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Privacy Policy – Meni Admin Panel

Last updated: January 3, 2026

This Privacy Policy explains how Individual Entrepreneur Aleksandr Verbitskii (Identification Number 345820891) ("we", "us", "our") collects and uses personal data when you use the Meni Admin panel available at https://admin.meni.ge (the "Admin Panel").

The Admin Panel is part of the meni.ge platform used by restaurant owners, managers, and staff to manage their establishments' digital presence, menus, orders, and customer interactions. This Privacy Policy applies to the Admin Panel. In this Policy, we refer to the Admin Panel and closely related features collectively as the "Service".

We are committed to protecting your privacy and processing your personal data in accordance with the EU General Data Protection Regulation (GDPR).

Language and translations: This Privacy Policy is drafted in English and the English version is the original and legally binding version. Any versions of this Privacy Policy that you may see in other languages are generated by machine translation and are provided solely for your convenience. In the event of any inconsistency or conflict between a translated version and the English version, the English version shall always prevail.

1. Data Controller and Contact Details

Data Controller
Individual Entrepreneur Aleksandr Verbitskii
Registered in the Republic of Georgia
Identification Number: 345820891

Registered address (Georgia):
6010, Georgia, city of Batumi, Grigol Eliava street, N 32e, floor 2, apartment N201a

Contact email for privacy matters: info@meni.ge

We do not have representative offices or branches in other countries.
At the moment we have not appointed an EU/EEA representative or a Data Protection Officer (DPO). If this changes, we will update this Policy.

2. Scope of this Policy

This Policy applies to the Meni Admin Panel – the administrative interface of the meni.ge platform that restaurant owners, managers, and staff use to:

  • Create and manage restaurant accounts
  • Create and update digital menus in multiple languages
  • Upload menu photos and content
  • Process customer orders in real-time
  • Manage table reservations
  • Configure pricing and availability
  • View analytics and reports
  • Communicate with customers
  • Manage restaurant locations and settings

The meni.ge platform also includes a separate customer-facing application used by guests to view menus and place orders. This Privacy Policy does not cover that customer application; the processing of personal data in the customer application is described in a separate privacy policy available at https://meni.ge/privacy.

3. Personal data we collect

Depending on how you use the Service, we may collect the following categories of data.

3.1 Registration and account data

  • Email address and/or mobile phone number
  • Full name or business contact name
  • Restaurant/venue name and business information
  • Job title or role within the establishment
  • Authentication data (such as password hash, authentication tokens, OAuth tokens, login timestamps)
  • IP addresses and session data for security purposes

3.1a Content upload metadata

When you upload content (menu items, photos, descriptions) to the Admin Panel, we collect:

  • Upload timestamps and dates
  • User account identifier associated with each upload
  • File metadata (file name, size, format, EXIF data where applicable)
  • Modification history (who edited content and when)
  • Content identifiers and storage locations

This metadata is necessary for system operation, content management, and to comply with legal obligations, including responding to intellectual property infringement claims.

3.2 Customer contact and delivery information

When customers place orders (especially delivery orders) through the customer-facing application, we transmit the following customer information to you:

  • Customer phone number
  • Customer email address
  • Delivery address (street, building, apartment, entrance, floor)
  • Additional delivery instructions or notes
  • Customer name or contact person name

Your responsibilities as data controller:

When you receive customer contact information, you become an independent data controller for that data. This means:

  • You are responsible for protecting customer data in accordance with applicable privacy laws (GDPR, local data protection regulations)
  • You must use customer contact information only for legitimate purposes:
  • Order fulfillment and delivery – contacting customers about their orders
  • Order-related communication – clarifications, status updates, delivery coordination
  • Marketing and promotions – only with customer consent or as permitted by applicable law
  • You must not share customer contact information with third parties (except delivery couriers working on your behalf)
  • You must implement appropriate security measures to protect customer data
  • You must honor customer requests to opt out of marketing communications
  • You must comply with customer data rights requests (access, deletion, correction)

Platform responsibility:

We (meni.ge platform) act only as a data processor for transmitting customer information to you. We do not control how you use customer contact information after you receive it. You are solely responsible for compliance with privacy laws regarding your use of customer data.

We do not share customer contact information with any other third parties beyond the specific Establishment that receives the order.

3.3 Geolocation data

  • Device location data (GPS, Wi-Fi, Bluetooth or similar), if you grant us access in your device or browser
  • Approximate location derived from your IP address, where permitted by law

3.4 Order and transaction data

  • Items ordered, date, time and place of order
  • Table number or area (where applicable)
  • Order status and basic payment-related metadata (for example, method of payment, payment status)

As a rule, payment card data is processed by external payment providers in accordance with their own privacy policies. We do not store full card numbers or CVV/CVC codes.

3.4a Reservation and booking data

When you make a table reservation through the Service, we collect:

  • Reservation details (date, time, number of guests)
  • Special requests or notes related to your reservation
  • Reservation status and history
  • Cancellation or modification data

3.4b Copyright infringement and content moderation data

To enforce our Terms of Service and respond to intellectual property infringement claims, we may collect and process:

  • Copyright infringement notices and counter-notifications received
  • Contact information of rights holders and their authorized representatives
  • Evidence of infringement (URLs, screenshots, descriptions of allegedly infringing content)
  • Records of content removal requests and actions taken
  • History of copyright violations associated with user accounts
  • Communication between us, rights holders, and users regarding infringement claims
  • Documentation of repeat infringer status

This data is processed to:

  • Comply with intellectual property laws and legal obligations
  • Respond to valid takedown notices
  • Enforce our repeat infringer policy
  • Protect the rights of copyright owners and other rights holders
  • Defend against false or abusive infringement claims
  • Maintain records for potential legal proceedings

Legal bases:**

  • Compliance with legal obligations (Art. 6(1)(c) GDPR) – to respond to valid legal notices
  • Our legitimate interests (Art. 6(1)(f) GDPR) – to protect intellectual property rights, prevent abuse, and enforce our Terms of Service
  • Establishment, exercise or defence of legal claims (Art. 9(2)(f) GDPR where applicable)

Retention: Copyright infringement records are retained for up to 5 years from the date of the incident or longer if required for ongoing legal proceedings or to comply with legal obligations.

3.5 Photo and caricature data

  • Photograph you upload or provide via your device's camera
  • Caricature image generated from your photo
  • Technical data and internal identifiers necessary to create, associate and store the caricature in your account

3.5a Dietary preferences and restrictions

If you choose to provide this information, we may collect:

  • Food preferences (for example, vegetarian, vegan)
  • Dietary restrictions or allergies (for example, gluten-free, lactose intolerance, nut allergies)
  • Special dietary requirements for religious or health reasons

This information is provided voluntarily and is used only to help venues better serve you and ensure your safety.

3.6 Device and technical data

To ensure correct display and convenient repeat orders, we collect basic technical information, such as:

  • Device type (for example, smartphone, tablet), operating system and version
  • Screen size, orientation and other display parameters
  • Browser or app version, language settings
  • IP address and other technical identifiers (for example, device or installation ID)
  • Log data about app events (for example, opening screens, button clicks, page load errors)
  • Push notification tokens (if you enable push notifications)

3.6a Push notification data

If you enable push notifications, we collect and use:

  • Device push notification token
  • Notification preferences and settings
  • Delivery status and engagement data (for example, whether notifications were delivered, opened, or dismissed)

3.7 Usage history and communication data

  • History of your orders in venues that use our platform
  • History of your interactions with different venues (for example, which venue you visited and when)
  • Messages sent to venues via the Service
  • Feedback, ratings and support requests related to venues or to the platform

3.8 Error and diagnostic data

To improve the stability and reliability of the Service, we collect error and diagnostic information when technical issues occur:

  • Error messages and stack traces
  • Actions you took before an error occurred (breadcrumbs)
  • Device and browser information at the time of the error
  • Approximate time and location of the error
  • Session replay data (with all personal information automatically masked)

This data is collected through Sentry, our error monitoring service, and is used solely to identify and fix technical problems.

3.9 Consent and preference data

  • Your consents and preferences (for example, consent to analytics, geolocation, camera use for photos)
  • Records of your requests regarding your data (access, deletion, etc.) and our responses

4. Purposes and legal bases for processing

Under the GDPR we must have a legal basis for each processing purpose. Depending on the situation, we rely on:

  • Performance of a contract (Article 6(1)(b) GDPR)
  • Compliance with legal obligations (Article 6(1)(c) GDPR)
  • Legitimate interests (Article 6(1)(f) GDPR)
  • Your consent (Article 6(1)(a) GDPR)

4.1 Providing and operating the Service

We process your data to:

  • Create and manage your restaurant account on the Admin Panel
  • Allow you to create and update digital menus in multiple languages
  • Enable you to upload menu photos and content
  • Process customer orders received through the customer-facing application
  • Manage table reservations
  • Provide analytics and reports about your restaurant's performance
  • Send service notifications (for example, new order alerts, system updates)
  • Allow you to communicate with customers
  • Provide you with customer contact information for order fulfillment and delivery
  • Manage restaurant locations, settings, and configurations

Legal bases:

  • Performance of a contract (Art. 6(1)(b) GDPR)
  • Our legitimate interests in operating and improving the platform (Art. 6(1)(f) GDPR)

Important: When we provide you with customer contact information (phone, email, delivery address), we act as a data processor. You become an independent data controller for that customer data and are responsible for compliance with privacy laws regarding your use of it. See Section 3.2 for your responsibilities.

4.1a Content upload and management

We process content upload metadata to:

  • Track who uploaded or modified content
  • Maintain version history and audit trails
  • Enable content management and organization
  • Provide attribution for uploaded content
  • Comply with legal obligations regarding content ownership and responsibility

Legal bases:

  • Performance of a contract (Art. 6(1)(b) GDPR) – to provide content management features
  • Our legitimate interests (Art. 6(1)(f) GDPR) – to maintain system integrity and accountability
  • Compliance with legal obligations (Art. 6(1)(c) GDPR) – to respond to legal requests

4.1b Copyright infringement prevention and enforcement

We process personal data related to copyright infringement claims to:

  • Receive and evaluate copyright infringement notices and counter-notifications
  • Identify and remove content that infringes third-party intellectual property rights
  • Communicate with rights holders, users, and their representatives
  • Enforce our Terms of Service and repeat infringer policy
  • Maintain records of infringement claims and actions taken
  • Defend against false or abusive infringement claims
  • Comply with intellectual property laws and legal obligations
  • Protect the legitimate interests of copyright owners and the integrity of our platform

Legal bases:

  • Compliance with legal obligations (Art. 6(1)(c) GDPR) – to respond to valid legal notices and comply with intellectual property laws
  • Our legitimate interests (Art. 6(1)(f) GDPR) – to prevent abuse, protect intellectual property rights, enforce our Terms of Service, and maintain the integrity of our platform
  • Establishment, exercise or defence of legal claims – where processing is necessary for potential or ongoing legal proceedings

Important: When we receive a valid copyright infringement notice, we may:

  • Remove or disable access to the allegedly infringing content
  • Notify the user who uploaded the content
  • Share relevant parts of the infringement notice with the user (excluding personal details not required by law)
  • Maintain records of the incident for enforcement of our repeat infringer policy
  • Suspend or terminate accounts of repeat infringers

Your rights: If your content was removed due to a copyright claim you believe was made in error, you may submit a counter-notification as described in our Terms of Service. We will process your counter-notification and may restore the content if the original complainant does not initiate legal proceedings.

4.2 Geolocation

We use geolocation to:

  • Show you relevant venues or the correct menu for your location
  • Associate your order with the correct venue (and in some cases table)
  • Prevent fraud and misuse (for example, abnormal locations or automated requests)

Legal bases:

  • Your consent to precise location (Art. 6(1)(a) GDPR) – when you allow the browser/app to access your location
  • Our legitimate interests (Art. 6(1)(f) GDPR) in using approximate IP-based location where permitted

You can disable geolocation in your device or browser settings at any time. This does not affect processing carried out before such change but may limit some features.

4.3 Photos and caricatures

We process photos and caricatures to:

  • Create a caricature from your photograph using our algorithms or third-party tools
  • Display the caricature in your account and, where configured by a venue, to staff (for example, for a more personalized experience)

Legal basis:

  • Your consent (Art. 6(1)(a) GDPR) – you choose whether to provide a photo

You can remove your photos and caricatures via your account or via the data deletion page, or by contacting us.

4.3a Push notifications

If you enable push notifications, we use them to:

  • Send you timely updates about your orders (for example, "Your order is ready")
  • Notify you about your table reservations (for example, reminders, confirmation)
  • Send important service announcements and updates
  • Provide personalized offers from venues you have visited (only if you separately consent to marketing communications)

Legal bases:

  • Your consent (Art. 6(1)(a) GDPR) – you enable push notifications in your device settings
  • Performance of a contract (Art. 6(1)(b) GDPR) – for transactional notifications related to your orders and reservations
  • Our legitimate interests (Art. 6(1)(f) GDPR) – for important service updates

You can disable push notifications at any time in your device settings. This will not affect other features of the Service.

4.4 Order history and venue interaction history

We keep history of your orders and interactions with venues to:

  • Help you see previous orders and re-order faster
  • Enable venues to understand your previous interactions with them (for example, to resolve disputes, remember preferences where allowed by law)
  • Comply with accounting, tax and consumer protection obligations
  • Protect our rights and the rights of venues and users in case of disputes

Legal bases:

  • Performance of a contract (Art. 6(1)(b) GDPR)
  • Compliance with legal obligations (Art. 6(1)(c) GDPR)
  • Our legitimate interests in service quality and dispute resolution (Art. 6(1)(f) GDPR)

4.5 Device and technical data

We use device and technical data to:

  • Ensure that the Service displays correctly on your device
  • Remember basic settings to make repeat orders more convenient (for example, language or interface layout)
  • Maintain the security and stability of the platform
  • Diagnose and fix technical problems

Legal basis:

  • Our legitimate interests (Art. 6(1)(f) GDPR) – to provide a secure, stable and convenient Service

4.5a Error monitoring and crash reporting

We use error monitoring (Sentry) to:

  • Detect and diagnose technical errors and crashes
  • Identify the root cause of problems
  • Prioritize bug fixes based on impact
  • Monitor the health and stability of the Service
  • Improve user experience by preventing recurring issues

When an error occurs, we collect diagnostic data as described in Section 3.8. This helps us quickly identify and resolve issues.

Legal basis:

  • Our legitimate interests (Art. 6(1)(f) GDPR) – to maintain a stable, reliable Service and quickly resolve technical problems
  • Your consent (Art. 6(1)(a) GDPR) – for session replay features, where enabled

4.6 Technologies used by the Admin Panel

The Admin Panel is a B2B tool and uses only essential technologies. We do NOT use:

  • ❌ Google Analytics
  • ❌ Firebase Analytics
  • ❌ Meta Pixel / Facebook tracking
  • ❌ Google Tag Manager
  • ❌ Any advertising or marketing cookies
  • ❌ Any behavioral tracking or profiling

What we DO use:

AWS Cognito (Authentication)

  • Purpose: User authentication and identity management
  • Data collected: User credentials, authentication tokens, email address, user profile information
  • Storage: Tokens stored in browser localStorage
  • Location: AWS US East (N. Virginia)
  • Legal basis: Performance of contract (Art. 6(1)(b) GDPR) - essential for providing the Service
  • Privacy Policy: https://aws.amazon.com/privacy/

Sentry (Error Monitoring)

  • Purpose: Error detection, diagnostics, and service reliability monitoring
  • Data collected: Error messages, stack traces, browser/device info (anonymized), user actions leading to errors
  • Data anonymization: All personal identifiers are removed before sending data to Sentry
  • Location: EU (Germany region)
  • Retention: 90 days
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) - maintaining service quality and fixing bugs
  • Privacy Policy: https://sentry.io/privacy/

AWS CloudFront (Content Delivery)

  • Purpose: Fast delivery of static assets (images, menu files)
  • Data collected: IP address, request logs (for technical operation only)
  • Location: Global CDN with edge locations worldwide
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) - essential for service performance
  • Privacy Policy: https://aws.amazon.com/privacy/

AWS S3 (Data Storage)

  • Purpose: Storing your restaurant data, menus, images, and account information
  • Locations:
    • EU Central (Frankfurt) - customer-facing menu data (cdn.meni bucket)
    • US East (N. Virginia) - user account data (data.meni bucket)
  • Legal basis: Performance of contract (Art. 6(1)(b) GDPR)
  • Privacy Policy: https://aws.amazon.com/privacy/

Important notes:

  • We do not track your behavior for advertising or marketing
  • We do not sell or share your data with third parties for their own purposes
  • All cookies we use are strictly necessary for the Service to function
  • No cookie consent banner is required (ePrivacy Directive exemption for essential cookies)

5. No use of data for advertising and no sale of data

We do not:

  • Use your personal data from the Admin Panel to show you third-party advertising
  • Sell or rent your personal data
  • Share your data with third parties so that they can use it for their own marketing or advertising
  • Track your behavior across other websites or applications
  • Build advertising profiles or use your data for targeted marketing

The Admin Panel is a B2B tool focused solely on providing restaurant management functionality. No behavioral analytics are collected.

6. Sharing of your personal data

As a general rule, personal data is processed within our platform and infrastructure. We do not share your personal data with third parties for their own independent purposes, except in the following limited cases:

External Hosting and Cloud Services

6.1 Amazon Web Services (AWS)

Our Service and web application are hosted by Amazon Web Services (AWS).

Provider: Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg

The (personal) data collected on this Service is stored on the servers of AWS, located in the eu-central-1 (Frankfurt, Germany) region. This may include:

  • IP addresses
  • Contact data
  • Contract data
  • Website access data
  • Date and time of requests
  • Time zone difference to Greenwich Mean Time
  • Content of requests
  • HTTP status codes
  • Transmitted data volumes
  • Websites from which requests originate
  • Information about browsers and operating systems
  • And other data generated via the Service

The use of AWS is for the purpose of contract performance with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR).

AWS acts as our data processor and will only process your data to the extent necessary to fulfill service obligations and will follow our instructions regarding this data. We have concluded a Data Processing Agreement with AWS.

Privacy Policy: https://aws.amazon.com/privacy/

6.2 AWS CloudFront (CDN)

We use AWS CloudFront as our Content Delivery Network (CDN) to ensure fast and reliable delivery of content (images, graphics, JavaScript, CSS, PDF files, and similar) globally and to ensure full functionality of our Service.

In this connection, your browser may transmit personal data (such as your IP address) to CloudFront to provide the service. Data processing may also take place in the USA.

CloudFront is certified under the EU-US Data Privacy Framework, ensuring GDPR-compliant processing of personal data of EU citizens within the USA.

We have concluded a Data Processing Agreement with AWS. This contract obligates CloudFront to protect the data of our users, process it in accordance with data protection provisions on our behalf, and in particular not to pass it on to third parties.

The use of this service is based on our legitimate interest in enabling simple and appealing use of our online offering (Art. 6(1)(f) GDPR).

Privacy Policy: https://aws.amazon.com/privacy/

6.3 Cloudflare R2 Storage

We use the Cloudflare R2 Storage service (operated by Cloudflare Inc., 101 Townsend St, 94107 San Francisco, USA) to load and deliver our content (such as images, graphics, JS, CSS, PDF files, and similar) and to ensure the full functionality of our Service.

In this context, your browser may transmit personal data (such as your IP address) to Cloudflare to provide the service. Data processing may also take place in the USA.

Cloudflare Inc. is certified under the EU-US Data Privacy Framework, ensuring GDPR-compliant processing of personal data of EU citizens within the USA.

We have concluded a Data Processing Agreement with Cloudflare. This contract obligates Cloudflare to protect the data of our users, process it in accordance with data protection provisions on our behalf, and in particular not to pass it on to third parties.

Cloudflare may also use a CDN (Content Delivery Network). A CDN is a network of high-performance servers that cache content at various locations around the world. A CDN has two tasks: to provide content in the shortest possible time and to relieve the web host by distributing data traffic.

The use of this service is based on our legitimate interest in enabling simple and appealing use of our online offering (Art. 6(1)(f) GDPR).

Privacy Policy: https://www.cloudflare.com/privacypolicy/

6.4 MongoDB Atlas

We use MongoDB Atlas (operated by MongoDB Inc., 1633 Broadway, 38th Floor, New York, NY 10019, USA) as our central database.

Through MongoDB, the following personal data is processed:

  • Name
  • Address
  • Tax number
  • VAT identification number
  • Bank connection details
  • Order and transaction data
  • User preferences and settings

The legal basis for using MongoDB is our legitimate interest pursuant to Art. 6(1)(f) GDPR. Our legitimate interest lies in the technically error-free and optimized provision of our services.

MongoDB is certified under the EU-US Data Privacy Framework, ensuring GDPR-compliant processing of personal data of EU citizens within the USA.

We have concluded a Data Processing Agreement with MongoDB.

Privacy Policy: https://www.mongodb.com/legal/privacy-policy

6.4a Redis Enterprise Cloud (if applicable)

For caching HTML content and use as a session store, we may use Redis Enterprise Cloud from Redis, Inc., 303 2nd St., Suite 525, San Francisco, CA 94107, USA ("Redis").

Your personal data (e.g., your IP address) may be processed on Redis servers in the USA.

Data processing and/or data transfer therefore also takes place outside the European Union. Only certain countries have an adequacy decision from the European Commission. For the USA, the EU-US Data Privacy Framework (DPF) exists, but not every data transfer to the USA is considered safe—only transfers to US companies with valid DPF certification.

As Redis does not have such certification, we have ensured adequate protection through:

  • Data Processing Addendum using EU Standard Contractual Clauses (Art. 46 GDPR)
  • Transfer Impact Assessment to ensure compliance with EU requirements

The use of Redis Enterprise Cloud allows us to improve the loading times of our Service and ensure efficient and user-friendly session management.

The legal basis for using this service is Art. 6(1)(f) GDPR. Our legitimate interest lies in optimizing our web services and ensuring high user-friendliness.

Privacy Policy: https://redis.io/legal/privacy-policy/

EU Standard Contractual Clauses: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj

Error monitoring and crash reporting

We use Sentry (Functional Software, Inc.) to monitor application errors and crashes as described in Section 4.6. Sentry acts as our data processor for error monitoring purposes. You can learn more about Sentry's privacy practices at https://sentry.io/privacy/

Payment service providers

6.5 Stripe

We have engaged the payment service provider Stripe (Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland) to process our payment transactions through a Connected Custom Stripe Account.

For this purpose, Stripe receives the information provided to us during the booking and onboarding process, along with information about your booking/order:

  • Name
  • Address
  • Account number
  • Bank code
  • Credit card number (if applicable)
  • Invoice amount
  • Currency
  • Transaction number

This data is transmitted pursuant to Art. 6(1)(b) GDPR exclusively for the purpose of payment processing with Stripe Payments Europe Ltd. and only to the extent necessary.

Stripe may use subprocessors for payment processing. We have concluded a Data Processing Agreement with Stripe.

Privacy Policy: https://stripe.com/privacy

Marketing and Customer Relationship Management

6.6 HubSpot CRM

We use the CRM (Customer Relationship Management) system from HubSpot (operated by HubSpot, Inc., 25 1st St Ste 200, Cambridge, MA 02141 USA) to manage various aspects of our online marketing.

This includes:

  • Contact management
  • Customer communication
  • Reporting and analytics
  • Marketing automation (if applicable)

The following personal data may be processed through HubSpot:

  • Customer names
  • Addresses
  • Email addresses
  • Phone numbers
  • IP addresses
  • Company information
  • Interaction history

Data is stored on HubSpot servers, which may be located in the USA and other countries.

The use of this service is based on your consent (Art. 6(1)(a) GDPR) where obtained, or on our legitimate interest in optimizing our business and website (Art. 6(1)(f) GDPR).

HubSpot is certified under the EU-US Data Privacy Framework.

Privacy Policy: https://legal.hubspot.com/privacy-policy

Email Communication Services

6.7 Mailgun

Our email communication is conducted using the email sending platform "Mailgun" (operated by Mailgun Technologies, Inc., 112 E Pecan St #1135, San Antonio, TX 78205, USA).

Your email address and other entered data are processed on Mailgun servers in the USA.

Data processing and/or data transfer therefore also takes place outside the European Union. While the USA has an adequacy decision (EU-US Data Privacy Framework), not every data transfer to the USA is considered safe—only transfers to US companies or organizations that have a valid DPF certification.

As Mailgun does not currently have such certification, we have entered into a Data Processing Addendum using EU Standard Contractual Clauses (Art. 46 GDPR) to ensure that personal data is adequately protected at the recipient.

Mailgun uses the information mentioned above to send and evaluate emails on our behalf. Additionally, Mailgun may use this data to optimize or improve its own services, such as technical optimization of sending and displaying emails. Mailgun does not use the data of our email recipients to contact them directly.

The use of Mailgun is based on your consent (Art. 6(1)(a) GDPR) where obtained for email communications.

Privacy Policy: https://www.mailgun.com/legal/privacy-policy/

EU Standard Contractual Clauses: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj

Security and Anti-Spam Services

6.8 Google reCAPTCHA

This Service uses the reCAPTCHA service from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

The function serves to distinguish whether an entry is made by a human or abusively by automated, machine processing. The query includes sending the IP address and possibly other data required by Google for the reCAPTCHA service to Google.

For this purpose, your input is transmitted to Google and used there. However, your IP address will be shortened by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of reCAPTCHA will not be merged with other data from Google.

The processing thus serves to prevent abuse of this Service and ultimately takes place anonymously.

The use of reCAPTCHA is based on our legitimate interests (Art. 6(1)(f) GDPR) to prevent abuse and maintain service security.

Privacy Policy: https://policies.google.com/privacy

Copyright holders and intellectual property rights holders

When we receive a valid copyright infringement notice or other intellectual property complaint, we may share relevant information with:

  • The rights holder or their authorized representative – to process the claim and communicate about the resolution
  • The user who uploaded the content – to notify them of the claim and provide an opportunity to respond
  • Legal advisers and authorities – where required for legal proceedings or compliance

Information shared may include:

  • User account information (name, email, restaurant name)
  • Content upload metadata (who uploaded, when, what content)
  • Communication history related to the infringement claim
  • Evidence and documentation related to the claim

Legal bases:

  • Compliance with legal obligations (Art. 6(1)(c) GDPR) – to comply with intellectual property laws
  • Our legitimate interests (Art. 6(1)(f) GDPR) – to protect intellectual property rights and enforce our Terms of Service
  • Establishment, exercise or defence of legal claims

We limit disclosure to what is necessary and maintain confidentiality where appropriate.

Service providers and professional advisers

We may share data with IT service providers, security providers, auditors, accountants and legal advisers where this is necessary and subject to confidentiality obligations.

Authorities and legal obligations

We may disclose personal data if required to do so by law, court order or a competent authority, or to protect our rights or the rights of other persons (for example, in case of fraud, abuse or disputes).

In all such cases, we limit access to what is necessary and, where required, conclude data processing agreements or other appropriate safeguards.

7. International data transfers and storage location

We primarily store and process your data on servers located in:

Frankfurt, Germany (AWS region eu-central-1)

This means your data is stored within the European Economic Area (EEA).

Some of our service providers may process data in other countries, including outside the EEA (for example, AWS services in US East Virginia for authentication). Where such transfers occur, we rely on appropriate safeguards under the GDPR, such as:

  • Adequacy decisions of the European Commission, and/or
  • Standard Contractual Clauses (SCCs) approved by the European Commission, possibly combined with additional technical and organisational measures

More information about these safeguards is available on request.

8. Data retention

As a rule, we do not keep your personal data longer than necessary for the purposes described in this Policy or as required by law.

We follow the general principle that:

Files, documents, activities and related personal data are stored for up to 5 (five) years.

In practice, this means:

Account and profile data

We store your account data (including restaurant information and staff accounts) while your account is active and for up to 5 years after your last significant interaction with the Service, unless you request earlier deletion and we are not legally required to keep certain data.

Content upload metadata

We store content upload metadata (who uploaded what and when) for as long as the content remains in the system, plus up to 5 years after content deletion, to maintain audit trails and comply with legal obligations.

Copyright infringement records

Copyright infringement records (notices, counter-notifications, correspondence, and records of violations) are retained for:

  • Active cases: Until the matter is resolved or legal proceedings are concluded
  • Resolved cases: Up to 5 years from the date of resolution
  • Repeat infringer records: Up to 5 years from the last violation

We may retain copyright infringement records longer if:

  • Required by law or legal obligation
  • Necessary for ongoing or potential legal proceedings
  • Necessary to establish, exercise, or defend legal claims
  • Required by court order or competent authority

After the retention period expires, we will delete or anonymize the records, unless continued retention is legally required.

Order and transaction data

We store order data and transaction history processed through your restaurant's Admin Panel for up to 5 years, taking into account accounting, tax, consumer protection and limitation periods. After this period, data will be deleted or anonymized.

Photos and caricatures

We store your photos and caricatures while your account is active or until you delete them via your account or the data deletion page. In any case, we do not store them longer than 5 years from the time of your last relevant interaction, unless longer retention is required by law or necessary for the establishment, exercise or defence of legal claims.

Technical logs and device data

Technical logs, device data and push notification tokens used for security and diagnostics are stored only as long as reasonably necessary, but not longer than 5 years, unless a specific log is needed longer for security or legal reasons.

Push notification tokens are deleted when you disable notifications or delete your account.

In detail, the following retention periods apply:

  • Tax-related data: 10 years from the end of the calendar year in which the data was created
  • Commercial correspondence and documents: 6 years from the end of the calendar year in which the correspondence was received/sent
  • Transaction and registration data: 10 years from the end of the calendar year in which the transaction occurred
  • Data protection consents: For the duration in which you may assert rights
  • Technical usage data (logs): Maximum 30 days, unless required for security incident investigation

After the relevant retention period expires, we will either delete the data or irreversibly anonymise it so that it can no longer be linked to you.

9. Your rights under GDPR

Under the GDPR, you have the following rights regarding your personal data:

Right of access

You have the right to obtain confirmation as to whether we process your personal data and, if so, to receive a copy of that data.

Right to rectification

You have the right to have inaccurate personal data corrected and incomplete data completed.

Right to erasure ("right to be forgotten")

You have the right to request deletion of your personal data, subject to our legal obligations (for example, to keep certain transaction data for accounting or tax purposes).

Important limitations for Admin Panel users:

We may retain certain data even after you request deletion if:

  • Legal obligations: Tax, accounting, and commercial record-keeping laws require us to retain transaction and business data for specified periods (typically 5-10 years)
  • Copyright infringement records: If your account has been involved in copyright infringement claims, we must retain records of violations for up to 5 years to enforce our repeat infringer policy and comply with intellectual property laws
  • Ongoing legal proceedings: Data related to active disputes, claims, or legal proceedings must be retained until resolution
  • Content upload metadata: We may retain metadata about uploaded content (who uploaded what and when) for audit and accountability purposes, even after content deletion
  • Security and fraud prevention: Data necessary to prevent fraud, abuse, or security incidents may be retained

When we retain data after deletion requests, we will:

  • Limit retention to what is legally required or necessary
  • Restrict access to the retained data
  • Delete or anonymize the data once the retention period expires
  • Inform you of the reasons for retention and the expected retention period

Right to restriction of processing

You can request that we restrict processing in certain circumstances (for example, when the accuracy of data is contested).

Right to data portability

You have the right to receive certain personal data in a structured, commonly used and machine-readable format and to transmit it to another controller, where processing is based on consent or contract and carried out by automated means.

Right to object

You can object to processing based on our legitimate interests. We will stop such processing unless we demonstrate compelling legitimate grounds or the processing is necessary for legal claims.

Right to withdraw consent

Where processing is based on your consent (for example, analytics, geolocation, photos), you may withdraw your consent at any time. This does not affect the lawfulness of processing before withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with your local data protection authority if you believe that your rights have been violated.

To exercise your rights, please contact us at info@meni.ge or use the self-service tools described below. We may need to verify your identity before responding.

10. Data deletion page and self-service controls

We provide a dedicated "Delete my data" function:

You can request deletion of your personal data on the following page:
https://meni.ge/privacy/delete

Through this page and/or your account settings, you can:

  • Request deletion of your account and profile data
  • Delete photos and caricatures (where available in the interface)
  • Request deletion of your order and communication history, where this is not in conflict with our legal obligations
  • Withdraw consents for analytics and/or geolocation (where these settings are available)

We will process your request without undue delay and within the time limits required by GDPR. Please note that we may need to retain some data if required by law (for example, for tax and accounting purposes) or where necessary for the establishment, exercise or defence of legal claims.

10a. Automated decision-making and profiling

We do not use your personal data for automated decision-making (including profiling) that produces legal effects concerning you or similarly significantly affects you within the meaning of GDPR Article 22.

We may use analytics and aggregated data to understand usage patterns and improve the Service, but these activities do not constitute automated decision-making under Article 22. You are not subject to decisions based solely on automated processing.

11. Security

We take appropriate technical and organisational measures to protect your personal data, including:

  • Encryption of data in transit (for example, HTTPS/TLS)
  • Access controls and authentication for systems and personnel
  • Regular software updates and security monitoring
  • Backups and disaster recovery procedures
  • Internal policies and training to ensure confidentiality and integrity of data

However, no system can be completely secure. If we become aware of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority where required by law.

11a. Sessions and Cookies

To operate the Service, we use cookies and server-side sessions in which data can be stored.

11a.1 Necessary cookies and sessions

We ensure that without your express consent, no personal data is taken from sessions or through cookies, and cookies are only used where technically required for the website to function (for example, spam protection in contact forms, shopping cart functionality).

The use of these technically necessary cookies is based on our legitimate interests (Art. 6(1)(f) GDPR) in providing a functioning, secure Service. Our legitimate interests do not override your interests or fundamental rights.

11a.2 Optional cookies with consent

With your express consent, we use cookies to:

  • Personalize content and features
  • Provide social media functions
  • Analyze usage of our Service

Where we use analytics cookies or similar technologies, we obtain your consent (Art. 6(1)(a) GDPR) through our cookie consent banner. You can withdraw your consent at any time through your browser settings or our cookie management interface.

The Admin Application uses only essential cookies for authentication and security. We use AWS Cognito for authentication (tokens stored in browser localStorage), Sentry for error monitoring, and AWS CloudFront CDN for content delivery. No advertising or analytics cookies are used.

With your consent, the information about your use of our Service may be shared with our partners for social media, advertising, and analytics. Our partners may combine this information with other data they have collected from you.

12. Children's privacy

The Customer Application is not intended for children under 16 years of age.

We do not knowingly collect personal data from children under 16 without verifiable parental or guardian consent, where required by law. If you believe that a child has provided us with personal data in violation of this Policy, please contact us and we will take appropriate steps to delete such data.

12a. Newsletter (if applicable)

If you subscribe to our newsletter, we use the data you provide (email address and any other information you voluntarily provide) to send you regular email newsletters based on your consent pursuant to Art. 6(1)(a) GDPR.

You can unsubscribe from the newsletter at any time by:

  • Sending a message to us via the contact details provided in the imprint/contact section, or
  • Using the unsubscribe link provided in each newsletter

After unsubscription, we will delete your email address unless you have expressly consented to further use of your data or we reserve the right to use data beyond this scope, which is permitted by law and about which we inform you in this Policy.

11b. Social Media Presence

We maintain a presence on the following social media platforms for business representation and communication:

Facebook / Meta

Operator: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland

Privacy Policy: https://www.facebook.com/about/privacy/

Opt-Out: https://www.youronlinechoices.com

These social media platforms may process personal data outside the EU. We refer to the privacy policies of the respective social media platforms linked above.

The respective social media platforms may create usage profiles from your usage behavior and the resulting interests and actions on your part, and may store cookies on your computer in which your usage behavior is stored.

If you have an account on the respective social media platform and are logged in, your usage behavior can even be stored across devices. Your usage profile can be used to place advertisements that presumably correspond to your interests.

We process personal data exclusively for communication with you via the social media platform you have chosen and to optimize our online presence. We ensure that no interests on your part are affected that outweigh this legitimate interest on our part (Art. 6(1)(f) GDPR).

If you have already given the respective social media platform operator effective consent for the corresponding data processing, the processing of your personal data is also based on this consent (Art. 6(1)(a) GDPR).

Your rights regarding social media data

You can exercise your data protection rights (access, rectification, deletion, restriction, data portability, objection) with respect to data processed by social media platforms by contacting the respective platform operator directly.

If you have concerns about how social media platforms process your data, you can also contact the relevant data protection supervisory authority.

11c. Storage of Guest Preferences

As part of our Service, we store certain preferences and choices of guests to enable a personalized user experience and to optimize food selection.

The stored information includes, among other things:

  • Frequency of orders
  • Preferred dishes and menu items
  • Individual settings within the application
  • Previous interactions with venues
  • Dietary preferences and restrictions (if you provided them)

The processing of this data is based on our legitimate interest in improving our offering and providing a service tailored to individual needs (Art. 6(1)(f) GDPR).

You can view, modify, or delete your preferences at any time through your account settings or by contacting us at info@meni.ge.

11d. Social Media Links

We have social media pages accessible through links on this Service. By using these links, you will reach the respective third-party websites (e.g., Facebook).

To avoid unnecessary data sharing, we recommend logging out of the respective third-party service before using such a link. This prevents the third-party service from potentially creating usage profiles just by using the link.

When you click on social media links:

  • You are redirected to external third-party platforms
  • Those platforms may collect data about you according to their own privacy policies
  • We have no control over the data processing by these third parties
  • You should review the privacy policies of those platforms before using them

We are not responsible for the privacy practices of third-party social media platforms. Their data collection and use is governed by their own privacy policies, not this Privacy Policy.

13. Changes to this Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

  • Update the "Last updated" date at the top of the Policy, and
  • Provide additional notice within the Service where appropriate (for example, a notification in the app or on the website).

We encourage you to review this Policy periodically to stay informed about how we process your personal data.

14. Country-specific provisions

14.1 For users in the United States of America

If you are a resident of the United States, the following additional provisions apply to you:

14.1.1 State privacy laws (California, Virginia, Colorado, Connecticut, Utah and other states)

Several US states have enacted comprehensive privacy laws that grant residents additional rights regarding their personal information. If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or another state with similar privacy legislation, you may have the following rights in addition to those described in this Policy:

Right to know / access: You may request details about the categories and specific pieces of personal information we collect, use, disclose, and sell (if applicable).

Right to delete: You may request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, fraud prevention, security purposes).

Right to correct: You may request correction of inaccurate personal information we maintain about you.

Right to opt-out of sale or sharing: We do not sell or share your personal information for cross-context behavioral advertising or targeted advertising purposes. Therefore, we do not offer an "opt-out of sale" link, as there is no sale or sharing to opt out of.

Right to limit use of sensitive personal information: To the extent we collect sensitive personal information (such as precise geolocation or photos, which may include biometric data if used to identify you), we only use it for purposes disclosed in this Policy and as permitted by applicable law. You can manage geolocation and photo permissions in your device settings or via the Service.

Right to non-discrimination: We will not discriminate against you for exercising any of your privacy rights.

Authorized agent: You may designate an authorized agent to make requests on your behalf. We may require verification of both your and the agent's identity and written authorization.

Appeal rights: If we deny your privacy request, you may appeal our decision by contacting us at info@meni.ge.

14.1.2 Categories of personal information collected and disclosed

In the preceding 12 months, we have collected and disclosed the following categories of personal information as described in section 3 of this Policy:

  • Identifiers (email, phone number, name, business name, device identifiers, IP address, session tokens)
  • Business information (restaurant name, business contact details, staff roles)
  • Commercial information (transaction records, order history processed through your restaurant account)
  • Internet or network activity (usage data, device and technical information, error logs, session data)
  • Professional information (job title, role within the establishment)
  • Content and files (menu items, photos, descriptions uploaded to the Admin Panel)
  • Content metadata (upload timestamps, user identifiers, file information, modification history)
  • Copyright and intellectual property records (infringement notices, counter-notifications, violation records, correspondence with rights holders)
  • Customer contact information (phone numbers, email addresses, delivery addresses that customers provide for orders)
  • Inferences drawn from usage patterns to improve the Service

We disclose these categories to the third parties described in section 6 for the business purposes described in section 4. We do not sell your personal information.

We may share copyright infringement records with rights holders, legal advisers, and authorities as necessary to comply with intellectual property laws and enforce our Terms of Service.

Important: When we provide you with customer contact information, you become an independent data controller for that data. You are responsible for compliance with privacy laws regarding your use and storage of customer information.

14.1.3 Children's privacy under COPPA

The Customer Application is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at info@meni.ge and we will promptly delete such information.

14.1.4 Do Not Track signals

The Admin Panel does not use tracking or analytics cookies. We use only essential cookies for authentication and security, which are strictly necessary for the Service to function. DNT signals do not apply to essential cookies required for service provision.

14.1.5 Retention periods for US residents

We apply the same retention periods described in section 8 to all users, including US residents. Personal information is retained for up to 5 years or as required by applicable law.

14.1.6 Exercising your US privacy rights

To exercise any of the rights described above, please:

We will respond to your request within the time period required by applicable state law (typically 45 days, with a possible extension).

We may need to verify your identity before processing your request. We may ask for additional information to match against our records. We will not use information provided for verification for any other purpose.

14.2 For users in the Russian Federation

If you are a resident of the Russian Federation, the following additional provisions apply to you in accordance with Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006:

14.2.1 Legal basis for processing under Russian law

We process your personal data based on:

  • Your consent (Article 6 of Federal Law No. 152-FZ) – when you register, grant permissions for geolocation, upload photos, or agree to analytics
  • Performance of a contract (Article 6 of Federal Law No. 152-FZ) – to provide the Service and process your orders
  • Legitimate interests – to ensure security, prevent fraud, improve the Service, and comply with legal obligations

14.2.2 Cross-border transfer of personal data

Your personal data is primarily stored on servers located in Frankfurt, Germany (AWS region eu-central-1), which constitutes a cross-border transfer of personal data from the Russian Federation.

By using the Service, you consent to the cross-border transfer of your personal data to Germany and other countries where our service providers operate.

We ensure that recipients of your personal data provide adequate protection in accordance with Russian law and international standards. You may withdraw your consent to cross-border transfer at any time by ceasing to use the Service and requesting deletion of your data.

14.2.3 Your rights under Russian law

Under Federal Law No. 152-FZ, you have the following rights:

Right to information: You have the right to obtain confirmation of whether we process your personal data, and to receive information about the processing.

Right to access: You may obtain a copy of your personal data that we process.

Right to rectification: You may request correction of inaccurate or incomplete personal data.

Right to withdraw consent: You may withdraw your consent to processing at any time. This does not affect the lawfulness of processing based on consent before its withdrawal, and does not affect processing based on other legal grounds.

Right to deletion (blocking): You may request deletion or blocking of your personal data if:

  • The data is processed unlawfully
  • The purpose of processing has been achieved
  • You withdraw consent and there is no other legal basis for processing
  • Your personal data was collected in violation of the law

We may refuse deletion if we have a legal obligation to retain the data or if retention is necessary for the establishment, exercise or defence of legal claims.

Right to object: You may object to processing if you believe it violates your rights or is carried out for unlawful purposes.

Right to lodge a complaint: You have the right to lodge a complaint with Roskomnadzor (Federal Service for Supervision of Communications, Information Technology and Mass Media) if you believe your rights have been violated.

14.2.4 Biometric personal data

To the extent that photos and caricatures may constitute biometric personal data under Russian law, we process them only with your explicit consent and for the purposes specified in this Policy. You can delete your photos and caricatures at any time via your account settings or the data deletion page at https://meni.ge/privacy/delete.

14.2.5 Personal data of minors

If you are under 18 years of age, you may use the Service only with the consent of your parent or legal guardian. We do not knowingly collect personal data from persons under 18 without such consent. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at info@meni.ge.

14.2.6 Data localization

Please note that Russian law may require certain categories of personal data to be stored on servers located within the territory of the Russian Federation. As an Individual Entrepreneur registered in Georgia, we currently store data on servers in Germany. If you have concerns about this or if you believe specific data localization requirements apply to you, please contact us at info@meni.ge.

14.2.7 Exercising your rights under Russian law

To exercise any of the rights described above, please:

We will respond to your request within the time period required by Russian law (typically within 30 days from the date of receipt of your request, with a possible extension of 30 days in complex cases).

14.2.8 Contact details for Roskomnadzor

If you believe your rights under Russian personal data law have been violated, you may lodge a complaint with:

Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor)
Address: 7 Kitaygorodsky Proezd, Moscow, 109074, Russian Federation
Website: https://rkn.gov.ru
Hotline: 8-800-707-77-66

14.3 For users in the European Union and European Economic Area

If you are a resident of the European Union (EU) or European Economic Area (EEA), this Privacy Policy is primarily designed to comply with the EU General Data Protection Regulation (GDPR). The following additional clarifications apply:

14.3.1 GDPR compliance

This entire Privacy Policy is drafted in accordance with the GDPR. Sections 1-13 of this Policy describe:

  • Our identity as data controller and contact details (Section 1)
  • The categories of personal data we collect (Section 3)
  • The purposes and legal bases for processing under GDPR Article 6 (Section 4)
  • How we share data and with whom (Section 6)
  • International data transfers and safeguards (Section 7)
  • Data retention periods (Section 8)
  • Your rights under GDPR Articles 15-22 (Section 9)
  • How to exercise your rights and lodge complaints (Sections 9, 10)

14.3.2 Data storage within the EEA

Your personal data is stored on servers located in Frankfurt, Germany (AWS region eu-central-1), which is within the European Economic Area. This means your data benefits from the protections of the GDPR and remains within the EEA.

Some of our service providers may process data outside the EEA (for example, AWS Cognito in US East Virginia for authentication). Where such transfers occur, we rely on:

  • European Commission adequacy decisions (where available), and/or
  • Standard Contractual Clauses (SCCs) approved by the European Commission, and/or
  • Additional technical and organisational measures to ensure adequate protection

You can request more information about these safeguards by contacting us at info@meni.ge.

14.3.3 Your rights under GDPR (summary)

As an EU/EEA resident, you have the following rights (detailed in Section 9):

  • Right of access (Article 15 GDPR) – obtain confirmation and a copy of your data
  • Right to rectification (Article 16 GDPR) – correct inaccurate data
  • Right to erasure (Article 17 GDPR) – "right to be forgotten"
  • Right to restriction of processing (Article 18 GDPR) – limit processing in certain cases
  • Right to data portability (Article 20 GDPR) – receive data in machine-readable format
  • Right to object (Article 21 GDPR) – object to processing based on legitimate interests
  • Right to withdraw consent (Article 7(3) GDPR) – withdraw consent at any time
  • Right not to be subject to automated decision-making (Article 22 GDPR) – we do not make solely automated decisions with legal or similarly significant effects

14.3.4 Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority in:

  • The EU member state of your habitual residence, or
  • Your place of work, or
  • The place of the alleged infringement

List of EU/EEA supervisory authorities:
You can find your local supervisory authority at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

Examples of supervisory authorities:

  • Germany (where our servers are located):
    Various Bundesländer authorities; for federal matters: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
    Website: https://www.bfdi.bund.de

  • France: Commission Nationale de l'Informatique et des Libertés (CNIL)
    Website: https://www.cnil.fr

  • Ireland (where many tech companies have EU headquarters): Data Protection Commission (DPC)
    Website: https://www.dataprotection.ie

  • Spain: Agencia Española de Protección de Datos (AEPD)
    Website: https://www.aepd.es

  • Italy: Garante per la protezione dei dati personali
    Website: https://www.garanteprivacy.it

14.3.5 EU representative

As a non-EU controller (registered in Georgia), we are not currently required under GDPR Article 27 to appoint an EU representative because we do not offer goods or services to EU data subjects on a large scale or monitor their behaviour on a large scale. However, we process data of EU residents in accordance with the GDPR and store data within the EEA.

If you are an EU/EEA resident and have questions about our data practices, you can contact us directly at info@meni.ge.

14.3.6 Legal basis for processing (GDPR Article 6)

We process your personal data based on the following legal bases under GDPR Article 6(1):

  • (b) Performance of a contract – to provide the Service, process orders, manage your account
  • (a) Consent – for analytics, geolocation (precise location), photos and caricatures
  • (f) Legitimate interests – to ensure security, prevent fraud, improve the Service, for direct marketing where permitted
  • (c) Legal obligation – to comply with accounting, tax and other legal requirements

You can find detailed information about purposes and legal bases in Section 4.

14.3.7 Automated decision-making and profiling

We do not use your personal data for automated decision-making (including profiling) that produces legal effects concerning you or similarly significantly affects you within the meaning of GDPR Article 22.

We may use analytics and aggregated data to understand usage patterns and improve the Service, but these activities do not constitute automated decision-making under Article 22.

14.3.8 Exercising your GDPR rights

To exercise any of your GDPR rights, please:

We will respond to your request without undue delay and in any event within one month of receipt. We may extend this period by two further months where necessary, taking into account the complexity and number of requests.

14.4 For users in the United Kingdom

If you are a resident of the United Kingdom, the following provisions apply to you under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018:

14.4.1 UK GDPR compliance

Following Brexit, the United Kingdom has its own data protection regime based on the UK GDPR. This Privacy Policy complies with both EU GDPR and UK GDPR requirements.

The rights, legal bases, and processing principles described in Sections 1-13 apply equally under UK GDPR.

14.4.2 Data storage and international transfers

Your personal data is stored on servers located in Frankfurt, Germany (AWS region eu-central-1). As the UK is no longer part of the EEA, this constitutes an international transfer from the UK perspective.

The European Commission has adopted an adequacy decision recognizing the UK as providing adequate data protection, and the UK has adopted a similar adequacy regulation for the EEA. These mutual adequacy decisions facilitate data flows between the UK and EEA.

For transfers to countries outside the UK and EEA (such as the United States for analytics services), we use appropriate safeguards such as:

  • Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO)
  • International Data Transfer Agreements (IDTA)
  • Additional technical and organisational measures

14.4.3 Your rights under UK GDPR

As a UK resident, you have the same rights as described in Section 9, including:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object
  • Right to withdraw consent
  • Right not to be subject to automated decision-making

14.4.4 UK supervisory authority

You have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner's Office (ICO)
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
Website: https://ico.org.uk
Helpline: 0303 123 1113

14.4.5 Exercising your UK rights

To exercise your rights under UK GDPR, please contact us at info@meni.ge or use our self-service data deletion page at https://meni.ge/privacy/delete.

We will respond within one month of receipt of your request, with possible extension by two further months in complex cases.

14.5 For users in Canada

If you are a resident of Canada, the following provisions apply to you under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws:

14.5.1 PIPEDA compliance

We process your personal information in accordance with PIPEDA's Fair Information Principles and applicable provincial legislation (such as Alberta's PIPA, British Columbia's PIPA, or Quebec's Law 25).

14.5.2 Consent and purposes

We collect, use and disclose your personal information only for the purposes identified in this Policy and only with your knowledge and consent, except where otherwise required or permitted by law.

Your consent may be express (for example, when you register or upload photos) or implied (for example, when you use the Service to place orders).

You may withdraw your consent at any time by contacting us, subject to legal or contractual restrictions and reasonable notice.

14.5.3 Sensitive personal information

We handle the following sensitive personal information with additional safeguards:

  • Biometric data – photos and facial caricatures
  • Health information – dietary restrictions or allergies

We obtain meaningful consent before collecting sensitive information and use it only for the purposes disclosed.

14.5.4 International transfers

Your personal information is stored on servers in Germany and may be processed by service providers in the United States and other countries. By using the Service, you consent to the transfer of your personal information outside Canada.

We ensure that foreign service providers provide a comparable level of protection through contractual and technical safeguards.

For Quebec residents: We ensure that international transfers comply with Law 25's requirements, including providing information about the country of transfer and implementing appropriate safeguards.

14.5.5 Your rights under PIPEDA and provincial laws

You have the right to:

  • Access your personal information – request access to your personal information in our custody or control
  • Challenge accuracy – request correction of inaccurate or incomplete information
  • Withdraw consent – withdraw consent for processing, subject to legal and contractual restrictions
  • Know how your information is used – understand the purposes for which your information is collected, used and disclosed
  • File a complaint – lodge a complaint with the Office of the Privacy Commissioner of Canada or provincial commissioners

Additional rights for Quebec residents under Law 25:

  • Right to portability – receive certain personal information in a structured, commonly used format
  • Right to de-indexing – request de-indexing of information in certain circumstances

14.5.6 Personal information of minors

We take special care when processing personal information of minors (persons under 18 in most provinces, under 19 in some provinces).

For Quebec residents: In accordance with Law 25, we obtain parental consent before collecting personal information from children aged 14 and under, except in limited circumstances.

14.5.7 Privacy incidents and breach notification

In the event of a privacy breach that poses a real risk of significant harm, we will:

  • Notify the Office of the Privacy Commissioner of Canada
  • Notify affected individuals
  • Keep records of the breach as required by law

For Quebec residents: We will also comply with Law 25's breach notification requirements, including notifying the Commission d'accès à l'information du Québec (CAI).

14.5.8 Retention and safeguards

We retain personal information only as long as necessary for the purposes identified (up to 5 years as described in Section 8) or as required by law.

We protect personal information with security safeguards appropriate to the sensitivity of the information, as described in Section 11.

14.5.9 Privacy Commissioner of Canada

If you believe your privacy rights have been violated, you may file a complaint with:

Office of the Privacy Commissioner of Canada (OPC)
Address: 30 Victoria Street, Gatineau, Quebec, K1A 1H3, Canada
Website: https://www.priv.gc.ca
Toll-free: 1-800-282-1376
Email: info@priv.gc.ca

14.5.10 Provincial Privacy Commissioners

Depending on your province, you may also contact:

Quebec - Commission d'accès à l'information (CAI)
Website: https://www.cai.gouv.qc.ca
Toll-free: 1-888-528-7741

Alberta - Office of the Information and Privacy Commissioner
Website: https://www.oipc.ab.ca
Phone: 1-888-878-4044

British Columbia - Office of the Information and Privacy Commissioner
Website: https://www.oipc.bc.ca
Phone: 1-250-387-5629

14.5.11 Exercising your Canadian rights

To exercise your rights, please contact us at:

Email: info@meni.ge

Subject line: "Privacy Rights Request" or "Demande d'accès aux renseignements personnels"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond within 30 days of receiving your request, as required by PIPEDA. For complex requests, we will notify you if we need additional time.

14.6 For users in Brazil

If you are a resident of Brazil, the following provisions apply to you under Lei Geral de Proteção de Dados (LGPD) – the Brazilian General Data Protection Law:

14.6.1 LGPD compliance

We process your personal data in accordance with LGPD (Law No. 13,709/2018). The principles and practices described in this Policy align with LGPD requirements.

14.6.2 Legal bases for processing under LGPD

We process your personal data based on the following legal bases under LGPD Article 7:

  • Consent (Article 7, I) – when you register, upload photos, or agree to analytics
  • Performance of a contract (Article 7, V) – to provide the Service and process orders
  • Legitimate interests (Article 7, IX) – to ensure security, prevent fraud, improve the Service
  • Legal or regulatory obligation (Article 7, II) – to comply with tax, accounting and consumer protection requirements

14.6.3 International data transfers

Your personal data is transferred and stored on servers located in Germany (Frankfurt). This constitutes an international transfer from Brazil.

We ensure adequate protection for international transfers through:

  • Standard Contractual Clauses
  • Technical and organisational security measures
  • Commitments by recipients to comply with LGPD principles

By using the Service, you consent to this international transfer.

14.6.4 Your rights under LGPD

As a Brazilian data subject, you have the following rights under LGPD Article 18:

  • Confirmation and access – confirm processing and access your personal data
  • Correction – request correction of incomplete, inaccurate or outdated data
  • Anonymization, blocking or deletion – of unnecessary, excessive or unlawfully processed data
  • Portability – receive your data in structured, commonly used format
  • Information about sharing – know with which public and private entities we share your data
  • Information about consent – be informed about the possibility of not providing consent and its consequences
  • Revocation of consent – revoke consent at any time
  • Opposition – oppose processing in certain cases

14.6.5 Children's personal data

We do not knowingly process personal data of children and adolescents under 18 without parental or guardian consent, as required by LGPD and the Brazilian Child and Adolescent Statute (ECA).

14.6.6 Data protection officer

We have not appointed a Data Protection Officer (Encarregado de Proteção de Dados) at this time. For privacy matters, please contact us at info@meni.ge.

14.6.7 National Data Protection Authority (ANPD)

You have the right to lodge a complaint with the Brazilian supervisory authority:

Autoridade Nacional de Proteção de Dados (ANPD)
Website: https://www.gov.br/anpd
Email: comunicacao@anpd.gov.br

14.6.8 Exercising your LGPD rights

To exercise your rights under LGPD, please contact us at info@meni.ge or use our data deletion page at https://meni.ge/privacy/delete.

We will respond to your request within 15 days from receipt, in accordance with LGPD requirements.

14.7 For users in Australia

If you are a resident of Australia, the following provisions apply to you under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs):

14.7.1 Australian Privacy Principles compliance

We handle your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988.

14.7.2 Collection and use of personal information

We collect personal information that is reasonably necessary for our functions and activities (providing the Service). We only collect personal information by lawful and fair means, and with your knowledge and consent where required.

The types of personal information we collect and the purposes for which we use it are described in Sections 3 and 4 of this Policy.

14.7.3 Sensitive information

Photos and caricatures may constitute sensitive information under the Privacy Act. We only collect sensitive information with your consent and where reasonably necessary for our functions.

14.7.4 Disclosure of personal information

We disclose personal information to third parties as described in Section 6. We do not sell or rent personal information.

When we disclose personal information to venue operators (who may be overseas entities), we take reasonable steps to ensure they comply with the APPs or are subject to similar privacy protections.

14.7.5 Overseas disclosure

Your personal information is stored on servers in Germany and may be processed by service providers in the United States and other countries.

By using the Service, you consent to the disclosure of your personal information to overseas recipients. We take reasonable steps to ensure overseas recipients handle personal information in accordance with the APPs.

14.7.6 Your rights under Australian privacy law

You have the right to:

  • Access your personal information – request access to personal information we hold about you
  • Correction – request correction of inaccurate, out-of-date, incomplete, irrelevant or misleading information
  • Complaints – make a complaint about our handling of your personal information

14.7.7 Office of the Australian Information Commissioner

If you are not satisfied with our response to your privacy complaint, you may lodge a complaint with:

Office of the Australian Information Commissioner (OAIC)
Website: https://www.oaic.gov.au
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

14.7.8 Exercising your Australian rights

To access or correct your personal information, or to make a complaint, please contact us at info@meni.ge.

We will respond to access requests within 30 days and to complaints within a reasonable period (typically 30 days).

14.8 For users in Japan

If you are a resident of Japan, the following provisions apply to you under the Act on the Protection of Personal Information (APPI):

14.8.1 APPI compliance

We handle your personal information (個人情報) in accordance with Japan's Act on the Protection of Personal Information (個人情報の保護に関する法律).

14.8.2 Purpose of use

We use your personal information only for the purposes specified in Section 4 of this Policy. We will not use personal information beyond the scope of these purposes without your consent, except as permitted by law.

14.8.3 Cross-border transfer of personal data

Your personal information is transferred to and stored on servers located in Germany. We may also transfer personal information to service providers in the United States and other countries.

We obtain your consent for cross-border transfers by providing this notice and obtaining your agreement when you use the Service. We take necessary measures to ensure that foreign service providers handle personal information appropriately.

14.8.4 Sensitive personal data (要配慮個人情報)

Photos and caricatures may include sensitive personal data under APPI. We obtain your explicit consent before collecting such information and use it only for the purposes disclosed.

14.8.5 Your rights under APPI

Under APPI, you have the right to:

  • Disclosure – request disclosure of personal information we hold about you
  • Correction – request correction, addition or deletion of inaccurate personal information
  • Suspension of use – request suspension of use or deletion of personal information obtained or used unlawfully
  • Suspension of provision to third parties – request suspension of provision to third parties if done unlawfully

We may charge a reasonable fee for disclosure requests as permitted by law.

14.8.6 Personal Information Protection Commission

You have the right to file a complaint with the Japanese supervisory authority:

Personal Information Protection Commission (個人情報保護委員会)
Website: https://www.ppc.go.jp
Phone: 03-6457-9680
Consultation line: 03-6457-9849

14.8.7 Retention period

We retain personal information for the periods described in Section 8 (up to 5 years), unless longer retention is required by Japanese law.

14.8.8 Exercising your Japanese rights

To exercise your rights under APPI, please contact us at info@meni.ge with sufficient details to identify you and your request.

We will respond to your request within a reasonable period in accordance with APPI requirements.

14.9 For users in Switzerland

If you are a resident of Switzerland, the following provisions apply to you under the Swiss Federal Act on Data Protection (FADP / nFADP):

14.9.1 Swiss data protection compliance

We process your personal data in accordance with the revised Swiss Federal Act on Data Protection (nFADP), which entered into force on September 1, 2023.

Switzerland is not part of the EU/EEA but has data protection standards recognized as adequate by the European Commission.

14.9.2 Data storage and transfers

Your personal data is stored on servers in Germany (Frankfurt), which is within the EEA. Switzerland and the EEA have mutual adequacy recognition.

For transfers to countries outside Switzerland and the EEA, we use appropriate safeguards such as Standard Contractual Clauses and additional security measures.

14.9.3 Your rights under Swiss law

As a Swiss resident, you have the following rights:

  • Right of access – obtain confirmation of processing and a copy of your data
  • Right to rectification – request correction of inaccurate data
  • Right to erasure – request deletion of data in certain circumstances
  • Right to data portability – receive data in structured, machine-readable format
  • Right to object – object to processing based on legitimate interests
  • Right to withdraw consent – withdraw consent at any time

14.9.4 Automated decision-making

We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

14.9.5 Federal Data Protection and Information Commissioner

You have the right to lodge a complaint with the Swiss supervisory authority:

Federal Data Protection and Information Commissioner (FDPIC / EDÖB)
Address: Feldeggweg 1, 3003 Bern, Switzerland
Website: https://www.edoeb.admin.ch
Phone: +41 58 462 43 95
Email: info@edoeb.admin.ch

14.9.6 Exercising your Swiss rights

To exercise your rights, please contact us at info@meni.ge or use our data deletion page at https://meni.ge/privacy/delete.

We will respond within 30 days of receiving your request.

14.10 For users in the People's Republic of China

If you are a resident of the People's Republic of China (excluding Hong Kong, Macau and Taiwan), the following provisions apply to you under the Personal Information Protection Law (PIPL):

14.10.1 PIPL compliance

We process your personal information in accordance with the Personal Information Protection Law of the People's Republic of China (中华人民共和国个人信息保护法), which entered into force on November 1, 2021.

14.10.2 Legal bases for processing under PIPL

We process your personal information based on the following legal bases under PIPL Article 13:

  • Consent – when you register, upload photos, grant location permissions, or agree to analytics
  • Performance of a contract – to provide the Service and fulfill our contractual obligations
  • Necessary for履行法定职责或者法定义务 – to comply with legal obligations
  • Responding to public health emergencies or protecting life/health/property – where applicable
  • Legitimate interests – where necessary for our or third parties' legitimate interests and does not have a major impact on your rights

14.10.3 Cross-border transfer of personal information

Your personal information is transferred outside of mainland China to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under PIPL, cross-border transfers require:

  • Notice and consent – we inform you of this transfer through this Policy and obtain your consent when you use the Service
  • Security assessment – we conduct security assessments of cross-border transfers
  • Protective measures – we implement Standard Contractual Clauses and technical/organizational measures to protect your information

By using the Service, you explicitly consent to the cross-border transfer of your personal information.

14.10.4 Sensitive personal information

Photos and facial images constitute sensitive personal information (敏感个人信息) under PIPL. We:

  • Obtain your separate consent before collecting sensitive personal information
  • Inform you of the necessity and impact on your rights
  • Use sensitive personal information only for the specific purposes disclosed
  • Allow you to delete such information at any time

14.10.5 Your rights under PIPL

As a Chinese data subject, you have the following rights under PIPL:

  • Right to know and decide – know how your personal information is processed and make decisions accordingly
  • Right to limit or refuse processing – limit or refuse processing that is unnecessary for providing the Service
  • Right of access – access your personal information
  • Right to correction – request correction of inaccurate or incomplete personal information
  • Right to deletion – request deletion in circumstances specified by law
  • Right to copy – obtain copies of your personal information
  • Right to data portability – transfer your personal information to other entities you designate
  • Right to explanation – request explanation of processing rules when automated decision-making is used
  • Right to withdraw consent – withdraw consent at any time (we do not discriminate against you for withdrawal)

14.10.6 Automated decision-making

We do not use automated decision-making to conduct price discrimination or other behaviors that materially impact your rights. If we use automated decision-making, we will inform you and provide options to refuse.

14.10.7 Personal information of minors

In accordance with PIPL, we obtain consent from parents or guardians before processing personal information of minors under 14 years old. The Service is not intended for children under 14 without parental consent.

For minors aged 14-18, we take special protection measures and limit the scope of processing to what is necessary for the Service.

14.10.8 Personal information protection officer

For privacy matters related to PIPL, please contact us at info@meni.ge. We will designate a person responsible for personal information protection when required by law.

14.10.9 Cyberspace Administration of China

While PIPL does not establish a specific complaint mechanism, you may report violations to:

Cyberspace Administration of China (国家互联网信息办公室)
Website: http://www.cac.gov.cn

Or contact local cyberspace administration authorities.

14.10.10 Exercising your PIPL rights

To exercise your rights under PIPL, please contact us at info@meni.ge or use our data deletion page at https://meni.ge/privacy/delete.

We will respond within 15 days of receiving your request. In cases where we cannot fulfill your request, we will explain the reasons.

14.11 For users in the Republic of Turkey

If you are a resident of the Republic of Turkey, the following provisions apply to you under the Personal Data Protection Law No. 6698 (KVKK):

14.11.1 KVKK compliance

We process your personal data in accordance with the Turkish Personal Data Protection Law (Kişisel Verilerin Korunması Kanunu - KVKK), which entered into force on April 7, 2016.

14.11.2 Legal bases for processing under KVKK

We process your personal data based on the following legal bases under KVKK Article 5:

  • Explicit consent – when you register, upload photos, grant location permissions, or agree to processing of sensitive data
  • Necessary for performance of a contract – to provide the Service, process orders and reservations
  • Compliance with legal obligations – to comply with Turkish tax, accounting and consumer protection requirements
  • Legitimate interests – where processing is mandatory for our legitimate interests, provided that it does not harm your fundamental rights and freedoms

14.11.3 Cross-border transfer of personal data

Your personal data is transferred outside of Turkey to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under KVKK, cross-border transfers require either:

  • An adequacy decision by the Turkish Personal Data Protection Board (Germany is within the EU, which is generally considered adequate), or
  • Your explicit consent and adequate safeguards

By using the Service, you explicitly consent to the cross-border transfer of your personal data. We implement appropriate safeguards including Standard Contractual Clauses and technical/organizational security measures.

14.11.4 Sensitive personal data under KVKK

Under KVKK, the following categories of data we may collect are considered sensitive and require explicit consent:

  • Biometric data – photos and facial caricatures
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive personal data only with your explicit consent and for the specific purposes disclosed in this Policy.

14.11.5 Your rights under KVKK

Under KVKK Article 11, you have the right to:

  • Learn whether your personal data is processed
  • Request information about processing if your data has been processed
  • Learn the purpose of processing and whether data is used for its intended purpose
  • Know third parties to whom your data is transferred domestically or abroad
  • Request correction of incomplete or inaccurate data
  • Request deletion or destruction of your data under conditions set forth in KVKK Article 7
  • Request notification of correction, deletion or destruction to third parties to whom your data was transferred
  • Object to processing that leads to unfavorable results for you
  • Request compensation for damages arising from unlawful processing

14.11.6 Data controller registration

As a data controller, we are registered with the Turkish Data Controllers Registry (Veri Sorumluları Sicil Bilgi Sistemi - VERBİS) as required by KVKK, or will complete registration if required based on the scope of our operations in Turkey.

14.11.7 Personal Data Protection Authority

You have the right to lodge a complaint with the Turkish supervisory authority:

Personal Data Protection Authority (Kişisel Verilerin Korunması Kurumu - KVKK)
Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat-Çankaya/Ankara, Turkey
Website: https://www.kvkk.gov.tr
Email: kvkk@kvkk.gov.tr

14.11.8 Retention periods for Turkish residents

We apply the same retention periods described in Section 8 to all users. Personal data is retained for up to 5 years or as required by Turkish law and regulations.

14.11.9 Exercising your KVKK rights

To exercise your rights under KVKK, you can submit a written application:

We will respond to your request within 30 days at the latest, free of charge. If your request requires additional costs, we may charge a fee in accordance with the tariff determined by the Personal Data Protection Board.

14.12 For users in Mexico

If you are a resident of the United Mexican States (Mexico), the following provisions apply to you under the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP):

14.12.1 LFPDPPP compliance

We process your personal data in accordance with the Mexican Federal Law on Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares - LFPDPPP), which entered into force on July 6, 2010, and its Regulations.

14.12.2 Legal bases for processing under LFPDPPP

We process your personal data based on the following legal bases under LFPDPPP:

  • Consent – when you register, upload photos, grant location permissions, or agree to processing
  • Performance of a contract – to provide the Service, process orders and reservations
  • Legal obligation – to comply with Mexican tax, accounting and consumer protection requirements
  • Legitimate interests – where processing is necessary for our legitimate interests and does not override your fundamental rights

14.12.3 Privacy notice (Aviso de Privacidad)

This Privacy Policy serves as our Privacy Notice (Aviso de Privacidad) under LFPDPPP and contains:

  • Identity and address of the data controller (Section 1)
  • Personal data we collect (Section 3)
  • Purposes of processing (Section 4)
  • Sharing of personal data (Section 6)
  • Mechanisms for exercising ARCO rights (Section 14.12.6)
  • Options to limit use and disclosure of personal data (Section 14.12.7)
  • Procedures for revoking consent (Section 14.12.6)
  • How we notify changes to this Privacy Notice (Section 13)

14.12.4 Sensitive personal data (Datos personales sensibles)

Under LFPDPPP, the following categories of data we may collect are considered sensitive and require express and written consent:

  • Biometric data – photos and facial caricatures that can be used to identify you
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive personal data only with your express consent and for the specific purposes disclosed in this Policy. You have the right to refuse to provide sensitive data, though this may limit certain features of the Service.

14.12.5 Cross-border transfer of personal data

Your personal data is transferred outside of Mexico to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under LFPDPPP, international transfers of personal data require your consent. By using the Service and accepting this Privacy Policy, you consent to the international transfer of your personal data.

We ensure adequate protection for international transfers through:

  • Standard Contractual Clauses
  • Technical and organizational security measures
  • Contractual commitments by recipients to comply with LFPDPPP principles

14.12.6 Your ARCO rights

Under LFPDPPP, you have the following rights (known as "ARCO rights"):

  • Access (Acceso) – obtain confirmation of whether we process your personal data and obtain copies
  • Rectification (Rectificación) – request correction of inaccurate or incomplete personal data
  • Cancellation (Cancelación) – request deletion of your personal data when you consider it is not being processed in accordance with LFPDPPP
  • Opposition (Oposición) – oppose processing of your personal data for specific purposes

You also have the right to:

  • Revoke consent – withdraw your consent for processing at any time
  • Limit use and disclosure – request that we limit the use or disclosure of your personal data

To exercise your ARCO rights, please submit a request to info@meni.ge with the following information:

  • Your name and email or postal address for receiving responses
  • Documents proving your identity (copy of official ID)
  • Clear description of the personal data for which you seek to exercise ARCO rights
  • Any other information that facilitates locating your personal data
  • In case of rectification, include the documents supporting your request

We will respond to your ARCO request within 20 business days from the date we receive your request. Our response will indicate whether your request was accepted and, if accepted, we will make it effective within 15 business days.

We may deny your ARCO request in the following cases:

  • You are not the data subject or your legal representative is not duly accredited
  • Your personal data is not in our databases
  • Your rights are restricted by law
  • Processing is necessary for compliance with legal obligations

14.12.7 Limitation of use and disclosure

You may limit the use and disclosure of your personal data by:

  • Opting out of marketing communications (if we send any)
  • Disabling analytics cookies through cookie settings
  • Withdrawing consent for geolocation and photos through device settings
  • Contacting us at info@meni.ge to request limitation

We do not use or disclose your personal data for secondary purposes (such as advertising or marketing) without your consent.

14.12.8 Personal data of minors

In accordance with LFPDPPP, we obtain consent from parents or legal guardians (tutores) before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent. For minors aged 16-17, we may require verification of parental consent for certain features.

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at info@meni.ge.

14.12.9 Cookies and web beacons

The Admin Application uses only essential cookies and browser local storage for authentication and core functionality. These are strictly necessary for the Service to work:

  • AWS Cognito tokens (localStorage) – for user authentication
  • Sentry – for error monitoring (anonymized)
  • AWS CloudFront – for content delivery

We do not use advertising, marketing, or analytics cookies. No cookie consent banner is required as all cookies are strictly necessary for the B2B service.

14.12.10 National Institute for Transparency, Access to Information and Personal Data Protection (INAI)

You have the right to file a complaint with the Mexican supervisory authority:

Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI)
Address: Insurgentes Sur 3211, Col. Insurgentes Cuicuilco, Alcaldía Coyoacán, C.P. 04530, Ciudad de México
Website: https://home.inai.org.mx
Phone: +52 (55) 5004-2400
Email: atencion@inai.org.mx

INAI handles complaints regarding violations of LFPDPPP and can impose sanctions on data controllers who fail to comply with the law.

14.12.11 Security measures

We implement physical, technical, and administrative security measures to protect your personal data against damage, loss, alteration, destruction, unauthorized access, or use, as required by LFPDPPP and its Regulations.

These measures include:

  • Encryption of data in transit and at rest
  • Access controls and authentication
  • Regular security audits and monitoring
  • Employee training on data protection
  • Incident response procedures

14.12.12 Retention periods for Mexican residents

We apply the same retention periods described in Section 8 to all users. Personal data is retained for up to 5 years or as required by Mexican law.

Once the retention period expires and there is no legal requirement to keep the data, we will delete or anonymize your personal data.

14.12.13 Changes to this Privacy Notice

We will notify you of material changes to this Privacy Notice through:

  • Email to the address associated with your account
  • A prominent notice on our website or app
  • In-app notifications

You will have 5 business days from the notification to express any objection to the changes. If you do not object, we will consider that you accept the changes.

If you object to the changes, we may terminate your access to the Service, or you may delete your account.

14.12.14 Exercising your rights under LFPDPPP

To exercise any of your rights under LFPDPPP, please contact us at:

Email: info@meni.ge

Subject line: "ARCO Rights Request" or "Solicitud de Derechos ARCO"

Or use our data deletion page at https://meni.ge/privacy/delete for cancellation requests.

We will respond within the timeframes required by LFPDPPP (20 business days for the response, 15 business days for implementation).

14.13 For users in Argentina

If you are a resident of the Argentine Republic (Argentina), the following provisions apply to you under the Personal Data Protection Act, Law No. 25.326 (PDPA):

14.13.1 PDPA compliance

We process your personal data in accordance with the Argentine Personal Data Protection Act (Ley de Protección de Datos Personales, Law No. 25.326), enacted on October 4, 2000, and its implementing regulations (Decree 1558/2001).

14.13.2 Legal bases for processing under PDPA

We process your personal data based on the following legal bases under PDPA:

  • Consent – when you register, upload photos, grant location permissions, or agree to processing
  • Performance of a contract – to provide the Service, process orders and reservations
  • Legal obligation – to comply with Argentine tax, accounting and consumer protection requirements
  • Legitimate interests – where processing is necessary for our legitimate interests and does not harm your rights

14.13.3 Information obligations

Under PDPA, we inform you of:

  • The identity and address of the data controller (Section 1)
  • The purpose of data collection (Section 4)
  • The recipients of your personal data (Section 6)
  • The existence of databases and their purpose (Section 3)
  • Your rights to access, rectify, and delete data (Section 14.13.6)
  • Whether providing data is mandatory or optional
  • The consequences of providing or refusing to provide data

14.13.4 Sensitive personal data

Under PDPA, the following categories of data we may collect are considered sensitive and require express consent:

  • Biometric data – photos and facial caricatures that can be used to identify you
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive personal data only with your express and informed consent. You have the right to refuse to provide sensitive data, though this may limit certain features of the Service.

14.13.5 Cross-border transfer of personal data

Your personal data is transferred outside of Argentina to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under PDPA, international transfers of personal data to countries that do not provide adequate protection levels require your consent. By using the Service and accepting this Privacy Policy, you consent to the international transfer of your personal data.

Argentina recognizes EU/EEA countries as providing adequate data protection. For transfers to other countries (such as the United States), we implement:

  • Standard Contractual Clauses
  • Technical and organizational security measures
  • Contractual commitments by recipients to comply with PDPA principles

14.13.6 Your rights under PDPA

Under PDPA, you have the following rights:

  • Right of access – obtain information about your personal data in our databases, free of charge, at intervals of not less than 6 months (unless you prove a legitimate interest)
  • Right to rectification – request correction, updating, or deletion of inaccurate, incomplete, or outdated data
  • Right to suppression (deletion) – request deletion of data that is not being processed in accordance with PDPA
  • Right to confidentiality – ensure that your data is kept confidential and used only for the purposes for which it was collected

You also have the right to:

  • Withdraw consent – revoke your consent for processing at any time
  • Object to processing – object to processing in certain cases

To exercise your rights, please submit a request to info@meni.ge with:

  • Your full name and contact information
  • Proof of identity (copy of national ID - DNI, or passport)
  • Clear description of the personal data concerned
  • Specification of the right you wish to exercise

We will respond to your request within 10 business days from the date we receive it. If we need additional time, we will notify you of the delay.

We may deny your request in cases provided by law, such as when:

  • Disclosure could obstruct judicial or administrative proceedings
  • Data is related to national defense, public security, or tax collection
  • Data is protected by professional secrecy
  • Your request is manifestly unfounded or excessive

14.13.7 Personal data of minors

In accordance with PDPA, we obtain consent from parents or legal guardians (tutores or representantes legales) before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent. For minors aged 16-17, we may require verification of parental consent for certain features.

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at info@meni.ge.

14.13.8 Database registration

Personal data databases must be registered with the Argentine Data Protection Authority (Agencia de Acceso a la Información Pública - AAIP) in the National Database Registry (Registro Nacional de Bases de Datos).

We comply with database registration requirements as applicable to our operations in Argentina.

14.13.9 Argentine Data Protection Authority (AAIP)

You have the right to file a complaint with the Argentine data protection supervisory authority:

Agencia de Acceso a la Información Pública (AAIP)
Address: Av. Pte. Gral. Julio A. Roca 710, Piso 3°, C1067ABC, Ciudad Autónoma de Buenos Aires, Argentina
Website: https://www.argentina.gob.ar/aaip
Phone: 0800-222-DATO (3286) / (+54 11) 2821-0047
Email: datospersonales@aaip.gob.ar

AAIP is responsible for supervising compliance with PDPA and has the authority to impose sanctions on data controllers who violate the law.

14.13.10 Security measures

We implement technical and organizational security measures to protect your personal data against unauthorized access, alteration, destruction, or disclosure, as required by PDPA and Decree 1558/2001.

These measures include:

  • Encryption of data in transit and at rest
  • Access controls and authentication mechanisms
  • Regular security audits and vulnerability assessments
  • Employee training on data protection
  • Incident detection and response procedures
  • Physical security of data storage facilities

14.13.11 Cookies and tracking technologies

The Admin Application uses only essential cookies and browser local storage for authentication and core functionality. These are strictly necessary for the Service to work:

  • AWS Cognito tokens (localStorage) – for user authentication
  • Sentry – for error monitoring (anonymized)
  • AWS CloudFront – for content delivery

We do not use advertising, marketing, or analytics cookies. These essential cookies cannot be disabled without preventing access to the Admin Application.

14.13.12 Retention periods for Argentine residents

We apply the same retention periods described in Section 8 to all users. Personal data is retained for up to 5 years or as required by Argentine law.

Once the retention period expires and there is no legal requirement to keep the data, we will delete or anonymize your personal data in a manner that prevents its reconstruction.

14.13.13 Direct marketing and automated processing

We do not use your personal data for direct marketing purposes without your prior consent. If we send marketing communications, you can opt out at any time.

We do not make decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

14.13.14 Data breach notification

In the event of a personal data breach that may significantly affect your rights, we will:

  • Notify the AAIP within the required timeframe
  • Notify affected data subjects when the breach may cause serious harm
  • Take measures to mitigate the effects of the breach

14.13.15 Exercising your rights under PDPA

To exercise any of your rights under Argentine law, please contact us at:

Email: info@meni.ge
Subject line: "PDPA Rights Request" or "Solicitud de Derechos - Ley 25.326"

Or use our data deletion page at https://meni.ge/privacy/delete for deletion requests.

We will respond within 10 business days as required by PDPA. If additional time is needed, we will notify you of the extension.

14.14 For users in Georgia

If you are a resident of Georgia, the following provisions apply to you under the Law of Georgia on Personal Data Protection:

14.14.1 Georgian data protection law compliance

We process your personal data in accordance with the Law of Georgia on Personal Data Protection (პერსონალურ მონაცემთა დაცვის შესახებ საქართველოს კანონი), adopted on December 28, 2011, and aligned with EU GDPR principles.

As a Georgian entity (Individual Entrepreneur registered in Georgia), we are subject to Georgian data protection law and supervised by the Personal Data Protection Service of Georgia.

14.14.2 Legal bases for processing under Georgian law

We process your personal data based on the following legal bases:

  • Consent – when you register, upload photos, grant permissions, or agree to processing
  • Performance of a contract – to provide the Service, process orders and reservations
  • Legal obligation – to comply with Georgian tax, accounting and consumer protection requirements
  • Legitimate interests – where processing is necessary for our legitimate interests and does not override your fundamental rights

14.14.3 Your rights under Georgian law

Under Georgian data protection law, you have the following rights:

  • Right of access – obtain confirmation of whether we process your personal data and receive a copy
  • Right to rectification – request correction of inaccurate or incomplete data
  • Right to erasure – request deletion of your data in certain circumstances
  • Right to restriction of processing – request limitation of processing in certain cases
  • Right to data portability – receive your data in structured, machine-readable format
  • Right to object – object to processing based on legitimate interests
  • Right to withdraw consent – withdraw consent at any time

These rights are similar to GDPR rights described in Section 9.

14.14.4 Personal Data Protection Service

You have the right to lodge a complaint with the Georgian supervisory authority:

Personal Data Protection Service (პერსონალურ მონაცემთა დაცვის სამსახური)
Address: 32 Kheivani St., 0179 Tbilisi, Georgia
Website: https://personaldata.ge
Phone: (+995 32) 2 12 35 01
Email: info@pdp.ge

14.14.5 Data storage in Georgia

While our servers are located in Germany (Frankfurt), we are a Georgian entity and subject to Georgian jurisdiction. This provides you with the protection of Georgian data protection law.

14.14.6 Exercising your rights

To exercise your rights under Georgian law, please contact us at info@meni.ge or use our data deletion page at https://meni.ge/privacy/delete.

We will respond within 30 days as required by Georgian law.

14.15 For users in Armenia

If you are a resident of the Republic of Armenia, the following provisions apply to you under the Law on Protection of Personal Data:

14.15.1 Armenian data protection law compliance

We process your personal data in accordance with the Law of the Republic of Armenia on Protection of Personal Data (Անձնական տվյալների պահպանության մասին, Law No. HO-59-N), adopted on March 26, 2015.

14.15.2 Legal bases for processing under Armenian law

We process your personal data based on the following legal bases:

  • Consent – when you register, upload photos, grant permissions, or agree to processing
  • Performance of a contract – to provide the Service
  • Legal obligation – to comply with legal requirements
  • Legitimate interests – where necessary for our legitimate interests

14.15.3 Sensitive personal data

Under Armenian law, the following data we collect is considered sensitive and requires express consent:

  • Biometric data – photos and facial caricatures
  • Health data – dietary restrictions or allergies related to health conditions

14.15.4 Your rights under Armenian law

Under Armenian data protection law, you have the following rights:

  • Right of access – obtain information about processing of your personal data
  • Right to rectification – request correction of inaccurate data
  • Right to deletion – request deletion of data in certain cases
  • Right to object – object to processing in certain circumstances
  • Right to withdraw consent – withdraw consent at any time

14.15.5 Cross-border transfer

Your personal data is transferred to Germany (Frankfurt) for storage. By using the Service, you consent to this international transfer.

14.15.6 Authorized Body for Protection of Personal Data

You have the right to contact the Armenian data protection authority:

Authorized Body for Protection of Personal Data
Address: 15 M. Mkrtchyan St., 0010 Yerevan, Republic of Armenia
Website: https://www.e-gov.am/gov-decrees/item/28321/
Phone: (+374 10) 51 14 42

14.15.7 Exercising your rights

To exercise your rights, contact us at info@meni.ge. We will respond within the timeframe required by Armenian law.

14.16 For users in Azerbaijan

If you are a resident of the Republic of Azerbaijan, the following provisions apply to you under the Law on Personal Data:

14.16.1 Azerbaijani data protection law compliance

We process your personal data in accordance with the Law of the Republic of Azerbaijan on Personal Data (Fərdi məlumatlar haqqında, Law No. 998-IIIQD), adopted on May 11, 2010.

14.16.2 Legal bases for processing under Azerbaijani law

We process your personal data based on the following legal bases:

  • Consent – when you register, upload photos, grant permissions, or agree to processing
  • Performance of a contract – to provide the Service
  • Legal obligation – to comply with Azerbaijani legal requirements
  • Legitimate interests – where necessary for our legitimate interests

14.16.3 Special categories of personal data

Under Azerbaijani law, the following data we collect may be considered special categories and require express consent:

  • Biometric data – photos and facial caricatures
  • Health data – dietary restrictions or allergies

We process such data only with your express consent.

14.16.4 Your rights under Azerbaijani law

Under Azerbaijani data protection law, you have the following rights:

  • Right to information – obtain information about processing of your data
  • Right to access – access your personal data
  • Right to rectification – request correction of inaccurate data
  • Right to deletion – request deletion of data in certain cases
  • Right to object – object to processing
  • Right to withdraw consent – withdraw consent at any time

14.16.5 Cross-border transfer

Your personal data is transferred to Germany (Frankfurt) for storage. By using the Service and accepting this Privacy Policy, you consent to the international transfer of your personal data.

14.16.6 Commissioner for Human Rights (Ombudsman)

For data protection matters in Azerbaijan, you may contact:

Commissioner for Human Rights (Ombudsman) of the Republic of Azerbaijan
Address: 16 U. Hajibeyov St., AZ1000 Baku, Azerbaijan
Website: http://www.ombudsman.az
Phone: (+994 12) 498 63 28
Email: office@ombudsman.az

14.16.7 Exercising your rights

To exercise your rights, contact us at info@meni.ge. We will respond within a reasonable timeframe.

14.17 For users in Kazakhstan

If you are a resident of the Republic of Kazakhstan, the following provisions apply to you under the Law on Personal Data and their Protection:

14.17.1 Kazakhstani data protection law compliance

We process your personal data in accordance with the Law of the Republic of Kazakhstan on Personal Data and their Protection (Дербес деректер және оларды қорғау туралы / О персональных данных и их защите, Law No. 94-V), adopted on May 21, 2013.

14.17.2 Legal bases for processing under Kazakhstani law

We process your personal data based on the following legal bases:

  • Consent – when you register, upload photos, grant permissions, or agree to processing
  • Performance of a contract – to provide the Service, process orders and reservations
  • Legal obligation – to comply with Kazakhstani legal requirements
  • Legitimate interests – where necessary for our legitimate interests and does not violate your rights

14.17.3 Biometric personal data

Under Kazakhstani law, biometric data is a special category of personal data. We collect:

  • Photos and facial caricatures – which may constitute biometric personal data

We process biometric data only with your consent and for the purposes specified in this Policy.

14.17.4 Your rights under Kazakhstani law

Under Kazakhstani data protection law, you have the following rights:

  • Right of access – obtain information about processing of your personal data
  • Right to rectification – request correction of inaccurate, incomplete, or outdated data
  • Right to deletion – request deletion of data in certain circumstances
  • Right to withdraw consent – withdraw consent at any time
  • Right to object – object to processing in certain cases
  • Right to restrict processing – request limitation of processing

14.17.5 Cross-border transfer of personal data

Your personal data is transferred outside of Kazakhstan to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

By using the Service and accepting this Privacy Policy, you consent to the cross-border transfer of your personal data. We ensure adequate protection through contractual and technical measures.

14.17.6 Personal data of minors

In accordance with Kazakhstani law, we obtain consent from parents or legal representatives before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.17.7 Personal Data Protection Authority

For data protection matters in Kazakhstan, you may contact the authorized state body responsible for personal data protection.

Information is available at the official government portal: https://egov.kz

14.17.8 Exercising your rights

To exercise your rights under Kazakhstani law, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "Запрос о правах на персональные данные"

Or use our data deletion page at https://meni.ge/privacy/delete for deletion requests.

We will respond within the timeframe required by Kazakhstani law (typically 30 days).

14.18 For users in Ukraine

If you are a resident of Ukraine, the following provisions apply to you under the Law of Ukraine on Protection of Personal Data:

14.18.1 Ukrainian data protection law compliance

We process your personal data in accordance with the Law of Ukraine on Protection of Personal Data (Про захист персональних даних, Law No. 2297-VI), adopted on June 1, 2010.

Ukraine is in the process of aligning its data protection legislation with EU GDPR requirements.

14.18.2 Legal bases for processing under Ukrainian law

We process your personal data based on the following legal bases:

  • Consent – when you register, upload photos, grant permissions, or agree to processing
  • Performance of a contract – to provide the Service, process orders and reservations
  • Legal obligation – to comply with Ukrainian legal requirements
  • Legitimate interests – where necessary for our legitimate interests and does not violate your rights

14.18.3 Special categories of personal data

Under Ukrainian law, the following data we collect is considered special categories and requires express consent:

  • Biometric data – photos and facial caricatures that can be used to identify you
  • Health data – dietary restrictions or allergies related to health conditions

We process special categories of personal data only with your express written consent.

14.18.4 Your rights under Ukrainian law

Under Ukrainian data protection law, you have the following rights:

  • Right to information – know about the collection, processing and use of your personal data
  • Right of access – obtain information about processing and copies of your data
  • Right to rectification – request correction of inaccurate or incomplete data
  • Right to deletion – request deletion of data in certain circumstances
  • Right to object – object to processing
  • Right to withdraw consent – withdraw consent at any time

14.18.5 Cross-border transfer of personal data

Your personal data is transferred outside of Ukraine to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

By using the Service and accepting this Privacy Policy, you consent to the cross-border transfer of your personal data. We ensure adequate protection through contractual and technical measures.

14.18.6 Personal data of minors

In accordance with Ukrainian law, we obtain consent from parents or legal representatives before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.18.7 Ukrainian Parliament Commissioner for Human Rights (Ombudsman)

You have the right to contact the Ukrainian data protection authority:

Ukrainian Parliament Commissioner for Human Rights (Уповноважений Верховної Ради України з прав людини)
Address: 21/8 Instytutska St., 01008 Kyiv, Ukraine
Website: https://www.ombudsman.gov.ua
Phone: (+380 44) 253-80-51
Email: hotline@ombudsman.gov.ua

14.18.8 Exercising your rights

To exercise your rights under Ukrainian law, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "Запит про права на персональні дані"

Or use our data deletion page at https://meni.ge/privacy/delete for deletion requests.

We will respond within the timeframe required by Ukrainian law (typically 30 days).

14.19 For users in Iran

If you are a resident of the Islamic Republic of Iran, the following provisions apply to you under Iranian data protection regulations:

14.19.1 Iranian data protection compliance

We process your personal data in accordance with Iranian laws and regulations, including provisions of the Computer Crimes Law (قانون جرایم رایانه‌ای) and regulations on protection of personal data and privacy.

14.19.2 Legal bases for processing under Iranian law

We process your personal data based on the following legal bases:

  • Consent – when you register, upload photos, grant permissions, or agree to processing
  • Performance of a contract – to provide the Service
  • Legal compliance – to comply with Iranian legal requirements
  • Legitimate purposes – where necessary for lawful business purposes

14.19.3 Sensitive personal data

Under Iranian law, we handle the following sensitive data with additional protection measures:

  • Biometric data – photos and facial caricatures
  • Health information – dietary restrictions or allergies
  • Personal identification information – that can be used to identify you

We process such data only with your consent and implement enhanced security measures.

14.19.4 Your rights under Iranian law

Under Iranian data protection regulations, you have the following rights:

  • Right to information – be informed about collection and use of your personal data
  • Right to access – access your personal data
  • Right to correction – request correction of inaccurate data
  • Right to deletion – request deletion in certain circumstances
  • Right to object – object to processing where permitted by law
  • Right to confidentiality – protection of your privacy

14.19.5 Data localization and cross-border transfer

Your personal data is transferred to and stored on servers located in Germany (Frankfurt). By using the Service, you acknowledge and consent to this international transfer.

We implement appropriate security measures to protect data transferred internationally, including encryption and access controls.

14.19.6 Personal data of minors

In accordance with Iranian law and Islamic principles, we require consent from parents or legal guardians before processing personal data of minors (persons under 18 years old).

The Service is not intended for children without parental consent and supervision.

14.19.7 Security and confidentiality

We implement technical, physical, and administrative security measures in accordance with Iranian regulations to protect your personal data against unauthorized access, disclosure, alteration, or destruction.

These measures include:

  • Encryption of data in transit and at rest
  • Secure authentication mechanisms
  • Access controls and monitoring
  • Regular security assessments
  • Employee confidentiality obligations

14.19.8 Exercising your rights

To exercise your rights or for data protection inquiries, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "درخواست حقوق داده‌های شخصی"

We will respond to your request within a reasonable timeframe in accordance with Iranian law.

14.20 For users in the United Arab Emirates

If you are a resident of the United Arab Emirates (UAE), the following provisions apply to you under the UAE Federal Data Protection Law:

14.20.1 UAE data protection law compliance

We process your personal data in accordance with the UAE Personal Data Protection Law (المرسوم بقانون اتحادي رقم 45 لسنة 2021 في شأن حماية البيانات الشخصية, Federal Decree-Law No. 45 of 2021), which came into effect on January 2, 2022.

14.20.2 Legal bases for processing under UAE law

We process your personal data based on the following legal bases under UAE law:

  • Consent – when you provide explicit consent for processing
  • Performance of a contract – to fulfill our contractual obligations to you
  • Legal obligation – to comply with UAE legal and regulatory requirements
  • Legitimate interests – where necessary for our legitimate business interests, provided this does not override your fundamental rights

14.20.3 Sensitive personal data

Under UAE law, the following data we collect is considered sensitive and requires explicit consent:

  • Biometric data – photos and facial caricatures used for identification
  • Health data – dietary restrictions, allergies, or other health-related information

We process sensitive personal data only with your explicit consent and implement additional security measures as required by UAE law.

14.20.4 Your rights under UAE law

Under UAE data protection law, you have the following rights:

  • Right to access – obtain confirmation of whether we process your personal data and receive a copy
  • Right to rectification – request correction of inaccurate or incomplete data
  • Right to erasure – request deletion of your data in certain circumstances
  • Right to restriction of processing – request limitation of processing in certain cases
  • Right to data portability – receive your data in structured, machine-readable format and transmit it to another controller
  • Right to object – object to processing based on legitimate interests
  • Right to withdraw consent – withdraw consent at any time without affecting prior processing
  • Right to lodge a complaint – file a complaint with the UAE Data Office

14.20.5 Cross-border transfer of personal data

Your personal data is transferred outside of the UAE to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under UAE law, we ensure that international transfers of your personal data are protected through:

  • Transferring to countries recognized as providing adequate protection (such as EU/EEA countries)
  • Implementing Standard Contractual Clauses approved by the UAE Data Office
  • Obtaining your explicit consent for the transfer
  • Applying appropriate technical and organizational security measures

By using the Service, you consent to the international transfer of your personal data as described above.

14.20.6 Personal data of minors

In accordance with UAE law, we obtain consent from parents or legal guardians before processing personal data of minors. In the UAE, minors are persons under 21 years old.

The Service is not intended for persons under 18 without parental consent. For persons aged 18-20, we may require verification of parental consent for certain features.

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us at info@meni.ge.

14.20.7 UAE Data Office

You have the right to lodge a complaint with the UAE supervisory authority:

UAE Data Office (مكتب البيانات)
Ministry of Justice
Website: https://www.uaedataoffice.gov.ae
Email: dataoffice@moj.gov.ae
Phone: (+971) 600 522 222

The UAE Data Office is responsible for supervising compliance with the Personal Data Protection Law and has the authority to investigate complaints and impose penalties for violations.

14.20.8 Data breach notification

In the event of a personal data breach that may pose a risk to your rights and freedoms, we will:

  • Notify the UAE Data Office within 72 hours of becoming aware of the breach
  • Notify affected data subjects without undue delay if the breach poses a high risk
  • Take immediate measures to mitigate the effects of the breach
  • Cooperate with the UAE Data Office in investigating and resolving the breach

14.20.9 Retention periods for UAE residents

We apply the same retention periods described in Section 8 to all users. Personal data is retained for up to 5 years or as required by UAE law.

Once the retention period expires and there is no legal requirement to keep the data, we will securely delete or anonymize your personal data.

14.20.10 Exercising your rights under UAE law

To exercise any of your rights under UAE law, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "طلب حقوق البيانات الشخصية"

Or use our data deletion page at https://meni.ge/privacy/delete for deletion requests.

We will respond to your request within 30 days as required by UAE law. If we need additional time due to the complexity of your request, we will notify you and may extend the response time by an additional 30 days.

14.21 For users in Uruguay

If you are a resident of the Oriental Republic of Uruguay, the following provisions apply to you under the Personal Data Protection and Habeas Data Action Law:

14.21.1 Uruguayan data protection law compliance

We process your personal data in accordance with the Personal Data Protection and Habeas Data Action Law (Ley de Protección de Datos Personales y Acción de Habeas Data, Law No. 18.331), adopted on August 11, 2008, and its implementing Decree No. 414/009.

Uruguay has been recognized by the European Commission as providing adequate protection for personal data, making it the first Latin American country to receive this recognition.

14.21.2 Legal bases for processing under Uruguayan law

We process your personal data based on the following legal bases under Uruguayan law:

  • Consent – when you provide express and informed consent
  • Performance of a contract – to fulfill our contractual obligations
  • Legal obligation – to comply with Uruguayan legal requirements
  • Legitimate interests – where processing is necessary for our legitimate interests and does not harm your fundamental rights

14.21.3 Sensitive personal data

Under Uruguayan law, the following data we collect is considered sensitive (datos sensibles) and requires express written consent:

  • Biometric data – photos and facial caricatures that can be used to identify you
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive data only with your express written consent and for the purposes explicitly disclosed.

14.21.4 Your rights under Uruguayan law

Under Uruguayan data protection law, you have the following rights:

  • Right of access (acceso) – obtain confirmation of whether we process your data and receive copies
  • Right to update (actualización) – request updating of incomplete or outdated data
  • Right to rectification (rectificación) – request correction of inaccurate data
  • Right to inclusion (inclusión) – request addition of data that should be part of the database
  • Right to deletion (supresión) – request deletion of data that is unlawfully processed or no longer necessary
  • Right to confidentiality (confidencialidad) – ensure your data is kept confidential
  • Right to information (información) – be informed about the existence of databases and their purpose
  • Right to object (oposición) – object to processing in certain circumstances

14.21.5 Cross-border transfer of personal data

Your personal data is transferred to servers located in Germany (Frankfurt) and may be processed by service providers in other countries.

Uruguay and the European Union mutually recognize each other as providing adequate data protection. Transfers to other countries require appropriate safeguards.

By using the Service, you consent to the international transfer of your personal data with appropriate safeguards in place.

14.21.6 Personal data of minors

In accordance with Uruguayan law, we obtain consent from parents or legal representatives (padres o representantes legales) before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.21.7 Data Protection Unit (URCDP)

You have the right to lodge a complaint with the Uruguayan data protection authority:

Unidad Reguladora y de Control de Datos Personales (URCDP)
Address: Andes 1365, Piso 10, 11100 Montevideo, Uruguay
Website: https://www.gub.uy/unidad-reguladora-control-datos-personales
Phone: (+598) 2901 2929
Email: urcdp@agesic.gub.uy

14.21.8 Habeas Data action

In addition to administrative remedies, Uruguayan law provides a constitutional action called Habeas Data (Acción de Habeas Data), which allows you to seek judicial protection of your personal data rights.

14.21.9 Exercising your rights

To exercise your rights under Uruguayan law, please contact us at:

Email: info@meni.ge
Subject line: "Solicitud de Derechos - Ley 18.331" or "Data Rights Request"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within the timeframes required by Uruguayan law (typically 5 working days for access requests, longer for complex requests).

14.22 For users in Peru

If you are a resident of the Republic of Peru, the following provisions apply to you under the Personal Data Protection Law:

14.22.1 Peruvian data protection law compliance

We process your personal data in accordance with the Personal Data Protection Law (Ley de Protección de Datos Personales, Law No. 29733), enacted on July 3, 2011, and its implementing regulations (Supreme Decree No. 003-2013-JUS).

14.22.2 Legal bases for processing under Peruvian law

We process your personal data based on the following legal bases under Peruvian law:

  • Consent – when you provide free, prior, express, informed and unequivocal consent
  • Performance of a contract – to fulfill contractual obligations
  • Legal obligation – to comply with Peruvian legal requirements
  • Legitimate interests – where processing is necessary for legitimate purposes, provided it does not violate your fundamental rights

14.22.3 Sensitive personal data

Under Peruvian law, the following data we collect is considered sensitive (datos sensibles) and requires express, written and prior consent:

  • Biometric data – photos and facial caricatures used for identification
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive data only with your express written consent, obtained prior to processing, and for the specific purposes disclosed.

14.22.4 Your rights under Peruvian law (ARCO rights)

Under Peruvian law, you have the following ARCO rights:

  • Right of access (Acceso) – know what personal data is being processed and obtain copies
  • Right to rectification (Rectificación) – request correction of inaccurate, incomplete or outdated data
  • Right to cancellation (Cancelación) – request deletion or blocking of data that is excessive, unnecessary, or processed in violation of law
  • Right to opposition (Oposición) – object to processing when you have legitimate reasons

You also have the right to:

  • Revoke consent – withdraw your consent at any time
  • Information – be informed about the processing of your data
  • Objection to automated decisions – object to decisions based solely on automated processing

To exercise your ARCO rights, please submit a request to info@meni.ge with:

  • Your full name and contact information
  • Copy of your national ID (DNI) or passport
  • Clear description of the right you wish to exercise
  • Any supporting documentation

We will respond to your ARCO request within 10 business days. If we need additional time, we may extend the response period by 5 business days and will notify you of the extension.

14.22.5 Cross-border transfer of personal data

Your personal data is transferred outside of Peru to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

By using the Service and accepting this Privacy Policy, you provide express consent to the international transfer of your personal data. We ensure adequate protection through contractual and technical safeguards.

14.22.6 Personal data of minors

In accordance with Peruvian law, we obtain consent from parents or legal guardians (padres o tutores legales) before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.22.7 National Authority for the Protection of Personal Data

You have the right to lodge a complaint with the Peruvian data protection authority:

Autoridad Nacional de Protección de Datos Personales
Dirección General de Transparencia, Acceso a la Información Pública y Protección de Datos Personales
Ministry of Justice and Human Rights
Address: Calle Scipión Llona 350, Miraflores, Lima, Peru
Website: https://www.minjus.gob.pe/proteccion-de-datos-personales/
Email: protecciondedatospersonales@minjus.gob.pe

14.22.8 Exercising your rights

Email: info@meni.ge
Subject line: "Solicitud de Derechos ARCO - Ley 29733" or "ARCO Rights Request"

Or use our data deletion page at https://meni.ge/privacy/delete

14.23 For users in Chile

If you are a resident of the Republic of Chile, the following provisions apply to you under the Law on Protection of Private Life:

14.23.1 Chilean data protection law compliance

We process your personal data in accordance with the Law on Protection of Private Life (Ley sobre Protección de la Vida Privada, Law No. 19.628), enacted on August 28, 1999.

Chile is in the process of modernizing its data protection legislation to align with international standards including GDPR.

14.23.2 Legal bases for processing under Chilean law

We process your personal data based on the following legal bases under Chilean law:

  • Consent – when you provide express consent
  • Authorization by law – when processing is authorized by legal provisions
  • Sources accessible to the public – for publicly available data
  • Performance of a contract – to fulfill contractual obligations

14.23.3 Sensitive personal data

Under Chilean law, the following data we collect is considered sensitive (datos sensibles) and requires express written consent:

  • Biometric data – photos and facial caricatures
  • Health data – dietary restrictions or allergies
  • Physical characteristics – information about your appearance or physical attributes

We process sensitive data only with your express written consent.

14.23.4 Your rights under Chilean law

Under Chilean data protection law, you have the following rights:

  • Right of access (información) – know what personal data is stored in databases
  • Right to rectification (modificación) – request correction of inaccurate or incomplete data
  • Right to deletion (eliminación) – request deletion of data when processing is unlawful or no longer necessary
  • Right to blocking (bloqueo) – request blocking of data in certain circumstances
  • Right to object (oposición) – object to processing
  • Right to revoke consent – withdraw your consent at any time

14.23.5 Cross-border transfer of personal data

Your personal data is transferred to servers located in Germany (Frankfurt) and may be processed by service providers in other countries.

By using the Service, you consent to the international transfer of your personal data. We implement appropriate safeguards to protect data transferred internationally.

14.23.6 Personal data of minors

In accordance with Chilean law and general principles of protection of minors, we obtain consent from parents or legal guardians (padres o representantes legales) before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.23.7 National Consumer Service (SERNAC)

For data protection matters, you may contact:

Servicio Nacional del Consumidor (SERNAC)
Website: https://www.sernac.cl
Phone: 800 700 100
Address: Teatinos 120, Santiago, Chile

You may also file a habeas data action (acción de protección or recurso de amparo) in Chilean courts to protect your personal data rights.

14.23.8 Exercising your rights

To exercise your rights under Chilean law, please contact us at:

Email: info@meni.ge
Subject line: "Solicitud de Derechos - Ley 19.628" or "Data Rights Request"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within a reasonable timeframe.

14.24 For users in Colombia

If you are a resident of the Republic of Colombia, the following provisions apply to you under the Statutory Law on Personal Data Protection:

14.24.1 Colombian data protection law compliance

We process your personal data in accordance with the Statutory Law on Personal Data Protection (Ley Estatutaria de Protección de Datos Personales, Law No. 1581), enacted on October 17, 2012, and its implementing regulations (Decree 1377 of 2013).

14.24.2 Legal bases for processing under Colombian law

We process your personal data based on the following legal bases under Colombian law:

  • Prior, express and informed consent – when you provide consent that is free, specific, informed and unequivocal
  • Performance of a contract – to fulfill contractual obligations
  • Legal or judicial mandate – to comply with legal requirements
  • Vital interests – to protect vital interests of the data subject

14.24.3 Sensitive personal data

Under Colombian law, the following data we collect is considered sensitive (datos sensibles) and requires prior, express and informed consent:

  • Biometric data – photos and facial caricatures used for identification
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive data only with your prior, express and informed consent. You have the right to refuse to provide sensitive data without negative consequences, though this may limit certain features of the Service.

14.24.4 Your rights under Colombian law

Under Colombian data protection law, you have the following rights:

  • Right to know (conocer) – know, update and rectify your personal data
  • Right to access (acceder) – access your personal data free of charge
  • Right to update (actualizar) – request updating of incomplete or outdated data
  • Right to rectification (rectificar) – request correction of inaccurate data
  • Right to deletion (suprimir) – request deletion when processing is unlawful or consent is revoked
  • Right to revoke consent (revocar) – revoke authorization at any time
  • Right to file complaints (presentar quejas) – lodge complaints with the Superintendence for violations of the law

To exercise your rights, please submit a request to info@meni.ge with:

  • Full name and contact information
  • Copy of your national ID (cédula de ciudadanía) or passport
  • Clear description of the right you wish to exercise and the data concerned
  • Contact address for receiving responses

We will respond to your request within 10 business days informing you whether we accept or reject it. If accepted, we will implement your request within 15 business days.

14.24.5 Cross-border transfer of personal data

Your personal data is transferred outside of Colombia to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under Colombian law, we ensure that international transfers comply with legal requirements through:

  • Transferring to countries with adequate protection (such as EU/EEA countries)
  • Implementing appropriate contractual and technical safeguards
  • Obtaining your prior express consent for the transfer

By using the Service, you provide consent to the international transfer of your personal data.

14.24.6 Personal data of minors

In accordance with Colombian law, we obtain authorization from parents or legal guardians (padres o representantes legales) before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

Colombian law provides special protection for personal data of children and adolescents, requiring that processing respect their prevalence and superiority of rights.

14.24.7 Superintendence of Industry and Commerce (SIC)

You have the right to lodge a complaint with the Colombian data protection authority:

Superintendencia de Industria y Comercio (SIC)
Dirección de Investigación de Protección de Datos Personales
Address: Carrera 13 No. 27-00, Pisos 1 y 3, Bogotá D.C., Colombia
Website: https://www.sic.gov.co
Phone: (+57 1) 587 0000
Email: contactenos@sic.gov.co

14.24.8 Database registration

In compliance with Colombian law, personal data databases must be registered with the National Registry of Databases (Registro Nacional de Bases de Datos - RNBD) administered by the Superintendence of Industry and Commerce.

We comply with database registration requirements as applicable to our operations in Colombia.

14.24.9 Exercising your rights

To exercise your rights under Colombian law, please contact us at:

Email: info@meni.ge
Subject line: "Solicitud de Derechos - Ley 1581" or "Data Rights Request"

Or use our data deletion page at https://meni.ge/privacy/delete

14.25 For users in Indonesia

If you are a resident of the Republic of Indonesia, the following provisions apply to you under the Personal Data Protection Law:

14.25.1 Indonesian data protection law compliance

We process your personal data in accordance with the Personal Data Protection Law (Undang-Undang Perlindungan Data Pribadi, Law No. 27 of 2022), enacted on October 17, 2022.

The law has a 2-year transition period for full implementation, during which we are working to ensure full compliance.

14.25.2 Legal bases for processing under Indonesian law

We process your personal data based on the following legal bases under Indonesian law:

  • Consent – when you provide explicit consent for processing
  • Performance of a contract – to fulfill our contractual obligations
  • Legal obligation – to comply with Indonesian legal requirements
  • Vital interests – to protect your vital interests or those of another person
  • Public interest – for tasks carried out in the public interest
  • Legitimate interests – where necessary for our legitimate interests, provided this does not override your fundamental rights

14.25.3 Sensitive personal data

Under Indonesian law, the following data we collect is considered specific personal data (data pribadi yang bersifat spesifik) and requires explicit consent:

  • Biometric data – photos and facial caricatures used for identification
  • Health data – dietary restrictions or allergies related to health conditions
  • Children's data – personal data of persons under 18 years old

We process specific personal data only with your explicit consent and implement additional security measures.

14.25.4 Your rights under Indonesian law

Under Indonesian data protection law, you have the following rights:

  • Right to information – be informed about the processing of your personal data
  • Right of access – obtain confirmation and copies of your personal data
  • Right to rectification – request correction of inaccurate or incomplete data
  • Right to erasure – request deletion of your data in certain circumstances
  • Right to restriction – request limitation of processing in certain cases
  • Right to data portability – receive your data in structured, machine-readable format
  • Right to object – object to processing based on legitimate interests
  • Right to withdraw consent – withdraw consent at any time
  • Right to complain – lodge a complaint with the supervisory authority

14.25.5 Cross-border transfer of personal data

Your personal data is transferred outside of Indonesia to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under Indonesian law, we ensure that cross-border transfers comply with legal requirements through:

  • Transferring to countries recognized as providing adequate protection (such as EU/EEA countries)
  • Implementing appropriate contractual safeguards (Standard Contractual Clauses)
  • Obtaining your explicit consent for the transfer
  • Implementing technical and organizational security measures

By using the Service, you provide consent to the cross-border transfer of your personal data.

14.25.6 Personal data of children

In accordance with Indonesian law, we obtain consent from parents or legal guardians (orang tua atau wali) before processing personal data of children under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.25.7 Data breach notification

In the event of a personal data breach, we will:

  • Notify the Indonesian data protection authority within 72 hours
  • Notify affected individuals if the breach poses a high risk
  • Take immediate measures to mitigate the effects of the breach
  • Document the breach and our response

14.25.8 Ministry of Communication and Informatics

For data protection matters in Indonesia, the supervisory authority is:

Ministry of Communication and Informatics (Kementerian Komunikasi dan Informatika / Kominfo)
Website: https://www.kominfo.go.id
Email: humas@mail.kominfo.go.id

The government is establishing a dedicated Personal Data Protection Agency as required by the law.

14.25.9 Exercising your rights

To exercise your rights under Indonesian law, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "Permintaan Hak Perlindungan Data Pribadi"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within a reasonable timeframe as required by Indonesian law.

14.26 For users in the Philippines

If you are a resident of the Republic of the Philippines, the following provisions apply to you under the Data Privacy Act:

14.26.1 Philippine data protection law compliance

We process your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), enacted on August 15, 2012, and its Implementing Rules and Regulations.

The Philippines has one of the most comprehensive data privacy frameworks in Southeast Asia.

14.26.2 Legal bases for processing under Philippine law

We process your personal data based on the following legal bases under Philippine law:

  • Consent – when you provide consent freely, specifically and informed manner
  • Performance of a contract – to fulfill contractual obligations
  • Compliance with legal obligation – to comply with Philippine legal requirements
  • Protection of vital interests – to protect your vital interests
  • Legitimate interests – where processing is necessary for our legitimate interests, provided this does not override your rights and freedoms

14.26.3 Sensitive personal information

Under Philippine law, the following data we collect is considered sensitive personal information and requires additional consent:

  • Biometric data – photos and facial caricatures that can identify you
  • Health information – dietary restrictions or allergies related to health conditions
  • Age – when collected for specific purposes

We process sensitive personal information only with your consent, and we implement strict security measures to protect it.

14.26.4 Your rights under Philippine law

Under the Data Privacy Act, you have the following rights:

  • Right to be informed – be informed about the collection and processing of your personal data
  • Right to access – obtain reasonable access to your personal data
  • Right to object – object to processing, including direct marketing and automated decision-making
  • Right to erasure or blocking – request suspension, withdrawal or removal of your data
  • Right to rectification – request correction of inaccurate or outdated data
  • Right to data portability – receive your data in electronic or structured format and transmit to another controller
  • Right to file a complaint – lodge a complaint with the National Privacy Commission
  • Right to damages – seek damages for violations of your rights

14.26.5 Cross-border transfer of personal data

Your personal data is transferred outside of the Philippines to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under Philippine law, we ensure that cross-border transfers comply with legal requirements through:

  • Ensuring the receiving country has adequate data protection standards
  • Implementing appropriate contractual safeguards
  • Obtaining your consent for the transfer
  • Implementing security measures to protect data in transit and at rest

By using the Service, you consent to the cross-border transfer of your personal data.

14.26.6 Personal data of minors

In accordance with Philippine law, we obtain consent from parents or legal guardians before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent. We take special measures to protect children's privacy and comply with Philippine laws on child protection.

14.26.7 Data breach notification

In the event of a personal data breach, we will:

  • Notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach
  • Notify affected individuals if the breach is likely to give rise to a real risk of serious harm
  • Document the breach and our response as required by NPC regulations
  • Take measures to mitigate harm and prevent future breaches

14.26.8 National Privacy Commission (NPC)

You have the right to lodge a complaint with the Philippine data protection authority:

National Privacy Commission (NPC / Pambansang Komisyon sa Pagkapribado)
Address: 5th Floor, Delegation Building, PICC Complex, Pasay City, Metro Manila, Philippines
Website: https://www.privacy.gov.ph
Email: info@privacy.gov.ph
Hotline: (+632) 8234-2228

The NPC has the authority to investigate complaints, impose penalties, and issue compliance orders for violations of the Data Privacy Act.

14.26.9 Registration with NPC

We comply with registration requirements under the Data Privacy Act as applicable to our operations in the Philippines.

14.26.10 Exercising your rights

To exercise your rights under Philippine law, please contact us at:

Email: info@meni.ge

Subject line: "Data Rights Request" or "Kahilingan para sa Karapatan sa Datos"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within 15 days for access requests, or within a reasonable period for other requests, as required by Philippine law and NPC guidelines.

14.27 For users in Vietnam

If you are a resident of the Socialist Republic of Vietnam, the following provisions apply to you under Vietnamese data protection regulations:

14.27.1 Vietnamese data protection law compliance

We process your personal data in accordance with Vietnamese laws and regulations, including the Law on Cybersecurity (Luật An ninh mạng, Law No. 24/2018/QH14) and the Decree on Personal Data Protection (Nghị định về Bảo vệ dữ liệu cá nhân, Decree No. 13/2023/NĐ-CP), which came into effect on July 1, 2023.

14.27.2 Legal bases for processing under Vietnamese law

We process your personal data based on the following legal bases under Vietnamese law:

  • Consent – when you provide consent freely, specifically and informed
  • Performance of a contract – to fulfill contractual obligations
  • Legal obligation – to comply with Vietnamese legal requirements
  • Vital interests – to protect your vital interests or public health
  • Public interest – for tasks carried out in the public interest
  • Legitimate interests – where necessary for our legitimate interests

14.27.3 Sensitive personal data

Under Vietnamese law, the following data we collect is considered sensitive personal data and requires explicit consent:

  • Biometric data – photos and facial caricatures used for personal identification
  • Health data – dietary restrictions or allergies related to health conditions
  • Data of minors – personal data of persons under 16 years old

We process sensitive personal data only with your explicit consent and implement enhanced security measures.

14.27.4 Your rights under Vietnamese law

Under Vietnamese data protection regulations, you have the following rights:

  • Right to be informed – be informed about the processing of your personal data
  • Right of access – access your personal data
  • Right to rectification – request correction of inaccurate or incomplete data
  • Right to erasure – request deletion of your data in certain circumstances
  • Right to restriction – request limitation of processing
  • Right to data portability – receive your data in structured format
  • Right to object – object to processing
  • Right to withdraw consent – withdraw consent at any time
  • Right to complain – lodge a complaint with the supervisory authority

14.27.5 Cross-border transfer of personal data

Your personal data is transferred outside of Vietnam to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under Vietnamese law, we ensure that cross-border transfers comply with legal requirements through:

  • Obtaining your consent for the transfer
  • Ensuring the receiving country has adequate data protection measures
  • Implementing appropriate contractual and technical safeguards
  • Complying with any data localization requirements

By using the Service, you consent to the cross-border transfer of your personal data.

14.27.6 Personal data of children

In accordance with Vietnamese law, we obtain consent from parents or legal guardians (cha mẹ hoặc người giám hộ hợp pháp) before processing personal data of children under 16 years old.

The Service is not intended for children under 16 without parental consent.

14.27.7 Data breach notification

In the event of a personal data breach, we will:

  • Notify the competent Vietnamese authority as required by law
  • Notify affected individuals if the breach may cause serious harm
  • Take measures to mitigate the effects of the breach
  • Document the breach and our response

14.27.8 Ministry of Public Security - Department of Cybersecurity and Hi-Tech Crime Prevention

For data protection matters in Vietnam, the supervisory authority is:

Ministry of Public Security - Department of Cybersecurity and Hi-Tech Crime Prevention
Bộ Công an - Cục An ninh mạng và Phòng chống tội phạm sử dụng công nghệ cao
Website: https://www.bocongan.gov.vn

14.27.9 Exercising your rights

To exercise your rights under Vietnamese law, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "Yêu cầu quyền về dữ liệu cá nhân"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within a reasonable timeframe as required by Vietnamese law.

14.28 For users in Thailand

If you are a resident of the Kingdom of Thailand, the following provisions apply to you under the Personal Data Protection Act:

14.28.1 Thai data protection law compliance

We process your personal data in accordance with the Personal Data Protection Act (พระราชบัญญัติคุ้มครองข้อมูลส่วนบุคคล พ.ศ. 2562, B.E. 2562 / 2019), which came into full effect on June 1, 2022.

Thailand's PDPA is based on EU GDPR principles and provides comprehensive data protection rights.

14.28.2 Legal bases for processing under Thai law

We process your personal data based on the following legal bases under Thai law:

  • Consent – when you provide consent freely, specifically, informed and unambiguous
  • Performance of a contract – to fulfill contractual obligations
  • Legal obligation – to comply with Thai legal requirements
  • Vital interests – to protect your vital interests or those of another person
  • Public interest or official authority – for tasks carried out in the public interest
  • Legitimate interests – where necessary for our legitimate interests, provided this does not override your rights and freedoms

14.28.3 Sensitive personal data

Under Thai law, the following data we collect is considered sensitive personal data (ข้อมูลส่วนบุคคลที่มีความอ่อนไหว) and requires explicit consent:

  • Biometric data – photos and facial caricatures used for identification
  • Health data – dietary restrictions or allergies related to health conditions

We process sensitive personal data only with your explicit consent. You have the right to refuse consent for sensitive data processing without negative consequences, though this may limit certain features.

14.28.4 Your rights under Thai law

Under Thai PDPA, you have the following rights:

  • Right to be informed – be informed about the collection and processing of your personal data
  • Right of access – access your personal data and request copies
  • Right to data portability – receive your data in structured, commonly used format and transmit to another controller
  • Right to object – object to processing including for direct marketing
  • Right to erasure – request deletion of your data in certain circumstances
  • Right to restriction – request restriction of processing
  • Right to rectification – request correction of inaccurate or incomplete data
  • Right to complain – lodge a complaint with the Personal Data Protection Committee
  • Right to withdraw consent – withdraw consent at any time

14.28.5 Cross-border transfer of personal data

Your personal data is transferred outside of Thailand to servers located in Germany (Frankfurt) and may be processed by service providers in other countries including the United States.

Under Thai law, we ensure that cross-border transfers comply with legal requirements through:

  • Transferring to countries with adequate protection standards (such as EU/EEA countries)
  • Implementing Standard Contractual Clauses
  • Obtaining your consent for the transfer
  • Implementing appropriate security measures

By using the Service, you consent to the cross-border transfer of your personal data.

14.28.6 Personal data of children

In accordance with Thai law, we obtain consent from parents or legal guardians (พ่อแม่หรือผู้ปกครอง) before processing personal data of minors.

Important: In Thailand, persons under 20 years old are considered minors. The Service is not intended for persons under 18 without parental consent.

14.28.7 Data Protection Officer (DPO)

As our operations in Thailand develop, we will appoint a Data Protection Officer (เจ้าหน้าที่คุ้มครองข้อมูลส่วนบุคคล) if required by law.

14.28.8 Personal Data Protection Committee (PDPC)

You have the right to lodge a complaint with the Thai data protection authority:

Personal Data Protection Committee (PDPC / คณะกรรมการคุ้มครองข้อมูลส่วนบุคคล)
Office of the Personal Data Protection Committee
Ministry of Digital Economy and Society
Website: https://www.mdes.go.th
Email: pdpc@mdes.go.th

14.28.9 Exercising your rights

To exercise your rights under Thai law, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request" or "คำขอใช้สิทธิข้อมูลส่วนบุคคล"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within 30 days as required by Thai law.

14.29 For users in Myanmar

If you are a resident of the Republic of the Union of Myanmar, the following provisions apply to you under Myanmar law and regulations:

14.29.1 Myanmar data protection compliance

We process your personal data in accordance with Myanmar laws and regulations, including the Privacy and Security Law (2013), the Electronic Transactions Law (2004), and relevant regulations.

Myanmar is in the process of developing more comprehensive data protection legislation.

14.29.2 Legal bases for processing under Myanmar law

We process your personal data based on the following principles:

  • Consent – when you provide consent for processing
  • Contractual necessity – to provide the Service you requested
  • Legal compliance – to comply with Myanmar legal requirements
  • Legitimate purposes – where necessary for lawful business purposes

14.29.3 Sensitive personal information

We handle the following sensitive information with additional care and security:

  • Biometric data – photos and facial caricatures
  • Health information – dietary restrictions or allergies
  • Personal identification information

We process such data only with your consent and implement appropriate security measures.

14.29.4 Your rights under Myanmar law

Under Myanmar law and international best practices, you have the following rights:

  • Right to information – be informed about the processing of your personal data
  • Right to access – access your personal data
  • Right to correction – request correction of inaccurate data
  • Right to deletion – request deletion of data in certain circumstances
  • Right to object – object to processing
  • Right to withdraw consent – withdraw consent at any time

14.29.5 Cross-border transfer of personal data

Your personal data is transferred outside of Myanmar to servers located in Germany (Frankfurt) and may be processed by service providers in other countries.

We implement appropriate safeguards for international data transfers, including:

  • Contractual protections with service providers
  • Technical security measures (encryption, access controls)
  • Compliance with international data protection standards

By using the Service, you consent to the cross-border transfer of your personal data.

14.29.6 Personal data of minors

In accordance with Myanmar law and international best practices, we obtain consent from parents or legal guardians before processing personal data of minors under 18 years old.

The Service is not intended for children under 16 without parental consent.

14.29.7 Security measures

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication
  • Regular security assessments
  • Employee training on data protection
  • Incident response procedures

14.29.8 Data protection inquiries

For data protection matters in Myanmar, you may contact relevant authorities or industry bodies such as:

Ministry of Transport and Communications
Website: https://www.motc.gov.mm

As Myanmar develops its data protection framework, dedicated supervisory authorities may be established.

14.29.9 Exercising your rights

To exercise your rights or for data protection inquiries, please contact us at:

Email: info@meni.ge

Subject line: "Personal Data Rights Request"

Or use our data deletion page at https://meni.ge/privacy/delete

We will respond to your request within a reasonable timeframe.

15. How to contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, you can contact us at:

Individual Entrepreneur Aleksandr Verbitskii
Registered in the Republic of Georgia
Email: info@meni.ge

Postal address:
6010, საქართველო, ქალაქი ბათუმი, გრიგოლ ელიავას ქუჩა, N 32ე, სართული 2, ბინა N201ა