Privacy policy

The controller for the personal data described here, under Article 4(7) of the General Data Protection Regulation (GDPR), is:

Full company details are in the legal notice.

We have not appointed a data protection officer. We are not required to under Article 37 GDPR. Questions about data protection go to privacy@tencoline.com, which a person reads.

This policy covers tencoline.com and the Tencoline application. It applies to visitors who only read the public pages, and to account holders who upload and analyse video.

A coach, club or academy that uploads video of other people is a controller in their own right for that video. We are their processor. The terms for that relationship are in the data processing agreement, and this policy then describes what we do as their processor.

What you give us

• Account. Your email address and a password. The password is never stored. We store a bcrypt hash of it, which cannot be turned back into the password.
• Video. The match videos you upload, the audio in them, the original file name, and the file size.
• Marks. The shot marks, comments, drawings and match scores you create on a video, and the earlier versions of them.
• Share links. The links you create to show a video to someone else, and the reactions people leave through them.

What the service records as you use it

• Sign-in sessions. A hash of the session token, when it was created, when it expires, and when it was last used.
• Views and watch time. Which video was opened, by which account, from which surface, and for how long it was watched. A video owner sees this for their own videos.
• Upload volume. The number of bytes you upload each month, used to apply the storage quota for your plan.
• Results of analysis. Shot types, timings and the match statistics computed from a video.

What your browser sends

• Server logs. Our web server records the IP address, the time, the requested address and the browser identification for each request. We use these to keep the service running and to investigate abuse.
• Country. We read a country code from the network request to decide whether to show the cookie hint. We do not look up your IP address in a location database. If the country cannot be read, we treat you as being in the EU and show the hint.
• Cookies and local storage. Described in the cookie policy.

Where we rely on legitimate interests, we have weighed our interest against yours. You can object to that processing under Article 21 GDPR. See your rights.

A match video usually shows more than the person who uploaded it. It can show an opponent, a coach, a hitting partner, and people beside the court. Their image and their voice are their personal data, not yours.

You are responsible for the legal basis to film them and to upload the recording. Before you upload, you need the agreement of the people who can be recognised in it. For a person under 18, you need the agreement of a parent or guardian. The rules are set out in the acceptable use policy, and they are part of the terms of service.

A video is private by default. Only you and the people you explicitly grant access to can open it. We do not publish it, we do not index it, and we do not use it to train models unless you ask us to.

If you appear in a video on this service and you did not agree to it, write to privacy@tencoline.com. Tell us the share link or the address of the page you saw. We will act on it, and we will contact the account that uploaded it.

Accounts are for people aged 16 and over. We do not knowingly create an account for a child under 16 in the EU, or under 13 in the United States. A younger player can appear in a video that a parent, coach or club uploads and controls. If you believe a child holds an account, write to privacy@tencoline.com and we will remove it.

Tencoline finds shots in a video automatically. To do that it detects the sound of a ball strike, locates the players in the frame, and estimates the position of their limbs so it can tell a forehand from a backhand.

None of this identifies anybody. The limb positions describe a movement, not a person. They are not compared against any database, they are not matched between videos, and they cannot be used to recognise the same player in another recording. Under Article 4(14) GDPR, data is biometric data when it is processed for the purpose of uniquely identifying a person. We do not process it for that purpose, so Article 9 does not apply to it. The same reasoning applies to the Illinois Biometric Information Privacy Act and the Texas CUBI statute: we collect no face geometry, no voiceprint, and no other identifier of that kind.

The results of the analysis are shot types and timings. They are stored with the video and deleted with it.

One optional step sends a small still image from a video to an external model, to check whether play is in progress at that moment. It is off by default. Where it is switched on, the processor is named in the subprocessor list with its transfer safeguards.

We set one cookie to keep you signed in. It is essential, and it is set only after you sign in.

Analytics are optional. They run only if you accept them, and they never run before you do. You can change your choice at any time, and withdrawing it is as easy as giving it.

Every cookie and every stored value is listed in the cookie policy, together with the controls to accept or decline analytics.

We do not sell personal data. We have never sold it.

Your data reaches other companies in three cases only.

• Service providers we use to run Tencoline. Each one is bound by a contract under Article 28 GDPR, may act only on our instructions, and is listed in the subprocessor list.
• People you share a video with. When you create a share link or grant access, the person you give it to can watch that video and see the marks on it. You control this and can revoke it.
• Authorities, where the law requires it. We check every request, we hand over the minimum, and we tell you unless we are forbidden to.

Your account, your video and your marks are stored in Germany. They do not leave the European Union in normal use.

Two optional services can transfer data to the United States: the analytics you can decline, and the frame check that is off by default. Both are covered by the European Commission's Standard Contractual Clauses, and the subprocessor list records the safeguard for each one.

We keep personal data for as long as it has a purpose, and then we delete it. The third column says what makes each period happen, because a period nothing enforces is not a period.

Where German commercial and tax law requires it, invoices and the records behind them are kept for six or ten years (§ 257 HGB, § 147 AO). During that time they are blocked from any other use.

Under the GDPR you have the right to:

• Access (Art. 15) — a copy of the data we hold about you.
• Rectification (Art. 16) — correction of data that is wrong.
• Erasure (Art. 17) — deletion of your data.
• Restriction (Art. 18) — a pause on processing while a dispute is resolved.
• Portability (Art. 20) — your data in a machine-readable form.
• Objection (Art. 21) — to processing based on legitimate interests.
• Withdrawal of consent (Art. 7(3)) — at any time, without affecting what was lawful before.

To use any of them, write to privacy@tencoline.com. We answer within one month. If a request is complex we may extend that by two months, and we will tell you why before the first month ends. We do not charge for this.

There is no button in the application for account deletion or data export yet. Until there is, email is the way, and it carries the same deadline and the same obligation.

You can also complain to a data protection authority (Art. 77 GDPR). You can complain to the authority where you live, where you work, or where the problem happened. The authority responsible for us is Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany (website).

This section is the notice required by the California Consumer Privacy Act as amended by the CPRA. It also describes the rights given by the privacy laws of Virginia, Colorado, Connecticut, Utah, Texas and other states with comparable statutes. Where a state law gives you more, that law applies.

What we collect, in the categories the statute uses

We do not sell or share your personal information

We do not sell personal information. We do not share it for cross-context behavioural advertising. We have not done either in the last twelve months, and we do not do it for anyone under 16. Because we do not, there is no “Do Not Sell or Share My Personal Information” link to give you. Nothing to opt out of is better than an opt-out.

Sensitive personal information

We do not use or disclose sensitive personal information for any purpose other than running the service, so the right to limit its use does not arise. See section 6 for why the analysis of a video is not biometric information.

Your rights

• To know what we collect, use and disclose, and to get a copy.
• To have it corrected.
• To have it deleted.
• To opt out of sale, sharing, and profiling with legal effects. None of the three happens here.
• Not to be treated worse for using any of these rights. We do not.

Write to privacy@tencoline.com. We answer within 45 days and may extend that once by another 45, with notice. We verify a request against the email address on the account. An authorised agent may act for you with written permission that we can check.

Global Privacy Control

If your browser sends a Global Privacy Control signal, we treat it as an opt-out and analytics stay switched off, with no further action from you. The cookie page shows whether we are receiving that signal from your browser right now.

• Every connection uses HTTPS.
• Passwords are stored as bcrypt hashes, never as text.
• The session cookie is HttpOnly, Secure in production, and SameSite=Lax, so a script cannot read it and another site cannot send it.
• Access to a video is checked on the server for every request, against the account making it. The list a browser shows is never the thing that decides.
• Repeated failed sign-ins are rate limited and blocked at the server.
• Only administrators can reach the administration pages, checked server-side.

If you find a security problem, write to security@tencoline.com. We will not take legal action against anyone who reports a problem in good faith and gives us a reasonable time to fix it.

If a data breach is likely to put your rights at risk, we will tell the supervisory authority within 72 hours and tell you without undue delay (Art. 33 and 34 GDPR).

We make no decision about you that is based only on automated processing and that has a legal or similarly significant effect (Art. 22 GDPR). The automatic shot recognition produces suggestions on a timeline. A person accepts, corrects or removes each one.

We update this policy when the service changes. The version number and the date at the top say which text you are reading. If a change affects you materially, we will tell you by email or in the application before it takes effect, and we will not apply it retroactively.