Privacy Policy

Effective date: 3 June 2026
Last updated: 3 June 2026

Manteco ("we", "us", "our") provides a SaaS management platform for Italian hospitality businesses (restaurants, bars, hotels). This Privacy Policy describes how we collect, use, and protect personal data when you use Manteco at app.manteco.io.

1. Data Controller

Amos Halfon (natural person, pre-incorporation phase)
Via Ignazio Giorgi, 32 — 00162 Roma, Italia
Codice Fiscale: HLFMSA85S01H501R
Email: privacy@manteco.io

Manteco is currently operated by Amos Halfon as a natural person during the pre-launch/beta phase. Upon incorporation of a legal entity, this Privacy Policy will be updated and all users notified.

2. Personal Data We Collect

2.1 Account data

When you register, we collect: full name, email address, hashed password, and the business name(s) you manage.

2.2 Operational data

Data you enter into Manteco to run your business:

• Supplier and product catalogs
• Stock movements, invoices, daily revenue
• Employee names, shift schedules, payroll metadata
• HACCP records (temperatures, cleaning, certificates)
• Customer reviews and replies

2.3 Google Business Profile data (when you connect your Google account)

When you authorize Manteco to access your Google Business Profile, we read and write the following data exclusively through the Google Business Profile API:

• The list of your business locations (name, address, account ID)
• The reviews left by your customers (text, rating, author, date)
• The replies we publish on your behalf (text written by you or AI-generated and approved by you)

We do NOT access, store, or modify: business descriptions, hours, photos, posts, attributes, services lists, menus, or any other information unrelated to reviews and replies.

2.4 Technical data

IP address, user agent, timestamps of API requests for security logging (HTTP server logs, retained 90 days).

3. Why We Process Your Data (Legal Basis)

• Contract performance (Art. 6(1)(b) GDPR): account creation, use of the platform features you subscribe to.
• Legitimate interest (Art. 6(1)(f) GDPR): security logging, fraud prevention, product improvement on aggregated/anonymized data.
• Consent (Art. 6(1)(a) GDPR): connection of your Google Business Profile is voluntary and based on explicit consent that you can revoke at any time.
• Legal obligation (Art. 6(1)(c) GDPR): retention of fiscal data per Italian tax and HACCP requirements (typically 10 years for fiscal records, 5 years for HACCP audit log).

4. How We Use Google Business Profile Data

The data accessed through the Google Business Profile API is used solely to:

1. Display your incoming reviews inside Manteco for you to view.
2. Generate AI-assisted reply suggestions in the same language as the review, using the tone settings you configure for each star rating bracket.
3. Post reply text that you have explicitly approved or that matches the auto-reply rules you have explicitly configured on the corresponding Google review.

We do NOT:

• Use Google data to train AI models. Replies are generated through Anthropic Claude with the prompt containing your business name and tone configuration, but the data is processed transiently and not used to train any model.
• Share, sell, or transfer Google Business Profile data to any third party, except as strictly necessary to operate Manteco (e.g., the AI provider for reply generation — see Section 6).
• Display Google data to anyone outside the authorized members of your business account in Manteco.
• Access Google data for any user analytics, behavioral profiling, or marketing purpose.

5. Data Retention

• Account data: kept until you delete your account, plus 30 days for backup retention.
• Operational data: kept as long as your subscription is active, plus the legal retention periods (10 years for fiscal data, 5 years for HACCP audit, per Italian regulations).
• Google Business Profile data (reviews and replies): kept as long as the connection is active. If you disconnect Google or delete your account, all locally cached reviews and replies are permanently deleted within 30 days. The data on Google's side is not affected by deletion in Manteco.
• HTTP server logs: 90 days.

You can request earlier deletion of any data at any time by emailing privacy@manteco.io.

6. Sub-processors

We use the following service providers to operate Manteco. Each is GDPR-compliant and bound by data processing agreements (DPA):

For US-based sub-processors, transfer is based on EU Standard Contractual Clauses (SCC) plus supplementary measures per the EDPB recommendations following Schrems II.

7. Your Rights (GDPR)

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data ("right to be forgotten")
• Restrict processing
• Data portability (export in machine-readable format)
• Object to processing based on legitimate interest
• Withdraw consent at any time (for Google Business Profile connection: simply click "Disconnect" in Manteco settings, or revoke access from your Google account security page)
• Lodge a complaint with the Italian Garante della Privacy (garanteprivacy.it) or your local DPA

To exercise any of these rights, email privacy@manteco.io. Response within 30 days.

8. Security

• Application-level encryption (Fernet/AES-128 + HMAC) for sensitive tokens (Google refresh tokens, POS API keys)
• Row-Level Security (PostgreSQL) for multi-tenant isolation
• Bcrypt hashing for user passwords
• HTTPS/TLS 1.3 for all data in transit
• Daily encrypted backups
• Access logs and audit trail for HACCP-critical operations

Despite reasonable security measures, no system is 100% secure. We will notify affected users within 72 hours of becoming aware of any data breach affecting their data, per Article 33 GDPR.

9. International Transfers

Data may be transferred to the United States via Railway, Netlify, Anthropic and Google. Transfers are protected by EU Standard Contractual Clauses (SCC) and additional safeguards.

10. Children's Data

Manteco is a B2B platform for hospitality businesses. We do not knowingly collect data from individuals under 16. If you believe we have collected data from a minor, contact privacy@manteco.io.

11. Changes to This Policy

We may update this policy. Significant changes will be notified by email to account owners at least 30 days before the effective date. The current version is always available at manteco.io/privacy.

12. Contact

For any privacy-related inquiry:

• Email: privacy@manteco.io
• Postal mail: Amos Halfon — Via Ignazio Giorgi, 32 — 00162 Roma, Italia
• Data Protection Officer (DPO): not appointed (not required at current scale per Art. 37 GDPR)