Website · customer account · emails and SMS
Privacy Policy
Version date: 1 September 2026
This document has not entered into force. It is a draft.
Scope. This policy covers the website www.reviewchef.eu (landing, sign-up, login), the customer account, emails and SMS sent to customers, and the processing of prospect data (postal outreach). It does not cover the guest page opened via QR code — see the separate Privacy Notice for Guests. In case of discrepancies, the German version prevails.
1. Privacy at a glance
General notes
The following notes give a simple overview of what happens to your personal data when you visit our website or use the ReviewChef service. Personal data is any data by which you can be personally identified. Full details are in the sections below.
Who is responsible for data processing?
Data processing on this website and in the service is carried out by the operator. Contact details are in the section “Controller”.
How do we collect your data?
Some data you provide yourself: during sign-up, in the account settings, or by email. Other data is collected automatically by our IT systems when you visit the website — mainly technical data (browser, operating system, time of request, IP address).
A separate category is data that our customers (restaurants and cafés) receive from their guests via the QR code. We process this data on behalf of the venue, not for our own purposes (section 6).
What do we use your data for?
To provide the contracted service (customer account, SMS alerts, weekly reports, card printing, invoices), to ensure error-free and secure operation of the website, and — in anonymised form — to understand how the service is used.
What rights do you have?
You have the right at any time to obtain free information about the origin, recipients and purpose of your stored personal data. You also have the right to request rectification or erasure of this data, to request restriction of processing under certain circumstances, and to lodge a complaint with the competent supervisory authority. If processing is based on your consent, you may withdraw it at any time with effect for the future. For these and any other questions about data protection, you can contact us at any time.
Analytics and third-party services
The service relies on external providers (hosting, SMS, email, payments, printing, AI summary). All of them are listed below together with the legal basis.
2. Hosting
Hetzner
The website, database and object storage (PDF print files) are hosted by Hetzner. Details of the provider are listed at www.reviewchef.eu/subprocessors.
All data is stored in data centres in Germany. The provider may process IP addresses, connection metadata, contract and contact data, and other data generated through use of the website and service.
Hosting is carried out for the performance of the contract with our customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our service by a professional provider (Art. 6(1)(f) GDPR).
Sentry
Application errors are reported to Sentry (Functional Software, Inc.) and stored in its EU data region (Germany). A report contains the technical details of the error — the address of the failing request, the error message and the program location — and never cookies, IP addresses or the contents of a request. Details of the provider are listed at www.reviewchef.eu/subprocessors.
3. General information and mandatory disclosures
Data protection
We take the protection of your personal data seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.
Please note that data transmission over the internet (e.g. by email) may have security gaps. Complete protection of data against access by third parties is not possible.
Controller
The controller for data processing on this website and in the service is:
Mykhailo Torcheniuk
Demianiplatz 41
02826 Görlitz
Germany
Email (data protection): privacy@reviewchef.eu
The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.
Data protection officer
No data protection officer has been appointed; the conditions for a mandatory appointment under Section 38 BDSG and Art. 37 GDPR are not met.
Storage period
Unless a more specific storage period is stated in this policy, your personal data remains with us until the purpose of processing no longer applies. If you make a legitimate request for erasure or withdraw consent, your data will be deleted unless we have other legally permissible grounds for storing it (e.g. retention periods under tax or commercial law); in that case, deletion takes place once those grounds no longer apply.
Legal bases for processing
- Art. 6(1)(b) GDPR — where your data is necessary for the performance of a contract with you or for pre-contractual measures (sign-up, customer account, payment, card printing, notifications, reports).
- Art. 6(1)(c) GDPR — where processing is necessary to comply with a legal obligation (retention of invoices).
- Art. 6(1)(f) GDPR — where processing is based on our legitimate interest (server logs, security, cookieless statistics, postal outreach to prospects).
- Art. 6(1)(a) GDPR and Section 25(1) TDDDG — where you have given consent (e.g. to load an embedded video).
Consent may be withdrawn at any time with effect for the future. The specific legal basis for each processing operation is stated in the relevant section.
Recipients of personal data
In the course of our business we work with external parties. We pass on personal data only where necessary for the performance of a contract, where we are legally obliged to do so (e.g. to tax authorities), where we have a legitimate interest in doing so, or where another legal basis permits it. Data is transferred to processors only on the basis of a valid data processing agreement.
The current list of sub-processors we engage for processing guest data on behalf of venues is published at www.reviewchef.eu/subprocessors (see section 6).
Transfers to third countries
We aim to process data within the EU/EEA. Where this is not guaranteed (Stripe, Google), transfers rely on an adequacy decision under Art. 45 GDPR (EU-US Data Privacy Framework) and/or on the European Commission’s standard contractual clauses under Art. 46(2)(c) GDPR. Details are in the sections on the respective services.
Withdrawal of consent
Some processing operations are only possible with your express consent. You may withdraw consent already given at any time. The lawfulness of processing carried out before withdrawal remains unaffected.
Right to object (Art. 21 GDPR)
Where processing is based on Art. 6(1)(e) or (f) GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data. The legal basis for each processing operation is stated in this policy. If you object, we will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (objection under Art. 21(1) GDPR).
Where your personal data is processed for direct marketing, you have the right to object at any time to such processing. If you object, your personal data will no longer be used for direct marketing (objection under Art. 21(2) GDPR).
Right to lodge a complaint with a supervisory authority
In the event of GDPR infringements, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or the place of the alleged infringement. The supervisory authority competent for us is:
Die Sächsische Datenschutz- und Transparenzbeauftragte (Saxon Data Protection and Transparency Commissioner), Devrientstraße 5, 01067 Dresden, Germany
The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.
Right to data portability
You have the right to receive data that we process automatically on the basis of your consent or in performance of a contract, in a commonly used, machine-readable format, for yourself or a third party. Direct transfer to another controller takes place only where technically feasible.
Access, rectification and erasure
Within the framework of applicable law, you have the right at any time to obtain free information about your stored personal data, its origin and recipients and the purpose of processing, and, where applicable, the right to rectification or erasure. You can contact us at the address above.
Customers (venue owners) can delete their account themselves in the account settings — see section 5 “Account deletion”.
Right to restriction of processing
You have the right to request restriction of the processing of your personal data in the following cases:
- you contest the accuracy of the data — for the duration of verification;
- the processing was/is unlawful and you request restriction instead of erasure;
- we no longer need the data, but you need it to establish, exercise or defend legal claims;
- you have objected under Art. 21(1) GDPR — until it has been determined whose interests prevail.
Where processing has been restricted, the data may — apart from storage — only be processed with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person, or for reasons of important public interest of the EU or a Member State.
SSL/TLS encryption
This website uses SSL/TLS encryption to protect the transmission of confidential content. You can recognise an encrypted connection by “https://” in the address bar and the padlock symbol. When encryption is active, data you transmit to us cannot be read by third parties.
4. Data collection on this website
Server log files
The hosting provider automatically collects and stores information in server log files that your browser transmits to us: browser type and version, operating system, referrer URL, hostname of the accessing device, time of the server request, IP address. This data is not merged with other data sources.
The legal basis is Art. 6(1)(f) GDPR: our legitimate interest in the technically error-free and secure operation of the website. Log files are automatically deleted after 14 days, unless they are needed to investigate a specific security incident.
Cookies
This website uses only technically necessary cookies: a session cookie for logging in to the customer account and a cookie for protection against cross-site request forgery (CSRF). They are deleted on logout or when the session expires. No cookies are used for analytics, advertising or tracking; consent under Section 25(1) TDDDG is not required (Section 25(2) no. 2 TDDDG). The legal basis for necessary cookies is Art. 6(1)(f) GDPR (legitimate interest in a functioning service) and Art. 6(1)(b) GDPR for contract-related functions.
No cookie banner is shown, as none is required. If you disable cookies in your browser, you will not be able to log in to the customer account.
The only exception is the embedded YouTube video on the dashboard of the customer account (see below).
Enquiries by email or via the contact form
If you contact us by email or via the contact form on the website, your enquiry including all resulting personal data (name, email address, content) is stored and processed for the purpose of handling your request. We do not pass this data on without your consent.
The legal basis is Art. 6(1)(b) GDPR where your enquiry relates to the performance of a contract or pre-contractual measures; in all other cases, our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR). The data remains with us until you request erasure or the purpose no longer applies (e.g. after your request has been dealt with). Mandatory statutory retention periods remain unaffected.
There are no other support channels (chat, ticketing system).
Sign-up and customer account
Sign-up is available only to entrepreneurs within the meaning of Section 14 BGB — owners or managers of hospitality venues. During sign-up and account setup we process: email address, password, name, venue details (name, city, identifier of the Google Maps listing), phone number for SMS alerts (optional), communication language, delivery and billing addresses, and service settings (QR code scheme, tables, card design and print run).
The legal basis is Art. 6(1)(b) GDPR (performance of the contract). We also use the email address to inform you about important changes to the service, the terms, and the sub-processors.
Account data is stored as long as you are registered and deleted when the account is deleted — except for data subject to statutory retention periods (section 5 “Invoices”).
Incomplete onboarding. If you started sign-up but did not complete it, your progress is saved and we send at most two email reminders (24 and 72 hours after your last activity). These are not advertising but service messages within the contract process you initiated (Art. 6(1)(b) GDPR). Data from incomplete sign-ups is deleted after 90 days of inactivity.
Sign in with Google (Google Sign-In)
Instead of a password, you can sign in with your Google account. Details of the provider are listed at www.reviewchef.eu/subprocessors. Google transmits your email address, name and an account identifier to us; Google in turn learns that you are signing in to our service. Any further processing by Google takes place under Google’s own responsibility according to its privacy policy: policies.google.com/privacy.
The legal basis is Art. 6(1)(b) GDPR; use is voluntary and you choose this sign-in method yourself. Any transfer to the USA relies on Google LLC’s certification under the EU-US Data Privacy Framework and on the European Commission’s standard contractual clauses.
Google Places Autocomplete (venue search during onboarding)
At the venue step we use the Google Places autocomplete function. Details of the provider are listed at www.reviewchef.eu/subprocessors. As you type in the search field, the characters entered and your IP address are transmitted to Google to generate suggestions. From the response we store only the listing identifier (place_id), the name and the city of the venue; no other Google Places data is stored.
The legal basis is Art. 6(1)(b) GDPR (linking the account to the Google listing is part of the contracted service) and Art. 6(1)(f) GDPR (legitimate interest in correctly identifying the venue without manual entry). Transfer to the USA: Google LLC’s DPF certification and standard contractual clauses.
YouTube (embedded video)
An explainer video from YouTube is embedded on the dashboard of the customer account and is shown until the first subscription is activated. Details of the provider are listed at www.reviewchef.eu/subprocessors. The video is embedded in privacy-enhanced mode (youtube-nocookie.com) and loads only after you actively click the preview image (two-click solution). Before the click, no connection to YouTube servers is established and no data is transmitted.
After the click, YouTube receives your IP address and the fact that you accessed the video; if you are logged in to your Google account, the view may be linked to your account. According to YouTube, in privacy-enhanced mode views are not used for personalisation and no cookies are set; however, local storage elements may be stored.
The legal basis is your consent given by the click (Art. 6(1)(a) GDPR, Section 25(1) TDDDG); you can withhold it by not starting the video. Transfer to the USA: Google LLC’s DPF certification.
Fonts
The fonts used are installed locally on our server. No connection to third-party font servers (e.g. Google Fonts) is established.
5. Providing the service to customers (customer account)
Account and contract data
In addition to the sign-up data (section 4), in the customer account we process subscription and payment data, card orders, SMS alert status and the archive of weekly reports. The legal basis is Art. 6(1)(b) GDPR. The Google listing identifier is refreshed at least every 12 months via Google Places (section 4).
Phone number for SMS alerts — third-party data
You can enter a phone number to which SMS alerts about negative ratings are sent. This is usually the shift manager’s number, not your own. By entering someone else’s number, you confirm that you are entitled to do so and that the holder of the number has been informed about the processing: receipt of SMS with table number, time and rating value, and transfer of the number to the SMS provider (below). The obligation to inform the holder of the number under Art. 13/14 GDPR lies with you as our customer; you may hand them this privacy policy for that purpose.
The number is verified by a one-time code on entry and on every change. Unverified numbers receive no SMS. The legal basis is Art. 6(1)(b) GDPR (towards the customer) and Art. 6(1)(f) GDPR (towards the holder of the number — the venue’s legitimate interest in responding promptly to guests’ concerns).
SMS provider
SMS are sent via BulkGate. Details of the provider are listed at www.reviewchef.eu/subprocessors. The following is transmitted to the provider: recipient phone number, message text (table number, time, rating value, standard instruction) and technical data for obtaining delivery status. Delivery statuses are used to automatically disable alerts in case of systematic non-delivery (after 10 consecutive undelivered SMS); you are informed of this by email.
Processing takes place in the EU (Czech Republic). The legal basis is Art. 6(1)(b) GDPR.
Transactional emails
Service emails (verification codes, onboarding reminders, weekly reports, notices about orders, subscription and sub-processors, invoices) are sent via Scaleway. Details of the provider are listed at www.reviewchef.eu/subprocessors. Recipient address, subject and content of the email as well as technical delivery data are transmitted to the provider. Processing takes place in the EU (France). The legal basis is Art. 6(1)(b) GDPR.
We do not send newsletters. Should one be offered in future, it will be sent only with your separate consent and with an unsubscribe option in every email.
Weekly report and AI summary
Once a week we compile and send you a report: number of sessions, distribution of ratings, number of comments, trend versus previous weeks, and a summary of guest comments generated by a language model. To generate it, the week’s comment texts are transmitted to the Anthropic Claude model operated on Amazon Web Services (Amazon Bedrock) infrastructure in the EU region eu-central-1 (Frankfurt). When used via Amazon Bedrock, the data is neither shared with Anthropic nor used to train models.
Sent reports are archived in the customer account as a snapshot of the time of sending. If the model is unavailable, the report is sent without a summary.
Guest comments are data we process on your behalf (section 6); the AI summary is part of the contracted service (Art. 6(1)(b) GDPR). The infrastructure provider is listed in the public list of sub-processors.
Card orders and printing
Cards with QR codes are printed and shipped by an external print service: Cloudprinter.com. Details of the provider are listed at www.reviewchef.eu/subprocessors. We are the customer towards the print service; it receives the PDF print file (venue name, table numbers, QR codes) as well as the recipient name and delivery address. Cloudprinter.com processes this data under its own responsibility for production and delivery of the order; processing takes place in the EU. The legal basis for the transfer is Art. 6(1)(b) GDPR (performance of the contract).
Payments
Payment for the subscription and card orders is processed via Stripe. Details of the provider are listed at www.reviewchef.eu/subprocessors. Payment methods: card and SEPA direct debit. Payment data (card number, IBAN, account holder name, billing address, amount) is entered directly into Stripe’s form and is not stored on our servers; from Stripe we receive only the payment status, the last digits of the payment method and transaction identifiers.
Stripe processes payment data under its own responsibility for payment processing and fraud prevention. Any transfer to the USA (Stripe, Inc.) relies on the European Commission’s standard contractual clauses and DPF certification. Stripe’s privacy policy: stripe.com/privacy.
The legal basis is Art. 6(1)(b) GDPR (performance of the contract) and Art. 6(1)(f) GDPR (interest in a secure payment process). Cookies set by Stripe in the payment form are technically necessary for carrying out the payment and for fraud prevention.
Invoices and retention periods
An invoice with the mandatory details under Section 14 UStG is issued for every payment. Invoices, transaction records and associated data (name, addresses, amounts, dates) are retained for 10 years in accordance with Section 147 AO and Section 14b UStG — including after account deletion. The legal basis is Art. 6(1)(c) GDPR.
Account deletion
You can delete your account at any time in the account settings, including during an active subscription. Deletion is irreversible: your personal data, all ratings and comments from your venue’s guests, and the weekly report archive are deleted. Retained: invoices and transaction records (10 years, see above) and anonymised aggregates from which individual ratings cannot be reconstructed (section 7). You are informed of this before confirming deletion.
This is the standard way for customers to exercise the right to erasure (Art. 17 GDPR); a request by email is also possible.
6. Processing guest data on behalf of the venue (data processing)
For guest data collected via the QR code — rating, table, time, chosen channel and comment — the venue is the controller and ReviewChef the processor under Art. 28 GDPR. The terms of that processing are set out in the Data Processing Agreement (Annex 1 to the Terms and Conditions).
7. Anonymised statistics and product analytics
From the stream of ratings we continuously build anonymised aggregates — statistics per venue and calendar day (distribution of ratings, number of sessions, channel choice, limit triggers) from which an individual rating with table and time cannot be reconstructed. These aggregates are not personal data and remain with us for our own purposes: monitoring the service, product analytics, and in future industry benchmarks. They are retained after account deletion.
We do not use personal data of guests or customers for product analytics.
8. Prospect data (information under Art. 14 GDPR)
We send letters by post to hospitality venues that may be interested in the service. Data processed: name and postal address of the venue and, where available, the name of the owner or manager. Sources: open data from OpenStreetMap (© OpenStreetMap contributors, ODbL licence) and publicly available information about the venue (website, Google Maps listing, directories).
The legal basis is our legitimate interest in direct marketing to businesses (Art. 6(1)(f) GDPR, Recital 47). We do not send marketing emails or make calls without a legal basis under Section 7 UWG.
Data is stored for 12 months after the last contact or until you object. You may object at any time to the use of your data for direct marketing (Art. 21(2) GDPR) by email to privacy@reviewchef.eu. Thereafter your data is kept only on a suppression list to prevent repeat contact.
9. Changes to this privacy policy
We reserve the right to amend this privacy policy so that it always complies with current legal requirements or to reflect changes to the service. The current version is available at www.reviewchef.eu/privacy. We inform customers by email of material changes affecting them.