Privacy Policy

Oversight Division Engineering LLC (d/b/a bavoli) ("Bavoli," "we," "us," or "our") operates the Bavoli restaurant reservation and guest management platform, including the website at bavoli.com, our dashboard application, booking widgets embedded on third-party restaurant websites, and related services (collectively, the "Service").

This Privacy Policy describes how we collect, use, disclose, and protect your personal information when you use our Service, whether you are a restaurant operator ("Restaurant Partner"), a guest making or managing a reservation ("Guest"), or a visitor to our website ("Visitor"). By accessing or using the Service, you agree to the practices described in this Privacy Policy.

1. Information We Collect

1.1 Restaurant Partner Account Information

When you create a bavoli account as a restaurant operator, we collect:

• Identity information: Full name, email address, phone number
• Business information: Restaurant name, address, phone number, website URL, cuisine type, seating capacity
• Account credentials: Email address and encrypted password (or third-party authentication tokens)
• Billing information: Business name, billing address, tax identification number (if applicable)

1.2 Guest Information

When a guest makes a reservation, joins a waitlist, or interacts with a Restaurant Partner through bavoli, we collect:

• Contact information: Name, phone number, email address
• Reservation details: Date, time, party size, seating preferences, special requests
• Dietary information: Allergies, dietary restrictions, or dietary preferences provided voluntarily by the guest
• Guest profile data: Visit history, no-show records, tags and notes added by Restaurant Partners, VIP status, and guest preferences
• Waitlist information: Party size, quoted wait time, contact information for SMS notifications

1.3 Payment Information

We use Stripe as our payment processor. When you provide payment information:

• What Stripe collects: Credit or debit card number, expiration date, CVC, and billing address
• What we store: We do not store full card numbers. We retain only a tokenized reference, the last four digits of the card, card brand, and expiration date for display and identification purposes
• No-show protection: When a restaurant enables card holds or deposit requirements, card details are collected and processed entirely by Stripe. We store only the Stripe token necessary to process the authorized charge

1.4 Usage Data and Analytics

We automatically collect certain information when you use the Service:

• Log data: IP address, browser type and version, operating system, referring URL, pages visited, date and time of access
• Device information: Device type, screen resolution, unique device identifiers
• Operational analytics: Reservation volume (covers), no-show rates, peak booking times, average party sizes, waitlist conversion rates, and other aggregated operational metrics
• Performance data: Page load times, error logs, feature usage patterns

1.5 Cookies and Similar Technologies

We use cookies and similar tracking technologies to:

• Essential cookies: Maintain your authentication session and security tokens
• Functional cookies: Remember your preferences such as theme selection, timezone, and language
• Analytics cookies: We use Google Analytics to understand how users interact with our Service. Google Analytics sets cookies to collect anonymous usage data, including pages visited, time spent on pages, browser type, device type, and general geographic region. This data is aggregated and does not include personally identifiable information

We do not use advertising or behavioral tracking cookies. You can opt out of Google Analytics by installing Google's opt-out browser add-on or by adjusting your browser's cookie settings. For more information on managing cookies, see Section 5.5.

1.6 Information from Third-Party Integrations

When a Restaurant Partner connects third-party services, we may receive:

• Google Reserve: Reservation requests originating from Google Search and Google Maps, including guest name, contact information, party size, and requested date and time
• Point-of-sale (POS) systems: Transaction data, table status, and check information as configured by the Restaurant Partner
• Other integrations: Data from any additional services a Restaurant Partner connects to their bavoli account, limited to what is necessary for the integration to function

1.7 Communications

We collect information from your communications with us, including support requests and correspondence, feedback and survey responses, and any information you voluntarily provide in these communications.

2. How We Use Your Information

2.1 Provide and Maintain the Service

• Operate the reservation management platform and booking widgets
• Create and manage Restaurant Partner accounts
• Enable guests to make, modify, and cancel reservations
• Manage waitlists and table assignments
• Display floor plans and real-time table status

2.2 Process Reservations and Waitlist Management

• Match reservation requests to available time slots and tables
• Manage seating assignments and party flow
• Track guest visit history and preferences for personalized service
• Record no-show data to support Restaurant Partners' no-show protection policies

2.3 Send Transactional Notifications

• Reservation confirmation messages via SMS and email
• Reservation reminder notifications
• Waitlist status updates and table-ready notifications via SMS
• Reservation modification and cancellation confirmations
• No-show protection notifications (card hold authorizations, deposit confirmations)

2.4 Process Payments and Billing

• Process Restaurant Partner subscription payments
• Process no-show fees, deposits, and cancellation charges on behalf of Restaurant Partners
• Generate invoices and billing statements
• Manage subscription upgrades, downgrades, and cancellations

2.5 Analytics and Service Improvement

• Generate operational analytics for Restaurant Partners (covers, no-show rates, peak hours, demand forecasting)
• Analyze aggregated, de-identified usage patterns to improve the Service
• Develop new features based on usage trends
• Monitor Service performance and reliability

2.6 Customer Support

• Respond to support requests and inquiries
• Troubleshoot technical issues
• Provide onboarding assistance

2.7 Marketing Communications

We may send product updates, feature announcements, and tips to Restaurant Partners who have opted in. We do not send marketing communications to guests unless they have explicitly opted in through a Restaurant Partner's marketing features.

2.8 Legal Compliance and Safety

• Comply with applicable laws and regulations
• Enforce our Terms of Service
• Detect, prevent, and address fraud, abuse, or security incidents
• Protect the rights, property, and safety of bavoli, our users, and the public

2.9 Legal Basis for Processing (EU/EEA Users)

We process personal information on the following lawful bases:

• Contract Performance: Processing necessary to provide the Service and manage reservations (Article 6(1)(b))
• Legal Obligation: Tax, financial reporting, and anti-fraud compliance (Article 6(1)(c))
• Legitimate Interests: Analytics, service improvement, and fraud detection (Article 6(1)(f))
• Consent: Marketing communications and optional features (Article 6(1)(a))

For special categories such as dietary restrictions, we rely on explicit consent (Article 9(2)(a)).

3. How We Share Your Information

3.1 With Restaurant Partners

When a guest makes a reservation or joins a waitlist at a restaurant, we share the guest's information with that specific Restaurant Partner, including name, phone number, and email address; reservation details and special requests; dietary restrictions and seating preferences; and visit history and no-show records at that restaurant.

Restaurant Partners access this information through their bavoli dashboard and are responsible for their own use of guest data in accordance with applicable laws.

3.2 Service Providers

We share information with third-party service providers who process data on our behalf:

These providers are contractually obligated to use your data only to perform services on our behalf and in accordance with this Privacy Policy. For a complete list of subprocessors, visit bavoli.com/subprocessors.

3.3 Legal Requirements

We may disclose your information if required to do so by law or in good faith belief that such action is necessary to:

• Comply with a legal obligation, subpoena, court order, or governmental request
• Protect and defend the rights or property of bavoli
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of users of the Service or the public

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

3.5 Aggregated and De-Identified Data

We may share aggregated or de-identified data that cannot reasonably be used to identify you for purposes including industry research, analytics, and marketing. For example, we may publish reports on dining trends based on aggregated reservation data.

3.6 What We Do Not Do

• We do not sell your personal information. We have not sold personal information in the preceding twelve months and have no plans to do so.
• We do not share personal information for cross-context behavioral advertising.
• We do not provide guest contact information to third parties for their own marketing purposes.

4. Data Retention

4.1 Retention Periods

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law:

• Restaurant Partner account data: Retained for the duration of the account and for up to two (2) years following account closure to support reactivation requests and comply with legal obligations
• Guest reservation data: Retained for as long as the Restaurant Partner's account is active. Guest profiles and visit history are maintained to provide the ongoing guest management features that Restaurant Partners rely on
• Payment records: Transaction records are retained for seven (7) years to comply with tax and financial reporting obligations
• Usage and analytics data: Aggregated analytics data is retained indefinitely. Identifiable usage logs are retained for up to twelve (12) months
• Support correspondence: Retained for up to three (3) years following resolution

4.2 Deletion

When personal information is no longer needed for the purposes for which it was collected, we securely delete or anonymize it. Deletion requests are processed as described in Section 5.

Backup copies are retained for up to 30 days beyond original retention. Anonymized data is retained indefinitely (irreversibly de-identified). Deleted data is purged from active databases within 30 days.

4.3 Restaurant Account Termination

Upon restaurant account termination, guest data is retained for 30 days to allow export, then deleted unless required by law or an active reservation exists.

5. Your Rights and Choices

5.1 Access and Portability

You have the right to request a copy of the personal information we hold about you. Restaurant Partners can export their data, including guest lists and reservation history, directly from the bavoli dashboard. Guests may request a copy of their data by contacting us at privacy@bavoli.com.

5.2 Correction

You have the right to request that we correct inaccurate or incomplete personal information. Restaurant Partners can update their account and guest records directly in the dashboard. Guests may request corrections by contacting us at privacy@bavoli.com.

5.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions:

• Restaurant Partners: You may delete your account through the dashboard settings or by contacting us. We will delete your account data in accordance with our retention schedule, subject to legal obligations
• Guests: You may request deletion of your personal information by contacting us at privacy@bavoli.com. Note that some information may be retained as part of a Restaurant Partner's business records where we are the data processor

5.4 Opt-Out of Marketing Communications

• You may unsubscribe from marketing emails by clicking the "unsubscribe" link in any marketing email
• You may opt out of SMS marketing by replying STOP to any marketing message
• Transactional notifications (reservation confirmations, reminders, waitlist alerts) are not marketing communications and are necessary for the operation of the Service. You may stop receiving these by canceling your reservations or removing yourself from waitlists

5.5 Cookie Preferences

The following types of cookies are used by the Service:

• Session cookies (authentication): Essential; expire at session end
• Preference cookies (theme, timezone): Functional; 1-year retention
• Analytics cookies (Google Analytics): Used to collect anonymous usage data such as pages visited, time spent on pages, browser type, device type, and general geographic region. No personally identifiable information is shared with Google. These cookies are set by Google Analytics and are subject to Google's Privacy Policy

Third-party cookies: Stripe and Google may set cookies subject to their own privacy policies. You can opt out of Google Analytics by installing Google's opt-out browser add-on. You can also control cookies via your browser settings. Please note that disabling essential cookies may prevent you from using certain features of the Service, including authentication.

5.6 California Residents — CCPA Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with the following additional rights:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collecting the information, and the categories of third parties with whom we share it
• Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions
• Right to Correct: You have the right to request that we correct inaccurate personal information
• Right to Opt Out of Sale or Sharing: We do not sell or share personal information for cross-context behavioral advertising. Therefore, there is no need to opt out, but you retain this right should our practices change
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights

California Residents have the right to direct us not to sell or share their personal information. We do not currently sell or share personal information. If our practices change, you may opt out by contacting privacy@bavoli.com with "California Privacy Request" in the subject line.

To exercise these rights, please contact us at privacy@bavoli.com. We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf.

Identity Verification: For requests to know or delete, we will verify your identity by matching information you provide against personal information we have on file. We may request account credentials, email verification, or government-issued ID. For guest data requests, we may require authorization from the restaurant that maintains your records.

Categories of Personal Information Collected (preceding 12 months):

During the preceding 12 months, we have shared personal information with the following categories of third parties: (1) Payment processors (Stripe), (2) Communications providers (Twilio, Resend), (3) Cloud infrastructure (Supabase), (4) Google (Google Reserve integration), and (5) Restaurant Partners.

5.7 Other State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights to access, correct, delete, and opt out. To exercise any rights available to you under applicable state law, please contact us at privacy@bavoli.com.

5.8 Do Not Track Signals

Some browsers include a Do Not Track feature. There is currently no industry standard for DNT, and bavoli does not respond to DNT signals. You can control tracking through browser cookie settings.

5.9 Automated Decision-Making

bavoli may use automated processes for demand forecasting, guest preference analysis, and fraud detection. These do not automatically restrict future bookings. You have the right to request human review of automated decisions by contacting privacy@bavoli.com.

6. Security

6.1 Technical Safeguards

We implement industry-standard security measures to protect your personal information:

• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS (Transport Layer Security)
• Encryption at rest: Sensitive data stored in our databases is encrypted at rest
• Row-level security (RLS): Our database enforces row-level security policies, ensuring that Restaurant Partners can only access data belonging to their own restaurant
• Authentication security: We use secure, HTTP-only cookies for session management. Passwords are hashed using industry-standard algorithms and are never stored in plaintext
• Access controls: Internal access to production data is restricted to authorized personnel on a need-to-know basis and requires multi-factor authentication

6.2 Organizational Safeguards

• Regular security assessments and code reviews
• Employee training on data protection and privacy
• Vendor security evaluations for all third-party service providers

6.3 Incident Response

In the event of a confirmed data breach, bavoli will:

• Investigate and contain within 72 hours
• Notify affected individuals without unreasonable delay
• Notify regulatory authorities as required by law
• Provide details of the breach, data affected, measures taken, and recommended precautions
• Offer credit monitoring if payment data was exposed

Notifications will be sent via email; if email is unavailable, via prominent website notice.

While we take reasonable measures to protect your information, no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee absolute security.

7. Children's Privacy

The Service is not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us at privacy@bavoli.com and we will take steps to delete such information promptly.

If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will delete that information as quickly as possible.

8. International Data Transfers

bavoli is based in the United States, and the Service is operated from the United States. If you access the Service from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States, where our servers are located and our central database is operated.

Data protection laws in the United States may differ from those in your country of residence. By using the Service, you consent to the transfer of your information to the United States as described in this Privacy Policy. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy regardless of where it is processed.

For EU/EEA data subjects, bavoli uses Standard Contractual Clauses (SCCs) approved by the European Commission to authorize data transfers to the United States, supplemented by encryption and access controls.

9. Third-Party Links and Widgets

9.1 Booking Widget

bavoli provides an embeddable booking widget that Restaurant Partners place on their own websites. When you interact with this widget on a third-party restaurant website:

• The widget collects your reservation information as described in Section 1.2
• The widget may set cookies necessary for its functionality
• The third-party restaurant website may have its own privacy practices, which are not governed by this Privacy Policy

The booking widget operates under this Privacy Policy. We do not combine widget interaction data with behavioral data from the restaurant's website.

9.2 Google Reserve Integration

When a guest books through Google Reserve (via Google Search or Google Maps), Google transmits the reservation request to bavoli. Google's collection and use of your information is governed by Google's own privacy policy. Once the reservation data reaches bavoli, it is governed by this Privacy Policy.

9.3 Other Third-Party Links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to read the privacy policies of any third-party websites you visit.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

• We will update the "Last Updated" date at the top of this policy
• We will notify Restaurant Partners via email or an in-app notification
• For material changes that affect guests, we will post a prominent notice on our website

We encourage you to review this Privacy Policy periodically. Your continued use of the Service after the effective date of any changes constitutes your acceptance of the revised Privacy Policy.

11. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Privacy: privacy@bavoli.com
• Legal: legal@bavoli.com
• General Support: support@bavoli.com

Oversight Division Engineering LLC (d/b/a bavoli)

Data Protection Officer: If appointed, contact dpo@bavoli.com

When contacting us about a privacy request, please include sufficient information to identify yourself and specify the nature of your request so we can respond promptly.

12. Data Processor and Controller Roles

bavoli acts in different capacities depending on the type of data:

• Data Controller: bavoli is the data controller for Restaurant Partner account information, billing data, and usage analytics
• Data Processor: For guest information collected through reservations and waitlists, bavoli acts as a data processor on behalf of the Restaurant Partner, who is the data controller. Restaurant Partners are responsible for ensuring they have a lawful basis for collecting and processing guest data and for providing appropriate privacy notices to their guests