
6. Reporting and alternative access Accessibility issues can be reported via support@tableplay.online, stating the page or game, device, browser, assistive technology, description and desired solution. TablePlay strives to acknowledge receipt within five working days and to provide a substantive response within a reasonable period. Where possible, information may be provided by email, support, an alternative instruction, manual processing or another play option.
7. Disproportionate burden and improvement An adjustment may be postponed where it is not technically feasible, materially compromises security, changes the fundamental nature of a game, is dependent on an external supplier, or constitutes a disproportionate organisational or financial burden. TablePlay will then assess an alternative. TablePlay may take accessibility into account in design, testing, prioritisation, user feedback and external audits, and may update this statement.
8. Contact TablePlay by Jimani - Jimani B.V. - Albert Plesmanweg 122 - 4462 GC Goes - The Netherlands - Trade Register No. 91644453 - VAT NL865722729B01 - support@tableplay.online.
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Additional sub-processor list This sub-processor list forms part of the Data Processing Agreement and Security Policy of TablePlay. The current list may change when suppliers, regions or functions change.
Supplier: Supabase Service: database, authentication, storage and backend. Possible data: accounts, table data, nicknames, sessions, scores and logs. Region / role: primarily EU region insofar as configured; core sub-processor.
Supplier: Vercel Service: hosting, runtime, content delivery and logging. Possible data: IP address, request, browser, device and application data. Region / role: EEA and possibly US; hosting sub-processor.
Supplier: Twilio SendGrid Service: transactional and operational email. Possible data: name, email address, account information, content and delivery status. Region / role: international; email sub-processor.
Supplier: OpenAI / other AI supplier Service: only when AI functions are activated. Possible data: limited data necessary for the function. Region / role: dependent on configuration; potential sub-processor. TablePlay does not provide identifiable guest data to an AI supplier for general model training, unless this is later expressly, lawfully and transparently arranged otherwise.
Supplier: Stripe Service: payments, invoicing and fraud. Possible data: business data, invoices, transactions and payment status. Region / role: international; role varies per processing activity.
Supplier: Google / Meta / LinkedIn Service: analytics and marketing following consent. Possible data: website, device, advertising and conversion data. Region / role: international; generally not a sub-processor for restaurant game data.
