Personal data processing agreement
This English translation is provided for information only. The French version is the only legally binding one.
See also: General terms of sale · General terms of use.
Annex to the general terms of sale. Version of 5 November 2026.
Between the Client, as controller, and DELIVIEW, an SAS (simplified joint-stock company) with share capital of 500 euros, 9 rue Maurice Hubert, 61340 Berd’Huis, France, RCS Alençon 102 681 509, as processor (hereinafter “Deliview”).
Article 1. Purpose
This agreement sets out the conditions under which Deliview processes personal data on behalf of the Client in connection with the Service, in accordance with Article 28 of Regulation (EU) 2016/679 (GDPR). The terms used have the meaning given to them by the GDPR; other terms have the meaning given to them by the Terms of Sale.
Article 2. Description of the processing
The processing is described in Annex A. Deliview acts as controller for its own processing, described in its privacy policy: commercial relationship, invoicing, exchanges with the Client through the messaging service, security of the Service, including its technical logs, and prospecting. This agreement does not cover that processing.
Article 3. Deliview’s obligations
Deliview undertakes to:
- process the data only to provide the Service, on documented instructions from the Client, including for transfers outside the European Union. The Contract and the Client’s use of the Service constitute its instructions. If Deliview considers that an instruction infringes the regulations, it informs the Client immediately. If European Union law or French law requires it to carry out other processing, it informs the Client before carrying it out, unless the law prohibits this;
- ensure that the persons authorised to process the data are bound by a duty of confidentiality;
- implement the security measures in Annex B, appropriate to the risk (Article 32 of the GDPR);
- engage another processor only under the conditions of Article 4;
- assist the Client, through appropriate technical and organisational measures, in responding to requests from data subjects exercising their rights. If a person contacts Deliview directly, Deliview forwards the request to the Client without delay;
- assist the Client in complying with the obligations of Articles 32 to 36 of the GDPR, taking into account the nature of the processing and the information available to Deliview;
- notify the Client of any personal data breach by email, within 48 hours at most of becoming aware of it, with the information listed in Article 33(3) of the GDPR that it has, then the rest as soon as it obtains it;
- at the end of the Contract, as the Client chooses, return the data to the Client or delete it within 30 days, and destroy existing copies, including backups at the end of their retention cycle and the robot’s files at the end of their retention periods (Annex B, 120 days at most after their creation), unless the law requires them to be kept; provide proof of this on request;
- make available to the Client the information needed to demonstrate compliance with this agreement, and allow the audits provided for in Article 6;
- keep the record of the processing activities carried out on behalf of its clients (Article 30(2) of the GDPR).
Article 4. Sub-processors
4.1. The Client authorises Deliview to engage the sub-processors listed in Annex C.
4.2. Deliview informs the Client by email at least 30 days before adding or replacing a sub-processor. The Client may object on legitimate grounds relating to data protection. Failing agreement, the Client may terminate the Contract at no cost before the new sub-processor starts.
4.3. Deliview imposes on each sub-processor, by contract, data protection obligations at least equivalent to those of this agreement. Deliview remains liable to the Client for their performance.
Article 5. Transfers outside the European Union
The Service’s database is hosted in the European Union. Where a sub-processor processes data from a third country or is established there, the transfer is governed by an adequacy decision, in particular the EU-US Data Privacy Framework, or by the European Commission’s standard contractual clauses, as indicated in Annex C.
Article 6. Audits
The Client may ask Deliview for the information needed to check compliance with this agreement. It may have an audit carried out at its own expense, at most once a year, with 30 days’ notice, either by itself or by an independent auditor bound by confidentiality who is not a competitor of Deliview. The audit must neither disrupt the Service nor give access to other clients’ data.
Article 7. The Client’s obligations
The Client gives Deliview its instructions, makes sure that the processing is lawful and informs the data subjects, in particular its Users. It ensures that Deliview complies with the GDPR throughout the processing.
Article 8. Duration
This agreement applies from the creation of the Account, including during the set-up that may precede the formation of the Contract (Article 6.4 of the Terms of Sale), then for the whole duration of the Contract, and until the data is deleted as provided for in Article 3.
Annex A. Description of the processing
| Item | Description |
|---|---|
| Subject matter | Provision of the Deliview Service to the Client |
| Nature of the operations | Collection from Uber Eats Manager and Deliveroo’s Partner Hub, with the access given by the Client; hosting, recording, consultation, display, authentication, transmission to the sub-processors in Annex C, deletion |
| Purposes | Giving the Client’s Users access to the Service, managing their access rights restaurant by restaurant, displaying the sales, reviews and refunds of the Locations, recording the Users’ decisions and requests, applying on the Platforms the changes provided for in Article 13.3 of the Terms of Sale, drafting replies to reviews, disputing refunds, sending notifications, keeping the Account secure |
| Data subjects | The Client’s Users: directors, managers, team members. Customers of the Locations whose orders, reviews, complaints or refunds are read on the Platforms |
| Data processed | Users: name, email address, role, restaurants they can access, invitations, login dates, decisions and requests (prices, promotions, ads, photos, descriptions, disputes, replies to reviews, putting restaurants back online), devices subscribed to notifications. Customers of the Locations: text, rating, date and dishes of their reviews and complaints, number, date and amounts of their orders. Photo or video evidence attached to disputes. The names and contact details of the Locations’ customers are not recorded; a screenshot taken by the robot may however show their first name (Annex B) |
| Sensitive data | None is requested. A review may however mention a customer’s health, for example an allergy: it is flagged as sensitive and always submitted to the Client before any reply |
| Duration | Duration of the Contract, then 30 days at most. Robot files, on the computer where it runs: downloaded reports 45 days, screenshots 30 days, log 120 days |
Annex B. Security measures
- Encrypted exchanges (HTTPS, TLS) between the browser, the app and the database.
- Database hosted in the European Union (Ireland), encrypted at rest by the hosting provider.
- Access control applied to each row of the database: a User only sees the restaurants of their business to which they have access.
- Passwords stored as a hash, never in plain text.
- Access keys to third-party services kept server-side in an encrypted vault, never in the app.
- Administrative access reserved for Deliview’s president, through a separate account.
- Personal invitation links, valid for 14 days and reserved for the invited email address.
- No Platform login details requested or kept.
- Robot that reads the Platforms: it runs on the computer of Tom Voisin, Deliview’s president, with the access given by the Client. It keeps downloaded reports there for 45 days, screenshots of the pages read for 30 days and its log for 120 days, then deletes them, including after the end of the Contract. It only does its rounds from one computer at a time; its files are deleted from the computers that no longer do them. A screenshot shows the whole page as the Platform displays it, and may therefore contain a customer’s first name.
- Backups: database backups provided by Supabase, under the terms of the plan subscribed to.
Annex C. Sub-processors
| Sub-processor | Role | Data location | Safeguards |
|---|---|---|---|
| Supabase Inc. | Database, authentication, server functions | European Union (Ireland) | US company: European Commission standard contractual clauses, provided for in its data processing agreement |
| OVH SAS | Hosting of the interface files; technical logs with IP address | France | No transfer |
| Sendinblue SAS (Brevo) | Service emails, when they are switched on | France | No transfer |
| Anthropic PBC | Claude AI, through its application programming interface (API): the Service’s assistant, replies in “Discuter avec Tom” (Chat with Tom) when Tom Voisin is not available, drafting replies to reviews, feedback on dish photos and descriptions. Data received: questions asked to the assistant, with the account data useful for the answer (sales, fees, recent reviews, menu and prices, promotions and ads, goals, pending requests), including when it replies in “Discuter avec Tom” (the messaging service itself falls under Article 2); text and rating of customer reviews; dish photos and descriptions | United States | European Commission standard contractual clauses, provided for in Anthropic’s data processing agreement |
| Anthropic PBC | Claude AI, to diagnose the robot: log and screenshots that Tom Voisin sends it to fix how a Platform page is read | United States | Transfer to the United States, under the terms of the Claude plan used by Deliview |
| Discord Inc. | Alerts received by Deliview’s president: requests to apply and urgent matters flagged by the assistant, morning update with sales and ratings, a restaurant closing (the trial requests and the excerpts of “Discuter avec Tom” messages he also receives there fall under Article 2) | United States | EU-US Data Privacy Framework, to which Discord adheres (European Commission adequacy decision of 10 July 2023) |
The following receive no personal data of the Users: Firecrawl (Mendable, Inc., United States), which reads the Platforms’ public pages, and the IGN’s Géoplateforme (France), which calculates distances.
Payment for the Subscription goes through Stripe (Stripe Payments Europe, Ireland). It is part of the commercial relationship between Deliview and the Client, which Deliview processes on its own behalf (Article 2): Stripe is therefore not a sub-processor within the meaning of this agreement.