PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA
Socialeat Customer · Extended and multi-layered notice
SHORT-FORM NOTICE – THE ESSENTIAL INFORMATION
| Item | Summary |
|---|---|
| Controller | Socialeat S.r.l., Via G. Compagnoni 26, Milano – VAT No./Tax Code 13257270960. Contacts: info@socialeat.net and privacy@socialeat.net. |
| Purpose | Creating and managing the account, enabling events/tables/bookings, social features and chat, security, support and, if activated, personalised features. |
| Data | Account, profile, photos/interests, geodata, bookings and participation, social relationships, messages/content, reviews, notifications, technical logs. |
| Sensitive data | Allergies/intolerances may reveal data concerning health and require separate handling. |
| Recipients | Restaurants and Hosts/Co-Hosts to the extent necessary; technical providers used by Socialeat to provide the service; authorities in the cases provided for by law. |
| Rights | Access, rectification, erasure, restriction, portability where applicable, objection, withdrawal of consents and complaint to the Italian Data Protection Authority (Garante per la protezione dei dati personali). |
1. Scope of the notice
This notice relates exclusively to Socialeat Customer and the corresponding web features intended for users/consumers. It does not govern the services dedicated to restaurateurs. Processing operations relating to restaurateurs/professional staff must be covered by separate documentation.
The notice is multi-layered: the initial summary provides an immediate overview; the following sections contain the detail required by the legislation.
2. Controller and contact details
Controller: Socialeat S.r.l., Via G. Compagnoni 26, Milano – VAT No./Tax Code 13257270960.
General e-mail: info@socialeat.net. Privacy contact: privacy@socialeat.net.
For matters relating to data protection, the privacy contacts indicated above may be used.
3. What data we process
| Category | Examples |
|---|---|
| Account and authentication | e-mail, first name, surname, nickname/username, date of birth, language, possibly gender if collected, authentication identifiers, e-mail verification status, access recovery data. |
| Profile | photos, bio, interests, preferences, area/city, visibility settings and other information entered voluntarily. |
| Places and geodata | manually selected area; device location when the user activates features that require it; addresses/coordinates of events and tables; any approximate public location associated with the profile. |
| Events and tables | events created, Host/Co-Host role, invitations, acceptances, places, dates/times, seat availability, settings and changes. |
| Bookings and participation | bookings, waitlist, cancellations, reminders, 8-hour confirmations, arrival statuses, participation history and no-show/internal reliability if used. |
| Social relationships | Hearts, Matches, Follow Host, Follow Restaurant, blocks, reports, people already met, number of evenings together, private post-event preferences and reciprocity. |
| Content and communications | posts, comments, replies, reactions, private and group chats, voice messages, attachments, scheduled messages, polls, mentions, pinned messages, requested translations, read receipts and typing indicators. |
| Reviews and feedback | ratings and texts on the event/evening, table, Host and restaurant; tags on what worked; any replies. |
| Preferences/recommendations | interests and signals used for filters, sorting and suggestions, including the “This evening looks right for you” feature. |
| Technical and security data | IP, timestamps, device type, operating system, app version, push tokens, logs, errors, rate limiting, anti-fraud and data necessary for security. |
| Operational communications | in-app/push notifications, confirmation/cancellation e-mails, reminders and technical delivery logs when available. |
4. Special category data and potentially sensitive information
4.1 Allergies and intolerances
Allergies, intolerances or other information revealing health status may fall within the special categories of data referred to in Art. 9 GDPR. Entering them must be optional and limited to the purpose necessary for managing the booking and food safety.
4.2 Interests and content that may reveal special categories
Interests, bio or free-form content could, in specific cases, reveal religious beliefs, sexual orientation, health or other special categories. Socialeat should avoid using such data for marketing or profiling without a specific legal assessment and an appropriate legal basis.
5. Purposes, legal bases, necessity and retention
| Purpose | Data | Basis | Provision of data | Retention |
|---|---|---|---|---|
| Registration and account | Account/minimum profile | Contract | Necessary | For the duration of the account and for the time strictly necessary for technical deletion and legal obligations. |
| Authentication and security | E-mail, identifiers, logs | Contract / legitimate interest in security | Necessary | For the period necessary for security, abuse prevention, incident management and the protection of rights. |
| Bookings, cancellations, waitlist, 4-hour rule | Booking history | Contract | Necessary for the feature | As long as necessary + obligations/disputes |
| 8-hour reminder and arrival statuses | Booking/status | Contract | Necessary for the feature | Until the end of the experience + minimal log |
| Creation of events/tables | Profile, event, place, participants | Contract | Necessary if used | For the duration of the event + necessary history |
| Host/Co-Host | Invitations, roles, actions | Contract | Necessary for co-organisation | For the duration of the event and, thereafter, for the period necessary for security, audit and the handling of disputes. |
| Hearts and Matches | ID, actions, status | Contract for the requested feature | Optional to use | Until removal/withdrawal/closure |
| Follow Host/Restaurant | ID and follow status | Contract for the requested feature | Optional | Until unfollow/closure |
| Board and chat | Content and metadata | Contract | Optional to use | As long as the chat or the content remains available under the rules of the service, in addition to the period necessary for moderation, security and the protection of rights. |
| Scheduled messages | Text, chat, time | Contract | Optional | Until sending/deletion + message retention |
| Reviews and How did it go? | Ratings, text, participation | Contract / legitimate interest, depending on the feature | Optional | As long as published/necessary |
| Evenings together / people met | Participation history | Performance of the contract for the requested social functionality | Derives from use | As long as the account is active or the feature is available |
| Personalised recommendations | Interests, area, history | Contract if essential; otherwise consent | Optional if not essential | As long as active / until withdrawal |
| Device location | Lat/lon | Consent/permission of the user for the requested feature | Optional | Minimise; avoid unnecessary retention |
| Public profile location | Geocoded address/area | Specific consent | Optional | As long as the feature is active + technical time frames |
| Allergies/intolerances | Health data | Explicit consent under Art. 9 | Optional | Only as long as necessary / until withdrawal |
| No-show/reliability/anti-abuse | Logs and history | Legitimate interest subject to a prior LIA (legitimate interest assessment) | Derives from use | For a period proportionate to the purposes of abuse prevention, security and the handling of disputes. |
| Support/reports | Requests and attachments | Contract / legal obligation / legitimate interest | Only if activated | Depending on the nature of the request |
| Marketing | Contacts/preferences | Consent | Optional | Until withdrawal / policy |
| Non-essential analytics/tracking | Identifiers and usage | Consent where required | Optional | According to the cookie/SDK policy |
6. Places, maps and location
6.1 Places of events and tables
An event may be associated with a restaurant or with a simple address, square, park or meeting point. This data describes the place of the experience and does not, on its own, imply tracking of the user.
6.2 “Near me” features
When the user uses a feature that requires the device location, the app may request the relevant permission. The request must take place in the context of the feature; where provided for, the user must be able to choose an area manually as an alternative.
6.3 Public profile location
If the user decides to show a location on the profile, the precision made visible to others must be reduced (e.g. area/neighbourhood) and must not expose the exact street number.
7. Recipients and categories of recipients
| Recipient | Purpose |
|---|---|
| Restaurants/Businesses | Data strictly necessary for the booking, table, promotion and related management. |
| Hosts/Co-Hosts | Data necessary for managing the event and participation. |
| Other users | Profile and content visible in accordance with the rules of the Service; public board; social data only where provided for. |
| Technical providers | Hosting/cloud, authentication, push, e-mail, maps/geocoding, analytics, translation, support and security providers used by Socialeat to provide the service. |
| Payment providers | Payment provider used for any paid Customer features made available. |
| Authorities/advisers | When necessary for legal obligations, security, litigation or the protection of rights. |
8. Transfers outside the EEA
When a provider processes data outside the EEA, Socialeat will have to indicate the basis for the transfer and the applicable safeguards, if required.
9. Recommendations and personalisation
Socialeat may suggest or sort content on the basis of parameters such as area/distance, date, declared interests, seat availability, participation history and people already met, according to the features actually implemented.
For “This evening looks right for you”, if the feature is not necessary for the service, the legal basis and the opt-out/consent arrangements are governed according to the legal basis indicated in this notice.
10. Automated decisions
The recommendations and filters described should not produce solely automated decisions with legal or similarly significant effects.
11. Chat, scheduled messages and board
The event/table chat is reserved for authorised participants and Hosts/Co-Hosts; anyone who joins later may see the previous history for as long as the chat exists.
The board may be readable by all users who see the event/table, while posting, comments, replies and reactions are reserved for authorised/booked users.
Scheduled messages are retained until the scheduled time, until deletion or until the right to send lapses. Before sending, the system must verify that the author is still authorised.
12. Moderation, reports and blocks
Socialeat provides reporting and blocking tools and may moderate content contrary to the law or to the Terms. Decisions must be proportionate and, where the DSA is applicable, accompanied by the information and remedies provided for.
13. Operational notifications and marketing
Booking confirmations/cancellations, security, reminders, messages and notifications requested by the user are operational communications.
Marketing and promotions are separate.
14. Cookies, SDKs and tracking technologies
For the website and for any SDKs/identifiers in the app that are not strictly necessary, the rules on cookies and other tracking tools apply.
15. Security and data breaches
Socialeat adopts technical and organisational measures appropriate to the risk.
In the event of a personal data breach, Socialeat applies the assessment, notification and communication obligations laid down in Arts. 33 and 34 GDPR when the relevant conditions are met.
16. Retention periods
| Category | Retention rule | Criterion applied |
|---|---|---|
| Account/profile | For the duration of the account and thereafter for the time necessary for technical deletion, backup management and legal obligations. | Progressive deletion according to the system’s technical cycles and the applicable obligations. |
| Chats/attachments | As long as the chat is active and thereafter for the period necessary for security, moderation and the protection of rights. | Apply the same rule to text and attachments, unless there are different obligations or needs. |
| Scheduled messages | Until sending/deletion + message retention | |
| Bookings/participation | Necessary duration + obligations/disputes | Retain for longer only what is necessary for legal obligations, litigation and security. |
| Reviews/posts/comments | As long as published or until removal, except for evidentiary needs | |
| Hearts/Matches/Follows | Until withdrawal/removal/closure + minimal logs | |
| Device location | Temporary and minimised; not retained beyond what is necessary for the feature. | Processed only in the context of the requested feature. |
| Public profile location | Until deactivation/withdrawal + technical time frames | |
| Allergies/intolerances | As long as necessary / until withdrawal | |
| Consent logs | Time necessary to demonstrate the management of choices | Retention proportionate to the need to demonstrate the collection, withdrawal and version of consent. |
| Security logs | Proportionate period | Period proportionate to the risk, incident prevention and the applicable obligations. |
| Reports/tickets | Depending on handling and protection needs |
17. Rights of the user
- access to the data and to a copy;
- rectification and completion;
- erasure in the cases provided for;
- restriction;
- portability where applicable;
- objection to processing based on legitimate interest;
- withdrawal of optional consents at any time;
- complaint to the Italian Data Protection Authority (Garante per la protezione dei dati personali);
- recourse to the judicial authorities.
18. Deletion of account and content
For messages/comments that form part of conversations with other users, deletion may require anonymisation or placeholders to maintain the coherence of the conversation.
19. Minors
Socialeat Customer is reserved for persons of legal age.
20. Updates to the notice
Substantial changes must be communicated transparently. A new purpose that requires consent must not be activated before valid consent has been obtained.