Data Processing Agreement and TablePlay Security Policy Including sub-processor list, technical and organisational measures, responsible disclosure and accessibility statement
TablePlay by Jimani Jimani B.V. Albert Plesmanweg 122, 4462 GC Goes Companies Registration Office 91644453 - VAT 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 Annex 1 - Sub-processors Annex 2 - Technical and organisational measures Part B - Security and Coordinated Vulnerability Disclosure Part C - Accessibility Statement
Data Processing Agreement and TablePlay Security Policy
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Part A - Data Processing Agreement Article 1 - Parties This data processing agreement applies between the business customer of TablePlay as Data Controller and Jimani B.V., trading under the name TablePlay by Jimani, Albert Plesmanweg 122, 4462 GC Goes, Companies Registration Office 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 the instructions and on behalf of the Customer and forms an integral part of the main agreement. It comes into existence through electronic acceptance, signature or actual use of the Service. For processing in respect of which TablePlay independently determines the purposes and means, TablePlay is data controller and the Privacy Statement applies. In the event of a conflict concerning 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 lasts for the duration of the main agreement and a limited period thereafter for deletion, return, back-up rotation, statutory obligations and legal protection. The processing may include collection, recording, organisation, structuring, storage, consultation, calculation, combination within the restaurant context, display, transmission, restriction, deletion and anonymisation.
Article 4 - Purposes • Linking QR codes to restaurant and table. • Starting and carrying out 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 named 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, game 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 TablePlay Security Policy
Page 3 of 10 • Name and business e-mail address of a contact person and content of support queries. • Other data entered within the agreed functionality. TablePlay is not intended for special category, 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 main 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 following adequate anonymisation. In the event of a suspected unlawful instruction, TablePlay shall inform the Customer, unless this is prohibited by law, and may suspend performance. Additional extensive instructions may be invoiced separately.
Article 8 - Obligations of the Client The Client shall be responsible for lawfulness, valid legal basis, information to Guests, lawful instructions, data minimisation, internal security and protection of login credentials. The Client shall be responsible for accuracy and quality, shall not require real names from Guests and shall 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 shall be granted access solely to the extent necessary, shall be bound by confidentiality and shall process data only in accordance with instructions. This obligation shall continue to apply 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 Annex 2 and may be amended provided that 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, information shall be provided on the nature, systems, categories of data and data subjects concerned, consequences, measures taken and contact information. Information may be provided in phases. TablePlay shall investigate, mitigate, preserve relevant evidence and carry out remediation. The Client shall assess the statutory notification obligation and TablePlay shall provide reasonable assistance. A notification shall not constitute an acknowledgement of liability. Work required due to circumstances within the Client's responsibility may be carried out at a reasonable cost.
Article 12 - Requests from data subjects Direct requests relating to the Client's role shall in principle be forwarded. TablePlay shall only respond independently on instruction, in its own role or where required by law. TablePlay shall provide reasonable assistance with access, correction, erasure, restriction, portability and objection.
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As 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 where it is not sufficiently established that it relates to the requester.
Article 13 - Support with compliance TablePlay shall provide reasonable assistance with security, data breach assessments, data protection impact assessments, prior consultation and necessary documentation. Substantial assistance beyond the standard service may be invoiced, unless it arises from a failure on the part of TablePlay.
Article 14 - Sub-processors The Client grants general authorisation for the sub-processors named in Annex 1. TablePlay may add, replace or remove such sub-processors and shall maintain an up-to-date electronic list. In the case of a new material sub-processor, TablePlay shall in principle provide thirty days' prior notice. Within that period, the Client may 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 established outside the EEA or may have access from outside the EEA. Where required, TablePlay shall use adequacy decisions, standard contractual clauses, supplementary measures or other valid mechanisms. Information shall be provided upon reasonable request, subject to confidentiality.
Article 16 - Requests from authorities TablePlay shall provide data to competent authorities solely where there is a lawful obligation to do so. Where permitted, the Client shall be informed in advance. TablePlay shall assess competence, scope and legal validity and shall limit disclosure wherever possible.
Article 17 - Audits and Information TablePlay shall make available reasonable information, including security documentation, audits, certifications, questionnaires or assurance statements. If this is insufficient, the Customer may request an audit no more than once per calendar year, with thirty days' notice, during office hours, conducted by an independent expert bound by confidentiality obligations, without damage to security, confidentiality or other customers. The Customer shall bear 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.
Article 18 - Return and Deletion Following 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 shall 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.
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Legally required data, data necessary for legal protection and anonymised data need not be deleted.
Article 19 - Liability The liability provisions from the General Terms and Conditions shall also apply. Each party is responsible for its own privacy obligations. The Customer shall indemnify 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.
Article 20 - Term and Termination This Data Processing Agreement shall terminate 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.
Article 21 - Governing Law and Disputes This Data Processing Agreement shall be governed by Dutch law. Disputes shall be handled in accordance with the General Terms and Conditions.
Appendix 1 - Sub-processors Supplier
Service
Possible Data
Region / Role
Supabase
Database, authentication, storage and backend Accounts, table data, nicknames, sessions, scores Primary and logs EU region where configured; core sub-processor
Vercel
Hosting, runtime, content delivery and IP address, logging request, browser, device and application data EEA and possibly US; hosting sub-processor
Twilio SendGrid
Transactional and operational email Name, email address, account information, content and International; email delivery statusemail sub-processor
OpenAI / other AI Supplier Only when AI features are activated
Limited data necessary for the function Depending on configuration; potential sub-processor
Stripe
Business data, invoices, transactions and payment status International; role varies per processing operation
Payments, invoicing and fraud
Google / Meta / LinkedIn Analytics and marketing following consent Website, device, advertising and conversion data International; generally not a sub-processor for re
The current list is made available via the website or the customer portal. In the event of a material new sub-processor, the notification and objection procedure from Article 14 shall apply. TablePlay shall not provide identifiable guest data to an AI Supplier for general model training, unless this is expressly, lawfully and transparently arranged otherwise at a later date.
Appendix 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 Separation • Separation between business Accounts and tenant-specific authorisation.
Data Processing Agreement and Security Policy TablePlay
Page 6 of 10 • 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 with selected cloud providers. • Limited employee access and contractual confidentiality obligations. • No storage of passwords in directly readable form.
4. Availability, Logging and Recovery • Backups and recovery provisions 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. Beveiligde ontwikkeling en leveranciersbeheer • 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. Gegevensminimalisatie en incidentbeheer • No mandatory real names, email or telephone number for Guests. • Temporary nicknames and limited leaderboard visibility. • Deletion or anonymisation after retention periods. • Internal escalation process, investigation, recording, assessment of notification obligations and remedial measures.
Part B - Security and Coordinated Vulnerability Disclosure 1. Purpose and reporting address TablePlay attaches importance to the security of the website, Platform, infrastructure and data. Potential technical vulnerabilities can be reported confidentially via support@tableplay.online with the subject Security report - confidential.
2. Content of a report • Clear description of the vulnerability. • Domain, endpoint, screen or system involved.
Page 7 of 10 • Reproducible steps and possible impact. • Limited screenshots or technical evidence. • Browser, device or environment used. • Contact details and, where applicable, a proposal for secure communication.
3. Permitted actions • Only actions necessary to establish the existence [of the vulnerability]. • Keep impact and data access as limited as possible. • Do not modify, delete or download data belonging to 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 period for investigation and remediation has been provided. • Extortion or coercion of payment by means of threats.
5. Response and disclosure TablePlay endeavours to confirm receipt within five working days, to assess the report, to ask questions where necessary, to inform the reporter in broad terms and to mitigate a verified vulnerability as soon as reasonably possible. The remediation time depends on severity, complexity, suppliers and necessary testing. TablePlay does not guarantee a fixed term. Details will not be disclosed publicly before TablePlay agrees, a reasonable date has been agreed, or at least ninety days have elapsed 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 confer any right to payment, assignment or publicity. TablePlay may, at its own discretion, express its 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 cases 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 containing the reporting address, policy link, languages, expiry date and, where applicable, an encryption key. This file must be periodically reviewed 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-based functions.
3. Measures • Semantic HTML and usable labels where appropriate. • Keyboard operability of essential functions and visible focus. • Sufficient contrast and scalable text. • Alternative texts 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 by their nature time-bound. Where technically and content-wise possible, TablePlay may offer alternative play modes, extended time limits, less movement, visual alternatives to sound and text or symbols in addition to colour. Not every play mode is equally suitable for every user. Restaurants are encouraged to offer multiple types of games.
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5. Responsibility of the business Customer The Customer remains responsible for physical and operational accessibility of the Venue, including placement of QR codes, legibility of printed material, alternative assistance, accessibility of screens, support by staff and own content. QR codes are placed within reach and visibly, and where reasonably possible an alternative is 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 aims for acknowledgement of receipt within five business days and a substantive response within a reasonable period. Where possible, information may be offered by e-mail, 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 affects 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 No. 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 e-mail. Possible data: name, e-mail address, account information, content and delivery status. Region / role: international; e-mail 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 differs per processing operation.
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.