01

Scope & Controller Identity

This Privacy Policy applies to all products, services, websites, applications, and APIs offered by TableGreet Ltd. under the brand name TableGreet, including but not limited to our digital menu SaaS platform, QR code generator, analytics dashboard, and any associated mobile or web applications (collectively, the "Services").

For the purposes of the General Data Protection Regulation (GDPR) 2016/679 and the UK GDPR, the data controller is:

TableGreet Ltd.

TableGreet Ltd., Legal Department, United Kingdom

Contact: [email protected]

This Policy does not apply to third-party websites, services, or applications that may be linked to from our Services. We encourage you to review the privacy policies of any third parties you interact with.

02

Information We Collect

We collect personal data under the following categories:

A. Data You Provide Directly

Category Examples
Identity Data Full name, business name, username, role
Contact Data Email address, phone number, billing address
Credentials Hashed password, authentication tokens
Venue & Menu Data Restaurant name, logo, menu items, prices, allergen info, images
Payment Data Billing details (processed by Stripe — we do not store raw card data)
Communications Support tickets, emails, chat transcripts

B. Data Collected Automatically

  • Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, language settings
  • Usage Data: Pages visited, features used, clicks, session duration, referral source, QR scan counts (anonymised)
  • Log Data: Server access logs, error logs, API request/response metadata (no payload content)
  • Cookies & Similar Technologies: Session cookies, preference cookies, analytics cookies (see Section 10)

C. Guest / End-User Data (Diner Data)

When diners scan a TableGreet QR code to view a digital menu, we collect minimal technical data (anonymised IP geolocation at country level, device type) purely for analytics. We do not build profiles on individual diners, require diner registration, or share diner data with third parties for advertising. Venue operators (our customers) are solely responsible for any data they independently collect from their guests.

Minimisation Principle

We apply strict data minimisation. We collect only the personal data that is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed (Art. 5(1)(c) GDPR). If you believe we are collecting data beyond these categories, please contact our DPO immediately.

03

Lawful Basis for Processing

Under GDPR, every processing activity must have a lawful basis. The following table maps our processing activities to their legal basis:

Processing Activity Lawful Basis (GDPR Art. 6)
Account creation & authentication Performance of contract (Art. 6(1)(b))
Delivering the platform & Services Performance of contract (Art. 6(1)(b))
Processing subscription payments Performance of contract (Art. 6(1)(b))
Sending transactional emails Performance of contract (Art. 6(1)(b))
Fraud prevention & security Legitimate interests (Art. 6(1)(f))
Platform analytics & improvement Legitimate interests (Art. 6(1)(f))
Legal compliance & record-keeping Legal obligation (Art. 6(1)(c))
Marketing communications (opt-in) Consent (Art. 6(1)(a))
Cookies (non-essential) Consent (Art. 6(1)(a))
04

Purposes of Processing

We process your personal data for the following specific, explicit, and legitimate purposes:

  • Service Delivery: Creating and managing your account, provisioning your venue workspace, storing your menu content, generating QR codes, and providing ongoing access to the platform.
  • Billing & Financial Management: Processing subscription fees, issuing invoices, handling refund requests, and preventing fraudulent transactions. Payment processing is handled entirely by Stripe, Inc., a certified PCI-DSS Level 1 service provider.
  • Customer Support: Responding to queries, debugging technical issues, and maintaining support records to improve service quality.
  • Security & Integrity: Detecting and preventing unauthorised access, fraud, abuse, and other threats to the security of our platform and our users.
  • Analytics & Product Improvement: Understanding how the platform is used to identify features that work well, areas for improvement, and capacity planning. Analytics are based on aggregated or appropriately anonymised data wherever possible.
  • Legal Compliance: Maintaining records required by applicable law, cooperating with regulatory investigations, and exercising or defending legal claims.
  • Communications: Sending service-related notifications (mandatory) and, where you have opted in, product updates, newsletters, and promotional communications (optional, withdrawable at any time).

We will not process your personal data for purposes that are incompatible with those described above without first obtaining your explicit consent or establishing a new lawful basis.

05

Data Sharing & Third-Party Processors

We do not sell, rent, or broker personal data. We share data only as described below, and only with parties who have agreed to process data in accordance with our instructions and applicable data protection law.

Sub-Processors

Processor Purpose Location
Supabase, Inc. Database, authentication, storage USA (SCCs applied)
Stripe, Inc. Payment processing USA (SCCs applied)
Cloudflare, Inc. CDN, DDoS protection, edge hosting Global (SCCs applied)
Resend / SendGrid Transactional email delivery USA (SCCs applied)
Sentry, Inc. Error monitoring & crash reporting USA (SCCs applied)
Vercel / Netlify Application hosting (if applicable) Global (SCCs applied)

SCCs = Standard Contractual Clauses (EU Commission Decision 2021/914)

Other Permitted Disclosures

  • Legal Obligations: Where required by court order, regulatory authority, or applicable law.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets, personal data may be transferred subject to confidentiality obligations and equivalent privacy protections. We will notify you of any such transfer.
  • Protection of Rights: To enforce our Terms of Service, prevent fraud, or protect the safety of users and third parties.
06

International Data Transfers

TableGreet operates globally. Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) or the United Kingdom, including the United States.

Where such transfers occur, we ensure an equivalent level of protection by relying on one or more of the following safeguards:

  • EU Standard Contractual Clauses (SCCs) — Commission Implementing Decision 2021/914
  • UK International Data Transfer Agreements (IDTAs) for UK-originating transfers
  • Adequacy Decisions where the destination country has been recognised by the European Commission or UK ICO as providing adequate protection
  • Binding Corporate Rules or equivalent mechanisms where applicable

You may request a copy of the applicable transfer mechanism by contacting our DPO at [email protected].

07

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The following retention schedule applies as a baseline:

Data Type Retention Period
Active account data Duration of account + 30 days post-cancellation
Billing & transaction records 7 years (legal/tax compliance)
Support communications 3 years from closure of ticket
Usage analytics (aggregated) 3 years
Server access logs 90 days
Security/audit logs 1 year
Backup data Up to 90 days in secure rotation
Deleted account data Purged within 30 days of deletion request

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

08

Security Measures

We implement and maintain a comprehensive information security programme that includes technical, organisational, and physical safeguards appropriate to the sensitivity of the data we process:

Encryption at Rest

AES-256 encryption for all stored personal data

Encryption in Transit

TLS 1.2+ enforced for all data transmission

Access Controls

Role-based access, MFA enforced for staff, least-privilege principle

Penetration Testing

Annual third-party security assessments

Breach Response

Documented incident response plan; GDPR Art. 33 notifications within 72 hours

Backup & Recovery

Daily encrypted backups with tested restoration procedures

No security measure is 100% impenetrable. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay where required under GDPR Art. 33–34.

09

Your Rights

Depending on your jurisdiction, you hold the following rights over your personal data. To exercise any right, submit a verified request to [email protected]. We will not discriminate against you for exercising your rights.

Right of Access (Art. 15 GDPR / CCPA §1798.110)

You have the right to obtain confirmation of whether we process your personal data and, if so, to receive a copy of that data along with information about:

  • The categories of personal data processed
  • The purposes of processing
  • The recipients or categories of recipients
  • The retention periods or criteria used to determine them
  • The existence of automated decision-making, including profiling

We will respond to access requests within 30 days (GDPR) or 45 days (CCPA) of verified receipt.

Right to Rectification (Art. 16 GDPR)

You may request correction of inaccurate or incomplete personal data we hold about you. We will action verified correction requests without undue delay, and in any event within one calendar month. Where data has been shared with third-party processors, we will notify them of the correction unless this proves impossible or involves disproportionate effort.

Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR / CCPA §1798.105)

You may request deletion of your personal data where one of the following grounds applies:

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw consent and there is no other legal basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed
  • Erasure is required to comply with a legal obligation

Exceptions apply where retention is required for legal obligations, the exercise of legal claims, or public interest purposes.

Right to Data Portability (Art. 20 GDPR)

Where processing is based on consent or a contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format (JSON or CSV). You may also request that we transmit that data directly to another controller where technically feasible.

Right to Object & Restrict Processing (Art. 18–21 GDPR)

You may object to processing based on legitimate interests or direct marketing purposes at any time. Upon receipt of a valid objection, we will cease processing unless we demonstrate compelling legitimate grounds that override your interests.

You may also request restriction of processing during the period while we verify accuracy, consider your objection, or establish whether there is a legal basis for processing.

Right Not to be Subject to Automated Decision-Making (Art. 22 GDPR)

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. TableGreet does not currently employ fully automated decision-making that legally affects our users. Any profiling we conduct (e.g., for analytics) is human-reviewed before any consequential action is taken.

Supervisory Authority: If you are located in the EEA or UK and believe we have violated your rights, you have the right to lodge a complaint with your local data protection supervisory authority (e.g., the UK Information Commissioner's Office at ico.org.uk, or your EU national authority).

10

Cookies & Tracking Technologies

We use cookies and similar technologies to operate and improve our Services. Our full Cookie Policy is available at /cookies. A summary of cookie categories:

Category Purpose Consent Required
Strictly Necessary Authentication, session management, security No (essential)
Functional User preferences, language, theme Yes
Analytics Usage statistics, feature performance Yes
Marketing Personalised ads, retargeting Yes (opt-in only)

You can manage cookie preferences at any time via our Cookie Settings panel or your browser settings. Withdrawing consent for non-essential cookies will not affect our legal basis for processing data under other grounds.

11

Children's Privacy

Our Services are directed exclusively to business operators and are not intended for individuals under the age of 18 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from minors.

If you are a parent or guardian and believe a minor has provided us with personal data, please contact us immediately at [email protected]. Upon verification, we will promptly delete the relevant data.

12

California Residents — CCPA / CPRA Rights

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you additional rights:

  • Right to Know: The categories and specific pieces of personal information we collect, use, disclose, or sell about you.
  • Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions.
  • Right to Opt-Out of Sale / Sharing: We do not sell or share personal information for cross-context behavioural advertising.
  • Right to Correct: Request correction of inaccurate personal information.
  • Right to Limit Use of Sensitive Personal Information: We collect sensitive personal information only as strictly necessary and do not use it for inferential or secondary purposes.
  • Right of Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To submit a verifiable consumer request, contact us at [email protected] with subject line "CCPA Rights Request." We will respond within 45 calendar days.

We do not sell or share personal information as defined by the CCPA/CPRA.

13

Changes to This Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or for other operational, legal, or regulatory reasons. Material changes will be communicated via:

  • Email notification to the primary account email address at least 14 days prior to the change taking effect
  • A prominent notice on our website and within the platform dashboard
  • An update to the "Last Updated" date at the top of this document

Your continued use of the Services after the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree with our Privacy Policy, you must cease using the Services and may request deletion of your account.

All prior versions of this Policy are archived and available upon request.

14

Contact & Data Protection Officer

For any privacy-related enquiries, requests to exercise your rights, or to report a concern, please contact:

Data Protection Officer

TableGreet Ltd.

[email protected]

Response SLA: 5 business days

General Privacy Enquiries

TableGreet Ltd.

[email protected]

Response SLA: 10 business days

We may need to verify your identity before processing any rights requests. Please be prepared to provide identifying information. We will never charge a fee for submitting a request unless it is manifestly unfounded or excessive.