Privacy Policy

1. Scope and principles

Different people take part in the Platform: visitors to our website, Restaurants and their Staff, Diners who order or book, Fudi ID holders, hotel guests and drivers. For each case, this Policy explains who decides about your data and what we do with it.

• Minimisation: we ask only for the data each feature needs.
• Isolation: each Restaurant's data is kept separate from the others.
• Control: Diners decide what they share with each Restaurant and can download or delete their Fudi ID.
• No advertising: we do not sell personal data, do not share it for targeted advertising and do not use advertising cookies or third-party analytics tools.

2. Who is responsible for your data

• Fudinow is the controller of the data in: Restaurant and Staff accounts as users of the Platform; Fudi ID accounts; visitors to our website; and the data needed for security, Plan billing and support.
• Each Restaurant is the controller of the data about its customers, bookings, waitlists, guests, orders, sales and Staff that it manages with the Platform. For that data, Fudinow acts as processor: it processes it on the Restaurant's behalf, following its instructions and the data processing agreement included in the Terms.

If your request concerns data a Restaurant holds, such as your customer profile, your booking or your hotel folio, send it to that Restaurant, which decides about it. If you cannot reach it, write to us and we will pass it on.

3. Personal data we process

Website visitors

• Technical data: IP address, browser and device type, language, pages requested and date and time, which our servers log to serve and protect the site.
• The data you send us when you write to us or ask for information.

Restaurants and their Staff

• Identification and access: name, email, job title, role, permissions, locations, employee code, password and PIN stored with irreversible hashing, passkeys (only their public key) and encrypted two-step verification secrets.
• Business data: legal name, tax ID, locations and their position, menus, prices, taxes, inventory, suppliers and settings.
• Staff operations: shifts, clock-ins and clock-outs, breaks, schedules, shift swaps, hourly rate, sales served, tips, commissions and actions recorded in the audit log. We do not collect photos, fingerprints, geolocation or other biometric data for time tracking.
• Plan billing: subscribed Plan, recorded payments and their method, without card details.

Diners and Restaurant customers

• Orders and bookings: name, phone, email, delivery address, items, notes and instructions, party size, amount, payment method and tip.
• The Restaurant's customer profile, if it creates one: contact details, birthday, language, preferences, allergies, notes, tags, history, points, tiers, gift cards, house accounts and marketing consent.
• Location: only if you choose to share your device's location when ordering delivery, to set the delivery point.
• Payments: only the card brand and the payment result recorded by the Restaurant. Never the full card number or its security code.

Fudi ID holders

• Account: public code FU-XXXXXXXX, first name, last name, display name, email, phone if you add it, country of residence, language, time zone and profile photo if you upload one.
• Use: saved addresses and favourites, Restaurant memberships, order and booking history, points and rewards.
• Consents: each acceptance or withdrawal, with its version, date, source, country and IP address.
• Security: open sessions, device, browser, IP address and security events.
• Linked identities: if you sign in with an identity provider, its identifier, your name and your verified email.

Hotel guests

• Name, phone, email, number of guests, stay dates, rate, notes, charges posted to the room and folio payments.

Drivers

• Name, contact details and assigned orders. The delivery app does not collect the driver's location.

4. Where we get the data

• Directly from you, when you create an account, place an order, book or write to us.
• From the Restaurant and its Staff, who enter data about their customers, guests and team.
• Automatically, through the use of the Platform and your devices.
• From third parties that you or the Restaurant connect: identity providers for sign-in and integrated delivery platforms, which send the order data.

5. What we use the data for

Purposes necessary for the Service

• Create, verify and manage accounts, and allow secure sign-in.
• Provide the Platform's features: record orders, payments, bookings, stays, inventory, shifts and reports; send tickets to the kitchen; show order tracking.
• Identify Diners with their Fudi ID, show their history and apply each Restaurant's rewards programs.
• Send service messages: verification codes, security alerts, confirmations, receipts, statements and Plan notices.
• Provide support, including the read-only access the Restaurant authorises.
• Bill Plans and meet legal, tax and accounting obligations.
• Protect the Platform: prevent fraud, abuse and unauthorised access, limit attempts, audit actions and respond to incidents.

Additional purposes

• Send news and promotions from Fudinow or, on behalf of a Restaurant, from that Restaurant, only to people who have agreed.
• Personalise the Diner's experience in Fudi ID, if they agree.
• Improve and develop the Platform, using aggregated or anonymised data wherever possible.

You may object to the additional purposes at any time, without affecting the necessary ones, from your account, with the link in each message or by writing to info@fudinow.com.

6. Legal bases

Where the law requires a legal basis, we process data on the basis of:

• performance of the contract with the User, to provide the Service under the Terms;
• consent, for marketing communications, personalisation and device location, which you can withdraw at any time;
• our legitimate interest in protecting the Platform, preventing fraud, providing support and improving the Service, balanced against your rights;
• compliance with legal and tax obligations or requests from authorities.

For data we process on behalf of a Restaurant, the legal basis is determined by the Restaurant as controller.

7. Who we share data with

We do not sell or rent personal data. We only share it with:

• Restaurants: Diners share with each Restaurant the data needed to serve them and, when joining with their Fudi ID, decide whether to share their contact details. A Restaurant never sees a Diner's activity at other Restaurants.
• Services loaded in your browser: maps for choosing a location use OpenStreetMap tiles, which receive your IP address; the driver's navigation button opens Google Maps.
• Integrations a Restaurant enables, such as Deliverect or PedidosYa, or a payment provider, which receive the data needed to work and process it under their own policies.
• Identity providers you choose for sign-in, which confirm your identity to us.
• Authorities, when the law requires it or to protect the rights, safety or property of Users, Restaurants or Fudinow.
• A buyer or successor, in a merger, acquisition or asset sale, who will be bound by this Policy.

8. Data processed on behalf of Restaurants

When a Restaurant uses the Platform to manage its customers, guests or Staff, Fudinow processes that data only to provide the Service to it. It does not use it to send its own advertising or to benefit another Restaurant.

The Restaurant has tools to honour its customers' rights: export all their data in a file and anonymise their profile, bookings, waitlist entries and delivery details, keeping sales without personal data. Each request is recorded in an audit log. The Restaurant can only send email campaigns to customers who gave their consent.

9. Fudinow AI and automated decisions

Fudinow AI is a feature for the Restaurant's authorised Staff. To produce answers, briefs and proposals, we send OpenAI or Anthropic the user's question, the Restaurant and location names, and aggregated business results, such as sales, products, costs, margins or kitchen times. Customers appear only as anonymous references, never with their name, email or phone, and no payment data or Staff names are sent.

Those providers act on Fudinow's behalf and, under their terms for business customers, do not use that information to train their models. We do not make decisions based solely on automated processing that produce legal effects on people or similarly significantly affect them.

10. Cookies and storage on your device

We only use cookies and local storage that are strictly necessary for the Platform to work and be secure. That is why we do not ask for prior consent for them. We do not use analytics, advertising or third-party tracking cookies. If we ever use non-essential cookies, we will ask your permission first.

Cookies

• fudinow_auth: keeps the Staff session. It expires after inactivity or, at most, after 12 hours.
• fudinow_branch: remembers the active location.
• fudinow_id: keeps the Fudi ID session, for up to 30 days.
• fudinow_id_login, fudinow_sso and fudinow_sso_mfa: protect sign-in with an identity provider and two-step verification. They last minutes.
• fudinow_store: keeps your shopping session in a Restaurant's store.
• fudinow_support: identifies a support session authorised by the Restaurant.

Local storage

• Your language and other interface preferences.
• The email you signed in with, if you choose to remember it.
• Pairing identifiers for terminals, kiosks, kitchen screens and customer displays.
• On the point-of-sale terminal, sales pending sync and a temporary copy of read data, deleted after 3 days. That copy does not keep the phone numbers or emails of orders, and is deleted on sign-out except for sales not yet synced.
• Tracking links for orders placed in that browser for 90 days, to add them to your Fudi ID when you sign in.
• A copy of the application, without personal data, so it loads fast and works offline.

You can delete cookies and storage from your browser. If you do, you will have to sign in again and a point-of-sale terminal will lose the sales it has not yet synced.

11. How long we keep data

We keep personal data only as long as it is needed for the purposes described, and then delete or anonymise it. Specifically:

• Restaurant accounts and their data: while the account is active and for at least 30 days after termination, so the Restaurant can export it, unless the law requires keeping it longer.
• Fudi ID: while the account is active. When you delete it, we anonymise the account, erase addresses, favourites and linked identities, revoke sessions and withdraw marketing consents.
• Sales, payments and accounting records: for the periods required by the tax and commercial law applicable to the Restaurant.
• Proof of consent, audit logs and security logs: for as long as needed to demonstrate compliance, protect the Platform and handle claims.
• Online order notifications: deleted after 180 days.
• Backups: overwritten in their ordinary cycles.

12. Security

We apply reasonable technical and organisational measures appropriate to the risk, including:

• encryption of communications via HTTPS;
• passwords, PINs and tokens stored as hashes, never in readable text;
• AES-256-GCM encryption of secrets and sensitive data, such as emails queued for sending, two-step verification secrets and integration keys;
• protected session cookies, inactivity timeout, attempt limits, passkeys and two-step verification, mandatory for Fudinow staff with administrative access;
• isolation of each Restaurant's data in the application and, where the infrastructure allows, also in the database;
• read-only support access, authorised by the Restaurant and with every request logged;
• audit logs and backups.

No system is infallible. If a security breach affects your data, we will notify the people affected, the Restaurants and the authorities within the deadlines the law requires.

13. International transfers

Fudinow operates in many countries and its providers may be in the United States or other countries. Your data may therefore be stored and processed outside your country of residence, where data protection laws may differ. In those cases we adopt appropriate safeguards, such as contracts with our providers including standard contractual clauses or other mechanisms recognised by applicable law, and transfer only the data needed. By using the Platform from outside the United States, and where the law requires it, you consent to those transfers.

14. Your rights

Depending on the law of your country, you may have the right to access your data, rectify it, erase it, object to or restrict its processing, request its portability, withdraw your consent and lodge a complaint with the data protection authority.

• Fudi ID holders: download your data in "Account" → "Privacy" → "Download my data", correct it in "Account", manage your consents and delete your account in "Privacy".
• Restaurants and their Staff: view and correct your data in settings, or write to us for any other request.
• A Restaurant's customers and guests: send your request to the Restaurant, which can export or anonymise your data; you can also write to us and we will route it.

To exercise any right, write to info@fudinow.com with your name, your account email and your request. We may ask you to prove your identity, or your authority if you act for someone else. We will reply within the legal deadlines, free of charge except for manifestly unfounded or excessive requests, and will tell you if we cannot fulfil it and why. We will not discriminate against you for exercising your rights.

15. Additional information for United States residents

This section applies to residents of California and other states with comprehensive privacy laws, such as Colorado, Connecticut, Virginia, Utah, Texas and Oregon, to the extent those laws apply to us.

• Categories of data collected in the last 12 months: identifiers (name, email, phone, IP address, account identifiers); commercial records (orders, bookings, purchases, points); internet and usage information; approximate geolocation from IP and, only if you share it, precise delivery location; Staff professional information; and limited inferences, such as the churn risk a Restaurant calculates. Sources, purposes and recipients are as described in this Policy.
• Sensitive data: account login data and precise delivery location are only used to provide the requested Service, and not to infer characteristics about people.
• Sale and sharing: we do not sell personal data or share it for cross-context behavioural advertising, and have not done so in the last 12 months, including data of people under 16. We honour browser opt-out signals such as Global Privacy Control.
• Your rights: to know and access data, correct it, delete it, obtain a portable copy and not be discriminated against. You may designate an authorised agent, whose authority we will verify. If we deny your request, you may appeal by replying to our response, and we will answer within the legal deadline.
• Direct marketing disclosure: we do not share personal data with third parties for their direct marketing.

16. Additional information for the European Economic Area, the United Kingdom and Switzerland

If you are in the European Economic Area, the United Kingdom or Switzerland, Fudinow is the controller as described in the section "Who is responsible for your data", on the legal bases stated in this Policy. In addition to the rights described, you have the right to object at any time to processing based on legitimate interest on grounds relating to your particular situation, and to lodge a complaint with the supervisory authority of your country of residence, work or of the alleged infringement. Transfers outside those territories rely on adequacy decisions or standard contractual clauses approved by the European Commission and their UK and Swiss equivalents.

17. Additional information for Mexico

This section is the comprehensive privacy notice under the Federal Law on the Protection of Personal Data Held by Private Parties and its regulations. The controller of your data is Fudinow, for the data it controls; the Restaurant is the controller of its customers' data.

• Primary purposes: those described as "necessary for the Service". Secondary purposes: those described as "additional". If you do not want your data processed for secondary purposes, you can say so at any time by writing to info@fudinow.com or from your account, without affecting the Service.
• ARCO rights: you may exercise your rights of access, rectification, cancellation and objection, and revoke your consent or limit the use or disclosure of your data, by sending a request to info@fudinow.com including your name, a means to send you the reply, a copy of your ID or proof of your representative's authority, a clear description of the data and the right you exercise, and any document that helps locate it. We will reply within 20 business days at most and, if applicable, give effect to it within the following 15 business days.
• Transfers: those made to Restaurants, providers and authorities described in this Policy do not require your consent because they are necessary to perform the legal relationship with you or required by law. We make no transfers that require your consent.
• Cookies: we do not use tracking technologies for advertising. The cookies we use are necessary for the Platform to work.
• Changes: we will inform you of any change to this notice on this page and, if relevant, by email.

If you believe your right to data protection has been infringed, you may go to the competent personal data protection authority in Mexico.

18. Additional information for Brazil

Under the Lei Geral de Proteção de Dados Pessoais (Law 13,709/2018), you may request confirmation that we process your data, access, correction, anonymisation, blocking or deletion of unnecessary or excessive data, portability, deletion of data processed with your consent, information about the entities we share it with and about the possibility of not consenting, and revocation of consent. You may also file a petition with the Autoridade Nacional de Proteção de Dados (ANPD). To contact our data protection officer, write to info@fudinow.com.

19. Additional information for Argentina

Under Law 25,326 on the Protection of Personal Data, data subjects may exercise their rights of access, rectification, update and deletion by writing to info@fudinow.com.

THE DATA SUBJECT HAS THE RIGHT TO ACCESS THEIR PERSONAL DATA FREE OF CHARGE AT INTERVALS OF NOT LESS THAN SIX MONTHS, UNLESS A LEGITIMATE INTEREST IS SHOWN, AS PROVIDED IN ARTICLE 14, PARAGRAPH 3 OF LAW 25,326. THE AGENCY FOR ACCESS TO PUBLIC INFORMATION, AS THE SUPERVISORY BODY OF LAW 25,326, HAS THE POWER TO HANDLE COMPLAINTS AND CLAIMS FILED BY THOSE WHOSE RIGHTS ARE AFFECTED BY NON-COMPLIANCE WITH THE RULES IN FORCE ON PERSONAL DATA PROTECTION.

20. Additional information for Colombia

Under Law 1581 of 2012 and its regulatory decrees, by accepting this Policy you give prior, express and informed authorisation for the processing of your data for the purposes described here. As data subject you may know, update and rectify your data, request proof of the authorisation, be informed about its use, revoke the authorisation or request deletion when there is no legal or contractual duty to keep it, access it free of charge and file complaints with the Superintendence of Industry and Commerce. We will answer enquiries within 10 business days and claims within 15 business days at most, extendable under the law. Data of children and adolescents will only be processed respecting their best interests.

21. Additional information for other Latin American countries

If you live in Chile, Peru, Panama, Costa Rica, Ecuador, Uruguay, Paraguay, Bolivia, Guatemala, Honduras, El Salvador, Nicaragua, the Dominican Republic or another country in the region, you have the rights granted by your personal data protection law, such as access, rectification, cancellation or objection, and can exercise them as described in the section "Your rights". You may also go to your country's data protection authority, such as Peru's National Authority for Personal Data Protection, Panama's National Authority for Transparency and Access to Information, Costa Rica's Agency for the Protection of Inhabitants' Data or Uruguay's Personal Data Regulatory and Control Unit. Where your law requires your consent to process or transfer your data, you give it by accepting this Policy, and you may revoke it at any time.

22. Children

The Platform is not directed at children under 16 or at people below the digital age of consent in their country, and we do not knowingly collect their data without the authorisation of their parents or guardians. If you believe a minor has given us personal data, write to info@fudinow.com and we will delete it. A Restaurant that records minors' data on the Platform, for example in a booking, is responsible for having the corresponding authorisation.

23. Marketing communications

We only send news and promotions to people who agree. We currently send them by email; if we ever send them by SMS or WhatsApp, it will only be to people who accepted that channel. You can unsubscribe with the link in each email, from "Account" → "Privacy" in Fudi ID or by writing to us. We will keep sending the service messages your account needs.

Restaurants can send email campaigns to their customers through the Platform, only to those who gave their consent and with an unsubscribe link. When a Restaurant's Staff writes to a customer by WhatsApp or SMS, they do so from their own phone and under their own responsibility.

24. Third-party links and services

The Platform may contain links to third-party sites, such as a Restaurant's review page or a map, or integrate with third-party services that have their own privacy policies. We are not responsible for their practices. We recommend reading their policies.

25. Changes to this Policy

We may update this Policy to reflect changes in the Platform, our providers or the law. We will publish the current version on this page with its date and version number. If the changes are material, we will notify you by email or on the Platform before they take effect and, where the law requires, ask for your consent again.

26. Contact

For any question, request or complaint about this Policy or how your data is processed, email us at info@fudinow.com. If you are not satisfied with our answer, you may contact your country's data protection authority.