The controller of personal data processed in connection with the use of the restaurant.digital service is:
Core Duo sp. z o.o. ul. Lipowa 3D, 30-702 Krakow, Poland KRS 0001091475, NIP 6793292643, REGON 527947734
GDPR-related contact: contact@restaurant.digital
We process your personal data on the following legal bases:
| Purpose | Legal basis (GDPR) |
|---|---|
| Provision of site-generation services | Art. 6(1)(b) — performance of a contract |
| Fulfilling the right to claim a site | Art. 6(1)(b) — performance of a contract |
| Ensuring the security of the service | Art. 6(1)(f) — legitimate interest |
| Handling complaints and reports | Art. 6(1)(c) — legal obligation |
| Analytics (upon consent) | Art. 6(1)(a) — consent |
| Marketing (upon consent) | Art. 6(1)(a) — consent |
| Financial settlements | Art. 6(1)(c) + tax laws |
is stored locally)
We may entrust your data to the following categories of recipients:
| Category | Entities | Basis | Location |
|---|---|---|---|
| Hosting | Core Duo's own servers | Internal DPA | Poland / EU |
| DNS/CDN | Cloudflare | DPA + SCC | USA (adequacy) |
| AI | xAI (Grok) | DPA + data minimisation | USA (adequacy) |
| Email provider | SMTP provider (to be determined) | DPA | EU |
| Stock photos | Pexels, Envato | — | various |
| Photo galleries | Google (Places API — metadata only after sc-404) | DPA + SCC | USA (adequacy) |
We do not sell your personal data.
Some data may be transferred outside the European Economic Area (EEA):
or the EU-US Data Privacy Framework, where applicable.
| Type of data | Retention period |
|---|---|
| Account data (after site claim) | Until account deletion + 30-day grace period |
| Unclaimed generated sites | 30 days from generation (auto-suspension) |
| Emails (magic-link messages) | 24 hours |
| Verification tokens | 24 hours |
| Error logs | 90 days |
| Analytics events | 26 months |
| Takedown reports and statements of reasons (DSA art. 17) | 5 years (DSA art. 24(5) — lex specialis with respect to art. 118 of the Polish Civil Code) |
| Accounting data (where applicable) | 5 years (Polish Accounting Act) |
You have the following rights in connection with the processing of your personal data:
You may request information about the data we process. How: email to contact@restaurant.digital — our DPO will respond within 30 days.
You may correct inaccurate data. How: in the site editor (Contact tab) or by email.
You may request erasure of your data. How: the "Delete My Site" button in the editor, or by email. Deletion takes place after a 30-day grace period.
You may request restriction of processing in specific situations. How: email to contact@restaurant.digital
You may receive your data in machine-readable form (ZIP with site.json + photos). How: email contact@restaurant.digital — our DPO compiles and delivers the export within 30 days.
You may object to processing based on legitimate interest. How: email or the cookie preferences panel.
We do not use fully automated decision-making or profiling producing legal effects.
You may lodge a complaint with the President of the Polish Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO):
We use cookies and localStorage for:
| Category | Purpose | Duration | Consent required |
|---|---|---|---|
| Essential | Session, CSRF, cookie-consent preferences | Session / 1 year | No |
| Analytics | Google Analytics (if enabled by the site owner) | 26 months | Yes |
| Marketing | Ads (if enabled by the site owner) | 13 months | Yes |
Details in the Cookie Policy.
In short: - Spotted content on a site we host that breaks the law? Submit a notice at https://restaurant.digital/takedown. - We process notices without undue delay, within the time limits set out below (from 4 hours for CSAM up to 14 days for unclear cases). - The procedure is free of charge and available in Polish and English. - Legal basis: DSA arts. 11, 12, 14, 16, 17 and 23(2).
8a.1. Canonical URL. The Controller offers a mechanism for reporting illegal content in accordance with art. 16 DSA. The canonical (permanent) URL of the notice form is https://restaurant.digital/takedown. The address is permanent, easy to access, user-friendly and allows notices to be submitted exclusively by electronic means, as required by art. 16(1) DSA.
8a.2. Alternative channels. A notice may also be submitted:
contact@restaurant.digital (a priority address — not subject to the form's rate-limiting);8a.3. DSA Point of Contact for authorities (art. 11 DSA). Member State authorities, the European Commission and the European Board for Digital Services contact the Controller at the canonical URL https://restaurant.digital/dsa-contact and by email at dsa@restaurant.digital. Languages supported: Polish (PL) and English (EN).
8a.4. Point of contact for recipients of the service (art. 12 DSA). Recipients of the service (Users, Restaurant Owners) may communicate with the Controller at contact@restaurant.digital. Communication does not rely solely on automated tools — every message is handled by a member of staff.
8a.5. Mandatory elements of a notice (art. 16(2) DSA). To be "sufficiently precise and adequately substantiated", a notice should contain:
The form at https://restaurant.digital/takedown automatically enforces each of the fields above.
8a.6. Acknowledgement of receipt and timely processing (art. 16(4) and 16(6) DSA). The Controller acknowledges receipt of a notice without undue delay, and no later than within 3 business days. Notices are processed:
These time limits correspond to the standard of "timely, non-arbitrary and objective" handling in art. 16(6) DSA and to the obligation to "act expeditiously to disable access" under art. 14(1) of the Polish Act on the Provision of Electronic Services (UŚUDE).
8a.7. Statement of reasons (art. 17 DSA). Every decision of the Controller that results in restricting the visibility of content, removing it, suspending a Site or terminating an account is documented and delivered both to the reporting party and to the Restaurant Owner, in the form of a written statement of reasons containing:
Statements of reasons are kept in the Controller's internal register for 5 years (lex specialis under DSA art. 24(5) with respect to the general retention period in § 6 of this Policy). Legal basis for processing: art. 6(1)(c) GDPR (legal obligation).
8a.8. Appeals against decisions (voluntary quality standard). A Restaurant Owner whose content has been restricted or removed, and a reporting party whose notice has been rejected, may lodge an internal appeal within 6 months of the date of the decision. Appeals are free of charge and accepted by electronic means at contact@restaurant.digital, marked "Appeal — moderation decision". Decisions on appeals are taken within 14 business days of receipt by a person independent of the person who issued the original decision. The Controller relies on the exemption from the obligations of Section 3 of the DSA (arts. 20–28) as a micro-enterprise within the meaning of Recommendation 2003/361/EC (art. 19 DSA); this appeal procedure is provided voluntarily as a quality standard.
8a.9. Out-of-court dispute settlement (art. 21 DSA). Once the internal procedure is exhausted, the parties may choose an out-of-court dispute settlement body certified by the European Commission. The current list is available at https://digital-strategy.ec.europa.eu/en/policies/dsa-out-of-court-dispute-settlement. Choosing this route does not deprive either party of the right to judicial proceedings.
8a.10. Bad-faith notices (art. 23(2) DSA). The Controller reserves the right to suspend processing of notices from persons or entities that have previously submitted manifestly unfounded notices on repeated occasions. Benchmark: 3 unfounded notices in a month → warning; at the 4th → suspension of processing of notices for 2 months. Suspension is preceded by a warning and an opportunity to respond. Knowingly submitting a false notice may constitute the offence of false accusation (art. 234 of the Polish Criminal Code).
Cross-references: Terms of Service § 15,docs/legal/notice-and-takedown-procedure.md(full operational procedure),docs/legal/content-moderation-policy.md, section 13 of this Policy.
The Service is not intended for persons under the age of 16. We do not knowingly collect data from children. If you learn that a child has provided us with their data, please contact us and we will erase it without undue delay.
We may update this Privacy Policy. Material changes will be announced at least 14 days in advance by email or via a notice in the Service.
Internal review cadence. The Controller maintains this Policy under a cadence aligned with GDPR art. 24(1) (measures "kept under review"): an annual baseline review (15 January each calendar year) plus event-triggered mandatory re-reviews. Trigger catalogue includes: new sub-processor, new data category, new lawful basis, cross-border transfer change, regulatory change (GDPR delegated acts, AI Act phased entry, UODO / AEPD / EDPB guidance), security incident, DSAR class-action or surge pattern, formal recommendation from retained counsel or the Data Protection Officer. Full procedure, versioning rules (semver-lite: 1.0 → 1.1 minor textual update; 2.0 structural rewrite), and the trigger catalogue are maintained in the internal document docs/legal/review-triggers.md (sc-1018 — supersedes the prior quarterly-review assumption).
Core Duo sp. z o.o. ul. Lipowa 3D, 30-702 Krakow Email: contact@restaurant.digital
Data Protection Officer (DPO): Grzegorz Książczyk
In short: - We act as the hosting provider of your Site once you have claimed it — not as publisher or editor. - We do not review each photo, description or menu item in advance. - If we receive a substantiated notice that a specific piece of content is unlawful, we react in line with the procedure in section 8a. - Legal basis: art. 14 of the Polish Act on the Provision of Electronic Services (ustawa o świadczeniu usług drogą elektroniczną, UŚUDE) + art. 6 of Regulation (EU) 2022/2065 (Digital Services Act, DSA).
13.1. Role of the Controller. In relation to content published on Generated Sites after they have been claimed by the Restaurant Owner, the Controller acts as a hosting service provider within the meaning of art. 14(1) of the Polish Act of 18 July 2002 on the Provision of Electronic Services (Journal of Laws of 2020, item 344, as amended; hereinafter "UŚUDE") and as a hosting service provider within the meaning of art. 3(g)(iii) of Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 (Digital Services Act, hereinafter "DSA"). The Controller does not carry out prior (ex ante) monitoring or moderation of content submitted by Restaurant Owners and stored in the Service. In practice: you are the author and publisher of the content after claim; we are the server host — in the same way that Allegro does not inspect every listing, and YouTube does not watch every video before it is published.
13.2. Exclusion of liability (safe harbour). In accordance with art. 14(1) UŚUDE and art. 6(1) DSA, the Controller is not liable for content stored at the request of the Restaurant Owner where:
13.3. Material scope of the exclusion. The exclusion of liability described in 13.2 covers only content supplied by the Restaurant Owner after claiming the Site (in particular photographs, descriptions, contact details and menu items). It does not cover:
13.4. Consequences of obtaining knowledge of unlawful content. Upon receipt by the Controller of an official notification (for example, a court or administrative order) or credible information (for example, a notice conforming to art. 16 DSA, as described in section 8a of this Policy) about the unlawful character of content, the Controller loses the conditional exclusion of liability in relation to that content unless it acts expeditiously to disable access to it. The procedure, deadlines and effects of a notice are described in section 8a of this Policy and in the "Notice-and-takedown procedure" document (docs/legal/notice-and-takedown-procedure.md).
13.5. Informing the recipient of the service about disabling access. In accordance with art. 14(3) UŚUDE, where the Controller disables access to content on the basis of credible information (as distinct from an official notification), it promptly informs the Restaurant Owner, providing reasons (DSA art. 17 — statement of reasons). The appeal procedure is described in section 8a of this Policy.
13.6. No general monitoring obligation. The Controller is not obliged to monitor or actively seek out facts or circumstances indicating the unlawful character of content stored at the request of the Restaurant Owner — in accordance with art. 15 UŚUDE and art. 8 DSA. This exclusion is without prejudice to orders of courts or authorities requiring specific actions to address unlawful content (art. 9 DSA).
13.7. DSA Point of Contact. The Controller designates a single point of contact for Member State authorities, the European Commission and the European Board for Digital Services (art. 11 DSA) at the canonical URL https://restaurant.digital/dsa-contact; email: dsa@restaurant.digital; languages: Polish, English. For recipients of the service (art. 12 DSA), the point of contact is contact@restaurant.digital.
Cross-references: Terms of Service § 14 (account suspension and deletion), Terms of Service § 15 (reporting illegal content), section 8a of this Policy (notice procedure and appeals),docs/legal/notice-and-takedown-procedure.md,docs/legal/content-moderation-policy.md.
In short: - Using the internet carries certain risks — we list them explicitly in 14.1 and show you how to protect yourself. - Cookies and session tokens are, in legal terms, "software" — the table in 14.2 explains why we install them. - On sites hosted by the Service, you must not publish illegal content (14.3). - Legal basis: UŚUDE art. 6(1) (risks), art. 6(2) (function of the software), art. 8(3)(2)(b) (prohibition on unlawful content).
In accordance with art. 6 of the Polish Act of 18 July 2002 on the Provision of Electronic Services, the Controller informs the User of specific risks linked to the use of the Service (art. 6(1)) and of the function and purpose of software installed on the User's device (art. 6(2)). In accordance with art. 8(3)(2)(b) UŚUDE, the User is under a duty not to supply content of an unlawful character.
14.1. Specific risks of using the Service (art. 6(1) UŚUDE). The Controller applies risk-reducing measures (TLS 1.3, HSTS, CSP, CSRF tokens, IP anonymisation, automatic session logout, password hashing). Even so, the User should be aware of the following risks:
restaurant.digital domain;If anything concerns you from a security perspective, write to contact@restaurant.digital. We treat every incident as a priority.
14.2. Function and purpose of software and data (art. 6(2) UŚUDE). The Controller installs on the User's device the following kinds of software and data that do not form part of the content of the service:
| Type | Function | Purpose | Retention | Legal basis |
|---|---|---|---|---|
| Session cookies (strictly necessary) | Maintaining the login session, CSRF protection, cookie preferences | Provision of the service | Session / 1 year | Art. 173(3) of the Polish Telecommunications Act (consent exemption) |
| LocalStorage (preferences) | Remembering editor choices (language, theme) and wizard state | Usability | Until cleared by the User | Legitimate interest (art. 6(1)(f) GDPR) |
| Analytics cookies (after consent) | Google Analytics — traffic and conversion measurement | Statistics / optimisation | 26 months | Consent (art. 6(1)(a) GDPR; art. 173(1) Polish Telecommunications Act) |
| Marketing cookies (after consent) | Personalised advertising (if enabled by the Owner) | Advertising | 13 months | Consent |
| Magic-link tokens (query string) | Verification of the Site claim | Passwordless authentication | 24 hours | Performance of a contract (art. 6(1)(b) GDPR) |
| Telemetry events (anonymised) | Detection of errors and attacks | Security of the Service | 90 days (error logs), 26 months (analytics aggregate) | Legitimate interest / consent |
A detailed list of all cookies (name, domain, type, duration, description) is available at docs/legal/cookies.en.md. The software above is ancillary (infrastructural, analytics, marketing) — it does not execute any code independently beyond the functions described in the table, does not modify the User's system and does not collect data beyond the scope declared.
14.3. Prohibition on supplying content of an unlawful character (art. 8(3)(2)(b) UŚUDE). The User is under a duty not to supply through the Service, or to publish on a Generated Site after claim, content of an unlawful character. The prohibition covers in particular:
A full list of prohibited uses is set out in § 7 of the Terms of Service and in the Acceptable Use Policy (docs/legal/acceptable-use-policy.md). A breach of the prohibition may trigger the measures described in section 8a of this Policy and in § 14 of the Terms of Service (account suspension, removal of content, notification to law-enforcement authorities).
Cross-references: Terms of Service § 7 (duties of the User), Terms of Service § 8 (AI content), Terms of Service § 14 (account suspension and deletion), Terms of Service § 15 (reporting illegal content),docs/legal/acceptable-use-policy.md(AUP),docs/legal/cookies.en.md(detailed list of cookies), section 8a of this Policy.