Privacy Policy

Note on precedence: For the German market, the German version of this Privacy Policy is the legally binding and authoritative version. This English translation is provided for information purposes. In the event of any discrepancy, the German version prevails.

This Privacy Policy informs you in accordance with Articles 13 and 14 of the General Data Protection Regulation (GDPR) about the processing of your personal data when you use the offerings at tenniix-robot.com, tenniix-robot.de and club.tenniix-robot.com (hereinafter the "Platform") and in the context of the purchase, rental and club use of the Tenniix tennis robot.

1. Controller

The controller within the meaning of Article 4 (7) GDPR is:

Xing Handels GmbH Schumanstr. 12 52146 Würselen Germany Phone: +49 2405 6039810 Email: info@xing-handels.de Represented by: Mr Zhenxing Wang

2. Data protection officer

We have appointed a data protection officer for our company. If you have any questions about data protection or wish to exercise your data subject rights, you can reach our data protection officer at:

Xing Handels GmbH – Data Protection Officer – Schumanstr. 12 52146 Würselen Germany Email: info@xing-handels.de

3. General information on data processing

In principle, we only process the personal data of our users insofar as this is necessary to provide a functional platform and our services. As a rule, processing takes place only with the consent of the user or where processing is permitted by statutory provisions.

Legal bases (overview):

• Article 6 (1) (a) GDPR – consent
• Article 6 (1) (b) GDPR – contract / pre-contractual measures
• Article 6 (1) (c) GDPR – legal obligation (e.g. commercial and tax retention)
• Article 6 (1) (f) GDPR – legitimate interest

Data storage location / third country: All data is processed and stored exclusively on servers within the Federal Republic of Germany or the European Union. No transfer to third countries outside the EU/EEA takes place.

4. Provision of the website and server log files

Each time our Platform is accessed, our system automatically collects data and information from the accessing device.

Data processed: browser type and version, operating system used, referrer URL, date and time of access, amount of data transferred, HTTP status code and a truncated/anonymised IP address.

Purpose: delivery of the website, ensuring system security and stability, defending against and investigating attacks (e.g. DDoS, brute force).

Legal basis: Article 6 (1) (f) GDPR (legitimate interest in secure, trouble-free operation).

Storage period: Server log files are stored for a maximum of 7 days and then deleted. Log data required to investigate a specific security incident is retained until the matter has been finally resolved.

5. Hosting

Our Platform is operated on a server in Germany.

Processor: hosting provider with a data centre in Germany

Legal basis: Article 6 (1) (f) GDPR. A data processing agreement pursuant to Article 28 GDPR exists with the hosting service provider.

Fonts (e.g. Poppins) and other assets are loaded exclusively locally from our server (self-hosted). They are not loaded via Google Fonts or third-party CDNs; no data is transmitted to third parties in this process.

6. Cookies and consent management

We use technically necessary cookies that are required for the operation of the Platform (e.g. session management, shopping cart, security/CSRF token, storage of your cookie decision).

Legal basis for technically necessary cookies: § 25 (2) TDDDG in conjunction with Article 6 (1) (f) or (b) GDPR.

We use non-necessary cookies and comparable technologies (e.g. reach measurement) only after your express consent via our consent banner.

Legal basis for technologies requiring consent: § 25 (1) TDDDG in conjunction with Article 6 (1) (a) GDPR. You can revoke your consent at any time with effect for the future via the cookie settings.

Consent log: To document the consent given, we log the time, scope and version of your decision. Storage period: period required for proof plus 3 years (limitation period).

7. Reach measurement / analysis

Only after consent (statistics): To improve our offering, we measure the use of our website – only with your consent via the consent banner (category "Statistics") – (e.g. pages viewed, clicks on buttons, steps in the purchase/rental process). Collection takes place pseudonymously and in a data-minimising manner: we store no real names, email addresses, full IP addresses or other data that directly identifies you in the measurement events. Before your consent, no measurement takes place; no analysis requests are triggered.

Self-hosted / EU, no third-party CDN: Measurement takes place via a self-hosted, EU-based, cookieless analysis method (planned: Matomo or Plausible). No data is transmitted to third parties and no scripts from third-party providers (e.g. Google) are loaded. As long as no analysis tool is configured, measurement events are only evaluated in our own server logs (no external transmission).

Performance measurement (Web Vitals / RUM): Also only after statistics consent, we measure anonymous technical performance values of your browser (e.g. loading time, interaction latency, layout stability) and send them to our own endpoint. Only anonymous metrics and the path accessed (without query parameters) are processed – no personal reference.

Marketing measurement (separate consent): Conversion events for measuring the success of advertising (e.g. completed purchase/completed rental) are processed only if you have additionally consented to the "Marketing" category (Consent Mode v2 data layer prepared, currently without an active third-party provider).

Storage period: Aggregated/pseudonymous measurement data is stored only for as long as it is required for evaluation. Any technical session marker is formed only in a non-reversible, daily-rotating form (no permanent re-identification).

Legal basis: Article 6 (1) (a) GDPR in conjunction with § 25 (1) TDDDG (consent). You can revoke your consent at any time with effect for the future via the cookie settings.

8. Customer account / registration

You can create a user account on our Platform (customer, club administrator or partner).

Data processed: name, email address, password (stored exclusively as a cryptographic hash, argon2id procedure), role, possibly address(es), language preference, order/rental/booking history.

Purpose: provision of the account, management of your orders, rental processes, bookings and credit balances, authentication.

Legal basis: Article 6 (1) (b) GDPR (performance of the user/purchase contract).

Storage period: For the duration of the existence of the account. After deletion of the account, the data is deleted, unless statutory retention obligations (in particular commercial and tax law, 10 years) prevent this; such data is blocked from further processing.

9. Order in the shop

Data processed: name, billing and delivery address, email, telephone number (optional), ordered items (SKUs), payment method, invoice data, order and invoice number, possibly the discount/club code used and rental credit balance.

Purpose: processing of the purchase contract, invoicing, shipping, warranty, accounting.

Legal basis: Article 6 (1) (b) GDPR (contract); for the retention of invoices Article 6 (1) (c) GDPR (§ 147 AO, § 257 HGB).

Storage period: invoice and accounting-relevant data 10 years. Remaining order data is deleted as soon as it is no longer required for contract processing and any warranty claims.

10. Rental booking (shipping rental), deposit and shipment tracking

For booking a shipping rental (e.g. Tenniix Basic/Pro), we process the data required to perform the rental contract.

Data processed: name, delivery/billing address, email, rental period and extensions, shipping and shipment tracking data (DHL delivery and acceptance scans), data on the deposit (pre-authorisation), damage documentation upon return.

Deposit (pre-authorisation): The deposit (Basic €350, Pro €500) is reserved exclusively as a pre-authorisation (pre-auth) via our payment service provider; no debit takes place unless there are legitimate claims (e.g. damage, late return). The reservation is released promptly after a defect-free return inspection.

Shipment tracking as a rental clock: The DHL delivery scan marks the start of the rental, the DHL acceptance scan (return) marks the end of the rental. For this purpose, we process the shipment status data.

Purpose: performance of the rental contract, shipping and return, deposit management, damage processing.

Legal basis: Article 6 (1) (b) GDPR (contract); enforcement of damage/claims Article 6 (1) (f) GDPR.

Storage period: rental and invoice data 10 years (tax); damage photos until the final clarification of any claims.

11. Damage documentation (photos)

When shipping and returning rental devices, we take photos to secure evidence of the device condition. These are stored outside the publicly accessible area.

Legal basis: Article 6 (1) (b) and (f) GDPR (performance of the rental contract, securing of claims).

Storage period: until the final clarification of the respective matter or expiry of the limitation period.

12. Club integration (commissioned processing)

In the club programme, clubs manage bookings of their members/guests via the club portal (`club.tenniix-robot.com`). Insofar as we process personal data of club members on behalf of the respective club (e.g. booking data in the dashboard), we act as a processor of the club pursuant to Article 28 GDPR. The respective club is the controller for this member data.

A data processing agreement (DPA) is concluded with each participating club during onboarding.

Data processed: booking data (time slot, price, payment method, status), possibly name/contact details of the booking player.

Legal basis: For our own purposes (platform operation) Article 6 (1) (b)/(f) GDPR; otherwise processing on behalf pursuant to Article 28 GDPR on the basis of the legal basis of the club.

Storage period: in accordance with the DPA or the instructions of the club and statutory retention obligations (accounting data 10 years).

13. Payment processing (Stripe) – in live operation

Note: Payment processing will only go live once the payment service provider is activated; in the current demo/test operation, no real payment data is collected or transmitted to Stripe.

For payment processing (purchase, rental, deposit, club bookings) we use the payment service provider Stripe Payments Europe, Ltd. (Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland). During payment, the payment data (e.g. card/SEPA data) is transmitted directly to Stripe and processed by Stripe; complete card data does not reach our servers.

Data processed (by us): name, amount, payment status, transaction/process references.

Purpose: payment processing, deposit pre-authorisation, club payouts (Stripe Connect), fraud prevention.

Legal basis: Article 6 (1) (b) GDPR (contract), Article 6 (1) (f) GDPR (fraud prevention).

Recipients / DPA: A data processing agreement exists with Stripe. Stripe processes the data within the EU/EEA. Further information: Stripe's privacy notices.

14. Shipping (DHL) – in live operation

Note: Shipping will only go live once the shipping service provider is activated; in the current demo/test operation, no real shipping takes place and no data is transmitted to DHL.

For shipping and returning purchase and rental shipments, we use DHL (DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn, Germany). For this purpose, we transmit the data required for shipping and shipment tracking (name, delivery address, possibly email/telephone for notifications).

Purpose: delivery and return, shipment tracking (rental clock start/end).

Legal basis: Article 6 (1) (b) GDPR (contract).

Recipients / DPA: DHL as the recipient of the shipping data; insofar as required, a data processing agreement exists.

15. Email dispatch (transactional) – in live operation

For sending transactional emails (order/rental confirmations, return reminders, credit countdown) we use the email service of our provider hashfox (SMTP server mail1.hashfox.com, server location EU/Germany); a data processing agreement pursuant to Article 28 GDPR exists with the provider.

Data processed: email address, name, content of the respective transaction message.

Legal basis: Article 6 (1) (b) GDPR (contract).

Recipients / DPA: email service provider as processor (Article 28 GDPR), EU processing.

16. Newsletter / marketing (double opt-in)

If you subscribe to our newsletter, we process your email address (and, where applicable, your name) to send advertising about our own products and offers.

Double opt-in: After your registration, you will receive a confirmation email; you are only registered after confirming the link. To document this, we log the registration and confirmation time and the IP address used.

Legal basis: Article 6 (1) (a) GDPR (consent); for advertising to existing customers, where applicable § 7 (3) UWG.

Storage period: until consent is withdrawn or you unsubscribe. You can unsubscribe from the newsletter at any time via the unsubscribe link in every email or by sending a message to info@xing-handels.de.

17. Contact

If you contact us by email, telephone or contact form, we process your details to handle your enquiry.

Legal basis: Article 6 (1) (b) GDPR (for contract-related enquiries) or Article 6 (1) (f) GDPR (other enquiries).

Storage period: until the enquiry has been finally handled; subsequently deletion, unless retention obligations exist.

18. Camera on the Tenniix device (on-device processing)

The Tenniix tennis robot has camera technology to detect ball and movement data for training (vision/tracking function).

Important – on-device processing: The image/video analysis takes place exclusively locally on the device (on-device). We do not collect, receive or store any video recordings.

No biometrics / no facial recognition: No facial recognition, no biometric identification and no emotion recognition take place. No special categories of personal data within the meaning of Article 9 GDPR are processed. The function serves exclusively for ball/movement tracking for training purposes and is to be classified as an application with minimal risk within the meaning of the EU AI Regulation (Regulation (EU) 2024/1689).

Fellow players / third parties: If the device is used in a club or in public, third parties may come into the field of view. Since no recording or identification takes place, the processing is limited to what is technically necessary. Clubs receive a signage kit from us ("AI training device with camera in operation") for information purposes.

Telemetry: For operating and maintenance purposes, the device processes technical telemetry data (e.g. operating hours, battery level, error codes, serial number). These do not contain any image/video content.

Legal basis: Article 6 (1) (b) GDPR (performance of contract/training function) and Article 6 (1) (f) GDPR (maintenance, security, fleet management).

Storage period for telemetry: 12 months, then deletion or anonymisation.

Data protection impact assessment (DPIA): For the use of the camera-based vision/tracking technology, we have examined whether a data protection impact assessment pursuant to Article 35 GDPR is required. Since the analysis takes place exclusively on-device, with no recording, no biometric identification and no processing of special categories of data (Article 9 GDPR), no high risk to the rights and freedoms of data subjects is assumed according to the current assessment. Status of the DPIA: assessed as not required (see the reasoning above); the assessment will be re-examined in the event of significant changes to the processing.

19. Recipients / processors (overview)

Your data is passed on to recipients only insofar as this is necessary for the performance of the contract or due to legal obligations. These are in particular:

• Hosting service provider (EU/DE) – processor
• Payment service provider Stripe (EU) – in live operation
• Shipping service provider DHL (EU/DE) – in live operation
• Email service provider (EU) – in live operation
• Tax advisor / accounting and tax authorities – within the statutory framework
• Participating clubs – only within the scope of the commissioned processing pursuant to section 12

Contracts pursuant to Article 28 GDPR exist with all processors. No transfer to third countries takes place.

20. Storage period (summary)

21. Your rights as a data subject

Under the GDPR, you have the following rights:

• Access (Article 15 GDPR)
• Rectification (Article 16 GDPR)
• Erasure (Article 17 GDPR)
• Restriction of processing (Article 18 GDPR)
• Data portability (Article 20 GDPR)
• Objection to processing based on legitimate interests (Article 21 GDPR)
• Withdrawal of consent given, with effect for the future (Article 7 (3) GDPR)

To exercise your rights, please contact info@xing-handels.de. In your customer account, we also provide functions for data export and for requesting account deletion.

22. Right to lodge a complaint with the supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority (Article 77 GDPR). The competent authority is, among others, the supervisory authority of your habitual residence or the authority responsible for us:

State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, LDI NRW) Kavalleriestraße 2–4 40213 Düsseldorf, Germany Phone: +49 (0) 211 38424-0 Email: poststelle@ldi.nrw.de

23. Obligation to provide data / automated decisions

The provision of certain data is necessary for the conclusion of the contract; without this data, we cannot conclude the contract (purchase/rental). Automated decision-making, including profiling within the meaning of Article 22 GDPR, does not take place.