Privacy Policy

Last updated: August 10, 2026 · Effective from: September 4, 2026

We take the protection of your personal data seriously. In this Privacy Policy you will learn what data we collect, why we collect it, how we process it and what rights you have. This policy applies to the "What's on the menu" mobile application (the "App") available on Google Play and Apple App Store, and the related back-end services.

If you have any questions regarding the processing of your personal data, please contact us at [email protected].

1. Definitions

For clarity we provide the following definitions used throughout this document:

• App – the "What's on the menu" mobile application that helps users discover nearby restaurants, analyse food photos and manage menu items using artificial intelligence.
• Analytical Data – analytics tools and metrics used to understand how our service is used and to improve it.
• Personal Data – any information relating to an identified or identifiable natural person.
• GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation).
• CCPA – California Consumer Privacy Act of 2018.
• EEA – European Economic Area.
• User (also "you") – a natural person who uses the App, whether as a registered or unregistered user.
• Controller – the entity that determines the purposes and means of processing Personal Data (in relation to your data, this is us).
• Processor – an entity we use to carry out certain processing of Personal Data on our behalf.
• Processing – any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• Web – our website www.wotm.cc.
• Marketing Data – data used for advertising, remarketing and measuring how our campaigns perform, including advertising identifiers and information about how you reached and use the App.
• Advertising Identifier – a resettable identifier assigned by your device that allows advertising performance to be measured.
• Remarketing – showing you our advertisements on third-party platforms because you have already used the App.
• Newsletter – informational and commercial e-mail messages about the App that we send only to Users who have asked for them.
• ATT – App Tracking Transparency, the Apple system prompt through which you allow or refuse tracking on iOS.
• Crash Data – technical diagnostic data generated when the App crashes or behaves unexpectedly.

2. Our Approach to Personal Data

Your privacy is our priority. Our App complies with the standards required by the GDPR. If you entrust your data to us, we commit to handling it in accordance with applicable legal regulations (including GDPR and CCPA).

Advertising, Remarketing and the Newsletter are always optional. We never make them a condition of using the App, and none of them start before you have given us your consent.

3. What Personal and Analytical Data We Collect

Depending on how you use the App, we may collect the following categories of data:

3.1 Account & Registration Data

• E-mail address and password (stored in a securely hashed form) – required for account creation and authentication.
• Display name (if provided) – for personalisation within the App.
• Preferred language – so we can display content in your language.

3.2 Device Permissions & Sensor Data

• Location (GPS): Your approximate location, used solely to find nearby restaurants via Google Places API. Location data is sent to Google's servers for the purpose of the search and is not permanently stored by us.
• Camera: Access to your device's camera to capture photos of menus and food items for AI analysis. Photos are transmitted to our server for processing and are not retained longer than necessary.
• Photo gallery: Access to photos stored on your device so you can select existing images for analysis.

3.3 Usage Data

• Information about which features you use, the items you search for, timestamps of activity and error logs.
• IP address and basic device information (OS version, app version) for security, debugging and analytics.

3.4 Subscription, Payment & Credit Data

• Subscription records – the plan you purchased, its status, and start, renewal and expiry dates, together with transaction identifiers we receive from Google Play or the Apple App Store.
• Credit records – your credit balance and the history of credit purchases and consumption. All payment processing is handled by Google Play or the Apple App Store – we never receive or store your payment card details.

3.5 Analytical Data

• Web – we use Google Analytics and Microsoft Clarity. Google Analytics helps us understand aggregated traffic and usage patterns, while Microsoft Clarity records user behaviour on screen.
• App – we use Google Analytics together with our own internal, server-side analytics monitoring.
• Consent state – in the App, every analytics and advertising setting starts switched off. We begin collecting Analytical Data only once you allow it, and we keep your choice on your device together with a record of when you made it.

3.6 Marketing & Advertising Data

• Advertising Identifier of your device, and on iOS the outcome of the ATT prompt.
• Attribution and conversion events – which campaign led to your installation and which key actions you took afterwards (for example completing registration or making a purchase).
• The state of your marketing consent, the moment you granted or withdrew it, and the version of this policy in force at that time.
• Basic device and campaign information (device type, operating system, country, the advertisement you came from).

3.7 Newsletter Data

• E-mail address – so that we have somewhere to send the Newsletter.
• Display name and preferred language – so we can address you properly and write in your language.
• Subscription status, together with the date and source of your consent.
• Delivery and engagement statistics – whether a message was delivered, opened or clicked, so we can tell whether the Newsletter is any good.

3.8 Crash & Diagnostic Data

• Stack traces, device model, operating system version, App version and the time of the crash.
• A pseudonymous installation identifier that lets us recognise repeated crashes on the same device.
• Crash Data never contain your photos, your menus or the content of your searches.

4. Why and on What Legal Basis We Process Your Data

We process your Personal Data on the following legal bases:

5. Third-Party Services (Processors)

We protect your Personal Data and never sell it. If you allow advertising in the App, we do share a limited set of data with advertising platforms so that our campaigns can be measured and shown to the right people. Under the CCPA this counts as "sharing" for cross-context behavioural advertising, and you can switch it off at any time – see Section 13. To provide a high-quality service we use the following third-party providers who may process your data on our behalf:

5.1 Google Places API

Used for searching restaurants and places near your location. Your approximate GPS coordinates are sent to Google's servers. Subject to Google's Privacy Policy.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

5.2 Google Gemini API

Used for AI-powered analysis of food photos and menu items, and for generating food images. Photos you capture or select are sent to Google's AI servers for processing. Subject to Google's Privacy Policy.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

5.3 Server Infrastructure

Our application and database are hosted on secured servers provided by Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany). All data is physically stored in data centres within the European Union (Germany/Finland) in compliance with GDPR standards.

5.4 Google Play / Apple App Store

In-app purchases (subscriptions and credits) and payment processing are handled entirely by Google Play or the Apple App Store, including automatic renewal of recurring subscriptions. We only receive confirmation and identifiers of the purchase – we never access your payment card details. Subject to Google's and Apple's Privacy Policy.

5.5 Public Authorities

In specific cases required by law, we may be obliged to provide your Personal Data to public authorities (e.g. law enforcement, courts, tax authorities).

5.6 Google Analytics

Used for analytical measurement on both the Web and the App – only when we have your consent.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

5.7 Microsoft Clarity

Used for analytical measurement on the Web – only when we have your consent.

Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland.

5.8 Meta Platforms

Used to measure how our advertising campaigns perform and, where you have consented, for Remarketing. We share your Advertising Identifier and information about key events in the App, such as an installation or a purchase. We never share your name, e-mail address, photos or the content of your menus, and we do not upload contact lists to build custom audiences.

Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

5.9 Google Firebase

The technical platform behind analytics, consent settings and crash reporting in the App (Firebase Analytics, Crashlytics and Google Tag Manager for Firebase). Crash reporting runs on our legitimate interest in a stable App; analytics and advertising run only with your consent.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

5.10 Apple SKAdNetwork

Apple's own system for measuring advertising performance on iOS. It tells us that a campaign led to an installation without identifying you – Apple aggregates and delays the results so that individual Users cannot be recognised.

Provider: Apple Inc., One Apple Park Way, Cupertino, CA 95014, United States.

5.11 Ecomail

Used to send the Newsletter and to maintain the list of subscribers. Ecomail processes your e-mail address, your name and language, and statistics on whether a message was delivered, opened or clicked. The data are held primarily on servers within the European Union (Frankfurt); some of Ecomail's sub-processors may operate outside the EEA under Standard Contractual Clauses.

Provider: Ecomail.cz, s.r.o., ID No.: 027 62 943, Na Příkopě 388/1, 110 00 Prague 1, Czech Republic.

6. Marketing, Advertising and Remarketing

We advertise the App on third-party platforms. If you allow it, we also use Remarketing – showing our advertisements to people who have already used the App – and we measure which campaigns actually bring in new Users.

When you first open the App, every analytics and advertising setting is switched off and nothing is sent to advertising platforms. Only if you agree do we enable advertising storage, advertising user data and ad personalisation. If you refuse, or later change your mind, all of them return to the disabled state.

On iOS, Apple additionally asks for your permission through the ATT prompt. We show it only after you have finished the introduction to the App, never on the first screen. If you refuse it, we do not access the Advertising Identifier, whatever you may have set elsewhere in the App.

You can withdraw your marketing consent at any time in the App settings, without giving a reason. Withdrawal takes effect from the moment you make it and does not affect processing that was lawful beforehand.

7. Newsletter

If you ask us to, we will send you a Newsletter with tips for using the App, news about features and occasional offers. We send it only to Users who have actively requested it in the App. Registering an account or making a purchase never subscribes you on its own.

You give this consent in the App by ticking a box that is never pre-ticked and is always separate from accepting our Terms of Service. Refusing it has no effect whatsoever on your ability to use the App. We record the moment you gave your consent so that we are able to prove it was validly given.

You can unsubscribe at any time through the link in the footer of every message, or by switching the Newsletter option off in the App settings. Unsubscribing takes effect immediately and costs you nothing.

8. Data Retention

We process your Personal Data only for as long as is necessary:

• Account data: For the duration of your account. When you delete your account, we erase your data within 30 days (unless legal obligations require longer retention).
• Photos submitted for analysis: Processed in real-time and not stored on our servers longer than necessary for the analysis (typically seconds to minutes).
• Location data: Used in real-time for restaurant search and not permanently stored.
• Subscription, transaction & credit history: Retained for the duration of your account and up to 3 years after deletion for accounting and legal purposes.
• Server logs (IP, errors): Retained for up to 90 days for debugging and security.
• Marketing & Advertising Data: For as long as your consent lasts. Once you withdraw it we stop sending data to advertising platforms immediately, and Google Analytics deletes advertising data no later than 14 months after your last activity.
• Newsletter Data: Until you unsubscribe. After that we keep your e-mail address on a suppression list so that we do not contact you again by mistake.
• Records of consent: For 3 years after a consent is withdrawn, so that we can demonstrate it was validly given.
• Crash Data: Retained for up to 90 days.

9. Data Security

The security of your Personal Data is very important to us. We have implemented a range of technical and organisational measures:

Technical measures

• All data is transmitted over encrypted connections (SSL/TLS, HTTPS).
• Passwords are stored using strong one-way hashing (bcrypt).
• Data at rest on our servers is encrypted.
• Regular data backups in case of technical failure.
• API keys and sensitive credentials are stored in environment variables, never in source code.
• Systems and applications are developed with privacy by design principles.

Organisational measures

• Access to systems containing Personal Data is limited to authorised personnel only.
• All team members are bound by confidentiality obligations.
• Access credentials are individualised and regularly reviewed.

10. International Data Transfers

When we use Processors located outside the EEA (e.g. Google's AI services), we ensure compliance with applicable data protection regulations. For transfers from the EEA to countries without an adequacy decision by the European Commission, we rely on Standard Contractual Clauses (SCCs) or equivalent safeguards to guarantee a high level of protection for your Personal Data.

Meta Platforms and Apple process part of the advertising data in the United States. For those transfers we rely on the EU–US Data Privacy Framework and, where it does not apply, on Standard Contractual Clauses. The same safeguards cover any sub-processor of Ecomail operating outside the EEA.

11. Children and Minors

Our App is intended for users aged 16 years and older. We do not knowingly collect Personal Data from children under 16. If we become aware that we have received personal data from a child without parental consent, we will take reasonable steps to delete such information as quickly as possible. If you believe we may have collected data from a minor, please contact us at [email protected].

12. Your Rights under GDPR

If you are located in the EEA, you may exercise the following rights by contacting us at [email protected]. We will respond without undue delay, and no later than 1 month from receipt of your request (in exceptional cases this may be extended by 2 additional months).

• 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 such data along with information about the purposes, categories, recipients and retention periods.
• Right to rectification: You may request the correction of inaccurate or incomplete Personal Data.
• Right to erasure ("right to be forgotten"): You may request deletion of your Personal Data when it is no longer necessary, when you withdraw consent, or when processing was unlawful. If another legal ground for retention exists, we will inform you accordingly.
• Right to restriction of processing: You may request that we restrict the processing of your data (e.g. while verifying accuracy or if processing is unlawful but you do not wish to delete the data).
• Right to data portability: You may request your Personal Data in a structured, commonly used and machine-readable format, or ask us to transmit it directly to another controller where technically feasible.
• Right to object: If we process your data based on legitimate interest, you may object at any time. If the objection concerns direct marketing, we will always cease processing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right not to be subject to automated decision-making: You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. We do not carry out such automated individual decision-making.

Withdrawing a consent does not require you to write to us. Marketing consent and the Newsletter can both be switched off in the App settings, every Newsletter carries an unsubscribe link, and on iOS tracking permission can be revoked in Settings › Privacy & Security › Tracking.

13. Your Rights under CCPA (California Residents)

If you are a California resident, the CCPA grants you the following rights:

• Right to know: You may request information about what Personal Data we collect, use, disclose or sell, where we obtained it and for what purpose.
• Right to delete: You may request that we delete your Personal Data (subject to legal exceptions).
• Right to opt-out of sale/sharing: We do not sell your Personal Data for money. If you have allowed advertising in the App, we do share your Advertising Identifier and event data with advertising platforms for cross-context behavioural advertising, which the CCPA treats as "sharing". You can stop it at any time by switching marketing consent off in the App settings – this is our "Do Not Sell or Share My Personal Information" mechanism. We never share the data of Users we know to be under 16.
• Right to correction: You may request correction of inaccurate Personal Data.
• Right to non-discrimination: You have the right not to be discriminated against for exercising any of your CCPA rights.

To exercise your CCPA rights, contact us at [email protected]. We may request identity verification to process your request.

14. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy. Changes will be posted on this page and, where appropriate, communicated within the App. By continuing to use the App after a change, you acknowledge the updated policy. We recommend checking this page periodically.

Where a change means we need a fresh consent from you, we will ask you for it again instead of relying on the one you gave before. Until you answer, we treat the affected processing as refused.

15. Contact Us & Complaints

If you have any questions about this Privacy Policy or the processing of your Personal Data, please contact us:

If you are dissatisfied with our approach to personal data protection, you have the right to lodge a complaint with a supervisory authority. In the Czech Republic this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů, Pplk. Sochora 727/27, 170 00 Praha 7, www.uoou.cz). You may also contact the supervisory authority in your country of habitual residence.