kaan.life

Privacy Policy kaan.life

Version 1.0, effective date: [INVULLEN: publication date]

DRAFT. This version has not had legal review yet and contains placeholders. Remove this notice only at final publication.

1. Who we are and what this policy covers

This privacy policy covers all online services of kaan.life and its subdomains:

Data controller:

2. What personal data we process

Feedback feature (kaan.life). Your chat messages, a technical session code, the page changes you suggest and, only if you choose to enter it, your email address.

Powerlifting records site. Data about competition athletes from public sources: name, sex, year of birth, country, weight class, body weight, competition results and, for registrations, club name. Chapter 4 explains where this data comes from. Visitors of this site do not enter any data; we collect nothing from visitors.

Advchat. Your account details (username and email address), your chat conversations and the documents you upload [ASSUMPTION - VERIFY: exactly what advchat stores]. If you use the service through WhatsApp: your phone number and your messages [ASSUMPTION - VERIFY: whether the WhatsApp channel is active]. The service can exchange data with a connected AFAS environment [ASSUMPTION - VERIFY: which data].

Account (sso.kaan.life). Your username, email address and an encrypted version of your password.

All services. Your IP address, briefly and only to prevent abuse (see chapter 8). We do not store IP addresses in a database.

3. Purposes and legal bases

ProcessingPurposeLegal basis (GDPR)
Feedback and chat messagesReceiving and following up on your feedbackConsent (art. 6(1)(a))
Optional email address with feedbackContacting you about your feedbackConsent (art. 6(1)(a))
Showing sports statisticsMaking the public Dutch powerlifting record accessibleLegitimate interest (art. 6(1)(f))
Account and sign-inProviding the services you have an account forPerformance of a contract (art. 6(1)(b))
AI chat (advchat)Answering your questions, processing documentsPerformance of a contract (art. 6(1)(b)) [ASSUMPTION - VERIFY]
Brief IP processingSecurity and abuse preventionLegitimate interest (art. 6(1)(f))

Our legitimate interest in the sports statistics is making the public competition record of the powerlifting sport accessible. You can object to this; see chapter 9.

4. Data from public sources (powerlifting)

The athlete data on the powerlifting records site does not come from the athletes themselves. It comes from three public sources:

  1. the international OpenPowerlifting dataset (data.openpowerlifting.org), a public archive of competition results;
  2. the live results service of the KNKF powerlifting section during competitions;
  3. the public competition calendar of the KNKF powerlifting section, including registration lists.

We do not inform athletes individually; with thousands of athletes from a public archive, that would take a disproportionate effort (art. 14(5)(b) GDPR). This policy serves as general information. If you do not want to appear on the site, object through our contact address (chapter 9). For removal from the source itself, OpenPowerlifting runs its own redaction process; we will point you there on request.

5. Who we share data with

We do not sell data. We share data only with parties we need to run the services:

PartyFor whatWhich data
Hetzner Online GmbH (Germany)Hosting of all servicesAll stored data
AnthropicAI answers in the feedback chat and advchatChat messages and page context
OpenAIAI answers in advchatChat messages [ASSUMPTION - VERIFY]
Microsoft (Azure)AI answers and document processing in advchatChat messages and uploaded documents [ASSUMPTION - VERIFY]
Meta (WhatsApp Business)WhatsApp channel of advchatPhone number and messages [ASSUMPTION - VERIFY]
AFASConnection between advchat and an AFAS environment[ASSUMPTION - VERIFY]
Google (Fonts)Fonts on kaan.lifeYour IP address when the page loads [ASSUMPTION - VERIFY: drops out if fonts are self-hosted before publication]

The public sources in chapter 4 supply data to us; they do not receive data from us.

6. Transfers outside the European Economic Area

Our servers are in the European Union (Germany). Some suppliers process data in the United States as well:

7. How long we keep data

DataRetention period
Feedback (chat, suggestions, email address)At most 12 months after receipt
Account detailsAs long as your account exists; deleted within 1 month after cancellation
Chat conversations and documents in advchat[ASSUMPTION - VERIFY: we still need to set this period]
Sports statistics (records, results)Indefinitely, as a historical sports archive; you can object (chapter 9)
IP addresses for securityA few minutes, in memory only
Technical log filesAt most 30 days [ASSUMPTION - VERIFY log retention]

8. How we protect your data

9. Your rights

You have the right to access, rectify and erase your data, to restrict processing, to data portability, and to object to processing based on our legitimate interest. The right to object applies in particular to the sports statistics: if you object, we assess whether we shield or remove your data, and we point you to the redaction process at the source.

Send your request to [INVULLEN, e.g. privacy@kaan.life]. We respond within one month. We may ask you to prove your identity before we carry out your request.

10. Withdrawing consent

If you gave consent, for example by entering your email address with feedback, you can withdraw it at any time through our contact address. Withdrawal does not affect processing that took place before you withdrew.

11. Automated decision-making

We make no decisions about you that rest solely on automated processing and have legal effects for you. The AI features give answers and suggestions; they make no decisions about you.

12. Cookies and local storage

We use no tracking cookies, no analytics cookies and no advertising cookies. That is why we show no cookie banner. We do use functional storage that the services need to work:

13. Filing a complaint

You have the right to lodge a complaint with the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). We appreciate it if you contact us first, so we can try to resolve your complaint ourselves.

14. Changes to this policy

We may change this policy, for example when the services change. The current version is always available at privacy.kaan.life, with a version number and effective date. For major changes we inform account holders where reasonably possible.

15. Contact

Questions about this policy or about your data? Contact us at [INVULLEN, e.g. privacy@kaan.life].