Privacy Policy of the kelbroo platform

Version 2026-08-29

Translation. This is an informative translation of the Polish document Polityka prywatności platformy kelbroo. In the event of any discrepancy between the language versions, the Polish version prevails.

§1. Role under the GDPR

Controller: For data provided by Clients (B2B) for the purposes of concluding the contract and settling subscriptions (e.g. through the operator PayU), the Controller is Kelbroo, ul. Rodła 24/4, 01-496 Warsaw, Poland, VAT ID (NIP): 5222269366. Contact for all data-related matters: kontakt@kelbroo.com.
Processor: For data entered during the venue’s work (Staff, Guests), the controller is the Client and Kelbroo acts on the Client’s instructions.

§2. Guest data

Ordering does not require creating an account. We process a nickname (e.g. “Quiet Badger”), a graphic marker, order history and the device language.

Exception (Guest online payments): If a Guest uses online payment, they may be asked on our screen for an e-mail address. That address is passed on in real time solely in order to initiate the payment with an external operator (e.g. PayU) and is not permanently saved or stored in Kelbroo’s databases.

§3. Session identifier and statistics

In the Guest application a single, strictly technical session token is stored. It is absolutely necessary for the Service to work at the user’s request (linking to the bill after a refresh), which is why it requires no consent banner. In the Guest application we use no tracking or advertising tools and we do not plan to change that.

On the product site kelbroo.com we use the statistical tool Google Analytics in order to know which content is read. We start it only after obtaining the visitor’s consent: without consent we load no analytics script and send no data to Google. Consent can be withdrawn at any time via the link in the site footer. Refusal does not restrict access to any part of the site.

§4. Staff data

On the Client’s instructions the system collects a Staff member’s first name, surname, role and e-mail address. A key element protecting the venue’s financial interest is the Audit Log, which is inalienable and records operations on bills. Passwords are protected by a cryptographic hash.

§5. Client billing data

As Controller we store company data: VAT ID (NIP), address and e-mail addresses. If the subscription is not renewed, 6 months after the service expires the account is deleted (anonymised), which allows us to retain statistics only, without personal data. The Client is informed of this 30 days in advance.

§6. Data recipients and transfers outside the EEA

Data does not leave the EEA — our servers are located in Frankfurt (Germany) at the provider Hostinger.com.

Payment services (PayU): The operator of subscription payments (and, in due course, of Guest payments) on the platform is PayU S.A., with its registered office in Poznań, Poland (ul. Grunwaldzka 186, 60-166 Poznań, NIP: 7792308495, KRS: 0000274399). In the payment process PayU acts as a separate, independent Controller of personal data. Kelbroo passes PayU the necessary parameters (e.g. the IP address in the API call), but does not store IP numbers, payment card details or BLIK codes in its own database.

§7. Rights of data subjects

Data subjects have the full rights arising from the GDPR (access, rectification, erasure), as well as the right to lodge a complaint with the President of the Personal Data Protection Office in Poland.

Because Guest profiles are heavily pseudonymised, deleting a specific order is not technically possible without the Guest supplying additional identifying information from outside the system (Art. 11 GDPR). Requests relating to orders and to the venue’s work should be addressed directly to the restaurant concerned. For B2B subscription matters please write to kontakt@kelbroo.com.

§8. Changes to the Privacy Policy

Clients will be notified of material changes to this document at the e-mail address on file, 14 days in advance.

The document enters into force on the day it is published on the kelbroo platform website.