How personal data is handled when you use Reprehendo, under European Regulation 2016/679 (GDPR). No data is ever sold, shared or used for advertising.
1. Who handles the data and in which role
·For sign-up data (owner email, venue name, payments) the data controller is Ivan Viglierco (Viglietron Project), reachable at viglietronproject@gmail.com.
·For data entered inside the system (staff, guests, bookings) the data controller is the restaurant owner: the provider acts as data processor, handling that data only to run the service and following the owner's instructions.
·By accepting the terms, this notice also serves as the data processing appointment under art. 28 GDPR.
2. What data and why
·Sign-up: venue name, email, language, billing details. Needed to create access, send credentials and manage the subscription.
·Staff: name and access PIN, role, state. Needed to let people work and to know who did what.
·Venue guests: name, phone, notes and visit history, if the owner enters them for bookings and the waiting list.
·Service usage: an action log (who took payment, voided, discounted) for security and to settle disputes.
·Feedback forms: rating and comment, to improve the product. Email is optional.
·Contact requests from the demo: business name, town and phone number left by anyone who asks to be called back after the guided demo. Used only for that call, never for advertising, deleted on request or after 12 months from the last contact.
·Onboarding assistance: to help a newly registered venue, the provider can see the setup progress (how many rooms, tables, dishes and people have been entered) and the date of the last sign-in, and may contact the person named at sign-up. The provider does not see takings, venue guest names or order contents.
3. Legal basis
·Performance of the contract for everything needed to run the service and invoice it.
·Legitimate interest for security, action logs and backups.
·Legitimate interest in helping the customer get the service up and running: you can ask not to be contacted again by writing to the contact address.
·Consent for optional feedback and non-essential communications, withdrawable at any time.
·Legal obligation for keeping tax and accounting records.
4. Where the data is and who sees it
·Data is hosted on cloud infrastructure managed by the platform provider (Emergent), appointed as data processor under the DPA available at app.emergent.sh/dpa.
·Processing takes place in the United States, the European Union and India: transfers outside the European Union rely on GDPR safeguards (standard contractual clauses).
·Providers involved: hosting and database platform (Emergent), email delivery service (credentials, reminders, backups), payment service (subscriptions), speech service (which only receives the order text to read out, with no guest data).
·Each provider handles data only for its own function, on our instructions and never for its own purposes.
·No profiling cookies and no advertising trackers: the app only uses the device's local storage to keep you signed in.
5. How long
·Venue data: for the whole duration of the relationship. On closure it is deleted within 30 days, unless tax law requires otherwise.
·Unconverted free trials: the trial venue and its data are deleted automatically 14 days after expiry.
·Backups: nightly copies stay available for 7 days, then they are overwritten.
·Action log: 12 months.
·Contact requests from the demo: 12 months from the last contact.
6. Your rights
·You can request access, correction, deletion, restriction, portability and object to processing, by writing to the contact address.
·You get an answer within 30 days. Optional consents can be withdrawn at any time.
·If you believe your data is handled improperly you can complain to the Italian data protection authority.
7. Security and breaches
·Access protected by venue code and personal PIN, locked after three wrong attempts; PINs and passwords stored encrypted; each venue's data kept separate.
·In case of a data breach posing a risk to people, affected customers are notified without delay and, where required, the authority within 72 hours.
·As a beta service on third-party infrastructure, transparency is part of the deal: what happened and what was done is put in writing.