Privacy Policy

The owner of the personal data base is the Seller, whose details are specified in section 9 of this Policy.

name, phone number, email (optional), delivery address.

IP address, browser type, site visit time, cookies.

• Processing and fulfillment of orders.
• Communication with the client regarding order status.
• Improving service quality and personalization. Review moderation: a moderator looks at every review before it is published, we match a review of an order against that order (this is how the "Verified order" label appears), and the website and app show the name, rating and text of reviews that have passed moderation. If a review is not published or is removed, we send the author the reason in their account or in the Telegram bot.
• Sending information about promotions and new products (only with your consent: a tick box at registration or in your profile settings; you can opt out in any e-mail or in your profile).
• Compliance with Ukrainian legislation.
• Processing of AI Assistant requests: the AI service receives the text of your messages, the cart contents, brief details of your current, last and most frequent orders, the names of your saved addresses (not the addresses themselves), the delivery comment and promo code. Your name, phone number and profile addresses are not sent. If you type an address or other details into the chat yourself, they are sent together with the text.

consent of the data subject (Art. 6 of Law No. 2297-VI); performance of the contract (public offer); legitimate interests of the owner.

By placing an order or creating an account, you consent to the processing of your personal data in accordance with this Privacy Policy and the Law of Ukraine "On Personal Data Protection".

You have the right to withdraw consent by contacting hello@poligon.vitrina.cafe. Withdrawal of consent does not affect the legality of processing prior to withdrawal.

If you enter an allergy or dietary restriction in the order form and tick the consent box (or entered it in the marketplace app the order came from), we use it only to prepare and hand over that order and delete it together with the order's other contact data within the periods in section 5. The legal basis is your explicit consent (Art. 9(2)(a) GDPR; Art. 7(2)(1) of the Law of Ukraine No. 2297-VI), which you may withdraw by contacting us. You may leave it out and ask the staff about ingredients instead.

Please do not share health information in the chat with the assistant.

If the venue shows dish likes, you can like a dish without signing in. With your first like, the site or app creates a random device identifier and keeps it on your device; it is used only for likes and not for analytics. The identifier itself is not stored on the server: for each like we record the dish, the time and an irreversible hash of the identifier (SHA-256) and, if you are signed in, your account. Likes given from the device before you sign in move to your account once you do. Staff see only how many likes each dish has, not who gave them.

To keep like counts from being inflated, the server counts how many different signed-out devices liked the same dish from one network within a day (by IP address; for IPv6, by the first 64 bits of the address). This counter exists only in the working memory of the server: the address is not written to the database, and restarting the server resets the counter. Purpose: one like per dish from one device or account, and protection of the like count from manipulation. Basis: our legitimate interest in an honest like count (Art. 6(1)(f) GDPR; Art. 11(1)(6) of the Law of Ukraine No. 2297-VI).

A like is kept until you remove it: press the same button again on the same device, or while signed in to the same account. The likes of your account are included in the file downloaded with the “Download my data” button in your profile and are deleted together with the account. If you clear the site data in your browser or delete the app, the identifier disappears from the device; a like given without signing in then remains only in the like count of the dish, and we can no longer link it to you.

Personal data may be transferred to:

• • The processor Complete solution s. r. o. (Slovakia, IČO 56 693 371), which processes the data under a contract with the database owner: it hosts and maintains the website, the app and the till;
• • A delivery partner, chosen by the venue (Glovo, Bolt Food, Uklon, Grand Plus), if your order is delivered by its courier: name, phone number, delivery address and coordinates; the partner processes them as an independent controller under its own policy.
• • The payment system (for payment processing);
• • Government agencies (based on legal requirements);
• • AI technology provider (processing AI Assistant requests): message text, cart contents, brief order details, names of saved addresses; name, phone and profile addresses are not sent.
• • SMS operator (phone number and message text: login codes and order notifications);
• • Email service Resend (email address and letter content: order confirmations, receipts, service emails);
• • Push notification service Expo (device identifier and the order notification text);
• • Mapping services (delivery address and its coordinates, for address search, address field suggestions, route and delivery time calculation);
• • Cloudflare (IP address and technical browser data, for the human verification check). Basis: our legitimate interest in protecting the forms from bots. Cloudflare also uses these signals as an independent controller to improve its bot detection; data may be transferred to the USA on the same grounds as to the hosting providers (below);
• • Error monitoring service Sentry (technical crash data: page address, browser, error stack; request bodies and personal data are stripped before sending);
• • Google, Apple or Facebook (Meta), only if you choose to sign in with their account: we verify the sign-in token with them and receive that account's name, email and profile photo (Apple does not share a photo);
• • Hosting and infrastructure providers (your data is stored on their servers or passes through them): Railway Corp. (USA), for the back end and the PostgreSQL database, scheduled jobs, creating the nightly backup and the weekly check that it can be restored; Vercel Inc. (USA), for the ordering website and the admin panel; Cloudflare, Inc. (USA), for the proxy and DNS through which connections to our servers pass, as well as Cloudflare R2 storage, where the profile photo you upload and encrypted database backups are kept. Transfers outside Ukraine are made to states with adequate protection (Art. 29(3) of Law No. 2297-VI) and otherwise under contractual safeguards provided by the database owner (Art. 29(4)(5));
• • Anthropic PBC (USA), provider of the Claude language model, for the venue's internal reports: if the venue has set up the “Day review” (a daily internal report on the venue's operations for the owner and managers) or the helper in the admin panel that answers the owner's questions about the venue's figures. This is not the site or app usage analytics that requires your consent; the basis is the venue's legitimate interest in overseeing its own work. The model receives aggregated figures and the texts of reasons for cancellations, write-offs and compensation to guests, entered by staff; e-mails, phone numbers and addresses are stripped from them before sending, but a guest's name may remain; reasons for refunds are sent only as a category from a list. Transfers outside Ukraine are made to states with adequate protection (Art. 29(3) of Law No. 2297-VI) and otherwise under contractual safeguards provided by the database owner (Art. 29(4)(5));
• • Anthropic PBC (USA), provider of the Claude language model, if the venue has set up automatic translation of reviews and drafting of replies to them: the text of your review, the ratings and the name of the dish are sent to the model for translation and for a draft of the venue's reply; your name, phone number and other contact details are not sent. If the venue has connected its Google Business Profile, replies to reviews of the venue on Google are prepared the same way: the model receives the text of the review, the rating and the author's name as Google shows them. Transfers outside Ukraine are made to states with adequate protection (Art. 29(3) of Law No. 2297-VI) and otherwise under contractual safeguards provided by the database owner (Art. 29(4)(5));
• • Services that the venue has itself connected to its system through the open API (POS, accounting, CRM, delivery service), only if the venue has allowed such a service to receive guest data: name, phone number, email and delivery address from orders and reservations, as well as profile data (date of birth, bonus balance, number and total of orders). Such a service processes the data under its contract with the venue;
• • The venue's POS system (for example, Poster or Syrve), only if the venue has itself connected it to its ordering system: name, phone number, email, delivery address with its point on the map, the order contents and comments on it, including an allergy note, so that the order reaches the venue's kitchen and till. The POS system processes the data under its contract with the venue;
• • Google Cloud EMEA Limited (Ireland), through the Gemini API service, if the venue enhances dish photos with this service in the admin panel: Google receives only the dish photo itself, without data on where and when it was taken. Staff photograph dishes with no people in the frame, but if a guest accidentally appears in a photo (for example, in the background or in a reflection), Google will also receive their image. Google processes the photos as a processor under the terms of the paid tier of the Gemini API and may process them in any country where it or its subprocessors maintain facilities. Transfers outside Ukraine are made to states with adequate protection (Art. 29(3) of Law No. 2297-VI) and otherwise under contractual safeguards provided by the database owner (Art. 29(4)(5));

In addition, your browser loads some content directly from third-party servers, and those services see your IP address and technical browser data: (1) the Google map on the Contacts page, only after you click “Show map” or enable the “Third-party content” category in the cookie settings (basis: your consent); we arrange the transmission of your data to Google, after which Google processes it on its own under its policy (policies.google.com/privacy) and may set its own cookies; (2) the Google, Apple or Facebook sign-in script, only after you click that sign-in button or enable the “Third-party content” category (basis: your consent and your request to sign in); (3) OpenStreetMap map tiles in the address picker and on the courier map of your order, which cannot work without them (performance of the contract); (4) the Cloudflare Turnstile check on the sign-in, registration, password-reset and phone-confirmation forms, for bot protection (our legitimate interest); (5) default avatars from api.dicebear.com (Florian Körner, Lübeck, Germany). The full list with durations is in the cookie settings (link at the bottom of the page).

We do not sell personal data to third parties.

Personal data is stored for the period necessary to achieve the purpose of processing, but not less than the periods established by law.

The specific periods Полігон applies:

• • An order as a financial document (total, contents, fiscal receipt) is kept indefinitely: tax law requires at least three years, and we do not delete the document once they pass. The guest’s personal data is anonymised separately, under the periods below; the total and contents remain. This period cannot be shortened at a guest’s request.
• • Contact details on a guest order placed without an account (name, phone, e-mail, delivery address, order comment): anonymised 12 months after the order. The total and contents remain, but are no longer tied to a person.
• • Personal data in payment records and fiscal receipts (name, phone, e-mail, masked card number, payer’s address): anonymised after 3 years (1095 days), even if you delete your profile; the total, transaction number, authorisation code and receipt lines remain as a financial document. Guest data in orders from delivery platforms and in requests to delivery partners (name, phone, address, courier, tracking link): anonymised after 12 months.
• • Conversations with the assistant Варенька: 12 months.
• • Order chat with the courier and support requests: 12 months.
• • Delivery logs (the number an SMS code was sent to, or the address an e-mail was sent to, with timestamp and delivery status): 90 days.
• • The courier location track you follow on the map: 30 days.
• • Usage analytics (app and site events): device, session and account identifiers are deleted from an event after 180 days; anonymised events (which event, on which page, when) are kept indefinitely for statistics.
• • Table bookings: your name, phone, e-mail and requests are anonymized 12 months after the visit date. Reviews: the published text and name stay, while the phone and Telegram contact are erased after 12 months; unpublished and rejected reviews are deleted after 12 months. Refund requests: the phone, text and photos are anonymized after 3 years (1095 days). Partnership applications: the contact details and application text are anonymized after 12 months. The notification feed is deleted after 12 months.

Account data is kept for as long as the account exists: deleting your profile anonymises it immediately, without waiting for the periods above. Encrypted database backups keep this data for up to 30 more days (daily backups) and up to 12 more months (monthly backups), until the backup is deleted; backups are needed only to restore the database after a failure. Regardless of any request, the financial part of an order (total, contents, receipt) is kept indefinitely: that is an obligation to the state, not to us.

In accordance with Art. 8 of the Law of Ukraine "On Personal Data Protection", you have the right to:

• • know about the sources of collection and location of your personal data;
• • receive information about the processing of your personal data;
• • demand correction or deletion of your personal data;
• • withdraw consent to the processing of personal data;
• • demand deletion of AI Assistant message history.

You have the right at any time to request the deletion of your personal data under Article 8 of the Law of Ukraine "On Personal Data Protection".

You can delete your account from the Profile page using the "Delete account" button. Profile data, addresses, saved cards and the contact details of completed orders are anonymized immediately. Correspondence, support requests, bookings, contacts in reviews, refund requests and the data in payment records and fiscal receipts are deleted or anonymized later, after the periods stated in the retention section. The total, contents and receipt of your orders remain indefinitely: Ukrainian tax law requires at least three years.

Alternatively, send a request to hello@poligon.vitrina.cafe from the email or phone number associated with your account.

After you delete your account, we keep for 12 months an irreversible fingerprint of your phone number (the number itself cannot be recovered from it) and notes on the one-time offers you have already received: the first-order discount, this year's birthday code, the new-customer referral bonus, "once per guest" promo codes, the treasure chest already opened in the current period, the number of friends you invited, and any bonus debt. Purpose: so that these offers are not received a second time by deleting the account and registering again with the same number. You can register again straight away, and the notes and the debt then move to the new account. After 12 months the record is deleted automatically. Basis: our legitimate interest in protection against abuse (Art. 6(1)(f) GDPR; Art. 11(1)(6) of the Law of Ukraine No. 2297-VI). You can object to this by writing to hello@poligon.vitrina.cafe with your phone number: we will then delete the fingerprint.

How and why we store data in your browser is described in the Cookie Policy and in the “Cookie settings” window at the bottom of every page, where you can change or withdraw your consent at any time. Cookie Policy

You can also restrict or block cookies and browser storage in your browser settings; some features (sign-in, cart) may then not work.

By placing an order or creating an account, you consent to the processing of your personal data in accordance with this Privacy Policy and the Law of Ukraine "On Personal Data Protection".

You have the right to withdraw consent by contacting hello@poligon.vitrina.cafe. Withdrawal of consent does not affect the legality of processing carried out prior to withdrawal.

For questions regarding personal data processing, contact: