Privacy Policy

01Introduction & Scope

This Privacy Policy explains how ThisRapt Ltd, a company registered in Scotland, UK, with its registered address at 68 Fords Road, Edinburgh, EH11 3HR, operating as Growtality ("Growtality", "we", "us", "our"), collects, uses, and protects personal data in connection with the Growtality platform ("Platform"), including our website, Manager Dashboard, Customer App, Guest CRM, AI Voice & Chat features, and Delivery Driver app.

This Policy covers two categories of individuals, whose data we handle differently:

• Restaurant account usersowners, managers, and staff of restaurants that sign up for Growtality ("Customer", "you").
• Gueststhe diners and end-customers of our restaurant Customers, whose data is collected through bookings, orders, and the Guest CRM.

02Who We Are

Growtality is a restaurant technology platform operated by ThisRapt Ltd, registered in Scotland, UK (registered address: 68 Fords Road, Edinburgh, EH11 3HR). ThisRapt Ltd is the data controller for information collected directly from restaurant account users (Section 1, first bullet) and the data processor for Guest Data collected on behalf of restaurant Customers.

03Information We Collect

3.1 Restaurant Account Information

• Business detailsrestaurant name, address, cuisine type, number of locations, tax/registration details where required for billing.
• Staff account detailsnames, email addresses, phone numbers, roles, and login credentials for individuals you authorize to access the Manager Dashboard.
• Billing informationprocessed via Stripe; Growtality does not store full card numbers.

3.2 Guest Data (collected on behalf of restaurant Customers)

• Booking detailsname, contact information, party size, date/time, special requests.
• Ordering detailsitems ordered, delivery or pickup address, order history.
• Guest CRM datavisit frequency, preferences, and any notes restaurants choose to record.
• AI Voice & Chat interactionscall recordings, transcripts, or chat logs when a Guest interacts with the AI Voice & Chat feature or the OG/Maya Pro assistant, processed via our voice and language processing sub-processors.

3.3 Technical & Usage Data

• Device and usage datadevice and browser information, IP address, and usage analytics collected when you use the Platform or visit growtalityapp.com.
• Cookiescookies and similar technologies, as described in Section 10.

3.4 Delivery Driver App Data

• When restaurant staff use the Delivery Driver app on their own devices, we collect order assignment data and, while a delivery is active, location data necessary to sequence and track fulfilment.

04How We Use Information

• To provide, operate, and maintain the Platform, including bookings, ordering, Guest CRM, and delivery coordination.
• To process payments and Commission billing via Stripe.
• To power AI Voice & Chat and the OG/Maya Pro onboarding assistant, using third-party speech-to-text, language, and text-to-speech providers.
• To provide customer support and respond to inquiries from restaurant account users.
• To send product updates, onboarding content, and, where account users have opted in, marketing communications about Growtality.
• To maintain the security and integrity of the Platform, including fraud prevention.
• To comply with legal obligations, such as tax and financial record-keeping.

05Legal Bases for Processing

Where applicable data protection law requires a legal basis (such as under the UK/EU GDPR), Growtality relies on: performance of a contract (providing the Platform to restaurant Customers), legitimate interests (improving and securing the Platform, and supporting restaurant Customers' own legitimate interests in managing their Guest relationships), consent (where Guests opt in to marketing communications from a restaurant), and compliance with legal obligations (such as billing records).

06How We Share Information

We do not sell personal data. We share information with the following categories of service providers (sub-processors) strictly to operate the Platform:

• Stripepayment processing.
• Twilio & voice/speech providerse.g. Deepgram for speech-to-text, ElevenLabs for text-to-speech — AI Voice & Chat functionality.
• Cloud hosting & database providerse.g. MongoDB Atlas — secure storage of Platform data.
• Analytics providersto understand Platform usage and improve the product.

We may also disclose information where required by law, to protect the rights and safety of Growtality, our Customers, or Guests, or in connection with a merger, acquisition, or sale of business assets, subject to continued protection of personal data under this Policy.

07International Data Transfers

As a global platform, Growtality may transfer and process personal data in countries other than where a restaurant Customer or Guest is located, including where our sub-processors operate. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms for cross-border transfers.

08Data Retention

We retain restaurant account information for as long as the Account remains active, and for a limited period afterward for legal, tax, and dispute-resolution purposes. Guest Data is retained in accordance with the instructions of the relevant restaurant Customer, who controls how long Guest records are kept, subject to Growtality's own minimum security and backup retention practices.

09Security

We use industry-standard technical and organizational measures, including encryption in transit, access controls, and monitoring, to protect personal data against unauthorized access, loss, or misuse. No system is completely secure, and we encourage restaurant account users to safeguard their own login credentials.

10Cookies & Tracking Technologies

Our website and Platform use cookies and similar technologies for essential functionality, analytics, and (where applicable) marketing. You can control cookie preferences through your browser settings or any cookie banner presented on growtalityapp.com.

11Your Rights

Depending on your location and applicable law, you may have rights to access, correct, delete, restrict, or port your personal data, and to object to or withdraw consent for certain processing.

• Restaurant account userscontact us directly using the details in Section 15 to exercise these rights.
• Guestsbecause the restaurant Customer is the data controller for Guest Data, please contact the restaurant directly in the first instance. Growtality will assist restaurant Customers in fulfilling verified Guest requests.

12Children's Privacy

The Platform is intended for use by restaurant businesses and their adult staff, and by Guests interacting with a restaurant's booking, ordering, or AI Voice & Chat features. We do not knowingly collect personal data from children through Account registration. Restaurant Customers are responsible for ensuring their own collection of Guest Data complies with applicable law where Guests may include minors (e.g. family bookings).

13Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Material changes will be notified via email or in-app notice, and the "Effective date" at the top of this Policy will be updated accordingly.

14Governing Law

This Privacy Policy is governed by the laws of Scotland, UK, consistent with the governing law provision in our Terms of Service.

15Contact Us