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Data Processing Agreement (DPA)

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This is a convenience translation. Only the German version is legally binding: Deutsche Fassung

This document is our standard offer pursuant to Art. 28 GDPR for server operators who use KynxBot on their Discord server. It is not an individually reviewed legal mandate. In the case of special risks (e.g. schools, public authorities, health data), please obtain your own legal advice.

1. Parties and roles

The controller of the personal data of server members for the purposes of server moderation, tickets, welcome messages and internal community rules is, as a rule, the respective Discord server operator (admin/owner).

The processor for the technical provision of KynxBot is Julius Zeeck (KynxStudios), kynxbot.de (contact details in the Imprint).

Discord Inc. also remains the platform provider. Google (Gemini) is only involved if the server operator deliberately uses Voice AI or comparable AI skills.

2. Subject matter

The processor provides the Discord bot and the dashboard and, in doing so, processes the data required for the features activated by the controller (configuration, tickets, leveling, moderation, optional AI).

3. Type of data

Typically: Discord user IDs, usernames, role and channel IDs, texts configured by the server, ticket content, XP/levels, moderation actions, and optionally voice or chat context where AI features are activated. Details can be found in the data inventory.

3a. Categories of data subjects

Members and visitors of the controller's Discord server, team members (moderators, admins), persons who open tickets or submit requests via an interface set up by the controller (e.g. contact form, game report), and persons speaking in voice channels with Voice AI enabled.

4. Instructions and purpose limitation

Processing takes place only for the performance of the contract and in accordance with the settings made by the controller in the dashboard. The data is not used for advertising or third-party analytics. If the controller sets up webhooks or the settings API, we transmit the selected event data (e.g. Discord IDs, usernames, message texts) on their instruction to the address they specify; the controller alone is responsible for this recipient (contract, third country, informing members).

5. Sub-processors

The following sub-processors process personal data on our behalf:

  • Hetzner Online GmbH, Gunzenhausen – hosting of website, bot, database and backups in Germany
  • Google (Gemini API, paid tier) – only if Voice AI, the AI assistant or other AI features are used; USA (EU-U.S. Data Privacy Framework / Standard Contractual Clauses)
  • Anthropic PBC (Claude API) – depending on our settings for the AI assistant, channel/role editor and website assistant; USA (Standard Contractual Clauses in the Anthropic Data Processing Addendum); no use for training, deletion generally after no more than 30 days. New, announced on 4 November 2026.
  • prepaid-host.de (e-mail delivery) – account and invoice e-mails and e-mail replies from tickets that the controller creates via the interface

Not sub-processors (receive no personal data):

  • Discord is the platform on which the controller runs their server and is independently responsible.
  • Media generation (Pixazo, India): only receive prompts that have been automatically anonymised beforehand and content generated by the bot itself, no identifiers and no uploaded images or videos.
  • Search services (Google Search, Tavily, Brave): only receive checked, anonymised search terms without user or server identifiers.
  • OpenAI and Z.ai are not used and receive no data.

Third countries: Personal data is only sent to the sub-processors listed above, and to third countries only with appropriate safeguards (EU-U.S. Data Privacy Framework or Standard Contractual Clauses). Further transfers to third countries only take place on the documented instruction of the controller – for example if they set up webhooks, the settings API or their own AI key of another provider (voice AI or “AI models & providers” in the server settings); they are responsible for this themselves.

Changes: We announce new or changed sub-processors at least 30 days in advance on this page and on the support server. The controller may object within this period for an important data protection reason; if we find no solution, they can terminate the contract by removing the bot and requesting deletion.

6. Security

The technical and organisational measures (Art. 32 GDPR) are set out in Annex 1.

6a. Obligations of the processor (Art. 28(3) GDPR)

  • Instructions: processing only on documented instructions from the controller; the settings in the dashboard and messages to support are deemed instructions. If the processor considers an instruction to be unlawful, it shall inform the controller without undue delay.
  • Confidentiality: all persons with access to personal data are bound to confidentiality.
  • Assistance: the processor assists the controller with data subject requests, data protection impact assessments and notifications to authorities (Art. 32–36 GDPR).
  • Data breaches: the processor notifies the controller of personal data breaches without undue delay, where possible within 48 hours of becoming aware of them, with the information required under Art. 33(3) GDPR (via the contact channels stored for the server or an announcement on the support server).
  • Sub-processors: only with equivalent data protection obligations; changes are announced in advance (section 5).
  • Evidence and audits: the processor makes available all information necessary to demonstrate compliance with its obligations (including the record of processing activities and the technical and organisational measures) and allows audits after reasonable prior notice, primarily by the provision of documents.
  • Return and deletion: after the end of the contract, the data is deleted (section 8) unless there is a statutory retention obligation; on request, the server owner may request an export beforehand.

7. Data subject rights and deletion

Information about your own website account: Privacy Center. The processor accepts deletion requests relating to the account. Data that the controller itself holds in the server context (tickets, leveling, configuration) is deleted by the controller in the dashboard; the server owner can also arrange for the deletion of all data of their server in the profile.

8. Term

The agreement applies for as long as the bot is installed on the controller's server or a website account exists. After the bot has been removed, the server data is retained for a further 60 days (e.g. to allow a switch to a whitelabel bot or a re-invitation) and is then deleted automatically; a technical backup copy is removed after a further 14 days. Statutory retention obligations remain unaffected.

9. White-label bots

If the controller uses their own bot (white label), this agreement applies equally. The bot token is stored encrypted and only used to operate this bot; the controller is responsible for the Discord developer account of their own bot.

10. Acceptance

The server operator expressly accepts this DPA in the dashboard (checkbox "As the controller, I conclude the DPA for this server and all other servers I manage with KynxBot"). The acceptance applies once per account and version to all servers this person manages. As proof, we store the Discord ID of the accepting person, the version and the time, plus a separate record for each server concerned. As long as there is no express acceptance, the DPA is deemed agreed by inviting and continuing to operate the bot. A signed version can be requested via support@kynxbot.de. Version: 2026-11.

Annex 1: Technical and organisational measures

  • Physical access: Hetzner data centre in Germany (ISO 27001), access only for the provider's staff
  • System access: Login only via Discord OAuth; admin area only for registered administrators; server access only via SSH key
  • Data access: Server-side permission check on every request; ticket and moderation content only for the team of the respective server, no special access for our administrators
  • Transfer: TLS encryption of all connections; credentials stored encrypted and never sent to the browser
  • AI privacy: Mandatory check before providers without a DPA (pattern matching + checking model), no transfer in case of doubt; uploads only to providers with a DPA
  • Input control: Logs of admin changes and payment events without content
  • Availability: Encrypted database backups (AES-256), deleted after 30 days; monitoring and automatic restarts
  • Separation: Data separated per Discord server; test and live payments separated
  • Data breaches: Incident response plan with 72-hour reporting path and breach register
  • Deletion: Automatic retention periods per data type; server data 60 days after the bot is removed

Last updated: November 2026 · Template, not certified by a lawyer