How we collect, manage, and protect your data.
At BettterMenu OÜ (operating the AVAARA platform), we take the security and privacy of your data seriously. This Privacy Policy explains how we process personal data under the General Data Protection Regulation (GDPR) and applicable German and Estonian law. AVAARA is a trademark of BettterMenu OÜ.
The Controller responsible for data processing on this platform is:
BettterMenu OÜ
Registry Code: 17401720 (Estonian Commercial Register / Äriregister)
Ahtri tn 12, Kesklinna linnaosa
Tallinn, Harju maakond, 15551
Republic of Estonia
Managing Director / CEO: Tushar Sood
Co-Founder & CTO: Abhigyan Gogoi
Privacy Inquiries: tusharsood@betttermenu.com
Phone: +49 173 936 7518
Roles. BettterMenu acts as:
Lead supervisory authority. Under the GDPR one-stop-shop mechanism, our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee. Data subjects in Germany may also lodge complaints with their competent Landesdatenschutzbeauftragte.
We classify data we process by user category:
A. Business Customers (Vendors & Organisers)
To provide our software, we process standard business and personal information including name, business name, work email, billing records, and authentication data. This is collected for account management, subscription processing, support, and legally required invoicing.
B. End-Users (Guests)
When an End-User accesses a digital menu via QR code or direct URL, the following technical data is processed automatically to deliver the service requested:
Legal basis: the transient processing of IP address and user-agent is based on Art. 6(1)(f) GDPR (legitimate interest in secure and functional service delivery). Client-side storage on the End-User's device, where strictly necessary to deliver the service the End-User actively requested, falls within the exemption of § 25(2) no. 2 TDDDG and does not require consent.
What we do NOT do on End-User menu surfaces:
Where Business Customer opts into aggregate menu usage analytics, BettterMenu provides such analytics on a server-side, aggregated, non-identifying basis (e.g., number of views per item, most-clicked items at the venue level), without placement of tracking technologies on the End-User's device.
| Processing activity | Data categories | Legal basis |
|---|---|---|
| Account creation and subscription management | Business and contact data | Art. 6(1)(b) GDPR (contract) |
| Invoicing and tax record-keeping | Billing data | Art. 6(1)(c) GDPR (legal obligation) |
| Service delivery to End-Users | IP, user-agent, session data | Art. 6(1)(f) GDPR (legitimate interest) |
| Communication with Business Customers | Contact data | Art. 6(1)(b) or (f) GDPR |
| AI-assisted content processing (on Customer instruction) | Customer Content, menu data | Art. 6(1)(b) GDPR (processor role) |
| Optional aggregated analytics | Non-identifying usage data | Art. 6(1)(f) GDPR |
| Fraud prevention and platform security | Technical and usage data | Art. 6(1)(f) GDPR |
| Marketing communications to Business Customers | Contact data | Art. 6(1)(f) GDPR with opt-out, or Art. 6(1)(a) GDPR |
| Compliance with legal obligations | As required | Art. 6(1)(c) GDPR |
| Product improvement & Feedback rewards | Email address, survey responses, star ratings | Art. 6(1)(a) GDPR (Explicit consent) |
| End-User (guest) feedback | Email address, survey responses, star ratings | Art. 6(1)(a) GDPR (Explicit consent) |
| Internal database management | Anonymised, aggregated menu item data (dish names, descriptions, allergen tags, dietary tags) | Art. 6(1)(f) GDPR (Legitimate interests) |
| Platform performance telemetry (e.g., aggregate scan counts, event traffic) | Non-identifying aggregate usage data | Art. 6(1)(f) GDPR (Legitimate interests — platform capacity and performance optimisation) |
Feedback and Rewards Program: Intermittently, we may invite users to submit feedback to help us improve AVAARA. If you choose to participate, we process your submitted text, ratings, and provided email address strictly for product development and to distribute program rewards (such as merchandise or offers). We do not share this data with third parties or use it for marketing purposes. You may withdraw your consent at any time by contacting us.
Internal Database Management. BettterMenu uses anonymised, aggregated menu data — including dish names, item descriptions, allergen tag combinations, and dietary classifications — for internal database management and platform maintenance purposes. No personal data is involved in this processing. Data is handled in aggregated form only and cannot be traced back to any specific venue, vendor, or individual. The legal basis is Art. 6(1)(f) GDPR (legitimate interests) — specifically, BettterMenu's interest in maintaining a well-functioning and reliable platform. This data is not shared with any third party.
Guest Feedback. End-Users (guests who access menus by scanning a QR code) may optionally submit feedback about their experience and provide their email address to participate in our product improvement program. This is entirely voluntary — guests are never required to provide their email address to access any menu or platform feature. Where a guest chooses to submit feedback and provides their email, we process that data solely for internal product development purposes. We do not use guest email addresses for marketing, share them with third parties, or link them to any other data we hold. The legal basis for this processing is Art. 6(1)(a) GDPR (explicit consent), obtained at the point of submission. Guests may withdraw their consent and request deletion of their data at any time by contacting us at tusharsood@betttermenu.com.
Where a vendor accesses the AVAARA Platform via an Event Organizer invitation, BettterMenu OÜ processes the following personal data: name, email address, and business name, as provided by the Event Organizer or entered directly by the Event Vendor at the point of invite acceptance.
This data is processed solely for the purpose of creating and managing temporary event-scoped platform access, and is retained for the duration of the event plus a standard post-event period of ninety (90) days, after which it is deleted unless the Event Vendor has entered into a Vendor Pro subscription.
The legal basis for this processing is Article 6(1)(b) GDPR (performance of a contract / steps prior to entering into a contract). BettterMenu OÜ does not use Event Vendor data for marketing purposes without separate consent.
Event Attendees (End-Guests). The AVAARA Platform does not collect, store, or process personal data from event attendees who scan QR codes to view menus. Guest-facing features such as dietary preference filters operate on a session-only basis with no persistent data storage and no user accounts required.
BettterMenu does not sell or share personal data with third parties for marketing purposes. Data is transferred only to sub-processors necessary to technically run the Platform.
| Sub-processor | Purpose | Location of processing | Transfer mechanism |
|---|---|---|---|
| Google Cloud EMEA Ltd / Google LLC (Firebase, Cloud) | Hosting, authentication, real-time database | EU regions (Frankfurt / Netherlands) preferred; fallback US | EU-US Data Privacy Framework + Standard Contractual Clauses |
| Google Cloud (Vertex AI / Gemini) | AI processing: menu extraction, description generation, allergen suggestion, image enhancement | EU regions where technically available | EU-US DPF + SCCs; Google contractually commits not to use customer data to train foundation models |
| DeepL SE (Cologne, Germany) | Machine translation of menu content | Germany, Finland (EU/EEA) | Intra-EU; DeepL Pro does not store translated texts after processing |
| Mollie B.V. (Amsterdam, NL) | Payment processing for subscriptions | Netherlands (EU/EEA) | Intra-EU; PCI DSS compliant |
| Usercentrics GmbH (Munich, Germany) | Cookie consent management (B2B portal only) | Germany (EU/EEA) | Intra-EU |
| BettterMenu OÜ engineering personnel based in India | Platform development, production debugging, incident response, technical support | India | EU Standard Contractual Clauses (Commission Decision 2021/914); Transfer Impact Assessment on file; role-based access controls; access logging |
All sub-processors are bound by Data Processing Agreements (Auftragsverarbeitungsvertraege) under Art. 28 GDPR.
Business Customer may request a current sub-processor list and summary of the applicable Transfer Impact Assessment by email. BettterMenu will notify Business Customer at least thirty (30) days in advance of new sub-processors; Business Customer may object within fourteen (14) days on reasonable data protection grounds.
You have the following rights with respect to your personal data:
To exercise these rights, contact tusharsood@betttermenu.com. We aim to respond within 30 days; under Art. 12(3) GDPR, we may extend the response time by up to two additional months for complex or numerous requests and will inform you of any extension within one month.
Personal data is processed within the European Economic Area (EEA) wherever technically feasible. The following transfers outside the EEA may occur:
United States. Hosting infrastructure (Google Cloud / Firebase) and AI processing (Google Vertex AI) may involve access by Google LLC personnel in the United States. Transfer is based on the EU-US Data Privacy Framework (adequacy decision of 10 July 2023) and, as a safeguard, EU Standard Contractual Clauses. Google contractually commits that Vertex AI customer data is not used to train foundation models.
India. BettterMenu's engineering team, based in India, has access to production systems for the purpose of platform development, debugging, incident response, and technical support. This access is necessary for the performance of the services. Transfer is based on EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914). BettterMenu has conducted a Transfer Impact Assessment in accordance with EDPB Recommendations 01/2020 and implements the following supplementary measures:
A copy of the applicable SCCs and a summary of the Transfer Impact Assessment is available to Business Customers on written request.
In the event any adequacy decision referenced above is invalidated, BettterMenu will promptly implement alternative safeguards in accordance with GDPR Chapter V.
Guest-facing menu surface. In line with § 25 TDDDG, no non-essential cookies, tracking technologies, or fingerprinting scripts are set on End-User devices when accessing menus. Only storage strictly necessary to deliver the service requested (session-scoped technical identifiers, language preference actively selected by the End-User) is used, falling within § 25(2) no. 2 TDDDG. No consent banner is displayed to End-Users because no consent-requiring storage occurs. Where a guest voluntarily submits feedback and provides their email address via the Platform, this constitutes an active, consent-based interaction and is governed by the Guest Feedback section above; it does not affect the no-tracking nature of standard menu access.
B2B portal (Business Customer accounts). The B2B portal uses essential cookies required for authentication, security, and session management, which do not require consent. Non-essential analytics and functionality cookies are set only after Business Customer grants explicit consent via the Usercentrics consent management platform. Consent may be withdrawn at any time via the consent management interface.
BettterMenu implements appropriate technical and organisational measures to protect personal data, including:
A summary of our Technical and Organisational Measures (TOM) is available to enterprise Business Customers on request.
In the event of a personal data breach, BettterMenu will notify the competent supervisory authority within 72 hours of becoming aware of the breach, pursuant to Art. 33 GDPR. Where the breach is likely to result in a high risk to the rights and freedoms of data subjects, affected individuals will be notified pursuant to Art. 34 GDPR. For Business Customers acting as controllers whose data we process, notification will occur without undue delay in accordance with the applicable AVV.
The Platform is not directed at children. BettterMenu does not knowingly process personal data of children under 16 without parental or legal guardian authorisation in accordance with Art. 8 GDPR and applicable national law.
BettterMenu has assessed its obligation under Art. 37 GDPR. A formal Data Protection Officer is not currently mandatory based on the nature, scope, and purposes of our processing. Our internal privacy contact is Tushar Sood, reachable at tusharsood@betttermenu.com.
Material changes to this Privacy Policy will be communicated to Business Customers at least 30 days in advance via email or in-platform notice. The "Last Updated" date at the top of this page reflects the most recent revision.