Privacy Policy

Entrline Ltd · Website: entrline.com

1. Introduction

1.1 Entrline Ltd ("we", "us", "our") is committed to protecting and respecting the privacy of our website visitors, the people who contact us or sign up through our website, the people who create and use an Entrline account, and the business contacts we reach out to.

1.2 This policy applies where we act as a data controller with respect to that personal data, in other words where we determine the purposes and means of processing it. It covers personal data we collect through our website (entrline.com), through our account dashboard (admin.entrline.com) and the Entrline apps when you create and manage your account, and personal data we collect and use for our own business outreach.

1.3 This policy does not cover personal data that we process on behalf of our customers within the Entrline point-of-sale software (for example, data a venue enters about its own employees, suppliers, or customers). For that data the venue is the controller and we act as a processor; that processing is governed by our customer agreement and data processing terms, not this policy. Personal data about you as an account holder (for example your login details, your contact details and your subscription and billing records) is covered by this policy, because we decide how that data is used.

1.4 We are registered with the UK Information Commissioner's Office (ICO) as a data controller under registration reference ZC169977.

2. What personal data we collect

2.1 Data you give us through our website. When you complete our sign-up form or our contact form, we collect the details you provide:

• Sign-up form: your name, email address, country and (optionally) your business type. This form is used for countries where Entrline is not yet available. In the United Kingdom, signing up creates an Entrline account, described in section 2.2.
• Contact form: your name, email address, and (optionally) your business name, together with your message.

2.2 Data you give us when you create an Entrline account. When you sign up on our dashboard (admin.entrline.com) or in the Entrline app, we collect:

• About you: your first and last name, email address, a password and a four-digit PIN for signing in on the till. We store your password only as a secure hash and your PIN only in encrypted form.
• About your business: business name, business email address, phone number, address, and (if your business is VAT registered) your VAT number.
• About your subscription: your subscription status and dates, and the identifiers Stripe gives us for your customer record and subscription. Your card details are handled by Stripe; we only display the card brand, last four digits and expiry date, which we read from Stripe and do not store.
• Account records: when your email address was confirmed, when your password was last changed, and the one-time codes we send you for confirming your email, resetting your password or deleting your account. These codes expire after 24 hours, 30 minutes and 15 minutes respectively, and we store them only in hashed form.

2.3 Security and sign-in data. When you or your staff sign in to Entrline, or reset a password, we record the time, the email address entered, whether the attempt succeeded, the IP address and the browser or device type. We use this to protect accounts, detect misuse and lock an account after repeated failed attempts. If a till sends us a receipt that fails our tamper check, we also record the IP address and device type of the till that sent it, so that we can investigate.

2.4 Business contact data we collect for outreach. We collect publicly available business contact details for hospitality venues (such as cafés, bars, and restaurants) in order to introduce our product. This is described in section 7 below. Where a business contact detail identifies an individual (for example, a named email address such as [email protected]), it is personal data and is covered by this policy.

2.5 Technical data. When you visit our website or use our dashboard or apps, our servers and infrastructure providers automatically receive certain technical data, including your internet protocol (IP) address, browser type and version, operating system, and similar information. Our website, dashboard and apps are protected and delivered through Cloudflare, and standard server request logs are generated. If an Entrline app crashes, we receive a crash report containing technical details about the device and app (see section 6).

2.6 Usage data. We use Plausible Analytics, a privacy-friendly, cookieless analytics tool, to understand in aggregate how visitors use our website (such as which pages are viewed). Plausible does not use cookies, does not collect personal data, and does not track visitors across websites.

2.7 Correspondence data. If you email us or reply to our messages, we keep the content and metadata of that correspondence.

3. How we collect and hold website form data

3.1 Contact form. When you submit our contact form, your details are sent to us by email through our email provider (Mailgun) and received in our business inbox (hosted on Google Workspace). We also keep a copy of each message in a private spreadsheet on Google Workspace (Google Sheets), so that no message is lost if an email fails to arrive. Mailgun processes and stores this email data in its European Union region. Access to the inbox and the spreadsheet is restricted to us.

3.2 Sign-up form and account sign-ups. When you submit our sign-up form, we notify ourselves by email (via Mailgun) and store the details you provide in a private spreadsheet on Google Workspace (Google Sheets). We use this record to tell you when Entrline becomes available in your country and to make sure we do not send you duplicate or unwanted messages. When you create an Entrline account, we add your name, email address, business name, city and phone number to the same spreadsheet, and we check your email address against our outreach list in Smartlead so that we stop any outreach emails to you. Access to this spreadsheet is restricted to us.

4. How we use your personal data

4.1 We process personal data for the following purposes:

(a) responding to your enquiries and providing information or services you have requested;

(b) keeping you informed about Entrline's availability in your country, where you have signed up to hear from us;

(c) contacting relevant hospitality businesses to introduce our product (see section 7);

(d) analysing use of our website, in aggregate, to improve it;

(e) complying with our legal and regulatory obligations;

(f) creating and running your Entrline account, including confirming your email address, signing you in and resetting your password;

(g) managing your subscription and taking payment through Stripe;

(h) sending you service emails, such as receipts, billing notices, data export links and warnings before your data is deleted;

(i) keeping our services secure and preventing misuse.

4.2 You can opt out of our marketing and outreach emails at any time using the unsubscribe link included in those emails, or by contacting us using the details in section 13.

5. Legal basis for processing

5.1 We only process personal data where we have a lawful basis to do so:

(a) Contract: where you create an Entrline account, we process your account, subscription and billing data because it is necessary to provide the service you have signed up for.

(b) Consent: where you have submitted your details through our website asking to hear from us (for example, joining our waitlist), we rely on your consent, which you may withdraw at any time.

(c) Legitimate interests: where we contact hospitality businesses to introduce our product, we rely on our legitimate interest in promoting our business to relevant commercial prospects. We have carried out a legitimate interests assessment balancing this against the rights of the individuals concerned, and we provide an opt-out in every message. You may object to this processing at any time. We also rely on legitimate interests to keep sign-in and security records that protect your account and our services.

(d) Legal obligation: where processing is necessary for us to comply with the law.

6. Sharing your personal data

6.1 We share personal data with the following categories of third-party service providers, who process it on our behalf and under our instructions:

• Mailgun (Sinch): delivers our website form emails and our service emails (such as account, billing, and receipt emails). We use Mailgun's European Union region, so the content and delivery records of these emails are processed and stored in the EU.
• Google Workspace (Google): hosts our email inboxes and the private spreadsheets in which we record website sign-ups, account sign-ups and contact messages.
• Google Firebase (Google): delivers push notifications to the Entrline apps and collects crash reports (Firebase Crashlytics) so we can fix faults. Crash reports contain technical details about the device and app, not your name or email address.
• Cloudflare: provides DNS, security and delivery for our website, dashboard, apps and domains.
• Hetzner: hosts the servers for our website, dashboard and apps, including our main database, in Nuremberg, Germany.
• Amazon Web Services (AWS): stores backups of our database, encrypted at rest, in its Frankfurt, Germany region.
• Stripe: processes subscription payments through its hosted checkout and billing pages. We give Stripe your email address and business name. Stripe handles card details directly; we do not collect or store full card numbers.
• Slack: sends internal notifications to our team, for example when a new account is created or deleted, which can include your name, email address and business name.
• Zapmail: provides the email inboxes and infrastructure we use for outreach.
• Smartlead: the platform we use to send and manage outreach emails and replies. When you sign up for an account, we use it to make sure you receive no further outreach emails.
• Hunter.io: assists us in finding and verifying business email addresses for outreach.
• MillionVerifier: verifies the validity of email addresses before we contact them.
• Plausible: provides cookieless website analytics.

6.2 We may also disclose personal data to law enforcement agencies, regulators, or other authorities where we are legally required or permitted to do so.

6.3 We require all our third-party providers to respect the security of your personal data and to process it only in accordance with our instructions and the law. We do not permit them to use your personal data for their own purposes.

7. How we collect and use business contact data for outreach

7.1 We identify potential customers by searching publicly available sources for hospitality businesses in the United Kingdom. Specifically:

(a) We use the Google Maps Places API to find hospitality venues in particular areas, collecting the business listing information Google publishes, such as business name, address, phone number, website, and rating. We do not collect Google account data, reviews, or reviewer identities.

(b) For venues with a website, we identify a published business email address from publicly accessible sources, including the venue's own website (such as its homepage and contact pages). We do this both directly and through our provider Hunter.io, which indexes publicly published business email addresses. We only use information that is publicly available; we do not use logins, bypass access controls, or access private information.

7.2 We use this data solely to contact the business to introduce our product. Because we collect this data from public sources rather than from you directly, we provide the information required under Article 14 of the UK GDPR, including our identity, our purpose, our lawful basis, and your rights, in our first message to you and by linking to this policy.

7.3 Our legal basis for this processing is our legitimate interests, as described in section 5. Every message includes a clear way to opt out, and if you opt out we will stop contacting you.

8. International data transfers

8.1 Some of our service providers are based outside the United Kingdom and the European Economic Area (for example, in the United States). Where we transfer personal data to such countries, we ensure appropriate safeguards are in place, including reliance on UK adequacy regulations / the UK-US data bridge where applicable, and Standard Contractual Clauses or the UK International Data Transfer Agreement where not.

8.2 We choose EU or UK data residency where our providers offer it. Our website, dashboard, apps and main database are hosted in the European Union (Hetzner, Nuremberg, Germany), our database backups are stored in the European Union (AWS, Frankfurt, Germany), and our service and transactional email is processed and stored in the European Union (Mailgun's EU region). Some providers, such as Stripe, Google, Slack and Smartlead, may process data in the United States, under the safeguards described in section 8.1. The United Kingdom and the European Economic Area each recognise the other as providing an adequate level of data protection, so transfers between them do not require additional safeguards.

8.3 You may request further information about these safeguards by contacting us using the details in section 13.

9. Data retention

9.1 We keep personal data only for as long as reasonably necessary for the purposes described in this policy, and to meet any legal, accounting, or reporting requirements.

9.2 Contact form submissions remain in our email inbox and spreadsheet, which we control, and we delete them when they are no longer needed. Sign-up details stored in our spreadsheet are kept only for as long as necessary to tell you when Entrline becomes available in your country, and are deleted when no longer needed for that purpose.

9.3 If you opt out of our outreach or ask us to stop contacting you, we retain the minimum information necessary to ensure we honour that request and do not contact you again.

9.4 Account data. We keep your account and business data while your subscription is active. If your subscription or trial ends, we keep the data for 12 months after the end of your last paid or trial period, so you can return without losing anything. We email you 60, 30 and 7 days before the data is deleted. After 12 months, we permanently delete your account and all of your business data. If you delete your account yourself from the dashboard, we delete it straight away and it cannot be recovered. When we delete an account, we also cancel any Stripe subscription and delete your customer record at Stripe. Stripe keeps its own billing records where the law requires it to, under Stripe's privacy policy.

9.5 Backups and exports. Our database backups are kept for 30 days, so deleted data may remain in a backup for up to 30 days before it is removed. If you request a data export, the file is kept for 10 days and then deleted.

9.6 Security records. We keep sign-in records (the time, the email address entered, the result, the IP address and the browser or device type) for 12 months and then delete them. They are also deleted when the account they belong to is deleted. The IP address and device type recorded when a receipt fails our tamper check are removed after 12 months.

10. Your rights

10.1 Under data protection law you have the right to: request access to your personal data; request correction of inaccurate data; request erasure of your data; restrict or object to our processing; and request the transfer of your data. Where we rely on consent, you may withdraw it at any time.

10.2 To exercise any of these rights, please contact us using the details in section 13. You will not usually have to pay a fee. We may charge a reasonable fee, or decline to act, if a request is clearly unfounded, repetitive, or excessive.

10.3 If you have an Entrline account, you can download a copy of your business data and delete your account at any time from the dashboard. You can also contact us using the details in section 13.

11. Cookies

11.1 Our website does not set any cookies. We use Plausible for analytics, which is cookieless and stores no information on your device. Our dashboard (admin.entrline.com) also sets no cookies, but when you sign in it stores your sign-in token and basic profile details (your name, email address and role) in your browser's local storage. This is strictly necessary to keep you signed in, and it is removed when you sign out. When you go to Stripe's hosted pages to pay or manage your subscription, Stripe may set its own cookies, which are covered by Stripe's privacy policy. Because we use only strictly necessary storage and no tracking, we do not display a cookie consent banner. If this changes, we will update this policy and seek your consent where required.

12. Children's privacy

12.1 Our website and services are intended for businesses and are not directed at children. We do not knowingly collect personal data from children.

13. How to contact us

13.1 If you have any questions about this policy or how we handle your personal data, or if you wish to exercise your rights, please contact us:

• By email: [email protected]
• By post: Entrline Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

14. Complaints

14.1 You have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection, at any time. The ICO's contact details are at https://ico.org.uk/make-a-complaint/. We would appreciate the chance to address your concerns first, so please contact us before approaching the ICO.

15. Changes to this policy

15.1 We may update this policy from time to time by publishing a new version on our website. Where changes are significant, we will take reasonable steps to notify you.