Privacy Policy

Effective from 1 January 2026 · Last updated 7 October 2026

This policy explains how the operator of Smart Menu (“Smart Menu”, “we”, “us”) processes the personal data of users of the Smart Menu service (the “Service”), in accordance with Regulation (EU) 2016/679 (“GDPR”) and applicable Albanian data protection law.

1. Data controller

The data controller is the founder of Smart Menu acting as a private individual based in Tirana, Albania (Smart Menu is not yet a registered company).
Contact: WhatsApp · Phone: Lorem ipsum

Data Protection Officer (DPO): Lorem ipsum.

2. What data we collect

2.1 Account and restaurant data

• email address and password (stored hashed) used to sign in; if you choose “Continue with Google”, we instead receive your name, email address and profile picture from your Google account;
• the name you set on your profile page;
• team members: the email address, name and role (owner, manager or staff) of the people an owner or manager invites to manage a restaurant, whether invited from the dashboard or through the Telegram assistant;
• business data for each restaurant on the account (an account can manage more than one): name, web address (slug), logo, background image, colours and fonts, links to review pages (Google, Tripadvisor), subscription plan and whether the free trial has been used;
• menu content (menus, categories, dishes, descriptions, prices, dish photos, ingredients, allergens, tags) entered by the user. This content does not normally contain personal data; if the user enters personal data, they are solely responsible for it;
• technical state of the dashboard, such as whether the first-login guided tour has been completed.

2.2 Payment data

Payments are handled by Stripe. We do not process or store full card details: from Stripe we receive only the customer identifier, the subscription identifier, the active plan, payment outcomes and the minimum billing details needed.

2.3 Telegram assistant data (optional)

If the user connects the Telegram assistant, we process their Telegram identifier, chat identifier, the content of messages and photos sent to the bot, and the language they write in, in order to carry out the requested menu operations. Photos sent to the bot with a dish name are stored as that dish’s photos. We keep the last 30 messages as conversation context, and a log of incoming messages for 30 days so that no message is processed twice. The assistant can also keep short notes about the restaurant (for example preferences such as “always write dishes in English”) when the user asks it to remember something, shared by the restaurant’s team; at most 40 notes are kept, and any of them can be deleted by asking the assistant to forget it. Operations that delete or change data in bulk are only carried out after the user confirms them.

2.4 Menu import files (optional)

If the user imports a menu from photos or PDF files, the files are stored in a private storage area, sent to our AI provider to read the menu, and deleted as soon as the menu has been extracted. The extracted draft is kept until the user confirms or discards it, and in any case no longer than 30 days after it expires.

2.5 Usage and technical data

• technical logs (IP address, browser and device type, date and time, pages visited, errors) generated automatically for security and operation of the Service;
• the approximate country of the device, derived from the IP address by our hosting provider on each request, used only to show the site in a suitable language until a language is chosen manually; it is not stored;
• cookies and similar technologies (see the Cookie Policy).

2.6 Communications

If you contact us by email or through the support channels (including the WhatsApp priority support offered on the Standard plan, which opens WhatsApp on your own device), we keep the correspondence and related contact details in order to respond and for support purposes.

3. Purposes and legal bases

4. Artificial intelligence features

Several features send content to our AI model provider (Google Ireland Ltd. (Gemini API)) to generate the requested output:

• automatic translation of menus and interface text;
• the virtual assistant (chatbot) for diners and dish suggestions (upselling);
• the AI menu analysis report;
• reading menus from uploaded photos and PDFs (menu import);
• understanding messages sent to the Telegram assistant.

Only the content needed for each task is sent (menu text, the message being answered and, for the Telegram assistant, the recent conversation). That content is used solely to generate the requested output and is not used to train the models. No decision producing legal or similarly significant effects on a person is taken by automated means. AI-generated output may contain inaccuracies and does not constitute professional advice.

5. Restaurant diners (public menu)

The digital menu accessed via QR code can be viewed without registration. For restaurant diners we process only:

• Chatbot messages (where the restaurant offers the assistant): sent to the AI provider to generate a reply. We do not store them - the conversation exists only in the diner’s open page and is lost when it is closed.
• Shared table (optional): a diner can open or join a table with a code, so that the people at the same table see each other’s chosen dishes. For this we store the name or nickname the diner types, the table code and the dishes they picked. It can only be seen by people who have the table’s code, is removed when the diner leaves the table, and is deleted automatically 24 hours after the table is created. A first name or nickname is enough.
• Preferences stored only on the diner’s device (favourite dishes, the name typed for a shared table, menu language, dismissed prompts) - see the Cookie Policy.
• Anonymous usage statistics: menu views, dish views, favourites, dish suggestions shown and accepted, and clicks on review links, with the menu language and time. These events carry no personal, device or session identifier and no IP address, cannot be linked back to an individual, and are used only to show the restaurant its own statistics, so no consent is required.
• essential technical logs as described in section 2.5.

In relation to this processing, the restaurant that publishes the menu acts as an independent or joint controller; Smart Menu provides the technical tool. See the Data Processing Agreement.

6. Recipients and processors

Data may be processed by our authorised staff and by the following third-party providers acting as processors on our behalf:

Data may also be disclosed to public authorities, legal or accounting advisors where necessary to comply with the law or to protect our rights. We do not sell personal data to third parties.

7. Transfers outside the European Union

Some providers may process data in third countries (including the United States). In those cases the transfer is covered by an EU Commission adequacy decision or by Standard Contractual Clauses, together with supplementary measures where needed. A copy of the safeguards can be requested from the controller’s email address.

8. Retention period

• Account and menu data: for the duration of the relationship and, after the account is closed, for as long as needed to resolve any disputes, and in any case no longer than 24 months, unless required by law.
• Billing and accounting data: for the period required by applicable tax law (typically 10 years).
• Telegram assistant: the last 30 messages as conversation context, for as long as the Telegram account stays connected; the log of incoming messages is deleted after 30 days; the assistant’s notes about the restaurant (at most 40) until the user asks to forget them or the restaurant is deleted.
• Pending confirmations and menu-import drafts: deleted 30 days after they expire; menu-import files are deleted as soon as the menu has been extracted.
• Shared tables on the digital menu: deleted 24 hours after the table is created.
• Diner chatbot messages: not stored.
• Anonymous usage statistics: kept for as long as the restaurant’s account exists, as they contain no personal data.
• Technical logs: typically up to 12 months.

9. Your rights

Within the limits of the GDPR, you have the right to:

• access your data and obtain a copy;
• request its rectification or update;
• request its erasure;
• request restriction of processing;
• object to processing based on legitimate interest;
• receive your data in a structured format and transmit it to another controller (portability);
• withdraw consent at any time, without affecting the lawfulness of prior processing.

You can view and update your profile and restaurant data directly in the dashboard. To exercise any of these rights, including closing your account and deleting its data, contact us via WhatsApp. We will respond within one month.

10. Complaint to a supervisory authority

If you believe the processing infringes the law, you may lodge a complaint with the competent supervisory authority: in Albania, the Information and Data Protection Commissioner of Albania (Komisioneri për të Drejtën e Informimit dhe Mbrojtjen e të Dhënave Personale), Tirana; if you reside in the European Union, the authority of your habitual residence.

11. Security

We apply appropriate technical and organisational measures, including encryption of data in transit (HTTPS), password hashing, role-based access control (owner, manager and staff roles), database-level row security so that each restaurant can only access its own data, verification of incoming webhooks, environment isolation and backups. No system is completely secure; in the event of a data breach that poses a risk to the rights of data subjects, we will make the notifications required by law.

12. Minors

The Service is intended for businesses and is not directed at persons under the age of 18. We do not knowingly collect data relating to minors.

13. Changes to this policy

We may update this policy. Where changes are material, we will give notice through the Service or by email. The effective date is shown at the top.

14. Contact

Smart Menu - Tirana, Albania
Contact: WhatsApp