Privacy Policy

1. Introduction

FornaxLink, LLC ("FornaxLink," "we," "us," or "our") operates the Tavvi point-of-sale platform and consumer mobile application (collectively, the "Service"). This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our Service.

We are committed to protecting your privacy and ensuring the security of your personal information. By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, please do not access or use the Service.

This Privacy Policy applies to all users of the Service, including consumers who place orders, merchants who operate businesses through our platform, and team members who are employed by merchants.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you voluntarily provide when using our Service, including:

• Account Information: Name, nickname, email address, phone number, date of birth, and password when you create an account
• Business Information: Business name, business address, tax identification numbers, bank account details, and merchant verification documents
• Payment Information: Credit card numbers, debit card numbers, bank account information, and billing addresses processed through our secure payment partner, Stripe
• Transaction Data: Purchase history, order details, order status, refund requests, and payment records
• Loyalty and Rewards Data: Reward point balances, coupon history, redemption records, lifetime spend, and loyalty tier information
• Communications: Customer support inquiries, feedback, reviews, review images, and correspondence with us
• Team Member Data: For merchant users, information about staff members including names, roles, work schedules, clock-in/clock-out times, shift history, and permission settings
• Address Information: Street address, city, state, and ZIP code when provided for delivery or profile purposes

2.2 Information Collected Automatically

When you access our Service, we automatically collect certain information, including:

• Device Information: Device type, operating system, unique device identifiers, browser type, and mobile network information
• Usage Data: Pages visited, features used, time spent on the Service, and interaction patterns
• Location Data: Approximate location based on IP address, and precise location if you grant permission for store locator and nearby store features
• Log Data: IP address, access times, referring URLs, and system activity
• Push Notification Tokens: Device tokens for sending push notifications when you opt in
• Local Device Storage: The Service stores certain data locally on your device (such as cached store and menu data, saved preferences, and offline transaction records) to enable offline functionality and improve performance

2.3 Biometric Information

If you enable biometric authentication (such as Face ID or Touch ID) for accessing the Service or authorizing actions, biometric data is processed entirely on your device by the operating system. We do not collect, store, or transmit biometric data to our servers.

2.4 Information from Third Parties

We may receive information from third parties, including:

• Payment Processors: Stripe provides transaction verification, fraud prevention data, and merchant onboarding status
• Identity Verification: Verification services used during merchant onboarding
• Analytics: Firebase Analytics provides aggregated usage data to help us improve the Service

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Service Operations

• Process payments and facilitate transactions between merchants and customers
• Create and manage your account
• Provide customer support and respond to inquiries
• Enable loyalty programs, rewards tracking, coupon issuance, and promotional offers
• Generate sales reports, analytics, and business insights for merchants
• Route orders to kitchen display systems and manage order fulfillment
• Enable team member management, shift tracking, and access controls

3.2 Security and Compliance

• Detect, prevent, and investigate fraud, unauthorized access, and other illegal activities
• Verify merchant identity and business legitimacy
• Comply with legal obligations, including tax reporting and anti-money laundering requirements
• Enforce our Terms of Service and other agreements

3.3 Service Improvement

• Analyze usage patterns to improve features and user experience
• Develop new products, services, and functionality
• Conduct research and analytics using aggregated, de-identified data
• Test and troubleshoot new features

3.4 Communications

• Send transactional messages (receipts, order confirmations, account updates)
• Provide security alerts and important notices
• Deliver push notifications for order updates (with your consent)
• Send SMS text messages as described in Section 5 below

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 With Service Providers

We share information with third-party service providers who perform services on our behalf, including:

• Stripe: Payment processing, merchant onboarding, and payout services. Stripe's use of your information is governed by the Stripe Privacy Policy
• Google Cloud Platform / Firebase: Cloud infrastructure, data storage, analytics, and push notification delivery
• Twilio: SMS text message delivery and phone number verification
• Resend: Transactional email delivery (receipts, invitations, account notifications)

These service providers are contractually obligated to use your information only as necessary to provide their services to us and in accordance with this Privacy Policy.

4.2 With Merchants and Customers

• Customer information (name, phone number, order details) is shared with merchants to fulfill orders and provide services
• Merchant business information (name, address, hours, menu) is displayed to customers for store discovery
• Transaction history is accessible to both parties involved in a transaction
• Customer reviews are publicly visible to other users when published

4.3 Data Controller and Processor Roles

For customer data collected through merchant stores, the merchant acts as the data controller and FornaxLink acts as the data processor. Merchants determine the purposes for which customer data is used within their stores. FornaxLink processes this data on the merchant's behalf to provide the Service. For data collected directly through the consumer application (account registration, app usage), FornaxLink acts as the data controller.

4.4 For Legal Purposes

We may disclose information when we believe disclosure is necessary to:

• Comply with applicable laws, regulations, or legal processes (including subpoenas and court orders)
• Respond to lawful requests from government authorities, including law enforcement
• Protect the rights, property, or safety of FornaxLink, our users, or others
• Investigate potential violations of our Terms of Service

4.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of the transaction. We will notify you via email and/or prominent notice within the Service of any change in ownership or control of your personal information at least 30 days before any such transfer.

5. SMS Text Messages and Telephone Consumer Protection

5.1 Types of SMS Messages

With your consent, we may send you the following types of text messages:

• Order Status Updates: Notifications when your order is received, being prepared, ready for pickup, or completed
• Account Notifications: Appointment reminders, reservation confirmations, and security alerts
• Team Member Communications: One-time invitation messages sent to phone numbers provided by business owners during team member onboarding

We do not send marketing or promotional text messages.

5.2 Consent

We obtain your explicit, separate consent before sending SMS messages. Consent is collected through:

• A separate SMS opt-in checkbox during account registration (unchecked by default)
• An SMS toggle in your Notification Settings
• For POS customers: verbal consent confirmed by staff via an SMS toggle during customer profile creation

Consent to receive text messages is not a condition of purchasing any goods or services.

5.3 Message Frequency and Rates

Message frequency varies based on your order activity. Typically 1–4 messages per order placed. Standard message and data rates from your wireless carrier may apply.

5.4 Opting Out

You may opt out of SMS messages at any time by:

• Replying STOP to any text message from us (processed immediately)
• Disabling SMS in your account Notification Settings

Reply HELP to any message for assistance. After opting out, you will receive a single confirmation message. You may opt back in by replying START or re-enabling SMS in your settings.

5.5 Phone Numbers

Phone numbers collected for SMS are used solely for the message types described above. We do not sell, lease, or share phone numbers with third parties for their marketing purposes.

For additional details, see our SMS Consent & Compliance page.

6. Data Security

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

• Encryption: All data is encrypted in transit using TLS 1.3 and at rest using AES-256 encryption
• PCI DSS Compliance: Payment processing is handled by Stripe, a PCI DSS Level 1 certified service provider. We do not store complete credit card numbers on our servers
• Access Controls: Role-based access controls and multi-factor authentication for sensitive systems
• Security Monitoring: Continuous monitoring for unauthorized access and security threats
• Firebase Security Rules: Granular access controls ensure users can only access data they are authorized to view

While we strive to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we are committed to implementing and maintaining appropriate safeguards.

7. Data Breach Notification

In the event of a data breach that compromises the security, confidentiality, or integrity of your personal information, we will:

• Investigate and take steps to contain and remediate the breach
• Notify affected users via email and/or through the Service without unreasonable delay, and in any event within the timeframes required by applicable law
• Notify applicable regulatory authorities as required by law
• Provide information about the nature of the breach, the types of data affected, and steps you can take to protect yourself

8. Data Retention

We retain your 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:

• Active Accounts: Account information is retained while your account is active
• Transaction Records: Financial records are retained for 7 years for tax and legal compliance
• Loyalty and Rewards Data: Reward point balances, coupon history, and related data are retained while your account is active and for 1 year after account deletion to support dispute resolution
• SMS Opt-Out Records: Opt-out records are retained indefinitely to ensure continued compliance with your preferences
• Deleted Accounts: Upon account deletion, personal data is removed within 90 days, except where retention is required by law or for the specific purposes noted above
• Anonymized Data: We may retain anonymized, aggregated data indefinitely for analytics purposes. Anonymized data cannot be used to identify you

9. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

9.1 Access and Portability

You have the right to request a copy of the personal information we hold about you in a structured, commonly used, machine-readable format. Merchants may export their transaction history, customer data, and reports through the Service.

9.2 Correction

You may update or correct inaccurate information through your account settings or by contacting us.

9.3 Deletion

You may request deletion of your personal information, subject to legal retention requirements. Some information may need to be retained for legal compliance, fraud prevention, or to complete transactions. We will respond to deletion requests within 45 days.

9.4 Opt-Out Rights

• SMS Messages: Reply STOP to any text message, or disable in Notification Settings
• Push Notifications: Disable through your device settings or through Notification Settings in the Service
• Email Notifications: Disable through Notification Settings in the Service
• Location Services: Disable precise location access through your device settings. Note that disabling location may affect store finder and nearby store features

9.5 Global Privacy Control

We honor Global Privacy Control (GPC) signals. If your browser or device transmits a GPC signal, we will treat it as a valid opt-out request for the sale or sharing of personal information, as applicable under your jurisdiction's law.

10. California Privacy Rights (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of the categories and specific pieces of personal information collected about you in the preceding 12 months
• Right to Delete: Request deletion of personal information, subject to certain exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: We do not sell or share personal information as defined under the CCPA/CPRA
• Right to Limit Use of Sensitive Information: Limit the use of sensitive personal information to what is necessary for the Service
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To exercise these rights, contact us at privacy@fornaxlink.com or write to us at the address in Section 16. We will verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf with written proof of authorization.

We will respond to verifiable requests within 45 days, with a possible 45-day extension if reasonably necessary (with notice to you).

11. Other State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with comprehensive privacy laws may have similar rights to those described in Section 10, including rights of access, deletion, correction, and opt-out. To exercise these rights, contact us at privacy@fornaxlink.com.

If we deny your request, you may appeal by contacting us at the same email address. We will respond to appeals within the timeframes required by your state's law.

12. International Data Transfers

The Service is operated in the United States. Your information is transferred to and processed in the United States, which may have different data protection laws than your country of residence.

When we transfer data internationally, we implement appropriate safeguards, including:

• Standard Contractual Clauses approved by relevant authorities
• Data processing agreements with service providers
• Compliance with applicable data transfer frameworks

By using the Service, you consent to the transfer and processing of your information in the United States.

13. Children's Privacy

Our Service is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. Our account registration requires users to be at least 13 years of age. Users under 18 may use the Service only with the consent and supervision of a parent or legal guardian.

If you believe we have collected information from a child under 13, please contact us immediately at privacy@fornaxlink.com, and we will take steps to delete such information promptly.

14. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies:

• Essential Cookies: Required for basic website functionality, authentication, and security. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website. We use Firebase Analytics for this purpose.
• Preference Cookies: Remember your settings and preferences across sessions.

You can control non-essential cookies through your browser settings. Disabling certain cookies may affect website functionality. The mobile application does not use cookies but does use local storage for caching and preferences as described in Section 2.2.

15. Changes to This Privacy Policy

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

• Update the "Last Updated" date at the top of this policy
• Notify you via email or through the Service at least 30 days before changes take effect
• Provide prominent notice within the Service for significant changes

Your continued use of the Service after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should discontinue use of the Service.

16. Contact Us

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