Privacy Policy

in accordance with EU Regulation 2016/679 (GDPR) and Legislative Decree 196/2003

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Data Controller: Manuel Saraceni (Tap2Order): Sole Proprietor
VAT ID: 02206920676
Registered Address: Viale Europa 55, 64100 Teramo (TE)
Email: [email protected]
Certified Email: [email protected]
Last Updated: October 6, 2026

1. Who We Are

Tap2Order ("we", "our", the "Data Controller") is a SaaS platform for the restaurant industry that provides order management, POS, reservations, takeaway, customer loyalty (CRM), and analytics services. This policy describes how we collect, use, and protect the personal data of:

  • Ristoratori (B2B customers using the platform)
  • Restaurant Customers (end consumers who interact with digital services)
  • Website Visitors tap2order.cloud

2. Personal Data Collected

2.1 Data Provided Directly by the User

ContestoData CollectedLegal Basis
Contact Form / Demo RequestName, email, phone, business name, messageConsent (Art. 6.1.a)
Website assistant (chat)The messages of the conversation, the page you write from and where you came from; if you ask to be contacted, name, email, phone and business nameRequest of the data subject, pre-contractual measures (Art. 6.1.b); for being contacted, consent (Art. 6.1.a)
CRM Registration (from digital menu)First name, last name, email, phone, date of birthConsent (Art. 6.1.a)
Table ReservationName, phone, email (optional), notesContract Performance (Art. 6.1.b)
Takeaway OrderName, phone, notesContract Performance (Art. 6.1.b)
RecensioneName (optional), rating, commentConsent (Art. 6.1.a)
Digital PaymentName, email (optional for receipt)Contract Performance (Art. 6.1.b)

2.2 Automatically Collected Data

  • Navigation Data: IP address, browser type and version, operating system, pages visited, access times. This data is used exclusively for technical and aggregated statistical purposes.
  • Session Data: for the operation of the ordering and payment service (table identifier, socket session).

2.3 The website assistant

The pages of tap2order.cloud have a chat that answers around the clock about Tap2Order's features, prices and trial. Its answers are written by an artificial intelligence (Claude, by Anthropic) and can contain mistakes: for a quote or a commitment, what a person writes to you is what counts. Don't write data that isn't needed in the chat, and never payment or health data. If you ask to be contacted and agree to share your details, name, email and phone reach our team like a request from the contact form. The chat uses no cookies: the conversation stays in the browser tab until you close it.

2.4 CRM System Data

If the customer registers for the restaurant's service, we additionally collect and process:

  • Visit history and amounts spent
  • Marketing consent preferences
  • Segment classification (calculated automatically)

3. Processing Purposes

  1. Service Delivery: order management, payments, reservations, takeaway (basis: contract performance)
  2. Customer Management: customer registration, visit history, personalized communications (basis: explicit consent)
  3. Marketing Communications: sending promotions, SMS/email/WhatsApp campaigns (basis: separate marketing consent)
  4. Service Improvement: aggregated analytics, usage statistics (basis: legitimate interest)
  5. Legal Obligations: retention of fiscal documents, invoices (basis: legal obligation)
  6. Commercial Inquiry: responding to demo/information requests (basis: consent)

4. Separate Consents

In compliance with GDPR's granularity principle, we request separate consents for:

  • Privacy Consent (mandatory): required for registration and service use
  • Marketing Consent (optional): to receive promotional communications via SMS, email, or WhatsApp

Marketing consent may be withdrawn at any time via the link in each communication or by contacting us at [email protected].

5. Data Retention

TipologiaRetention Period
Contact Data (website form)24 months from request
Conversations with the website assistant180 days from the last message; contact details left in the chat, like those of the form
CRM / Loyalty DataUntil consent revocation or account deletion
Reservation Data12 months from reservation date
Order and Payment Data10 years (tax obligation)
RecensioniUntil deletion request
System Logs6 months

6. Data Sharing

Personal data may be shared with:

  • The Related Restaurant: data entered via reservation, order, or CRM registration is accessible to the restaurant using the Tap2Order platform as a joint controller
  • Service Providers (Data Processors):
    • MongoDB Atlas (database hosting - EU/EEA)
    • Stripe (payment processing - PCI-DSS certified)
    • Twilio (SMS/WhatsApp sending - with DPA signed)
    • Nodemailer/SMTP (transactional email sending)
    • Anthropic, PBC (United States): writes the answers of the website assistant, receiving the messages of the conversation. Anthropic commits not to use data sent through its API to train its models

We do not sell, rent, or share users' personal data with third parties for marketing purposes.

7. International Transfers

Where possible, data is stored on servers located in the European Union. In case of transfers to third countries (e.g., USA cloud infrastructure), we ensure that adequate safeguards are in place pursuant to Arts. 46-49 GDPR, such as Standard Contractual Clauses (SCC) or European Commission adequacy decisions.

8. Data Subject Rights

Pursuant to Arts. 15-22 of the GDPR, users have the right to:

  • Accesso (Art. 15): obtain confirmation of processing and a copy of their data
  • Rettifica (Art. 16): correct inaccurate or incomplete data
  • Deletion / Right to Be Forgotten (Art. 17): request deletion of their data
  • Processing Restriction (Art. 18): restrict processing in certain cases
  • Portability (Art. 20): receive their data in structured format (JSON)
  • Opposizione (Art. 21): object to processing based on legitimate interest
  • Consent Withdrawal (Art. 7.3): withdraw consents at any time

To exercise your rights, you may:

  • Send an email to [email protected]
  • Use the "Export Data" or "Right to Be Forgotten" function in your CRM profile (if registered)

We will respond within 30 days from your request, as required by GDPR.

9. Data Security

We implement appropriate technical and organizational measures to protect personal data, including:

  • Encrypted Communications (HTTPS/TLS)
  • Authentication via tokens and password hashing (bcrypt)
  • Role-based data access (admin, manager, waiter)
  • Regular database backups
  • Access monitoring and logging

10. Tap2Order Mobile App (Android and iOS)

The Tap2Order app for tablets and smartphones is a work tool for restaurant staff. It does two things: it shows the management panel, the same one reachable from a browser, and it connects the venue to its own printers and fiscal register on the restaurant's network.

10.1 Data processed by the app

The app collects no personal data on Tap2Order's behalf. Whatever is entered in the panel (orders, tables, customers) is processed by the restaurant in its own database, as described in the sections above. The app is the means of access, not an additional collection point.

The only things kept on the device are:

  • The operator's session token, stored in the system's protected storage (Keychain on iOS, SharedPreferences on Android) so the login need not be repeated at every reopening. It is erased on logout or when the app is uninstalled.
  • The address of the restaurant the device is paired with, and the pairing credentials themselves.

10.2 Permissions requested, and what they are for

  • Camera: solely to scan the QR code that pairs the device with the restaurant. The image is processed on the device and is neither stored nor transmitted. The permission is optional: the code can be typed by hand.
  • Local network: to reach the printers and the fiscal register on the venue's network. Those communications stay within that network and do not pass through external servers.
  • Notifications: to signal incoming orders, and for the persistent notification that on Android indicates the printer connection is active.
  • Background execution (Android): to keep the printer connection alive while the operator uses other applications.

10.3 No tracking

The app contains no third-party analytics, advertising or tracking tools, does not access the device's advertising identifier, does not collect location, contacts, photos or the list of installed applications, and shares data with no one. No data is processed for profiling purposes, and no tracking is performed across other applications or websites.

11. Cookies and measurement tools

11.1 Technical tools, no consent required

These make the service work and do not require consent under Art. 5.3 of the ePrivacy Directive:

  • Technical session cookies: authentication and table session.
  • LocalStorage / SessionStorage: user preferences, CRM authentication tokens, menu cache.

11.2 Google Analytics, only with your consent

On the tap2order.cloud website we use Google Analytics (measurement ID G-V7CRFFYFZ3) to understand which pages get read and how the site is used. It is a third-party tool, and therefore:

  • it is not loaded until you agree. On your first visit a request appears with equally prominent choices: accept, decline, or choose category by category; until you choose, no measurement script runs;
  • if you decline, it is not loaded at all, and your choice is remembered in LocalStorage, not in a cookie: it makes no sense to write a cookie to remember that you don't want them;
  • your IP address is transmitted in anonymised form;
  • you can change your mind at any time: reopen the cookie choice. Withdrawing consent must be as easy as giving it.

The controller for the data collected by this tool is Google Ireland Limited. Transfers to the United States take place on the basis of the Standard Contractual Clauses and the EU-US Data Privacy Framework.

11.3 Advertising: the Meta and Google Ads pixels, only with your consent

When we advertise on Facebook, Instagram or Google, the Meta pixel and the Google Ads tag may be active on the tap2order.cloud website, to measure the results of our campaigns (for example how many contact requests they bring) and to show our advertising to people who have already visited the site. The same rules as Analytics apply:

  • they are not loaded until you agree to the «Advertising» category, which is separate from statistics: you can accept one and decline the other;
  • they send Meta and Google online identifiers, the pages visited and the submission of the contact form, not the content of the form;
  • the contact request and the sign-up to the portal may also reach Meta from our server (Meta's Conversions API), so they are not lost when the browser blocks the pixel: only with the same consent, and with the event, the page, the IP address, the browser and the identifiers of the pixel cookies, never the content of the form;
  • if you sign up to the portal after giving this consent, we keep with your account the identifiers of the Meta pixel cookies and the identifier of the click on the Google ad that brought you here, if there is one: when you open your first real venue, we tell Meta and Google only that you became a customer, with those identifiers, to know which campaigns bring customers and not just visits. No email and no name. We delete them as soon as they are sent, and in any case within 90 days of signing up;
  • you can change your mind at any time, with the same link: reopen the cookie choice.

The controllers for the data collected by these tools are, each for its own part, Meta Platforms Ireland Limited and Google Ireland Limited. Transfers to the United States take place on the basis of the Standard Contractual Clauses and the EU-US Data Privacy Framework.

11.4 What we do not do

We do not sell or share data with other advertising operators beyond what is described above, and without your consent we load no measurement or advertising tool. The Tap2Order mobile app (section 10) contains no measurement tool at all, not even those described above.

12. Our YouTube channel and YouTube API Services

To publish our own videos on our own YouTube channel we use YouTube API Services, from an internal tool: the marketing dashboard (tap2order.cloud/marketing), reserved for Tap2Order staff. It is not offered to restaurants or to anyone else, and it does not connect to any channel other than ours.

  • The rules that apply: by using the dashboard, users agree to be bound by the YouTube Terms of Service, and data that comes from YouTube is also handled under the Google Privacy Policy.
  • What we access: with the consent given through "Sign in with Google" we upload our videos (the youtube.upload permission) and read the name and ID of the connected channel (the youtube.readonly permission), to show in the dashboard which channel is connected.
  • What we store: the email address of the Google account used to connect, the channel name and ID, the IDs and links of the videos we published, and the connection token, encrypted on our servers. We store no data about other channels or about the people who watch our videos.
  • How we use it: only to publish our videos, after they have been approved in the dashboard, and to keep the archive of our publications. We do not use it for advertising or to profile anyone, and we do not share it with third parties.
  • For how long: the connection and its token are kept while the channel is connected, and are deleted when it is disconnected from the dashboard. The links to the published videos stay in the archive of our publications. On request to [email protected] we delete everything within 30 days.
  • How to revoke access: at any time, from the permissions page of the Google account, security.google.com/settings/security/permissions, or by disconnecting the channel from the dashboard.

People who watch our videos do so on Google's platform, under YouTube's rules: we do not receive their personal data.

13. Minors

Tap2Order's services are not intended for individuals under 16 years of age. We do not knowingly collect personal data from minors. If a parent or guardian believes a minor has provided personal data, they may contact us to request deletion.

14. Policy Changes

We reserve the right to update this policy. In case of material changes, we will inform users via a notice on the website or by email. The date of the last update is indicated at the top of the document.

15. Contacts and Complaints

For any privacy-related questions:

  • Email: [email protected]
  • Certified Email: [email protected]
  • Address: Viale Europa 55, 64100 Teramo (TE)

Users also have the right to file a complaint with theData Protection Authority (www.garanteprivacy.it) if they believe their data is being processed in violation of applicable regulations.

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