Privacy Policy
Last updated: 16th May 2026
1. Data controller
The data controller for personal data processed through ordinia.net and the Ordinia platform services is:
Albert Kweku Ogoe Via don Bonsignori, 156, Prevalle, Brescia, Italy VAT number: IT 04653400988 Email: privacy@ordinia.net
For any matter related to the processing of your personal data you can contact us at the email address above.
2. Data Protection Officer
As of the effective date of this policy, Ordinia is not required to appoint a Data Protection Officer under Article 37 GDPR: as a core activity it does not carry out large-scale systematic monitoring of data subjects, nor large-scale processing of special categories of data (Article 9 GDPR) or data relating to criminal convictions and offences (Article 10 GDPR). Ordinia onboards tenants (restaurants) individually and processes ordinary contact and order data on behalf of those restaurants.
This position is stated as of the effective date above and will be reassessed if the scope of processing changes — for example, a significant increase in scale or the introduction of systematic monitoring. Regardless of whether a DPO is appointed, every privacy matter can be addressed to privacy@ordinia.net, which is monitored as the dedicated privacy contact.
3. Categories of data processed
Ordinia processes the following categories of personal data:
Browsing data (the ordinia.net site itself): the institutional site collects no personal data. We do not use cookies, we do not use analytics tools, we do not use third-party tracking pixels.
Tenant administrator account data (platform): when a customer (restaurant) signs up for the Ordinia platform, we collect name, email address, and a Google OAuth identifier through Google’s authentication provider.
Restaurant end-customer data (a tenant’s webstore): when an end customer orders through a restaurant’s webstore hosted on the platform, we process name, phone number, email address, and order contents. The data controller for this data is the restaurant itself; Ordinia acts as data processor under Article 28 GDPR.
WhatsApp ordering data: when an end customer sends an order via WhatsApp, we receive the phone number, the WhatsApp display name, and the message contents. Here too Ordinia acts as data processor on behalf of the restaurant.
4. Purposes and legal bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Providing the platform service to customers | Art. 6(1)(b) — performance of contract |
| Authentication via Google OAuth | Art. 6(1)(b) — performance of contract |
| Processing orders on behalf of restaurants | Art. 6(1)(b) — performance of contract (restaurant↔customer) |
| Service communications (transactional email) | Art. 6(1)(b) — performance of contract |
| Product analytics (platform and tenant webstores) | Art. 6(1)(f) — legitimate interest in maintaining and improving the service |
| Tax and accounting compliance | Art. 6(1)(c) — legal obligation |
| Defense of legal claims | Art. 6(1)(f) — legitimate interest |
We do not perform consent-based processing (Art. 6(1)(a)) on the institutional site, because we do not use cookies or direct-marketing tools.
5. Recipients of data
Your data may be communicated to the following categories of recipients, all bound by data processing agreements under Article 28 GDPR:
- Hetzner Online GmbH (Germany, EU) — hosting and storage provider
- Google Ireland Limited (Ireland, EU) — OAuth authentication
- Meta Platforms Ireland Limited (Ireland, EU) — when a restaurant enables the WhatsApp Cloud API integration
- PostHog Inc. (United States; data processed and stored in the EU region — Frankfurt, Germany) — product analytics for the platform and tenant webstores. Privacy notice: https://posthog.com/privacy
- Anthropic, PBC (USA) — AI provider used only for optional Pro/Scale plan features; data is transmitted only if the restaurant enables those features
- Legal, tax, and administrative advisors bound by professional secrecy
We do not sell, rent, or transfer your personal data to third parties for marketing purposes.
6. Transfers outside the EU
Transfers to Anthropic (USA) take place under the Standard Contractual Clauses approved by the European Commission (Implementing Decision (EU) 2021/914) and within the framework of the EU-US Data Privacy Framework.
WhatsApp message content traverses Meta’s global infrastructure during delivery; Meta is contractually our sub-processor under the Standard Contractual Clauses (Implementing Decision (EU) 2021/914), and message content is encrypted in transit.
PostHog analytics data is processed and stored in PostHog’s EU region (Frankfurt, Germany), so no transfer outside the EU arises in normal operation; where PostHog Inc. (United States) provides support or technical access, that access takes place under the Standard Contractual Clauses (Implementing Decision (EU) 2021/914).
Further details on any of the above are available on request at privacy@ordinia.net.
7. Retention periods
| Category | Period |
|---|---|
| Tenant administrator account | Duration of contract + 10 years for tax obligations |
| End-customer orders | Duration of restaurant contract + 10 years for tax obligations of the restaurant |
| System logs | 90 days |
| Authentication data (sessions) | 30 days from last access |
After these periods data is deleted or irreversibly anonymized.
8. Your rights
Under Articles 15–22 GDPR you have the right to:
- Access your personal data (Art. 15)
- Rectification of inaccurate data (Art. 16)
- Erasure (“right to be forgotten”, Art. 17) — see also the
dedicated
/en/data-deletionpage - Restriction of processing (Art. 18)
- Portability of data (Art. 20)
- Object to processing (Art. 21)
- Withdraw consent at any time, where applicable
To exercise these rights write to privacy@ordinia.net. We will respond within 30 days of receipt of the request.
You also have the right to lodge a complaint with the Italian data protection authority (Garante per la protezione dei dati personali — garanteprivacy.it) or the supervisory authority of your country of residence within the EU.
9. Security
We adopt technical and organizational measures appropriate to the risk, including: encryption in transit (TLS 1.3), encryption of credentials at rest, role-based access control, per-tenant data isolation via separate Postgres schemas, audit logging, daily backups.
10. Changes
Any changes to this policy will be published on this page with the “Last updated” date refreshed at the top. For substantial changes we will notify tenant administrators via email.
11. Contact
For questions about this policy or the processing of your data: privacy@ordinia.net