Privacy Policy

This Privacy Policy explains how StartApp collects, uses, shares, and protects personal data when you visit our website, create an account, or use our platform. It also explains the role StartApp plays when we process the personal data of your own customers on your behalf. We are committed to processing personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.

1. Who We Are (Data Controller)

For personal data relating to StartApp account holders and website visitors, the data controller is:

2. Information We Collect

• Account data: your name, email address, phone number, business address, and billing details when you register and subscribe.
• Business content: your company name, logo, menus, products, images, opening hours, and operational settings that you add to the platform.
• Your customers' data: when your diners place orders or book tables through your StartApp website or app, we process their name, contact details, order and reservation history on your behalf — see section 4.
• Usage & technical data: information about how you use the platform, including log data, device and browser information, and access times. We do not use advertising or third-party tracking cookies on our marketing site.

AI-assisted setup: if you use our AI menu import or AI website setup features, the menu photos, documents, and business details you provide for that purpose are sent to our AI sub-processor (Anthropic) to generate the result. This content is processed only to produce your output and is not used to train third-party models.

3. How We Use Your Information (and Our Legal Bases)

We process your personal data for the following purposes, each with a legal basis under Article 6 GDPR:

• Provide and operate the platform — to create your account and deliver the service. Legal basis: performance of a contract (Art. 6(1)(b)).
• Process payments and manage billing — to take subscription and setup fees. Legal basis: performance of a contract (Art. 6(1)(b)).
• Secure, maintain, and improve the platform — to keep the service reliable and to develop new features. Legal basis: our legitimate interests (Art. 6(1)(f)).
• Service communications — to send you account, transactional, and support messages. Legal basis: performance of a contract and our legitimate interests.
• Marketing — where we send product news or offers, we do so only with your consent, which you can withdraw at any time. Legal basis: consent (Art. 6(1)(a)).
• Legal and tax compliance — to meet accounting, tax, and other legal obligations. Legal basis: compliance with a legal obligation (Art. 6(1)(c)).

4. Your Customers' Data — Controller vs. Processor

When your diners interact with your StartApp website or app — placing an order, booking a table, or creating an account — you are the data controller of that personal data and StartApp acts as your data processor, processing it only on your documented instructions to provide the service. Our responsibilities in that role are set out in our Data Processing Agreement, which forms part of our agreement with you. You remain responsible for informing your own customers about how you use their data.

5. Sharing Your Information & Sub-processors

We do not sell your personal data. We share it only with the sub-processors below, who help us run the platform and are bound by contract to protect it and use it solely to provide their service to us:

6. International Data Transfers

Some of our sub-processors are located outside the European Economic Area (notably in the United States). Where personal data is transferred outside the EEA, we rely on appropriate safeguards — primarily the European Commission's Standard Contractual Clauses — to ensure your data receives an equivalent level of protection.

7. Data Retention

We keep personal data only for as long as it is needed for the purposes above:

• Account & business data: for the life of your subscription, and up to 90 days after account closure; residual copies in backups are removed within 12 months.
• Content you create: retained while your account is active; you can edit or delete it at any time from your dashboard.
• Your customers' data: retained while you use the platform and handled per your instructions and our Data Processing Agreement.
• Contact & demo enquiries: up to 24 months from your last contact with us.
• Invoices & financial records: retained as required by Irish tax law (typically 6 years).

8. Data Security

We use administrative, technical, and physical safeguards — including encryption in transit, encrypted storage of sensitive credentials, and access controls — to protect personal data. No method of transmission or storage is completely secure, but we work to protect your data and to notify you and the relevant authority of any qualifying breach without undue delay.

9. Your Rights

Subject to the conditions in the GDPR, you have the right to:

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Erase your data (the “right to be forgotten”).
• Restrict or object to certain processing.
• Data portability — receive your data in a structured, machine-readable format.
• Object to processing based on legitimate interests.
• Withdraw consent at any time, where processing is based on consent.

To exercise any of these rights, contact us at support@startapp.solutions. If you believe we have not handled your data properly, you also have the right to lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie) or your local supervisory authority.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the “Last Updated” date above; where changes are significant, we will take reasonable steps to notify you.

11. Contact Us

If you have any questions about this Privacy Policy or your data, please contact us at support@startapp.solutions.