POSPal · Legal
Privacy Notice
The Greek text controls. This English version is provided for convenience only.
Provider / Licensor:
ZOUMPOULIS ERI ROMPERTOS tou EFSTRATIOU
Greek legal name: ΖΟΥΜΠΟΥΛΗΣ ΕΡΗ ΡΟΜΠΕΡΤΟΣ του ΕΥΣΤΡΑΤΙΟΥ
Sole proprietorship — trading as POSPal
Registered address: ΚΥΒΟΠΟΥΛΟΥ ΠΕΤΡΟΥ 13Β, ΜΥΤΙΛΗΝΗ / ΛΕΣΒΟΣ, 81100, Ελλάδα
AFM: 159497740
GEMI: 195335742000
EUID: ELGEMI.195335742000
Controller and licensor: the provider identified above. POSPal currently operates under the Greek small-business VAT exemption regime, so VAT is not added to the subscription fee. Contact: [email protected].
1. Scope and roles
This notice covers pospal.gr, the Windows app, trial, licensing and subscription, Stripe billing, fiscal-profile collection, transactional communications, public Customer Menus, diagnostics, and support reporting.
For operational data the merchant enters for its own purposes—such as orders, notes, or staff/customer details—the merchant is controller. POSPal is a tool and acts as processor only where merchant-controlled data is sent to a cloud feature on the merchant's behalf, subject to the DPA.
2. Predominantly local data
Menus, orders, operational receipts, store settings, printer configuration, local logs, and backups are stored predominantly on the merchant's computer. The app may serve authorised devices on the same LAN. The merchant is responsible for lawful entry, security, backup, retention, and deletion of this local data.
3. Cloud data
| Function | Data | Purpose / basis |
|---|---|---|
| Trial and abuse prevention | Hashed hardware/machine identifiers, identifier tails, IP, dates, version, platform, and tamper indicators | Trial delivery and legitimate interests in security/abuse prevention |
| Licence, account, sessions | Name, email, activation/recovery tokens, hashed identifiers, session/device IDs, language, timezone, screen, platform, browser/user agent, IP, timestamps | Contract and service security |
| Billing | Stripe customer, checkout-session and subscription IDs, status, billing periods, payment failures, amount and currency | Contract and accounting obligations |
| Fiscal profile | Legal/full name, phone, country, AFM/VAT, tax office, activity, address, VAT zone | Lawful fiscal documents and legal obligation |
| Transactional email | Email, verification-code/token hashes, attempts, times, rate-limit IP | Contract, security, legitimate interests |
| Public Customer Menu | Published menu, prices, descriptions, allergens, options, slug, version, device name, appearance, optional logo | Contract after merchant chooses publication |
| Diagnostics | Aggregated errors, funnel steps, app version, request IDs, technical events | Legitimate interests in reliability, security, improvement |
| Support reports | Title, description, steps, version, identifiers/tails, platform and optional redacted diagnostic/log extracts | User-requested support and legitimate interests |
| Website | IP, online identifiers, pages/events, referrer, device/browser and, with consent, measurement or advertising data | Necessary operation, consent for analytics/marketing, and legitimate interests where applicable |
4. Payments and fiscal documents
Stripe collects card and billing data in its checkout; POSPal does not store full card numbers. The bank account to which the provider receives Stripe payouts is not a POSPal customer-payment processor.
Payments are processed through Stripe. Payment confirmations may be provided through Stripe and are not necessarily the statutory Greek fiscal document. Required fiscal documents and accounting obligations are handled separately by the POSPal business. The POSPal application does not automate fiscal-document issuance or transmission to myDATA. The POSPal application does not use an integrated e-invoicing/myDATA provider.
5. Website and trackers
The pospal.gr website is hosted on GitHub Pages. App licensing and data functions are separately provided through Cloudflare Workers/D1/R2, while the public Customer Menu frontend at menu.pospal.gr is delivered through Cloudflare Pages. Google Analytics 4, Google Ads, and Microsoft Clarity load on pospal.gr only after the matching positive choice. Guide videos use YouTube privacy-enhanced mode and do not connect to YouTube before external-media consent. The preference is stored locally and requested again after six months. Details are in the Cookie Policy.
6. GitHub: public reports and updates
In-app reports create a public GitHub issue and may be copied by search engines or caches. POSPal attempts automatic redaction, but users must not include personal, confidential, or payment data. Later deletion cannot guarantee removal of third-party copies. The packaged app checks for and downloads updates from public repositories/artifacts; GitHub receives ordinary request data such as IP, user agent, requested file, and time.
7. Recipients and transfers
Depending on the feature, providers are GitHub Pages for pospal.gr, Cloudflare Workers/D1/R2/Pages for the backend and Customer Menus, Stripe, Resend, GitHub, Google/YouTube, and Microsoft/Clarity. See the Subprocessor List for each provider's role, location, and transfer-mechanism information. Verification of current contractual mechanisms and their application to the specific account for any transfer outside the EEA remains pending.
8. Retention
| Category | Target retention |
|---|---|
| Active account, licence, subscription, and fiscal profile | For the active contract; fields are updated or restricted when no longer necessary |
| Active published menu and logo | While published/active and up to 90 days after cancellation or withdrawal, unless law requires longer |
| Active sessions | While active; 30 days after expiry/revocation |
| Consent preference | 6 months |
| Used/expired email-verification records | 24 hours |
| Funnel and aggregated error data | 90 days |
| Clarity website data | Playback 30 days; click/heatmap and labelled or favourite sessions up to 9 months under current Microsoft documentation |
| Google/other website data | Under the account setting and provider terms; verification and recording of the specific setting remain pending |
| Webhook, delivery, audit, support metadata | 180 days |
| Trial-abuse identifiers | 24 months after trial expiry |
| Cancelled account, menu, logo | 90 days unless deletion is requested sooner or law requires retention |
| Contract acceptance and fiscal records | At least 5 years after the relevant accounting period, or longer for law, dispute, or legal hold |
| Closed public GitHub reports | Owner review for deletion/redaction after 180 days |
The schedule is enforced through a documented manual quarterly review. We do not promise automated deletion. Minimal data may be kept longer for law, security, audit, or legal claims.
9. Sources, required fields, automated rules
We receive data directly from you and the app, automatically from devices/requests, and from Stripe, Resend, Cloudflare, or GitHub for transaction, delivery, hosting, and support status. Checkout, contact, and fiscal-profile fields marked mandatory are required for a paid subscription and lawful fiscal document; without them the related service cannot be completed. Menu publication and support reporting are merchant choices.
Automated rules may reject a repeat trial, flag tampering, restrict a session/licence, or suspend use after a failure reported by Stripe. App data is not used for advertising profiling. You may request human review at [email protected].
10. Rights
You may request access, correction, deletion, restriction, portability, or object where applicable, and withdraw consent without affecting earlier processing. Contact [email protected]. Reasonable identity verification may be required; we normally answer within one month, subject to lawful exceptions. You may complain to the Hellenic Data Protection Authority: https://www.dpa.gr/.
11. Security, changes, children
We use HTTPS, access controls, hashing of selected identifiers, minimisation/redaction, and risk-appropriate safeguards. No system is completely secure. POSPal is a professional product not directed to children. Material changes receive a new revision date and appropriate notice where required.
Acceptance records
POSPal keeps versioned acceptance records containing the relevant document identifier and revision, acceptance timestamp and action context. Where an account is verified, acceptance is linked to that account; anonymous trial acceptance is linked to a technical host identifier. Previous 1.0 records remain historical evidence and do not establish acceptance of this revision. Publication or continued use alone does not establish such acceptance. Acceptance records are stored in the Cloudflare infrastructure described in this notice. Local receipt caches are not independent proof of acceptance.