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1. Who We Are

Tout Compris is a trade name of Macher B.V., a company registered in the Netherlands, which operates this Service.

KVK number: 92995551
VAT number: NL866242958B01
Address: Herengracht 320, 1016 CE Amsterdam
Website: www.toutcompris.nl
Privacy contact: info@toutcompris.nl

2. Who This Policy Applies To

This policy applies to:

• Restaurant operators ("customers") who subscribe to and use the application
• Staff members whose data is managed within the application by their employer
• Visitors to our website or login page

3. What Data We Collect and Why

3a. Account data (restaurant operators)

• Email address and encrypted password (via Supabase Auth)
• Restaurant name, country, and VAT rate configuration
• Subscription and billing information (when payment is active)

Legal basis: Performance of contract (Article 6(1)(b) GDPR)

3b. Staff operational data (entered by the restaurant operator)

• Staff names, roles, and hourly rates
• Clock-in/out timestamps and scheduled shifts
• Leave and holiday requests
• Certifications, training records, and PIN codes (stored in hashed form)
• Tip distribution records

Legal basis: Legitimate interest (Article 6(1)(f) GDPR) and compliance with employment law obligations. The restaurant operator is the Data Controller for their staff data. We act as Data Processor.

3c. Guest and reservation data (entered by the restaurant operator, or submitted by guests through the online booking page)

• Guest names, contact details, dietary requirements, and allergy information
• Reservation history and visit records
• Booking requests submitted by guests themselves through a restaurant's public online booking page or embedded booking widget: name, phone number, requested date, time and party size, any free-text special requests, and the guest's chosen language

Allergy and dietary information constitutes health data under Article 9 GDPR. It is processed solely to deliver safe and appropriate service to guests, on behalf of the restaurant operator who acts as Data Controller for this data.

Online booking requests are used solely to deliver the request to the restaurant, where it becomes part of that restaurant's reservation records. To protect the public booking page against abuse, a salted, truncated hash derived from the sender's network address is stored alongside the request for rate-limiting; it cannot be reversed into the address and is deleted together with the request record. Delivered booking requests are removed from the transfer inbox within 90 days.

Legal basis: Processed on behalf of the restaurant operator as Data Controller. Where the restaurant operator relies on consent, they are responsible for obtaining and recording that consent.

3d. Supplier and financial data (entered by the restaurant operator)

• Supplier names, contact details, and invoice data
• Purchase orders, stock levels, sales figures, and VAT records

Legal basis: Performance of contract and legitimate interest (Article 6(1)(b) and (f) GDPR)

3e. AI Assistant interactions

When a user interacts with the built-in AI Assistant, two different things are sent to Anthropic PBC, and the difference matters:

• The operational context the app assembles is aggregated. It contains figures and summaries — stock levels, covers, cost percentages, counts of outstanding tasks — and no staff names, guest names, booking notes or wage figures.
• The question your user types is sent exactly as written. The app cannot filter it, because it cannot know in advance what it contains. The conversation is also re-sent in full with each follow-up message, for up to twenty messages, so anything typed earlier in a conversation is transmitted again with every later message.

For that reason the app displays a notice beside the chat box asking users not to type guest or staff names. What personal data, if any, reaches Anthropic through the AI Assistant is therefore determined by what your users type.

The same applies in reverse to the AI daily brief: it is generated from aggregated operational figures only and contains no free text entered by anyone.

We do not store AI Assistant conversations. They exist in the browser's memory for the length of the session and are not written to our database. Anthropic processes this data as a sub-processor under a Data Processing Agreement and Standard Contractual Clauses, and Anthropic's own data retention policies apply to it.

Legal basis: Legitimate interest in providing a functional and intelligent operational tool (Article 6(1)(f) GDPR)

3f. Usage and error data (collected automatically)

• Browser type, page interactions, and feature usage events (PostHog)
• JavaScript errors and performance data (Sentry)

This data is pseudonymised, not anonymous, and we prefer to say so precisely rather than claim more than is true. Analytics events are tagged with your account's internal identifier — a random code that means nothing outside our systems, but which is stable, so events from the same account can be linked together over time. That is what makes it pseudonymous rather than anonymous.

We do not send staff names, guest names, or the content of anything typed into the app to either service. Specifically:

• Analytics events carry no restaurant name, staff name or guest name.
• Automatic click tracking has element attributes masked, so text such as a guest name shown in an accessibility label on a reservation row is not captured.
• Session recording is switched off in both services: neither records what is on your screen, so no video, screenshots or page recordings of your reservations, staff or guest data exist anywhere.
• IP addresses are not stored with analytics events — they are discarded on arrival rather than saved against your activity.
• Error reports carry technical context (browser type, page address, error message) with name-shaped text removed before it leaves your browser.

It is used solely to maintain and improve the service.

Legal basis: Legitimate interest in maintaining a reliable and improving service (Article 6(1)(f) GDPR)

4. Where Your Data Is Stored

Data type	Service	Location
All restaurant operational data	Supabase (PostgreSQL)	EU — Ireland (AWS eu-west-1)
Authentication	Supabase Auth	EU — Ireland
Error monitoring	Sentry	EU — Germany (de.sentry.io)
Usage analytics	PostHog	EU — EU Cloud (eu.posthog.com)
AI Assistant queries and invoice scanning (when used)	Anthropic PBC	United States — transferred under Standard Contractual Clauses (SCCs)
Subscription billing (when active)	Stripe Inc.	United States — transferred under Standard Contractual Clauses (SCCs)
Account emails (address confirmation, password reset) and operational notification emails (when enabled)	Resend Inc.	EU — Ireland (eu-west-1 sending region); Resend Inc. is US-based, SCCs in place
Hosting of the application and these legal pages	Netlify, Inc.	United States, global CDN — SCCs in place
Support mailbox (info@toutcompris.nl)	Antagonist B.V.	EU — Netherlands

Everything you enter into the app is stored in Europe. Your restaurant's operational data — staff, guests, reservations, recipes, temperatures, invoices, sales — lives in a database in Ireland and is never copied anywhere else. Below is every case in which any personal data leaves the European Economic Area. We would rather list them plainly than make a shorter promise we cannot keep.

1. Invoice scanning (only when you use it). The document you submit is sent to Anthropic in the United States and read in full — as a complete page, not as isolated fields. Although only a fixed set of values is returned to the app, anything visible anywhere on that document forms part of what is sent: a supplier's contact name, telephone number, email address, bank details, handwritten notes or a signature. You control which documents you submit. The app refuses files that are not an image or PDF before anything is sent.
2. Whatever your users type into the AI Assistant (only when they use it). The context the app builds is aggregated and carries no names, but the typed question travels verbatim to Anthropic in the United States, and is re-sent with each follow-up for up to twenty messages. The app displays a notice beside the chat box asking users not to enter guest or staff names. See section 3e.
3. Billing (only while you hold a paid subscription). Your billing data is processed by Stripe in the United States.
4. Hosting. The application and these pages are served by Netlify, a United States company operating a global network. Netlify sees the IP address and request details of every visitor, as any host must in order to serve a page. No data you enter into the app is sent to Netlify.
5. Two features that load a component from an external network when opened. The barcode scanner and the spreadsheet (XLSX) import each fetch a software component from a content delivery network outside the EEA at the moment you use them. Those networks see only your IP address and the name of the file requested — no account data, no data you have entered, and no request at all unless you use one of those two features.

Email is not in this list: account emails and notification emails are sent from Resend's EU (Ireland) infrastructure. Resend Inc. is a United States company, so Standard Contractual Clauses cover any access from there. Notification emails go to your own account address, and depending on the notification can contain a guest's name and booking details, or the names of the staff members concerned (leave and TOIL decisions, shift swaps, certificate expiry).

Anthropic, Stripe, Resend and Netlify operate under Standard Contractual Clauses approved by the European Commission, providing an adequate level of data protection.

5. How Long We Keep Your Data

• Account and operational data: retained for the duration of your subscription plus 30 days after cancellation, then permanently deleted.
• Tip distribution records: retained for 3 years in line with UK Employment (Allocation of Tips) Act 2023 requirements, for customers operating in the UK.
• AI Assistant queries and uploaded invoice images: transmitted to Anthropic for processing (AI Assistant answers, and invoice OCR when you use Scan Invoice) and not stored by Tout Compris. Anthropic's own data retention policies apply to any processing on their infrastructure.
• Online booking requests (transfer inbox): once delivered into the restaurant's reservation records, the inbox copy is deleted within 90 days. The reservation itself is part of the restaurant's operational data.
• Notification emails: not stored by Tout Compris; Resend processes them for delivery. We keep only a minimal send log (event type and time — no message content) for rate-limiting.
• Error monitoring data: retained for 90 days on Sentry, then automatically deleted.
• Usage analytics data: retained for 12 months on PostHog, then automatically deleted.
• Data backup exports: once downloaded by you, these are your responsibility.

6. Your Rights Under GDPR

If you are based in the EU or UK, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data ("right to be forgotten")
• Object to processing based on legitimate interest
• Request a portable, machine-readable export of your data
• Withdraw consent where processing is based on consent
• Lodge a complaint with your national supervisory authority

Netherlands: Autoriteit Persoonsgegevens
UK: Information Commissioner's Office (ICO)

To exercise any of these rights, contact us at info@toutcompris.nl. We will respond within 30 days.

7. Sub-Processors

We engage the following third-party sub-processors to deliver the service:

Sub-processor	Purpose	Location
Supabase Inc.	Database storage and authentication	EU (Ireland)
Sentry	Error monitoring and crash reporting	EU (Germany)
PostHog Inc.	Product analytics (pseudonymised — see section 3f)	EU Cloud
Anthropic PBC	AI Assistant processing and invoice OCR — only when these features are used	United States (SCCs in place)
Stripe Inc.	Subscription billing and payment processing — only when a paid subscription is active	United States (SCCs in place)
Resend Inc.	Delivery of email notifications — only when email notifications are enabled by the account holder	EU (Ireland) sending region — US parent company, SCCs in place
Netlify, Inc.	Web hosting and content delivery of the application and legal pages	United States, global CDN (SCCs in place)
Antagonist B.V.	Support mailbox hosting (info@toutcompris.nl)	EU (Netherlands)

Our Data Processing Agreement (DPA) forms part of the Terms of Service for all business customers and takes effect automatically — no signature or separate request is required. Questions: info@toutcompris.nl.

8. Cookies and Tracking

We do not use advertising cookies or third-party tracking cookies. The application uses browser local storage to maintain your authenticated session. This is not a cookie but operates in a similar way — it persists your login across page reloads and browser restarts until you explicitly log out.

Analytics data collected via PostHog does not link usage events to individual names or email addresses. It is, however, tied to your account’s internal identifier, which makes it pseudonymised rather than anonymous — see section 3f. Error reports collected via Sentry include technical context (browser type, page URL, error message), with name-shaped text removed before the report leaves your browser.

9. Security

We implement appropriate technical and organisational measures including:

• Encrypted connections (HTTPS) on all data in transit
• Role-based access controls within the application
• API keys and service credentials stored as server-side secrets, never in client-side code
• Row-Level Security on all database tables, ensuring each restaurant's data is fully isolated from all other customers
• Staff PIN codes are stored in hashed form and never transmitted or stored as plaintext

10. Children's Data

Tout Compris is a business operations tool intended for use by adults in a professional context. We do not knowingly collect personal data from individuals under the age of 16. If you become aware that a minor's personal data has been submitted to the application without appropriate authorisation, please contact us at info@toutcompris.nl and we will delete it promptly.

Restaurant operators who employ staff under the age of 16 are responsible for ensuring they have the appropriate legal basis to process that staff member's data under their national employment law.

11. Users Based Outside the EU and UK

This policy is written primarily in reference to the GDPR (EU) and UK GDPR. If you are based outside the EU or UK, the following additional information applies:

United States

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete it, and the right to opt out of its sale (we do not sell personal data). To exercise your CCPA rights, contact us at info@toutcompris.nl.

Other jurisdictions

We apply the standards set out in this policy to all users regardless of location. If local laws in your jurisdiction provide additional rights or impose additional obligations, we will comply with those requirements to the extent applicable.

12. Data Breach Notification

In the event of a personal data breach that poses a risk to individuals' rights and freedoms, we will notify the relevant supervisory authority (Autoriteit Persoonsgegevens in the Netherlands) within 72 hours of becoming aware of the breach, as required by Article 33 GDPR. Where the breach is likely to result in a high risk to affected individuals, we will also notify those individuals directly without undue delay, in accordance with Article 34 GDPR.

If you become aware of a potential security issue affecting your data, please contact us immediately at info@toutcompris.nl.

13. Changes to This Policy

We will notify registered customers by email of any material changes at least 14 days before they take effect. The "last updated" date and version number at the top of this page will always reflect the current version.

14. Contact

Macher B.V.
Herengracht 320, 1016 CE Amsterdam
Website: www.toutcompris.nl
info@toutcompris.nl