Privacy Policy

1. Who we are

This service (Integrate) is operated by Integrate Ink LLC, a Limited Liability Company (LLC) registered in Wyoming, United States. Registered address: 30 N Gould St Ste N, Sheridan, Wyoming 82801, USA. Wyoming Filing ID: 2026-002029445.

Integrate Ink LLC sells Integrate in the following commercial markets: Italy and Colombia. For visitors and customers in Italy, EU General Data Protection Regulation (GDPR) obligations apply. For visitors and customers in Colombia, Ley 1581 de 2012 (protección de datos personales) obligations apply.

2. EU Representative (Article 27 GDPR)

For the purposes of Article 27 of the GDPR, Integrate Ink LLC has appointed an EU representative:

iuro Rechtsanwälte GmbH, trading as Prighter
Schellinggasse 3, 1010 Vienna, Austria

Integrate Ink LLC remains the data controller (and, where we process diner/customer data on behalf of the business we serve, the data processor) for the personal data described in this Privacy Policy. Prighter does not process personal data on our behalf and is not itself a data controller or processor — it acts solely as our appointed point of contact under Article 27 GDPR. EU data subjects and EU supervisory authorities may contact Prighter, in addition to contacting us directly, regarding matters covered by the GDPR.

Prighter Group, together with its local partners, gives you an easy way to exercise your privacy-related rights — for example, requests to access or erase personal data. If you want to contact us via Prighter, or make use of your data subject rights, please visit our Trust Center at app.prighter.com/portal/12278130689.

3. What data we collect

• Business account data:the restaurant/business's name, contact details, and the login credentials of its staff, collected at registration and while using the product.
• Diner/customer data, processed by us on behalf of the business we serve: name, phone number, and — where the business chooses to use these features — call transcripts/recordings, SMS/WhatsApp message content, and booking history. The business is responsible for having a lawful basis (e.g. consent under the GDPR where applicable, or the prior, express, and informed authorization required under Colombia's Ley 1581 de 2012 where applicable) to give us this data; our product records that consent status (see consent_given in the CRM) but does not independently verify it.
• Cookies: first-party cookies for login sessions, security, and display preferences — see the Cookie Policy. We do not use third-party advertising or tracking cookies.

4. Why we process this data

To provide the Integrate service to the business that has contracted with us (performance of a contract), to comply with legal obligations, and — for diner/customer data — on the lawful basis the contracting business has recorded for that individual, consistent with the GDPR (where applicable) and Colombia's Ley 1581 (where applicable).

5. How long we keep it

We apply two distinct retention rules, depending on whether your account is active or has been terminated.

While your account is active:different categories of data have different operational retention periods. Call and message logs are archived after 90 days of inactivity and permanently deleted after 12 months from creation. Other operational records, including bookings/reservations, are retained for as long as they are needed to provide the Services, following your account's normal lifecycle — there is no separate automatic deletion schedule for booking records today. Deleting a customer record anonymizes any linked call/message history rather than leaving personal data behind.

After your account is terminated or you request deletion: your business data and associated diner/customer records may be retained for up to 90 days. During this period your account remains inaccessible, and the data is retained solely for account restoration, fraud prevention, billing disputes, backup recovery, security investigations, and legal compliance. After that period, the data is permanently deleted or irreversibly anonymized, unless a longer retention period is required by applicable law.

Financial, accounting, tax, and other legally required business records may be retained for as long as required by applicable law.

Backups are maintained for disaster recovery and business continuity purposes. Deleted information may temporarily remain in secure backups until those backups expire through the normal rotation process; backup copies are not restored except when necessary for disaster recovery or system restoration. Once backup media reaches the end of its retention cycle, deleted information is permanently removed.

6. Who we share it with

We use a small number of third-party service providers ("subprocessors") to deliver the product — see the full list, purpose, and data shared with each on the Subprocessors page (11providers as of this document's last update). Our subprocessors provide appropriate safeguards for any international transfer of personal data outside the EEA, including mechanisms such as Standard Contractual Clauses, participation in the EU–U.S. Data Privacy Framework where applicable, or other legally recognized transfer mechanisms. A separate Data Processing Agreement, incorporating Standard Contractual Clauses where applicable, is available on request for customers who require one. We do not sell personal data.

7. Automated calls and AI-assisted communication

A business using Integrate may have us place phone calls or send messages to their diners/customers using an AI voice or AI-drafted text, for purposes like booking confirmations, reminders, or promotions. Where a call is placed by our AI calling system, the call script is required to identify itself as an automated/AI assistant calling on the business's behalf, not as a human staff member. Marketing content (ad copy/images) generated with AI tools is reviewed by the business before it is published anywhere. We do not use a business's data, or the AI-generated outputs created for it, to train AI models or for any purpose beyond delivering the Services, without that business's explicit permission.

8. Your rights

Depending on your jurisdiction, you may have some or all of the following rights:

• Under the EU General Data Protection Regulation (GDPR), for visitors and customers in Italy: the right to access, correct, or request erasure of your personal data, to request a copy of it in a portable format, and to object to or restrict certain processing.
• Under Colombia's Ley 1581 de 2012 (habeas data), for visitors and customers in Colombia: the right to know what personal data of yours is being processed, to access it, to update or correct inaccurate or incomplete information, to request proof that valid authorization was obtained where required, to request deletion where legally applicable, and to revoke previously granted authorization where legally applicable.
• Under either law:the right to lodge a complaint with the competent supervisory authority — the Italian Garante per la Protezione dei Dati Personali, or Colombia's Superintendencia de Industria y Comercio (SIC) — after following any required procedure.

To exercise any of the rights above — including access, correction, erasure, restriction, objection, portability, or any other privacy-related request — you may submit it through our GDPR Trust Center at app.prighter.com/portal/12278130689, which lets us securely receive, track, and respond to your request.

You can also direct a request to the business you interacted with directly, or contact us at privacy@integrate.ink; we support access and erasure requests through both the Trust Center above and an internal Data Subject Request process.

9. Data breach notification

If a personal data breach occurs that affects your data, we will notify affected business customers without undue delay, and where feasible within 72 hours of becoming aware of it. Notifications include, where known: the nature of the breach, the categories of data affected, the likely impact, the mitigation measures taken, and recommended actions for the customer.

10. Contact

Privacy questions: privacy@integrate.ink. General support: support@integrate.ink (available in English, Spanish, and Italian). Legal notices: legal@integrate.ink. GDPR-related requests may also be submitted through our Trust Center at app.prighter.com/portal/12278130689.