Privacy Policy
Version 0.1 (draft) · Draft — not yet in effect
This policy explains how Löhr & Sørensen GmbH i.G. ("Debrief", "we") handles personal data when you use Debrief at https://debrief.games, the Debrief client on your PC, when you send a recording to a coach through Debrief, or when your voice or in-game name is part of a recording someone else uploads. It follows Articles 13 and 14 of the EU General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and, for cookies and similar technologies, the German Telecommunications Digital Services Data Protection Act (TDDDG).
1. Who is responsible
Löhr & Sørensen GmbH i.G., Am Krähenberg 5, 22587 Hamburg, Germany, represented by its managing director (Geschäftsführer) Nicolai Sørensen; in formation and not yet entered in the commercial register (see the Impressum).
Privacy questions and requests: privacy@debrief.games, or the contact form ("Privacy and data protection"). Data protection officer / data protection contact: [DPO_OR_CONTACT].
2. Our role: controller or processor
Debrief handles personal data in different roles:
| Data | Who decides (controller) | Our role |
|---|---|---|
| Your account: sign-in, profile, org memberships, sessions, notifications, the security log, support, messages you send us, emails we send you | Debrief | Controller |
| An org's recordings and everything made from them: videos with their sound, statistics, positions, flags, fights, clips, voice comms transcripts, speaker names, comments and verdicts, the org's Coach reports | The org (the team or organisation that uses Debrief) | Processor, under the org's Data Processing Agreement |
| A coach's students' recordings, the reports made from them, the coach's notes and reviews (section 10) | The coach | Processor, under the Data Processing Agreement the coach accepts |
| A coach's application (the name students see, a short bio) | Debrief | Controller |
| Your voiceprint, only if you agree to voice recognition (section 6) | Debrief, for the org in which you agreed | Controller |
| Training samples cut from an org's recordings and the labels members give them, to improve Debrief's models (section 11) | Debrief, with the org's permission in the Data Processing Agreement | Controller |
| Payments, invoices and contract declarations when an org buys a plan or credits (section 12) | Debrief | Controller |
| The public "meta brief" (section 8) | Debrief | Controller (it holds no data about our users) |
| (Planned) a solo subscriber's own recordings, Solo plan | Debrief | Controller |
For an org's recordings, the org decides why and how they are processed: which recordings are uploaded, whether voice comms are transcribed, whether recordings may be processed in the cloud, whether their videos are kept for later processing (section 9), whether the Coach runs, who in the org sees what and how long it is kept. The org is responsible for having a legal basis and for informing its players. The same applies to a coach for their students' recordings. Questions about an org's or a coach's recordings are best sent to that org's admins or that coach; we help them answer, and our self-service tools (section 18) work for everyone with an account.
3. What we collect, and where it comes from
| Category | Examples | Source |
|---|---|---|
| Sign-in identity | the sign-in provider's user id, email address, name as the provider reports it (details in section 3a) | the provider you sign in with (Google, Facebook, Discord or Microsoft, whichever the site offers) |
| Profile | display name, in-game names, Discord user id, your choices (for example "Help train Debrief", voice recognition) | you, or the admin who invited you |
| Org data | memberships and roles, invites (with the inviter's note), access requests (with your message) | you and your org's admins |
| Sessions | when you signed in, last activity, your browser's user agent | your browser |
| Nodes (the client) | your PC's name (by default its Windows computer name), client version, status (for example "paused while the game runs"), capabilities | the client on your PC |
| Recordings | the video file and its sound, file name, size, date, format | the member who uploads or processes it, or a coach's student |
| What we derive from recordings | in-game names of you, your teammates and, from the kill feed, opponents; legends; kills, damage, placement and other statistics; positions on the map; pings and other kill-feed lines; play-style figures (for example looting time, aim mode, use of abilities); flags, fights, clips | automatic analysis of the video |
| Voice comms (only when the org turns transcripts on) | what was said in the voice channel, as text, with times and a speaker label (Speaker 1, Speaker 2 ...); names people give to speakers; figures derived from the lines (for example how fast a fight was called out) | automatic transcription on the computer that processes the recording; names from members |
| Voiceprint (only with your explicit consent) | a set of numbers computed from voice lines confirmed as yours; your consent (which text, when given and withdrawn) | your confirmed lines and your own microphone track; you (section 6) |
| Your activity in the org | comments, right / wrong verdicts on flags (with the reason you give), feedback on fights, decisions on the Coach's proposals, deletions you asked for, confirmations you gave | you |
| Training labels (only if you choose to help) | your answers to labelling tasks, your accuracy on check samples | you (section 11) |
| The org's Coach reports | the report, its findings about the team and named players, quotes from the voice comms (while transcripts are on) | written by the AI model the org's admin uses (section 7) |
| Coaching | a coach's name shown to students, bio, the data processing agreement they accepted; for each student: the name and (optional) email address the coach entered, the student's confirmations (age, notice), an optional "tell me about Debrief later", the coach's notes, pinned moments, agenda and review | the coach; the student (section 10) |
| Notifications and emails | what you were notified about; emails we send you (section 13) | the site |
| Messages to us | contact form: your name (optional), email address, topic and message; emails you send us | you |
| Payments (only when an org buys) | the org's name, the billing contact's email, billing name and address, VAT number, plan, payments, invoices, refunds, cancellation or withdrawal declarations | the org admin who buys, the payment provider (section 12) |
| Security log | sign-ins, refused sign-ins, admin actions, exports, deletions, consents given and withdrawn (who, what, when) | the site |
| Legal acceptances | which version of these documents you accepted, and when | you |
We do not store IP addresses in our database; the site uses your IP address only briefly in memory, to limit how many sign-in attempts, access requests, uploads through a coach's link or contact messages come from one network. We do not use analytics, advertising or tracking tools, and we do not buy or sell personal data.
You do not have to give us personal data by law. Without a sign-in identity we cannot give you an account; without an email address we cannot answer a message.
3a. Signing in with Google, Facebook, Discord or Microsoft
Debrief has no passwords: you sign in with an account you already have at a sign-in provider. Which ones the site offers is shown on the sign-in page. When you sign in, the provider tells us only:
| Provider | What we receive | What we ask for |
|---|---|---|
| Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) | your Google account id, your name, your email address and whether Google has verified it | the scopes openid, email and profile |
| Facebook (Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland) | your app-scoped Facebook user id (an id only for Debrief), your name and, if you allow it, your email address | the permissions public_profile and email |
| Discord (Discord Inc.) | your Discord user id, username, display name, email address and whether Discord has verified it | identify and email |
| Microsoft | your Microsoft account id, name and email address | openid, email and profile |
We never post anything on your behalf, never read your friends list, contacts, photos or other content, and keep no access token after the sign-in (we use it once, to read the details above). We use your email address only to recognise you (the allow-list, invites and access requests) and to contact you about your account; your name is the starting point of your display name, which you can change. If Facebook does not give us an email address (for example because you declined it, or your Facebook account only has a phone number), we cannot recognise you and do not create anything for that sign-in: you can sign in another way, or connect Facebook later on your Profile. You can connect several sign-ins to one account and remove them again (Profile → Connected sign-ins; the last one stays).
The legal basis is the contract with you (Art. 6 (1) (b) GDPR): signing you in is part of the service. The provider learns that you signed in to Debrief; it is an independent controller of your account with it under its own privacy policy (Google, Meta / Facebook, Discord, Microsoft). If you remove Debrief in your Facebook settings or ask Facebook to have your data deleted, Facebook tells us, and we delete the link to your Facebook account (your Facebook id and the email address Facebook shared), the sessions you started with Facebook and any access request you sent while signed in with Facebook; Facebook gives you a confirmation code you can check at https://debrief.games/auth/facebook/deletion-status. Your Debrief account itself is deleted with Profile → Delete my account (section 18).
4. Why we use it, and our legal basis
Where we are the controller:
| Purpose | Legal basis (GDPR) |
|---|---|
| Create and run your account, sign you in, run orgs, invites and memberships, show notifications, send you the emails the service needs | Art. 6(1)(b): to provide the service under the Terms you accept |
| Handle a request for access from someone who is not a member yet, or an application to coach on Debrief | Art. 6(1)(b) (steps before a contract) and 6(1)(f) |
| Answer messages you send us (contact form, email) | Art. 6(1)(b) where it concerns a contract with you or steps before one, otherwise 6(1)(f): our legitimate interest in answering enquiries |
| Keep Debrief secure: sessions, the security log, rate limits, abuse prevention, investigating incidents | Art. 6(1)(f): our legitimate interest in a secure service |
| Support, including a time-limited support access to an org (section 14) | Art. 6(1)(b) and 6(1)(f) |
| Backups and restoring after a failure | Art. 6(1)(f) |
| Record which version of the terms you accepted, and the consents you gave or withdrew | Art. 6(1)(f) (proving the agreement), 6(1)(c) and Art. 7(1) where the law requires it |
| Handle notices about illegal content and our decisions on them (EU Digital Services Act) | Art. 6(1)(c) |
| Answer your data protection requests | Art. 6(1)(c): our legal obligation |
| Recognise your voice in your org's transcripts (voiceprint, section 6) | your explicit consent, Art. 9(2)(a) and 6(1)(a) |
| Improve how accurately Debrief reads gameplay and detects mistakes (training data, section 11) | Art. 6(1)(f): our legitimate interest in improving the service, with the org's permission in the Data Processing Agreement |
| Sell plans and credits, take payments, issue invoices, handle cancellations and withdrawals, keep the accounts (section 12) | Art. 6(1)(b) and 6(1)(c) (German Commercial Code and Fiscal Code) |
| Tell a coach's student about Debrief later, if they ticked that box | Art. 6(1)(a): their consent |
| Research the public game meta (section 8) | Art. 6(1)(f): our legitimate interest in giving teams current, sourced background |
| (Planned) a solo subscriber's own recordings, including the voices and names of other people in them | Art. 6(1)(b) for the subscriber; 6(1)(f) for other people in the recording (reviewing one's own games) |
Where we are the processor for an org or a coach, they choose the legal basis. For a team reviewing its own games this is usually the org's legitimate interest in training and improving (Art. 6(1)(f)) or its contracts with its players (Art. 6(1)(b)); for a coach, usually the coaching agreement with the student (Art. 6(1)(b)). We process that data only on their instructions.
Debrief makes no decisions about you based solely on automated processing that have legal or similarly significant effects (GDPR Art. 22).
5. Recordings and game data
A recording shows what was on the player's screen: the game, the in-game names of players, and anything else on screen (for example an overlay or chat). Its sound usually holds the game and the voice chat of the player's channel. Debrief reads the game's on-screen information to build statistics, find fights and flag likely mistakes by fixed rules. It does not read the running game.
What the org's members see depends on the org: a recording is shared with the org's members unless its owner makes it private. A squad view puts several members' recordings of the same match side by side when they played together, and Player Stats show each member's statistics and play style over time to the org's members.
Flags and statistics are automatic and can be wrong. Debrief makes no decisions about anyone: it produces material for a team's own review. Orgs should not base decisions about a player (for example their contract) on Debrief's output alone. Debrief does not analyse emotions, health or personality.
6. Voice comms
Recordings often contain the voices of everyone in the player's voice channel, including people who are not on Debrief.
Sound in the video. The playback copy of a recording and its clips keep the recording's sound, including voices, whether or not transcripts are on. Only members of the org who can see the recording can play it.
Transcripts are off unless the org turns them on. An org admin decides per org (off for a new org). While on, the member who uploads confirms once for the org that everyone in their voice channel agreed that the recording of the comms is shared with the org and transcribed (until 1 October 2026 the confirmation said everyone knows; those who confirmed that are asked again). Without that confirmation, nothing is transcribed and no transcript is stored.
How transcription works. The computer that processes the recording (a member's PC, or Debrief's own cloud server in the EU when the org allows cloud processing, section 9) separates the voices from the game sound and writes down what was said with speech recognition that runs on that computer (Whisper). The audio is not sent to any speech-recognition or AI service. The text, with times and speaker labels, is stored with the recording and shown to the org's members who can see the recording.
Telling voices apart (speaker grouping). To show who said what, the computer computes a numeric description of each stretch of voice (a voice embedding) and groups similar ones within that one recording into Speaker 1, Speaker 2, and so on. These embeddings:
- are computed on the computer that processes the recording and are never uploaded to Debrief;
- are kept on that computer only with its own copy of the transcript, and only while the org uses voice recognition (below), so that lines can be compared again; otherwise they are discarded after processing;
- are never used to build a voiceprint of anyone who has not agreed to voice recognition.
Members can put a name on a speaker by hand ("Speaker 2 is Alex"), for that recording only; that name comes from people, not from voice matching. Our assessment is that grouping the voices of one conversation is not processing of biometric data "for the purpose of uniquely identifying a natural person" (GDPR Art. 9), because it only separates the voices of that conversation.
Recognising your voice (voiceprints)
What. In an organisation that has voice comms transcripts turned on, you can choose to let Debrief recognise your voice ("Recognise my voice" in your profile). We then make a voiceprint: a set of numbers computed from the voice lines that you or your teammates confirmed as yours, and from your own microphone track when your recording has one. A voiceprint is biometric data.
Why. Only to put your name on your lines in that organisation's voice comms transcripts, so you and your teammates can see who said what.
Legal basis. Your explicit consent (Art. 9(2)(a) and Art. 6(1)(a) GDPR), which you give per organisation: by ticking the consent text in your profile, or by answering "Yes" when Debrief asks you once in an organisation with transcripts on (the full consent text is one click away in that question). "Not now" and "Never" are no consent and have no consequences; Debrief never turns voice recognition on by default, and an organisation's admins cannot agree for you. Without your consent nothing is made, and nothing changes about the transcripts you already have.
Who sees what. Members of that organisation see your name on your lines. Nobody sees the voiceprint itself: it is stored in our database in the EU and used only by the computers that process that organisation's recordings (its members' PCs, never our cloud servers), and only while a recording is processed. It is never used in another organisation, never shared with anyone outside Debrief, and never used for anything else (no advertising, no profiling, no model training).
Other voices. To find your voice in a recording, the voices in it are compared with the voiceprints of the members who agreed. Voices that do not belong to such a member stay unnamed; we keep no voiceprint of anyone who did not agree.
How long, and withdrawing. Your voiceprint is kept while your consent lasts. You can withdraw it at any time in your profile: the voiceprint is deleted at once, and so are the names it put on lines (names a person confirmed stay, as if they had typed them). It is also deleted when you leave the organisation, delete your account, the organisation turns transcripts off, or the organisation is deleted. When a voice line or a transcript is deleted, it no longer counts toward any voiceprint. We keep a record of your consent (which text, when given and withdrawn) until your account is deleted. Your data download lists your consents and whether a voiceprint exists, not the numbers themselves.
Your lines, your choice
Anyone who can see a recording can delete every line of their own voice ("These are my lines"); the recording's owner and the org's admins can delete single lines or the whole transcript; the org can delete all its transcripts. A deletion removes the text, and everything computed from it (for example callout times, the Coach's quotes and training samples), from every stored copy at once, and it stays deleted when the recording is processed again. If you are in someone's voice channel but not on Debrief, ask that player, the org's admins or us (privacy@debrief.games) to delete your lines.
How long. Each org chooses: as long as the recording, or 30, 90 or 365 days (section 16).
7. The Coach and AI-drafted reviews
An org can let an AI coach write a team report, and a short review of each new match, from its recordings' statistics. The org's admins turn it on; it then runs on the PC of one of the org's admins, with that admin's own Claude account (Anthropic's Claude Code program). For each run, that PC downloads from Debrief the org's computed statistics and flags, the names of the players it coaches (display and in-game names), the team's decisions on earlier proposals with their reasons and, only while the org has transcripts on, short quotes from the voice comms; it sends them to Anthropic (the maker of Claude, United States) and uploads the report it gets back. Video, audio and voice embeddings are never sent.
Who is responsible. Debrief does not send this data to Anthropic itself, and Anthropic is not our subprocessor for it: the org decides to use the Coach and its admin's own Claude account, under the terms of that account. On a personal Claude plan (Free, Pro or Max), Anthropic may use the conversations to train its models and keep them longer unless "Help improve Claude" is turned off in that account's privacy settings; on Anthropic's commercial plans it does not train on them. We tell orgs this on the Coach's settings and recommend a commercial plan or the setting turned off.
Reviews for a coach's students (section 10) are drafted the same way: on the coach's own PC, with the coach's own Claude account, from the computed facts of that one recording (statistics, flags, fights; voice lines only if the coach has transcripts on). If Debrief drafts such reviews, or Coach reports, on its own servers instead, it sends the same facts, never video, audio or voice embeddings, to Anthropic through Anthropic's API as our subprocessor (see the list of subprocessors); according to Anthropic's commercial terms, it does not use data received through its API to train its models.
What you see. Coach reports and reviews are marked as written by AI ("Written by Claude"). A coach checks and edits a review before the student sees it. Coach reports are shown to the org's members (notes about a player's role, if the org turns them on, only to the org's admins and that player in their data export) and can be wrong. The org should not base decisions about a player on them alone. Quotes from deleted voice lines are removed from stored reports.
8. The meta brief
Debrief keeps a short, sourced summary of the current Apex Legends meta (maps, legends, weapons, team compositions) for all orgs. It is researched by an AI model (Claude) from public web pages and the captions of a few recent public YouTube videos, on a Debrief admin's PC. It contains no data about our users or their recordings. It may name people who made public statements about the game (for example professional players or video creators), with a link to the source; we use only what they published, to give teams current background (Art. 6(1)(f)), and store only summaries and links. If you are named and object, write to privacy@debrief.games.
9. Where recordings are processed: members' PCs and the cloud
Members' PCs (the swarm). Recordings are processed by the Debrief client on members' own PCs. A member can share their PC with their org's swarm; it then also processes other members' recordings of that org. In that case the recording (with its sound), and the report, clips and transcript made from it, are stored on that member's PC: the downloaded source for up to 30 days, the report folder until that member deletes it. Members who share their PC agree in the Terms to keep these copies confidential and to delete them when asked. When a recording is deleted on Debrief (by its uploader, an org admin, a coach on a student's request, or with the uploader's account), every PC that processed it is told to delete its copies, and does so the next time it is online; the same happens to the copy of the voice comms on those PCs when lines, a voice or a whole transcript are deleted. A PC removed from Debrief gets these deletions the next time its client contacts Debrief. If a PC does not come back online within 90 days, Debrief cannot reach it and its copies may remain; we then know which PC it is. Only Debrief's own copies are deleted: video files a member recorded themselves stay on their PC. On your own PC, the client also keeps a local history of your matches (statistics and player names) for your own use.
Debrief's cloud servers. When an org allows it (its admins choose: never, only when none of the org's PCs is free, or always), a recording can instead be processed on a virtual server that Debrief starts for this in Microsoft Azure in the EU (Sweden Central). The recording is uploaded, processed there and the results are stored like any other; the server keeps no copy and deletes itself when it is idle. The uploaded source is deleted after processing (for a recording whose voice comms still need transcribing on a PC, after at most 7 days). Recordings an org's member made private are processed in the cloud only if the org allows it. A coach's students' recordings are processed on the coach's PC or, when none is available, on these cloud servers.
Keeping the video for later (source archive). When an org turns it on (its admins decide; it is off for a new org and never used for a coach's students), the PC that processed a recording uploads the video the report was made from, with its sound, including voices, to Debrief's storage in Microsoft Azure in the EU (Sweden Central). It is kept there for 12 months after it was stored, so the org can process the recording again later with a newer version of Debrief (on any of the org's PCs, or on Debrief's cloud servers when the org allows cloud processing). Only that processing reads it; members see no more than before (the recording's owner and the org's admins see until when it is kept). It is deleted after the 12 months, and earlier when the recording or its owner's account is deleted, when it is moved to an org that does not keep videos, or when the org turns the archive off. Deleted videos can remain in backups as described in section 16.
10. Coaching
Independent coaches can use Debrief to review their students' games. A coach applies on Debrief; we decide on the application and keep the name students see, the bio and the version of the Data Processing Agreement the coach accepted (we are the controller of this application data).
Students' recordings: the coach is responsible. A coach sends a student an upload link. The upload page tells the student who the coach is and that the coach decides what happens with the recording (the coach is the controller); Debrief stores and analyses it for the coach and for nothing else (we are the coach's processor). The student does not need an account. Before uploading, the student confirms that they are at least 16 and that they read the notice, and chooses the sound (game sound only, or none).
What is processed. The recording and everything in it (in-game names on screen, and voices if the sound holds them), the report Debrief makes from it, the name and (optional) email address the coach entered for the student, the student's confirmations and the coach's own notes, pinned moments, agenda and review. The recording is processed on the coach's PC or on Debrief's cloud servers in the EU (section 9). The coach can let an AI draft a review (section 7), checks and edits it, and can give the student a view-only link to that one report with the approved review; the link can be withdrawn at any time and can expire.
Who sees it. The coach (and anyone the coach adds to their coaching org). The student sees only what the coach shares through a link. Debrief's staff do not look at students' recordings except through the audited support access described in section 14.
How long, and deletion. Until the coach deletes it; the uploaded file itself is deleted once the report is made. To have a recording deleted, a student asks the coach, or writes to privacy@debrief.games and we pass the request to the coach. Deleting a student's recording removes its report, the coach's notes, the review, every share link and the student's details at once.
"Tell me about Debrief later." This box on the upload page is optional and unticked. If a student ticks it, we store that choice (we are the controller; legal basis: consent, Art. 6(1)(a)). We do not send anything during the beta; before we send anything we will ask the student to confirm their email address. The student can withdraw at any time by writing to privacy@debrief.games.
11. Improving Debrief's models (training data)
What we use. When an organisation runs labelling tasks on Debrief ("Help train Debrief"), we cut small samples from that organisation's own recordings: still images of the game's interface (ability icons, item slots, the kill feed, death-recap screens, supply bins), frames around a moment a detection rule flagged, and, only where the organisation has voice comms transcripts turned on, short audio clips of a voice line with its transcribed text and the lines around it. Members who choose to help (they turn it on in their profile and can stop at any time) label these samples; we store each answer with the member's account. When you mark a flag as wrong, the reason you pick is used the same way.
Why. To measure and improve how accurately Debrief reads gameplay and detects mistakes (our readers, detectors and rules: "the models").
Legal basis. Our legitimate interest in improving the service (Art. 6(1)(f) GDPR) for samples taken from the players' own gameplay footage, together with the organisation's agreement in our Data Processing Agreement, which allows us to use these samples for this purpose.
Other players. Kill-feed lines, death recaps and some frames show the in-game names of other players, and comms clips contain the voices of the organisation's members. We keep this to what a labelling task needs, use it only to label and to train and test our models, and do not combine it with other information about those players.
Who can see it. While a task is open: the organisation's members who help label and its admins. After a task is closed, its samples stay in the organisation's training archive, which only the organisation's admins and Debrief can see. Samples are never shared with, or pooled with the data of, other organisations, and never published.
How long. Up to 24 months from when a sample was added. After that we delete its images, audio and text; the labels are kept only as numbers and choices that no longer contain personal data.
Deletion. Deleting a recording removes every sample taken from it. Deleting a voice line, your own voice ("These are my lines") or a whole transcript removes the comms samples that contain it, and an organisation turning voice comms transcripts off removes all of its comms samples. Deleting your account removes your labels and the samples taken from your recordings. Deleting an organisation removes its training data.
12. Payments
When an org buys a plan or report credits, the payment is handled by Stripe (Stripe Payments Europe, Limited, Dublin, Ireland). You enter your card or other payment details on Stripe's own pages; they go to Stripe, never to Debrief, and we never see full card numbers.
What we keep. The org's name, the email address of the admin who buys, the billing name and address, the VAT number if given, the plan or credits bought, Stripe's references for the customer, subscription and payments, the payment status, invoices and refunds. If someone uses the site's "Cancel contracts here" or "Withdraw from contract" form, we keep the declaration (name, email address, which contract, an optional reference and reason, when) and confirm it.
Who does what. Stripe processes payment data for us to take payments and issue invoices, and as an independent controller for its own legal duties (for example fraud prevention and anti-money-laundering checks) under its privacy policy. Stripe may transfer data to Stripe, Inc. in the United States (section 15).
Legal basis. Art. 6(1)(b) (the contract the org makes with us) and 6(1)(c) (German commercial and tax law, which requires us to keep invoices and records).
How long. Invoices and accounting records 8 years, books and annual accounts 10 years, business letters (including cancellation and withdrawal declarations) 6 years (§ 257 German Commercial Code, § 147 German Fiscal Code). These records belong to the org: if the admin who bought deletes their account, the records stay without the link to their account. If the org is deleted, its payment records stay as accounting records (amounts, dates, invoice and payment references) without the link to the org, and cancellation or withdrawal declarations stay for their 6 years; the invoices themselves are kept by Stripe.
13. Messages to us, and emails we send
When you write to us with the contact form, we store your name (optional), email address, topic and message in our database in the EU and show them to our administrators, who are told in Debrief that a message arrived. We use them only to answer you and delete them 90 days after they arrived (earlier when you ask). If you were signed in, the message is also in your data export and is deleted with your account.
Emails to our addresses (contact@debrief.games, privacy@debrief.games) are received by Cloudflare (Cloudflare, Inc., United States; Cloudflare Email Routing, which also runs the DNS of our domain) and forwarded to our mailbox at Google (Gmail). Both process the email (sender, content, attachments) to deliver and store it. We keep emails as long as needed to answer and settle the matter, and longer only where a legal duty requires it (for example business letters, which German commercial and tax law requires us to keep for 6 years).
Emails we send. When Debrief sends emails (for example an invitation, a notice about your account or your org's plan, or a link a coach asked us to send to a student), it sends them through Azure Communication Services (Microsoft, data location Europe). The service processes the recipient's address and the email's content to deliver it. We send only emails that belong to the service you use, and no newsletters or advertising without your consent.
14. Who receives your data
- Your org. The org's members see the org's shared recordings, reports, transcripts, comments, verdicts, Player Stats and Coach reports, and each other's display names. Org admins see the members, their sign-in email or Discord id and their nodes.
- Your coach (if you send a recording to a coach): everything in section 10.
- Members' PCs in the swarm (section 9), and the org admin's or coach's PC and Claude account that run the Coach or draft a review (section 7).
- Our subprocessors, who host and run Debrief for us: see the list of subprocessors (Microsoft Azure in the EU, including Azure Communication Services for emails we send; Cloudflare and Google for email to us; Stripe for payments; Anthropic when Debrief itself drafts AI reviews).
- Stripe as an independent controller for its own legal duties when an org pays (section 12).
- The site's platform admin (us) manages accounts and orgs but does not see an org's recordings. To help an org, the platform admin can start a support access with a reason: for at most 72 hours it gives read-only access to the org's shared recordings (never private ones). The org's admins are notified at once, see the reason and can end it at any time. Every start and end is in the security log. The platform admin also sees the samples of closed training tasks (section 11).
- Viewing the site as you (support). When you report a problem, the platform admin can look at Debrief as you see it to find it: with a reason, read-only (nothing can be changed, uploaded, deleted or downloaded as you, and your data download stays yours), for at most 30 minutes at a time. They then see what you see: your orgs' recordings and reports, your Profile, notifications and settings. You get a notification with the reason at once, every start and end is in the security log, and your data download (Profile → Download my data) lists every such view with its reason.
- Sign-in providers (Google, Meta for Facebook, Discord, Microsoft) learn that you signed in to Debrief. They are independent controllers under their own privacy policies (section 3a).
- Authorities and courts, when the law requires it.
15. Transfers outside the EU
We host Debrief in Microsoft Azure's Sweden Central region (EU): the database, the stored recordings, the cloud processing servers and the backups stay there. Microsoft may access data from outside the EU only in the limited cases its EU Data Boundary and data protection addendum allow (for example security and support), protected by the EU Standard Contractual Clauses and the EU-US Data Privacy Framework.
Emails to us pass through Cloudflare and are stored by Google, both in the United States among other places, under the EU-US Data Privacy Framework (both companies are certified) and the EU Standard Contractual Clauses.
Stripe may transfer payment data to Stripe, Inc. in the United States, under the EU-US Data Privacy Framework and the EU Standard Contractual Clauses. When Debrief itself drafts AI reviews, Anthropic receives the facts described in section 7 in the United States, under Anthropic's data processing addendum with the EU Standard Contractual Clauses.
The Coach and coaches' AI-drafted reviews on their own PCs (section 7) send data to Anthropic in the United States under the terms of that admin's or coach's Claude account. Your sign-in provider may process your data outside the EU under its own terms.
16. How long we keep data
| Data | How long |
|---|---|
| Your account and profile | until you delete your account (Profile → Delete my account) or the platform admin deletes it |
| Sessions | until you sign out, after 14 days without use, or 30 days at most |
| Sign-in in progress | 10 minutes |
| A connected sign-in (the provider's id and the email it reported) | until you remove it on your Profile, delete your account, or (Facebook) remove Debrief in your Facebook settings |
| The record of a Facebook data deletion request (its confirmation code, when, what was removed; not your Facebook id) | 1 year |
| Access requests | 30 days after they are approved or refused; 60 days if nobody answers |
| Invite links | until they expire (7 days by default, 90 at most); deleted 30 days after they expire, are revoked or used |
| Notifications | 90 days |
| Contact form messages | 90 days, or until you ask us to delete them or delete your account |
| Emails to us | as long as needed to answer and settle the matter; business letters 6 years (§ 257 German Commercial Code, § 147 Fiscal Code) |
| Security log | currently without a fixed limit; before launch limited to [AUDIT_LOG_RETENTION] |
| Recordings, reports, statistics, clips, comments, verdicts, Coach reports | until the recording's owner or an org admin deletes them, the org's admins delete the org, or the org ends its use of Debrief (60 days after the end) |
| Everything of an organisation (its recordings and everything above made from them, its members list, invites, settings, Coach, training data, voiceprints and coaching data) when its admins delete it | deleted at once; members keep their accounts; payment records stay as described in section 12 |
| A coach's students' recordings, with the student's details, notes, reviews and share links | until the coach deletes them, or the coach's organisation (section 10) |
| Coach applications | as long as the coach's account exists |
| The uploaded source file | deleted once the recording is processed; unprocessed leftovers after 30 days (section 9 for cloud processing) |
| The video a report was made from, when the org keeps it (source archive) | 12 months after it was stored, or until the recording or account is deleted or the org turns the archive off (section 9) |
| The 720p playback copy | 90 days after processing (the report and clips stay) |
| Unfinished uploads | stopped after 7 days |
| Voice comms transcripts | as the org chooses: as long as the recording, or 30, 90 or 365 days |
| Voice embeddings | on the processing computer only (section 6), never uploaded |
| Voiceprints | while your consent lasts (section 6); consent records until your account is deleted |
| Records of deleted transcript lines (no text: which recording, which speaker, who asked, when) | as long as the recording is stored, so deleted lines stay deleted |
| Training samples | up to 24 months, then images, audio and text are deleted and only anonymous labels stay (section 11); your labels until you delete your account |
| Payment records, invoices, cancellation and withdrawal declarations | invoices and accounting records 8 years, books and annual accounts 10 years, business letters 6 years (section 12) |
| A student's "tell me about Debrief later" | until withdrawn, or with the recording |
| Support access records, and the records of views of the site as you (section 14) | currently without a fixed limit (under review); the views as you are deleted with your account |
| Legal acceptances | as long as your account exists; an org's DPA acceptance as long as the org exists |
| Copies on members' PCs | section 9 |
| Application logs (errors, no IP addresses stored by us) | 30 days |
Backups. Deleted data can remain in backups for a short time: a nightly database copy is kept for 30 days, the database can be restored to any moment in the last 7 days, and deleted files stay recoverable for 7 days. So everything you delete is gone from all backups within 37 days. Backups are only used to restore the service after a failure.
17. How we protect it
Data is encrypted in transit (HTTPS/TLS) and at rest (Azure storage and database encryption). Access is limited by role: members see only their own orgs, the platform admin sees an org's recordings only through an audited, time-limited support access or a read-only view of the site as a member who asked for help (section 14), and our own staff and systems use least-privilege access. Session and device tokens, upload links and share links are stored only as hashes; secrets are kept in Azure Key Vault. Cloud processing servers have no public address and accept no incoming connections. Links to videos are signed and expire within hours. Voiceprints are never sent to a browser, an export or a log. Details are in Annex 2 of the Data Processing Agreement.
18. Your rights, and how to use them
You have the right to access your data (GDPR Art. 15), to have it corrected (Art. 16) or deleted (Art. 17), to restrict its processing (Art. 18), to data portability (Art. 20), to object (Art. 21, below) and to withdraw a consent at any time with effect for the future (Art. 7(3)). Most of this you can do yourself:
- Access and portability: Profile → Download my data (a JSON file with your account, memberships, recordings with links to their files, comments, verdicts, notifications, security log entries, contact messages, the documents you accepted, your confirmations and consents, training labels, coaching data and more).
- Correction: Profile (display name, in-game names); ask your org's admin or us for the rest.
- Deletion: Profile → Delete my account; delete single recordings on their page; delete your voice lines with These are my lines. An organisation's admins can download the organisation's data and delete the whole organisation on its admin page.
- Withdrawing a consent or a choice: voice recognition and "Help train Debrief" can be switched off in your Profile at any time; a student's "tell me about Debrief later" by writing to privacy@debrief.games.
- Objection and restriction: write to privacy@debrief.games or use the contact form.
For an org's or a coach's recordings, the org or the coach is the controller: we pass requests on to them and help them answer. We answer requests within one month. We may ask you to confirm who you are.
Your right to object (Art. 21 GDPR). Where we process your data on the basis of our legitimate interests (Art. 6(1)(f)), for example training data (section 11), you can object at any time on grounds relating to your particular situation. We then stop, unless we can show compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims. Write to privacy@debrief.games.
19. Cookies and storage on your device
Debrief stores only what is strictly necessary for the service you ask for on your device (signing in, remembering choices you make on the site), which German law allows without consent (§ 25(2) no. 2 TDDDG); no tracking. See the cookie notice.
20. Children
Debrief is for people aged 16 or older. In Germany, a person can consent to an online service on their own from 16 (GDPR Art. 8), and Apex Legends is rated 16 (PEGI 16, USK 16). We do not knowingly let younger people create accounts, and a coach's students confirm that they are at least 16 before they upload. If you believe a child uses Debrief, or that a recording holds a child's voice that should be removed, contact privacy@debrief.games.
21. Plans not offered yet
Not offered yet; this section will be completed before it starts.
- Solo plan. A person reviews their own recordings. We are the controller for these recordings. We may offer a coach's student the Solo plan inside Debrief (for example on their report). We do not send marketing emails to students unless they opted in.
22. Changes to this policy
We publish each version of this policy on this site and keep earlier versions readable. We tell users about material changes before they take effect.
23. Complaints
If you think we handle your data wrongly, please tell us first at privacy@debrief.games. You also have the right to complain to a data protection supervisory authority (GDPR Art. 77), in particular in the EU country where you live or work. The authority responsible for us is Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI), Ludwig-Erhard-Straße 22, 20459 Hamburg, Germany, mailbox@datenschutz.hamburg.de, https://datenschutz-hamburg.de.