Privacy Policy for Earpiece WhatsApp Service
Effective Date
2 May 2025
Last Updated
2 May 2025
1. Who We Are
Twelve Football AB
Brännkyrkagatan 95
117 26 Stockholm, Sweden
Corporate ID: SE559219677701
Contact: hello@twelve.football
We are the data controller for personal data collected through the Earpiece WhatsApp Service.
2. What Data We Collect
We collect and process the following categories of personal data:
- Identity Data: Name, employer (club), role/title.
- Contact Data: Phone number (used to deliver the WhatsApp service), email address (if provided).
- Usage Data: Messages sent through the Service, feature usage patterns, feedback.
- Technical Data: Device type, operating system, IP address (used minimally and temporarily for security and
diagnostics).
- Payment Data: Payment method and subscription history (processed via third-party providers; we do not
store full payment card details).
3. How We Use Your Data
We use your personal data to:
- Deliver the WhatsApp-based Service.Privacy Policy for Earpiece WhatsApp Service
- Respond to your questions and provide support.
- Monitor and improve the performance and relevance of the Service.
- Enforce our Terms and Conditions.
- Comply with legal obligations.
- (If applicable) Send you updates about new features or relevant offers, with your consent.
4. Legal Basis for Processing
Under the General Data Protection Regulation (GDPR), we process your data on the following legal bases:
- Contractual Necessity: To provide the Service you've signed up for.
- Legitimate Interest: To improve the Service, prevent misuse, and protect our systems.
- Consent: For optional communications such as marketing updates (you can withdraw consent at any time).
- Legal Obligation: When required to retain or disclose data under law.
5. Data Sharing
We do not sell your personal data. We may share it with:
- WhatsApp (Meta): To deliver the Service through their platform, in accordance with their privacy policy.
- Third-party processors: Including Azure OpenAI, Azure cloud services, Auth0 (authentication), and payment
providers - all GDPR-compliant and under data processing agreements.
- Authorities: If legally required to comply with obligations or respond to lawful requests.
A full list of sub-processors is available on our Third-Party Services.
6. International Transfers
Some of our service providers operate outside the EU/EEA. When data is transferred internationally, we
ensure adequate safeguards such as Standard Contractual Clauses (SCCs) are in place.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined above or to comply
with legal obligations. If you cancel your account or request deletion, we will delete or anonymize your dataPrivacy Policy for Earpiece WhatsApp Service
within 30 days, unless otherwise required by law.
8. Your Rights Under GDPR
As a data subject, you have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate or incomplete data.
- Request deletion of your data ("right to be forgotten").
- Object to processing based on legitimate interests.
- Withdraw consent where processing is based on consent.
- Request data portability to another service.
- Lodge a complaint with your national data protection authority (in Sweden: Integritetsskyddsmyndigheten).
To exercise your rights, contact us at: hello@twelve.football
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including
encryption, access controls, and monitoring of system activity.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Significant changes will be communicated via
WhatsApp or email. Continued use of the Service indicates acceptance of the updated policy.
11. Pricing and Payment
The Earpiece WhatsApp Service is offered through three subscription tiers:
€19/month – Includes 50 message tokens
€34/month – Includes 200 message tokens
€59/month – Includes 2000 message tokens (marketed as Unlimited use)
Message tokens represent the number of requests you can send to the Service each month. Unused tokens do not roll over. The “Unlimited” plan is subject to fair use limits to prevent misuse.
All payments are processed through secure, GDPR-compliant third-party providers. We do not store full payment card details on our servers. Subscription history and payment methods may be stored securely by our providers to manage billing and support.
Questions?
Please contact us at: hello@twelve.football