SENARO
Privacy Policy
How we handle personal data.
Effective: 3 June 2026 · Version 1.0
Senaro is an operating stack for independent restaurants. This policy explains what personal data is processed when you (a) visit senaro.net, (b) book a table at a Senaro venue, (c) use a Senaro venue's WhatsApp / Instagram / website conversation channels, or (d) integrate with Senaro as an agent or developer partner.
1. Who we are
"Senaro" is operated by Bruno Barreto, working under the trading name Senaro (Portugal, NIF on request), with a planned transition to Senaro Unipessoal Lda during 2026. Contact:
2. Roles under GDPR
For each restaurant ("venue") that uses Senaro:
- The venue is the data controller for personal data of its diners (reservations, orders, conversations with that venue).
- Senaro is the data processor for that data — we process it on the venue's behalf, in line with our service agreement with the venue.
For data about visitors to senaro.net itself, Senaro is the data controller.
3. What we process
3.1 If you book a table or order through a Senaro venue
- Your name (provided by you)
- Your phone number (provided by you, with country code)
- Your email address (optional, provided by you)
- The content of your messages with the venue's WhatsApp, Instagram or website channel
- Reservation details: date, time, party size, table, notes you provide
- Order details: items, prices, payment status
- Visit history at that venue (linked to your phone number)
3.2 If you visit senaro.net, /agents, or /llms.txt
- Standard web server logs (IP address, user agent, timestamp, requested URL) — retained 30 days for security and abuse detection
- No cookies are set on senaro.net beyond a session ID used for the optional language preference
- Crawler / agent visits are logged for analytics purposes only
3.3 If you integrate as an MCP or REST partner
- Your contact details (provided in your partner application)
- API call logs (timestamp, calling principal, tool name, venue context) — retained 90 days for audit and abuse detection
4. Why we process it (lawful bases)
- Contract performance (GDPR Art. 6(1)(b)) — to deliver the booking, the order, the conversation reply you asked for
- Legitimate interest (GDPR Art. 6(1)(f)) — server logs, abuse detection, audit trails on tool calls
- Consent (GDPR Art. 6(1)(a)) — where applicable, e.g. optional marketing communications by the venue
- Legal obligation (GDPR Art. 6(1)(c)) — tax records, invoice retention as required by Portuguese law
5. Sub-processors
Senaro uses the following sub-processors to deliver the service. Each operates under its own privacy policy. Personal data is shared only as needed for the service.
| Sub-processor |
Purpose |
Location |
| Hetzner Online GmbH |
Hosting (Senaro infrastructure) |
Germany (EU) |
| Twilio Inc. |
WhatsApp / Instagram / SMS messaging delivery |
USA (Standard Contractual Clauses) |
| Meta Platforms (WhatsApp / Instagram) |
WhatsApp Business Platform and Instagram Messaging |
Ireland (EU) |
| Stripe Payments Europe Ltd. |
Reservation deposits and order payments |
Ireland (EU) |
| OpenRouter Inc. + Anthropic PBC |
Large language model inference for the Conversation AI |
USA (Standard Contractual Clauses) |
| Telegram FZ-LLC |
Operator handover notifications |
UAE |
Each venue may add its own sub-processors (e.g. their own Twilio sub-account, their own Meta Business identity, their own Stripe account) — those are listed in the venue's own privacy statement.
6. Retention
- Conversation messages: 12 months from the last message (rolling cron at 00:05 UTC)
- Reservations: kept while the venue uses Senaro, plus statutory retention periods (typically 10 years for invoiced transactions under Portuguese tax law)
- Customer records (name / phone / email): kept while the venue uses Senaro, or until you exercise erasure
- Web server logs: 30 days
- Partner API call logs: 90 days
7. Your rights (data subject rights under GDPR)
You have the right to:
- Access the personal data we hold about you
- Rectify inaccurate personal data
- Erase your personal data ("right to be forgotten"), subject to legal retention obligations
- Restrict processing of your personal data
- Portability — receive your data in a structured, machine-readable format
- Object to processing based on legitimate interest
- Withdraw consent at any time, where consent is the basis
- Lodge a complaint with the Portuguese supervisory authority — Comissão Nacional de Proteção de Dados (CNPD), cnpd.pt
To exercise any of these rights, email admin@senaro.net. We respond within one month.
8. International transfers
Some sub-processors (Twilio, OpenRouter, Anthropic) are based outside the EU. Transfers are governed by the European Commission's Standard Contractual Clauses (SCCs). No personal data is sold to third parties.
9. Security
Senaro uses HTTPS / TLS for all data in transit, encrypted database fields for sensitive credentials (Stripe keys, etc.), rate limits and signature validation on inbound webhooks, and per-venue isolation of customer data across separate databases.
10. Children
Senaro is not directed at children under 16 and we do not knowingly collect data from children. If a venue's WhatsApp customer turns out to be a minor, the venue (as data controller) is responsible for handling that under the relevant legal regime.
11. Changes to this policy
Material changes will be posted at this URL with an updated effective date. The version history is preserved in the Senaro repository on request.
12. Contact
Privacy enquiries and data subject rights requests: admin@senaro.net