This Privacy Policy explains how Rhinomenu Productions OÜ processes personal data in connection with its public website and web application. It is based on the supplied Data Flow Map. It describes processing roles, purposes, data categories, retention, service providers, and individual rights.
This policy applies to Rhinomenu’s own website and restaurant account/administration data. When a restaurant uses Rhinomenu to collect or manage information about its diners, employees, or contacts, the restaurant—not Rhinomenu—determines the purposes and means of that processing, subject to the service terms and DPA.
Company: Rhinomenu Productions OÜ | Registry code: 17303064 | Tallinn, Harju County, Republic of Estonia
1. Who is responsible and which role applies
Rhinomenu Productions OÜ (“Rhinomenu”, “we”) is the controller for personal data it determines the purposes and means of processing, including website visitor data and restaurant account registration data as described below. The restaurant account holder is a separate controller for its own account administration and for personal data it enters about diners, employees, contacts, or other individuals.
For personal data a restaurant submits to or collects through the Rhinomenu SaaS service concerning its diners, employees, and contacts, the restaurant is the controller and Rhinomenu acts as its processor, processing that data only on documented instructions and to provide, secure, and support the service. The restaurant is responsible for its notices, lawful basis, and responding to requests relating to its processing. The parties’ processing terms are set out in the applicable Data Processing Agreement (DPA).
Roles depend on the particular processing operation; use of a service provider does not by itself change the controller/processor allocation.
2. Personal data and data flows
The following categories and purposes reflect the supplied Data Flow Map. Data may be stored in the service database, CRM, cookie technologies, or marketing tools as appropriate to the activity.
Restaurant registration — Rhinomenu as controller
- Data: username, email address, restaurant name, location (country, city, street address and postal code), and telephone number.
- Purposes: create and administer an account, communicate about the service, marketing where permitted, and internal data analysis.
- Source and basis: supplied by the restaurant; the map identifies consent as the lawful basis. Where consent is relied upon, it may be withdrawn prospectively without affecting prior processing.
- Retention: 2 years, as stated in the Data Flow Map.
Website visits — Rhinomenu as controller
- Data: IP address, browser information, country, clicks, and visit/activity information; cookies or similar technologies may be used.
- Purpose: marketing and website-use analysis, and operation/security of the website.
- Source and basis: collected from website interactions. The map identifies deletion on request and does not specify a lawful basis for each analytic technology; where consent is legally required (including for non-essential cookies), we will seek it before use. Cookie choices can be managed using the available browser or site controls.
- Retention: 1 year as stated in the map.
Restaurant profile completion and menu builder — restaurant controller, Rhinomenu processor
- Data: restaurant logo and branding, social media profile names, telephone number, branch locations, and venue images.
- Purpose: provide SaaS profile, menu-building, and related functions. Source: restaurant. Basis identified in map: contract. Retention: for the duration of the contract.
Employee / role-management information — restaurant controller, Rhinomenu processor
- Data: employee name, telephone number, and email address. Source: restaurant. Purpose: SaaS role-management functionality. Basis identified in map: contract. Retention: duration of contract.
Restaurant contacts — restaurant controller, Rhinomenu processor
- Data: contact name, telephone number, and email address. Source: restaurant. Purpose: contacts functionality. Basis identified in map: contract. Retention: duration of contract. The restaurant owns and controls this information; the map lists no independent rights-handling role for Rhinomenu.
Online ordering — restaurant controller, Rhinomenu processor
- Data: diner name, telephone number, email, address, and GPS/location information. Source: diner. Purposes: food ordering and restaurant marketing as determined by the restaurant. Basis identified in map: consent. Retention: duration of contract. The restaurant is responsible for providing the applicable diner notice and collecting valid consent where required.
Customer club registration — restaurant controller, Rhinomenu processor
- Data: diner name, telephone number, email, address, GPS/location information, and birthday. Source: diner. Purposes: customer-club/ordering functions and restaurant marketing as determined by the restaurant. Basis identified in map: consent. Retention: duration of contract. The restaurant is responsible for the club’s notices and consent.
The Data Flow Map describes hosting or access locations as EU/UAE and lists Estonia, EU, and UAE access locations for relevant flows. Actual access depends on the service and support needs. For restaurant-controlled information, Rhinomenu uses it on the restaurant’s instructions and does not use it for its own independent purposes.
3. Processors and other service providers
We use service providers to support the service. The supplied information identifies:
- Hetzner Online GmbH — hosting and infrastructure. Company-level hosting information states Hetzner (EU data centers); the Data Flow Map additionally lists initial hosting locations as EU/UAE and access locations including Estonia, EU, and UAE. The applicable service configuration and transfer safeguards govern any access or processing outside the EEA.
- Paddle Payments — merchant of record / payment gateway and billing partner. Paddle handles payment transactions under its own applicable privacy terms and may act as an independent controller for payment-related processing.
- Mailchimp — email marketing and automated campaigns / marketing tools. It may process contact information for email delivery and campaign functions according to our instructions or its applicable terms, depending on the activity.
We require processors to protect personal data and process it in accordance with applicable agreements and law. Provider locations, subprocessor details, and international-transfer mechanisms may change; contact us for current information. Where personal data is transferred outside the EEA, the responsible controller will ensure an appropriate GDPR transfer mechanism and supplementary safeguards where required.
4. Legal bases
The Data Flow Map identifies consent for registration, website visits, online ordering, and customer-club registration, and contract for SaaS profile, employee, and contacts functions. The exact legal basis depends on the controller, purpose, and applicable law. Where Rhinomenu is a processor, the restaurant as controller determines and documents the lawful basis. Rhinomenu may also process limited data where necessary for legitimate interests such as service security, fraud prevention, and handling support requests, subject to applicable balancing requirements.
5. Retention and deletion
Retention periods provided in the Data Flow Map are: restaurant registration, 2 years; website browsing, 1 year; and SaaS profiles, employee/contacts data, online orders, and customer-club records, for the duration of the contract. The map does not specify a separate post-contract grace period. At contract end, restaurant-controlled data is handled under the DPA and service agreement: it is made available for export for the applicable period and then deleted or returned, except where retention is required by law or data remains in routine, access-restricted backups until overwritten. Restaurants should export needed data before termination. Controller-held records may be retained longer where legally required or necessary to establish, exercise, or defend legal claims.
6. Your rights under the GDPR
Where Rhinomenu is the controller, individuals may exercise the rights below, subject to GDPR conditions and exceptions:
- Article 15 — access to personal data and information about its processing.
- Article 16 — rectification of inaccurate or incomplete data.
- Article 17 — erasure (“right to be forgotten”).
- Article 18 — restriction of processing.
- Article 19 — notification of rectification, erasure, or restriction to recipients where required.
- Article 20 — data portability, where applicable.
- Article 21 — objection, including to processing based on legitimate interests and to direct marketing.
- Article 22 — safeguards regarding decisions based solely on automated processing, including profiling, where such decisions produce legal or similarly significant effects.
You may also withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal, and lodge a complaint with a competent supervisory authority. In Estonia, the supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).
If your request concerns information processed by a restaurant through its account, contact that restaurant first: it is the controller. Rhinomenu will assist the restaurant as required by the DPA. We may need to verify identity and may explain if a request cannot be fulfilled under a legal exception.
7. Security and incident handling
We use appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. No internet transmission or storage system can be guaranteed completely secure. For restaurant-controlled data, we notify the restaurant of personal data breaches as required by the DPA and applicable law so the controller can meet its notification obligations.
8. Children
The service is intended for businesses and is not directed to children. Restaurants are responsible for ensuring that any collection of diner data, including information about minors, is lawful and supported by any required parent/guardian authorization.
9. Changes to this policy
We may update this policy to reflect changes in our service, providers, or legal requirements. We will publish the revised version with an updated effective date and provide any additional notice required by law.
10. Contact
Privacy questions or rights requests concerning Rhinomenu’s controller processing: privacy@rhinomenu.com
Service and support: support@rhinomenu.com
Rhinomenu Productions OÜ | Registry code: 17303064 | Tallinn, Harju County, Republic of Estonia