# Lannore privacy policy

**Version:** `2026-10-14.1` (replaces `2026-10-09.1`)
**Language:** English (source text). The German version has the same content; both are equally binding.
**Controller:** RPK Digital Solutions GbR, operating the AGIMetis brand and the Lannore product, Ludwig-Quidde-Straße 5, 13127 Berlin, Germany, represented by its partners Ramin Khorsandi and Parisa Khayamdar
**Contact:** contact@agimetis.com
**Status:** prepared on 2026-10-14 after an AI-assisted legal review that the founders delegated. It applies from its publication in the app.

## 1. Who is responsible

RPK Digital Solutions GbR ("Lannore", "we", "us") is the controller for the
processing described here. You can reach us for every privacy question and
request at **contact@agimetis.com** or at the postal address above. We have not
appointed a data protection officer because the law does not require one for
our organisation.

## 2. What this policy covers

This policy covers the Lannore app on the web (app.lannore.com), on Android and
on Google TV, including accounts, viewing, purchases and subscriptions, creator
profiles and payouts, comments, advertising and the Lannore Awards. The
marketing site lannore.com has its own privacy information.

Free areas of Lannore may show advertising. We choose it only by context (the
film, collection, genre or premiere and your country), never by a personal or
behavioural profile. We do not use advertising trackers, do not build
advertising profiles, do not give advertisers personal data and do not sell or
share personal data for advertising. Lannore Plus and paid access show no
advertising.

We apply the standards of the EU General Data Protection Regulation (GDPR) in
sections 1 to 13 to every member worldwide. Section 14 adds what the law of
your country or region requires in addition; where it gives you more rights,
it prevails.

## 3. Data we process, why, and on which legal basis

| Activity | Data | Purpose and legal basis |
|---|---|---|
| Account and sign-in | email address, password (stored only as a secure hash), display name, account identifier, your confirmation that you are at least 18, sign-in and session events, IP address and browser or device information for security, multi-factor settings, and your Google account identifier and email if you sign in with Google | Create and run your account and keep it secure: Art. 6(1)(b) GDPR; detect and stop account abuse: Art. 6(1)(f). |
| Accepted documents | the exact version, address and hash of the terms and privacy policy you accepted, with date and time | Prove what was agreed: Art. 6(1)(b), (c) and (f). |
| Viewing and playback | film, time, short-lived signed access token, playback session, device type and the country derived from your network connection | Deliver the films you are entitled to and respect the territories in our licences: Art. 6(1)(b); protect rights holders against unlicensed access: Art. 6(1)(f). |
| Country of residence and use while travelling | the country you state in your account (your country of residence for contracts); when you watch a paid film from another country: that country, the day and the decision whether the film may be shown there; if a film needs it, the confirmation of your residence from the billing address of a purchase | Provide paid films while you travel in the EU and respect licence territories elsewhere (Regulation (EU) 2017/1128): Art. 6(1)(b) and (c); suggest updating your country after a long stay elsewhere: Art. 6(1)(f). |
| Advertising on free areas | which advertisement was delivered or viewed in full, when, with which film, collection or premiere, a daily pseudonymous value that limits how often you see the same advertisement, clicks on it and fraud signals; your reports about advertisements | Show contextual advertising on free areas, cap its frequency, bill advertisers for valid deliveries, pay creators their share and prevent fraud: Art. 6(1)(f), our legitimate interest in financing free films; handling reports: Art. 6(1)(c). Advertisers receive only aggregated figures. |
| Advertisers (only if you book a campaign) | advertiser profile, consumer or business status, commissioning party and payer, creatives, destination, campaign settings, reviews, payments and invoices | Provide and bill the campaign and review it: Art. 6(1)(b) and (c); show the advertiser and payer on the advertisement, as the law requires: Art. 6(1)(c). |
| Watch time for creator pay, Awards and fraud checks | per account and film: playback session, start and end time, seconds watched, completion, how access was granted (for example purchase, Plus or free), device type, country and whether the viewing is excluded as staff, test or suspicious traffic | Pay creators their share of Lannore Plus by qualified watch time as our creator agreements require, check that an Award vote meets the watch rule, and detect automated, duplicate or fraudulent viewing: Art. 6(1)(f), our legitimate interest in paying creators correctly, keeping the Awards fair and preventing fraud; for your own Award vote also Art. 6(1)(b). This is recorded whether or not you allow optional analytics. |
| Optional product analytics | pseudonymous product and playback events and their contribution to daily film statistics | Understand and improve Lannore, only if you switch it on: Art. 6(1)(a) GDPR and, where your device is accessed for it, § 25(1) TDDDG. Saying no does not limit anything else. |
| Purchases, subscriptions and payments | orders, rentals, tickets, credits and passes, Lannore Plus status and trial, invoices and receipts, amounts, currency, tax country, the seller and payment provider of each purchase, payment-provider customer and transaction references, refunds and chargebacks, the documents and versions you accepted for the purchase with language, country and device, your request for immediate access with its time, withdrawals and cancellations you declare with the name and email address you give for their confirmation (and, for a cancellation without signing in, the account email address and plan you name), and a one-way hash of the payment method used for a Plus trial | Sell and provide what you buy, bill, refund and handle cancellations: Art. 6(1)(b); keep accounting and tax records: Art. 6(1)(c); prevent payment fraud and repeated free trials, and establish or defend legal claims: Art. 6(1)(f). We never receive your full card number. |
| Creator profiles, submissions, earnings and payouts (creators only) | creator and team details, film metadata, rights declarations, the youth protection questionnaire and the rating of each film, licences, review and moderation records, earnings, statements, tax details (payee, legal form, residence, VAT status, exemption certificates), payout account status and the verification status that the payout provider reports | Operate the creator agreement and pay creators and Award prizes: Art. 6(1)(b); tax and accounting duties: Art. 6(1)(c); rights clearance and fraud prevention: Art. 6(1)(f). |
| Comments and community | comments you post (shown to other members with your display name), reports you send or receive, moderation decisions and appeals | Provide comments and keep the community safe and lawful: Art. 6(1)(b) and (f), and Art. 6(1)(c) where the law requires us to act on reports. |
| Lannore Awards | entries, eligibility reviews, audience votes, jury scores, results and complaints | Run an Award season under its published rules: Art. 6(1)(b); keep results fair: Art. 6(1)(f). A vote is linked to your account internally only to enforce one vote per category and the watch rule; other people only ever see totals. |
| Notifications and email | in-app notifications, notification preferences, your email address and the push token of your device | Send service messages and the notifications you chose: Art. 6(1)(b). Contract confirmations, withdrawal and cancellation receipts, the notice to your account address about a cancellation made without signing in, and reminders before a trial ends or a subscription renews are sent regardless of your notification settings, because the law requires them or they protect you from unwanted charges: Art. 6(1)(b), (c) and (f). |
| Support, privacy requests and safety | messages, privacy requests, reports, appeals, restriction and takedown evidence and audit records | Answer you, handle your rights and keep the service secure and lawful: Art. 6(1)(b), (c) and (f). |

Where we rely on Art. 6(1)(f), our legitimate interests are named in the table:
security, fraud prevention, respect for licences, correct pay for creators,
fair Awards, financing free films through contextual advertising and the
establishment or defence of legal claims. We keep this data to the minimum,
show creators only totals and never use it for personalised advertising.

## 4. Automated checks

We do not take decisions based solely on automated processing that have legal
or similarly significant effects on you (Art. 22 GDPR). Automated signals, for
example for suspicious playback, payment fraud or repeated trials, can exclude
watch time from creator pay or a vote from an Award count, hold a payout or
start a review. You can contest such an outcome, and a person reviews it.

## 5. Who receives data

**Service providers that process data on our behalf (Art. 28 GDPR):**

- **Supabase** for the database, sign-in, file storage and server functions;
  our data is stored in the European Union (Stockholm region);
- **Bunny Stream** (BunnyWay d.o.o., Slovenia) for video processing and
  streaming;
- **Cloudflare** for storing original film files (R2);
- **Netlify** for hosting the web app and the website;
- **IONOS** (Germany) for sending email;
- **RevenueCat** for verifying purchases and subscriptions made through Google
  Play; and
- **Google Firebase Cloud Messaging** for push notifications.

**Providers acting as independent controllers under their own privacy
terms:**

- **Stripe** (Stripe Payments Europe, Ltd., Ireland) as payment service
  provider for RPK direct sales on the web and for creator payouts, including
  the identity, bank and tax checks that payouts require;
- **Google** (Google Ireland Limited; for purchases Google Commerce Limited) for
  purchases in the Android and Google TV app through Google Play, where Google
  is the seller, and, if you choose it, for signing in with Google;
- a **merchant of record** named in a checkout, where one sells the purchase in
  its own name, for the data it needs for the sale;
- our **bank**, where we pay creators by bank transfer.

**Others:** authorities and courts where the law requires it; tax advisers and
auditors who are bound to confidentiality; in a copyright or rights complaint,
the parties involved to the extent needed to resolve it; a recognised youth
protection self-regulation body for the films we escalate to it (film data and
the creator's answers, not data about viewers); and advertisers, who receive
only aggregated figures about their campaigns.

Other members see your display name with your comments. Creators see totals
per film, never who watched. Audience votes are never shown individually.

## 6. International transfers

We are based in Germany, and our data is stored in the European Union. If you
use Lannore from outside the European Economic Area, your data is transferred
to us in Germany for the purposes in section 3.

Some providers (Supabase, Cloudflare, Netlify, RevenueCat, Stripe and Google)
are based in the United States or use sub-processors there. Such transfers rely
on the European Commission's adequacy decision for the EU-U.S. Data Privacy
Framework (Art. 45 GDPR) where the recipient is certified, and otherwise on the
EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) in the provider's data
processing terms. Section 14 names the additional safeguards some countries
require. You can ask us for a copy of the safeguards.

## 7. How long we keep data

- **Account data** is kept until you delete your account. Deletion takes
  effect 30 days after your request, which you can cancel during that time.
  Your account data is then deleted or anonymised, except for the records
  below.
- **Watch time and fraud review records** are deleted automatically 180 days
  after the viewing started. A monthly Plus calculation keeps only the total
  qualified watch time per film, without viewer identity.
- **Optional analytics events** are deleted after 90 days at the latest, and
  immediately when you switch analytics off.
- **Playback access tokens** expire within hours; their records are deleted
  one day after expiry.
- **Audience votes:** the link between a vote and your account is deleted when
  you delete your account, and at the latest 12 months after the season's
  results are published. The vote itself stays in the result without any link
  to you.
- **Your request for immediate access, withdrawals and cancellations** are
  kept with the contract records below as evidence of what was agreed.
- **Purchases, invoices, ledger postings, payouts and tax evidence** are kept
  for the statutory periods of German commercial and tax law (§ 257 HGB,
  § 147 AO): accounting vouchers for 8 years and books and records for 10
  years, counted from the end of the calendar year. When you delete your
  account they are separated from it and kept under a pseudonymous reference
  with restricted access.
- **The payment-method hash of a Plus trial** is kept while we offer the trial,
  so that each payment method gets one trial; after you delete your account it
  is no longer linked to you.
- **Comments** are deleted when you delete them or your account. **Reports,
  moderation and rights decisions, appeals and audit records** are kept for as
  long as they are needed to prove the lawful operation of the service, in
  general until the statutory limitation period ends (usually three years from
  the end of the year, § 195 BGB) and for the duration of any dispute. After
  your account is deleted they refer to you only by a pseudonymous account
  identifier.
- **Data exports** you request are available for download for a limited time
  and are then deleted.
- **Advertising deliveries:** the daily pseudonymous frequency value is
  removed after 7 days; delivery and click records are deleted after 13
  months, when the campaign and the creator shares have been settled.
- **Use while travelling:** the record of a day spent in another EU country is
  deleted after 120 days, and each decision about watching abroad after 90
  days; a confirmation of your residence is valid for 12 months and is removed
  when you change your country.
- **Youth protection questionnaires and ratings** are kept for as long as the
  film is available on Lannore and three years afterwards.
- Deleted data can remain in our encrypted backups for up to 90 days, until
  those backups are rotated out.

## 8. Your rights

You have the right to access your data (Art. 15 GDPR), to rectification
(Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18), to data
portability (Art. 20) and to withdraw consent at any time with effect for the
future (Art. 7(3)).

**Right to object (Art. 21 GDPR):** you may object at any time, on grounds
relating to your particular situation, to processing based on Art. 6(1)(f). We
then stop unless we can demonstrate compelling legitimate grounds that override
your interests, or the processing serves the establishment, exercise or defence
of legal claims.

You can request and download a copy of your data and switch optional analytics
on or off in the app's privacy settings, and delete your account in the
account settings. Switching analytics off deletes the analytics events linked
to your account but not the watch time described in section 3, which creator
pay, Award votes and fraud checks depend on. For anything else, write to
contact@agimetis.com.

You may also lodge a complaint with a data protection supervisory authority, in
particular in the EU member state of your habitual residence, place of work or
the place of the alleged infringement. The authority responsible for us is the
Berliner Beauftragte für Datenschutz und Informationsfreiheit.

## 9. What you need to provide

To create an account you need an email address and a password, or a Google
account. To buy something you need a payment method accepted by the seller or
its payment provider (Stripe, Google Play or the merchant of record named in
the checkout). Without this data we cannot open an account or complete a
purchase. Everything else is optional.

## 10. Storage on your device

The app stores your sign-in session, settings and the technical data needed to
secure your account and play films on your device. This is strictly necessary
for the service you request (§ 25(2) No. 2 TDDDG). Optional analytics only runs
after your consent.

## 11. Age

Lannore is for adults. You must be at least 18 years old and of legal age where
you live to create an account, and you confirm this when you sign up. We do not knowingly process data of
children; if we learn that an account belongs to a minor, we delete it.

## 12. Security

We protect data with authenticated and encrypted connections, least-privilege
access, multi-factor authentication for staff, short-lived signed media access,
encrypted backups and audit records. No method of transmission or storage is
completely secure; please keep your credentials confidential and tell us
promptly if you suspect misuse.

## 13. Changes

We update this policy when our processing changes. The current version is
always available in the app and on our website. If a change affects you
materially, we show it in the app before it applies. The exact version you
accepted is kept as evidence.

## 14. Regional information

### 14.1 European Union and European Economic Area

Sections 1 to 13 are written for the GDPR. The authority responsible for us is
named in section 8; you may also complain to the authority where you live or
work.

### 14.2 United Kingdom

The UK GDPR and the Data Protection Act 2018 apply. Transfers from the United
Kingdom to us rely on the UK's adequacy regulations for the European Economic
Area, and onward transfers to the United States on the UK Extension to the
EU-U.S. Data Privacy Framework or the UK Addendum to the EU Standard
Contractual Clauses. Our representative in the United Kingdom under Article 27
UK GDPR will be named here once appointed; until then, contact us directly. You
may complain to the Information Commissioner's Office (ico.org.uk).

### 14.3 Switzerland

The Federal Act on Data Protection (FADP) applies. Transfers rely on the Swiss
Federal Council's adequacy decisions (including for Germany, the European
Economic Area and certified recipients under the Swiss-U.S. Data Privacy
Framework) or on the EU Standard Contractual Clauses with the Swiss addendum.
You may complain to the Federal Data Protection and Information Commissioner
(edoeb.admin.ch).

### 14.4 United States

**Categories of personal information** we collect, in the terms of the
California Consumer Privacy Act and similar state laws: identifiers (email
address, account identifier, IP address, device push token); commercial
information (purchases, subscriptions); internet and network activity
(viewing, watch time, comments); coarse geolocation (country derived from your
network); and account log-in credentials, which we use only to give you
access and keep your account secure. We collect them from you, from your
device and from our payment providers, for the purposes in section 3, and
disclose them only to the recipients in section 5. We keep them as section 7
describes.

**No sale or sharing.** We do not sell personal information and do not share
it for cross-context behavioural advertising, and we have not done so in the
past twelve months. We do not knowingly collect data of anyone under 18. We
treat a Global Privacy Control signal as a valid opt-out of sale and sharing.

**Your rights.** Depending on your state, you may ask to know, access, correct
and delete your personal information and to obtain a portable copy, and you
may not be discriminated against for doing so. Write to contact@agimetis.com
or use the privacy settings in the app; we verify your request through your
account. An authorised agent may act for you with your signed permission. If
we decline your request, you may appeal by replying to our answer; we decide on
the appeal within 45 days and, if we deny it, you may contact your state
attorney general.

### 14.5 Canada

The Personal Information Protection and Electronic Documents Act applies, and
in Quebec the Act respecting the protection of personal information in the
private sector. The person in charge of the protection of personal
information is our managing partner, reachable at contact@agimetis.com. You may
complain to the Office of the Privacy Commissioner of Canada or, in Quebec, the
Commission d'accès à l'information.

### 14.6 Brazil

The General Data Protection Law (LGPD) applies. Our legal bases correspond to
those in section 3: performance of a contract, compliance with a legal
obligation, legitimate interest, the regular exercise of rights and, for
optional analytics, consent. You have the rights in Article 18 LGPD, including
confirmation, access, correction, anonymisation, portability, deletion and
information about sharing. Our channel for data subjects (encarregado contact)
is contact@agimetis.com. International transfers rely on the standard
contractual clauses of the National Data Protection Authority (ANPD) or other
mechanisms of Article 33 LGPD. You may complain to the ANPD.

### 14.7 Australia and New Zealand

The Australian Privacy Principles and the New Zealand Privacy Act 2020 apply.
We disclose personal information to recipients in Germany and other countries
of the European Union and in the United States (section 5). You may complain
to us first and then to the Office of the Australian Information Commissioner
or the New Zealand Privacy Commissioner.

### 14.8 India

The Digital Personal Data Protection Act, 2023 applies once Lannore is offered
in India. Where the Act requires your consent, we ask for it; you can withdraw
it at any time, which may mean we can no longer provide parts of Lannore. You
may access, correct, complete and erase your data, nominate a person to
exercise your rights, and raise a grievance with our grievance officer, who
will be named here before Lannore is offered in India. You may complain to the
Data Protection Board of India after using our grievance process.

### 14.9 Japan

The Act on the Protection of Personal Information (APPI) applies. We provide
personal data to recipients in Germany and other countries of the European
Union, which the Personal Information Protection Commission recognises as
having equivalent protection, and in the United States, which has no
comprehensive federal data protection law; recipients there are bound by
contract to protect the data as described in this policy. You may request
disclosure, correction, suspension of use and deletion of your retained
personal data by writing to contact@agimetis.com. Section 12 describes our
security measures.

### 14.10 South Korea

The Personal Information Protection Act (PIPA) applies.

**Items, purposes and retention:** as described in sections 3 and 7. When the
retention period ends, we delete electronic records irreversibly or anonymise
them.

**Provision to third parties:** only as described in section 5 under "Others"
and to the independent controllers named there.

**Entrustment and overseas transfer:** we process your data in Germany and
entrust it to the providers in section 5. They receive it over the network when
you use Lannore and keep it as section 7 describes:

| Recipient | Country | Data | Purpose |
|---|---|---|---|
| Supabase | United States (data stored in Sweden) | account, viewing, purchase and support data | hosting, database, sign-in |
| Bunny Stream | Slovenia | viewing data, IP address | video delivery |
| Cloudflare | United States | creator uploads | file storage |
| Netlify | United States | IP address, browser data | hosting of the web app |
| IONOS | Germany | email address, message content | sending email |
| RevenueCat | United States | account identifier, Google Play purchase data | purchase verification |
| Google (Firebase) | United States | device push token | push notifications |

You may refuse the overseas transfer by not using Lannore or by deleting your
account, because Lannore cannot be provided without it. The contact details of
each recipient's privacy team are listed on its privacy page; we provide them
on request.

**Your rights:** you may request access, correction, deletion and suspension
of processing, withdraw consent, and request an explanation of, or refuse, a
decision based solely on automated processing. Section 4 explains that people
review automated outcomes. Write to contact@agimetis.com. You may also apply to
the Personal Information Dispute Mediation Committee or the Personal
Information Protection Commission.

### 14.11 Turkey

The Law on the Protection of Personal Data No. 6698 (KVKK) applies once
Lannore is offered in Turkey. We process your data on the legal grounds in
Articles 5 and 6 that correspond to section 3 (performance of a contract,
legal obligation, legitimate interest and, for optional analytics, explicit
consent). Transfers abroad rely on the standard contracts notified to the
Personal Data Protection Authority under Article 9. You have the rights in
Article 11, which you can exercise by writing to contact@agimetis.com; we
answer within 30 days.

### 14.12 Gulf states

The data protection laws of the United Arab Emirates, Saudi Arabia, Qatar,
Bahrain, Oman and Kuwait apply once Lannore is offered in the country
concerned. You may request access to, correction and deletion of your data and
information about its processing. Transfers to Germany and the United States
take place under the safeguards those laws require. Where a law requires a
representative in the country (for example in Saudi Arabia), we will name it
here before Lannore is offered there.

### 14.13 Mainland China

Lannore is not offered in mainland China.

### 14.14 Other countries

Where the data protection law of your country gives you additional rights,
write to contact@agimetis.com and we will help you exercise them.