Data Processing Agreement and Security Policy TablePlay 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 KvK 91644453 - Btw NL865722729B01 support@tableplay.online
Version 1.0 Last updated: 10 July 2026
Legal review note This document has been drafted for business use by TablePlay. Have the final publication, international application, current suppliers, technical set-up and country-specific rules reviewed periodically 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
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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 as 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 to the extent that TablePlay processes personal data on behalf of and for the benefit of the Customer and forms an integral part of the main agreement. It is formed by electronic acceptance, signature or actual use of the Service. For processing for which TablePlay independently determines the purposes and means, TablePlay is the controller and the Privacy Statement applies. In the event of any 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 lasts for the duration of the main agreement and a limited period thereafter for deletion, return, back-up rotation, statutory obligations and legal defence. The processing may include collecting, recording, organising, structuring, storing, consulting, calculating, combining within the restaurant context, displaying, transmitting, restricting, erasing and anonymising.
Article 4 - Purposes • Linking QR codes to restaurant and table. • Starting and running 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 ticket.
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 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 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 defence purposes, or processing following adequate anonymisation. In the event of a suspected unlawful instruction, TablePlay shall inform the Customer, unless prohibited by law, and may suspend performance. Additional extensive instructions may be invoiced separately.
Article 8 - Obligations of the Customer The Customer is responsible for lawfulness, valid legal basis, information to Guests, lawful instructions, data minimisation, internal security and protection of login credentials. The Customer 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 only process in accordance with instructions. This obligation continues to apply after termination. Disclosure to third parties takes place solely on the basis of this agreement, the principal agreement or the law.
Article 10 - Security TablePlay implements appropriate technical and organisational measures, taking into account the state of the art, costs, nature, scope, context, purpose and risk. The measures are set out in Schedule 2 and may be adjusted provided the overall level of protection is not materially diminished. No system can guarantee absolute security.
Article 11 - Data Breaches TablePlay shall inform the Customer without undue delay after becoming aware of a breach of personal data being processed on behalf of the Customer. Where possible, information shall be provided on the nature, systems, categories of data and data subjects concerned, consequences, measures and contact details. Information may be provided in phases. TablePlay shall investigate, contain, retain relevant evidence and carry out remediation. The Customer shall assess the statutory notification obligation and TablePlay shall provide reasonable support. A notification does not constitute an admission of liability. Work carried out due to circumstances within the Customer's responsibility may be performed at a reasonable cost.
Article 12 - Requests from Data Subjects Direct requests relating to the Customer's role shall in principle be forwarded. TablePlay only responds independently on instruction, in its own capacity or in the event of a statutory obligation. TablePlay shall provide reasonable support with access, correction, 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 security, data breach assessments, data protection impact assessments, prior consultation and necessary documentation. Extensive support beyond the standard service may be invoiced, unless it arises from a shortcoming on the part of TablePlay.
Article 14 - Sub-processors The Customer grants general consent for the sub-processors listed in Schedule 1. TablePlay may add, replace or remove these and maintains an up-to-date electronic list. In the event of a new material sub-processor, TablePlay shall in principle provide notice thirty days in advance. Within that period, the Customer 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 Customer may terminate the directly affected part prior to deployment. TablePlay shall impose substantially equivalent obligations and remains responsible to the extent provided for under 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 have access from outside the EEA. Where required, TablePlay uses 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 only provide data to competent authorities where there is a lawful obligation to do so. Where permitted, the Customer shall be informed in advance. TablePlay shall assess competence, scope and legal validity and shall limit disclosure where 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, by an independent expert bound by confidentiality, without damage to security, confidentiality or other customers. The Customer shall bear the costs unless a material attributable breach is established. TablePlay may shield 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 its standard policy. Back-ups may contain data for a maximum of one month and shall be used solely for recovery purposes.
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Data that is legally required, necessary for legal protection, or anonymised need not be deleted.
Article 19 - Liability The liability provisions of 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 lawful 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 that their nature so requires.
Article 21 - Governing Law and Disputes This Data Processing Agreement shall be governed by Dutch law. Disputes shall be dealt with in accordance with the General Terms and Conditions.
Annex 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 the 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 functions 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 activity
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 set out in Article 14 shall apply. TablePlay shall not provide identifiable guest data to an AI supplier for general model training, unless this is later explicitly, lawfully and transparently arranged otherwise.
Annex 2 - Technical and Organisational Measures 1. Access Security • Unique user accounts and secure authentication. • Hashed passwords and limitation 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.
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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 • Back-ups and recovery provisions where appropriate. • Monitoring of technical errors and relevant login attempts. • Detection and investigation of anomalous use. • Back-ups in principle for a maximum of one month. • Logs in principle for a maximum of one year, unless a longer period 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, notification obligation assessment, and remedial measures.
Part B - Security and Coordinated Vulnerability Disclosure 1. Purpose and Reporting Address TablePlay attaches importance to the security of its website, Platform, infrastructure, and data. Potential technical vulnerabilities can be reported in confidence via support@tableplay.online with the subject line Security report - confidential.
2. Content of a Report • Clear description of the vulnerability. • Domain, endpoint, screen, or system involved.
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Page 7 of 10 • Reproducible steps and potential impact. • Limited screenshots or technical evidence data. • 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 any third-party data. • Do not affect availability and stop as soon as sufficient evidence exists. • Only investigate systems 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. • Burdensome automated scans. • Disclosure before reasonable investigation and remediation time has been provided. • Extortion or coercing payment through threats.
5. Response and Disclosure TablePlay aims to confirm receipt within five working days, assess the report, ask questions where necessary, inform the reporter of the general course of action, and 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 timeframe. Details will not be disclosed publicly before TablePlay agrees, a reasonable date has been agreed upon, 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 entitle the reporter to payment, commission, or publicity. TablePlay may, at its own discretion, provide a token of 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 containing the reporting address, policy link, languages, expiry date, and, where applicable, an encryption key. This file must be reviewed and renewed periodically.
Part C - Accessibility Statement 1. Ambition and Reference Framework TablePlay aims 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 is fully compliant 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 compliance. 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 solely through colour. • 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 time-bound by their nature. 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 game mode is equally suitable for every user. Restaurants are encouraged to offer multiple game types.
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5. Responsibility of business customer The Customer remains responsible for physical and operational accessibility of the Venue, including placement of QR codes, legibility of printed materials, alternative assistance, accessibility of screens, staff support, and own content. QR codes will be placed within reach and visibly, and where reasonably possible, an alternative will be offered to Guests who cannot 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 to send an acknowledgement of receipt within five business days and a substantive response within a reasonable period. Where possible, information may be offered by email, support, an alternative instruction, manual processing, or another way of playing.
7. Disproportionate burden and improvement An adjustment may be postponed where it is not technically feasible, materially undermines 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 - NZBN 91644453 - VAT NL865722729B01 - support@tableplay.online.
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Supplementary 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 where 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 expressly, lawfully, and transparently arranged otherwise at a later date.
Supplier: Stripe Service: payments, invoicing, and fraud. Possible data: business data, invoices, transactions, and payment status. Region / role: international; role differs 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.
