1. Who this policy is for
This policy explains how Sudo Software, publisher of gonnabook.it, processes the personal data of visitors to the gonnabook.it website, of restaurant owners and their teams who use the service, and the data of the restaurants’ guests.
Have you booked a table at a restaurant? The section “You booked at a restaurant” concerns you directly.
2. Controller
The controller of the processing described here is Sudo Software, a French simplified joint-stock company (société par actions simplifiée, SAS) with a share capital of €1,000, registered with the Paris Trade and Companies Register (RCS) under number 902 520 188, whose registered office is at 15 rue des Halles, 75001 Paris, France. For any question about your data: contact@gonnabook.it.
For the data of the restaurants’ guests (bookings, guest files), the controller is the restaurant, and Sudo Software acts on its behalf as processor.
3. Data collected
- Sign-up and account: first name, last name, e-mail address, password (handled by our authentication provider, never stored in plain text), language, restaurant name and details, role, version of the accepted terms.
- Use of the service: log of the operations performed (who, what, when), display preferences.
- Invoicing: company name, address, VAT number, invoices and payments.
- Business verification: SIRET or intra-community VAT number, and the public data the official business register or the European Commission’s VIES service returns for that number (legal name, address of the establishment, activity, creation date, status).
- Contact form: name, e-mail address and, if you provide them, restaurant name, phone number, your message.
- Security: IP address, technical data of the request and of the browser analysed by the anti-abuse service, technical logs.
We collect no data for advertising or audience measurement.
4. Purposes and legal bases
- Creating and managing your account, providing the service and its support: performance of the contract (article 6.1.b GDPR).
- Invoicing the subscription and keeping our accounts: legal obligation (article 6.1.c).
- Answering your contact and demo requests: pre-contractual steps at your request (article 6.1.b) or our legitimate interest in answering people who write to us (article 6.1.f).
- Informing you about the service (changes to the terms, maintenance, new features): performance of the contract and legitimate interest; you may refuse messages that are not essential.
- Protecting the website and the service against abuse, fraud and attacks (reCAPTCHA, rate limiting, logs): legitimate interest in securing the service.
- Checking that each restaurant is run by a real business before opening its online bookings, to protect its guests from fake restaurants: legitimate interest (Article 6(1)(f)).
- Keeping evidence of our contractual relationship and defending our rights: legitimate interest and legal obligation.
5. You booked at a restaurant
When you book a table through a restaurant’s widget or with its team, the restaurant is the controller of your data. gonnabook.it is only its technical provider: we process your data solely on its behalf and on its instructions, and never use it for ourselves.
The restaurant receives your contact details (name, phone, e-mail), the details of your booking and any special request. Its team may add notes, your preferences or your allergies if you tell them. You receive by e-mail the confirmation of your booking, its changes and a reminder, with a personal link to view, change or cancel it; you have no account to create. You receive the restaurant’s news only if you ticked the box provided.
The booking form is protected by reCAPTCHA Enterprise, which analyses technical data from your browser to tell a person from a robot.
To exercise your rights (access, rectification, erasure, objection), contact the restaurant directly; its details appear in the widget and in your booking e-mails: it can view and correct your record from its back office, and obtain its export or erasure. If you write to us at contact@gonnabook.it, we forward your request to the restaurant concerned. The retention period of your data is set by the restaurant.
6. Recipients and processors
Your data is accessible only to the members of our team who need it, to the members of the restaurant’s team for that restaurant’s data, and to our providers, within the limits of their task:
- Google Cloud (Google Cloud France SARL, Google Cloud EMEA Limited, Google LLC): hosting of the application, the database and the files in Paris (France); technical task queue in Belgium, holding nothing but identifiers.
- Firebase Hosting (Google Ireland Limited): hosting and delivery of the pages of the website, the back office and the widget.
- Firebase Authentication (Google Cloud, Google LLC): authentication of restaurant owners’ accounts (e-mail address, hashed password, sign-in IP address); this service runs from the United States.
- Google reCAPTCHA Enterprise (Google Cloud): anti-abuse protection of the sign-up, contact and booking forms.
- Twilio SendGrid (Twilio Inc., United States): sending the service’s e-mails.
- The French State business register (the Recherche d’entreprises API of the DINUM, or else the Sirene API of INSEE) and VIES (European Commission): queried with the business number entered only, no other data.
- Google Fonts (Google): typefaces of the widget and the back office; your browser sends your IP address to Google to download them.
- Where applicable, Sentry (Functional Software, Inc.): technical error reports of the application, hosted in the European Union (Germany), without any restaurant guest data.
- Upcoming: Brevo (Brevo SAS, France) for text messages; Stripe (Stripe Payments Europe, Limited, Ireland) for the card guarantee and invoicing.
We neither sell nor rent any data. We may disclose data to the authorities where the law requires it.
7. Transfers outside the European Union
The service’s data is stored in France. Some providers may nevertheless process data from the United States: Twilio SendGrid for sending e-mails, Firebase Authentication for account authentication and, for some operations, Google LLC.
These transfers rely on the European Commission’s adequacy decision of 10 July 2023 on the EU–US Data Privacy Framework, to which these companies state that they adhere, and otherwise on the European Commission’s standard contractual clauses included in their data processing agreements. You can obtain a copy of these safeguards by writing to us.
8. Retention periods
- Restaurant owner and team accounts: for the whole term of the contract, then 30 days to allow export, before deletion; the items needed to prove the contract (identity, acceptance of the terms, exchanges) are archived for 5 years after the end of the contract (commercial limitation period).
- Sign-up never confirmed or trial without subscription: 12 months after the end of the trial, after a reminder by e-mail.
- Invoices and accounting records: 10 years (article L. 123-22 of the French Commercial Code).
- Contact requests: 3 years after our last exchange.
- Technical and security logs: 30 days; sign-in logs of our authentication provider: a few weeks.
- A restaurant’s operation log: for the term of the contract, then deleted with the restaurant’s data.
- Backups: overwritten on a rolling basis, at the latest 30 days after their creation.
- Restaurant guests’ data: period set by each restaurant; at the end of its contract, it is deleted from live systems within 90 days at the latest, then from backups within the following 30 days.
9. Security
The data is hosted with Google Cloud in Paris, encrypted in transit and at rest, and backed up daily. Each restaurant’s data is kept separate and back-office access uses named accounts, with rights by role. The links sent to restaurant guests rely on random tokens of which we keep only the fingerprint. Our technical logs contain no restaurant guest names, phone numbers or e-mails.
In the event of a data breach that puts your rights at risk, we notify the CNIL and, where necessary, inform you, as provided by the GDPR.
10. Your rights
You have the right of access, rectification, erasure, restriction of processing, objection on grounds relating to your particular situation, and portability of the data you provided to us. You may also set instructions on what happens to your data after your death.
To exercise them, write to us at contact@gonnabook.it. We answer within one month, extendable by two months for a complex request; we may ask you to prove your identity in case of reasonable doubt.
If, after contacting us, you consider that your rights are not respected, you may lodge a complaint with the French data protection authority (Commission nationale de l’informatique et des libertés, CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, www.cnil.fr.
12. Changes to this policy
We may update this policy to reflect changes to the service or to the law. The effective date is shown at the top of the page; restaurant owners are informed by e-mail of any significant change. For any question: contact@gonnabook.it.