Privacy Policy
Last updated: August 10, 2026
1. Data Controller
The data controller responsible for processing your personal data is:
Louis Bienaimé
La Ruai 1
2738 Court, Switzerland
Email: contact@minibarflow.com
This policy applies to the MinibarFlow website (minibarflow.com) and to the service relationship between MinibarFlow and its hotel customers. It explains how we collect, use, store, and protect your personal data in compliance with the EU General Data Protection Regulation (GDPR/RGPD) and the Swiss Federal Act on Data Protection (nLPD/nDSG), in force since September 1, 2023.
For the data processed inside the MinibarFlow mobile application (employee accounts, guest names, room check records, photos, notifications), the detailed reference is the App Privacy Notice. Where the two documents overlap, the App Privacy Notice prevails for app data.
2. Data We Collect
2.1 Account Data
When your hotel registers for MinibarFlow, we collect:
- User name and email address
- Hotel name and property configuration (rooms, buildings, floors)
- User role (Manager, Supervisor, Employee)
Legal basis (GDPR Art. 6(1)(b)): Performance of the service contract between MinibarFlow and your hotel.
2.2 Operational Data
Through normal use of the application, we process:
- Minibar stock levels and product information
- Room check records and shift activity logs
- Trolley loading and reconciliation data
- Consumption and restocking records
- Before/after photos (when the photo verification feature is enabled)
Legal basis (GDPR Art. 6(1)(b)): Performance of the service contract. This data is necessary to operate the minibar management service. The retention and anonymization schedule for these records is detailed in the App Privacy Notice.
2.3 Guest Data
Hotels may enter guest names and dietary preferences into MinibarFlow for billing and room personalization purposes. This data is provided by the hotel (not directly by the guest). In the context of this processing, the hotel acts as the data controller and MinibarFlow acts as a data processor on the hotel's behalf.
MinibarFlow does not invoice guests. When a minibar consumption is recorded, the application transmits the charge information to the hotel's property management system (PMS). The hotel then bills the guest and issues the invoice in its own systems, where the hotel's legal archiving obligations apply.
Legal basis (GDPR Art. 6(1)(f)): Legitimate interest of the hotel for accurate guest billing and service personalization.
Automatic anonymization: Guest names are automatically anonymized 30 days after the room check is completed. After anonymization, consumption data is retained for reporting purposes but can no longer be linked to any individual guest.
2.4 Technical and Device Data
To ensure the application functions correctly, we collect:
- Push notification tokens (device identifiers used to deliver notifications)
- Crash reports and performance metrics (via Firebase Crashlytics and Performance Monitoring), only with the user's explicit consent, given and revocable at any time in the app's privacy settings
Legal basis: GDPR Art. 6(1)(b) (contract performance) for push notification tokens; GDPR Art. 6(1)(a) (consent) for crash reports and performance metrics.
2.5 Website Data
When you visit minibarflow.com, we may collect standard server logs (IP address, pages visited, browser type, referring URL). We also use GoatCounter, a privacy-friendly analytics service, to count page views. GoatCounter uses no cookies and stores no IP addresses and no tracking identifiers; we only see aggregated statistics such as page views, referrers, browser type, and country. We do not use advertising cookies or Google Analytics.
Legal basis (GDPR Art. 6(1)(f)): Legitimate interest in website security, performance, and understanding which pages are useful to visitors.
3. How We Use Your Data
We use your personal data exclusively to:
- Provide and operate the MinibarFlow application
- Generate reports and analytics for your hotel
- Deliver push notifications about shift events, alerts, and system updates
- Diagnose technical issues and improve the application
- Communicate with you about your account and the service
We do not sell, rent, or share your personal data with third parties for marketing or advertising purposes. We do not use your data for profiling or automated decision-making.
4. Data Storage and Cross-Border Transfers
4.1 Storage Location
Your data is stored on Firebase (Google Cloud) servers located in Europe. All data is encrypted at rest and in transit using industry-standard encryption (TLS 1.2+, AES-256).
The MinibarFlow app also stores data locally on your device for offline functionality. This local data is synced securely with our servers when connectivity is restored.
4.2 Cross-Border Transfers
While our primary data storage is in Europe, some of our service providers are based in the United States. Google LLC (parent company of Firebase) may access data from the US for support and maintenance purposes.
Safeguards in place:
- Google LLC is certified under the EU-US Data Privacy Framework (DPF) and the Swiss-US Data Privacy Framework
- We have signed Google's Cloud Data Processing Addendum (CDPA), which includes EU Standard Contractual Clauses (SCCs)
- Data is encrypted at rest and in transit
For transfers to other countries, we rely on adequacy decisions by the European Commission or the Swiss Federal Council, or on Standard Contractual Clauses where no adequacy decision exists.
5. Sub-Processors and Third-Party Services
MinibarFlow uses the following third-party services to operate. Each acts as a data processor or sub-processor:
| Service | Purpose | Data Processed | Location |
|---|---|---|---|
| Firebase / Google Cloud | Authentication, database, file storage, hosting | All application data | Europe (primary), US (support access) |
| Firebase Crashlytics | Crash reporting (with user consent) | Device info, crash logs | US (Google) |
| Firebase Performance Monitoring | App performance metrics (with user consent) | Device info, performance traces | US (Google) |
| Expo Push Service | Push notification delivery | Device push tokens, notification content | US |
| Apple APNs | iOS push notification delivery | Device tokens | US (Apple) |
| Google FCM | Android push notification delivery | Device tokens | US (Google) |
| GoatCounter | Website analytics | Aggregated page view statistics, no cookies, no stored IP addresses | EU (Hetzner, Finland and Germany) |
| Cal.com | Discovery call scheduling | Name, email, meeting time | EU / US |
Each service has its own privacy policy. We ensure all sub-processors provide adequate data protection guarantees through contractual agreements (DPAs) and/or certification under applicable data privacy frameworks.
6. Data Retention
We retain data only as long as necessary for the purposes described in this policy:
| Data Type | Retention Period | Justification |
|---|---|---|
| Hotel customer accounts and contract data | Duration of contract + 2 years | Contract performance + statutory limitation periods |
| Our accounting records and invoices to hotel customers | 10 years | Swiss commercial and tax law (Art. 958f CO, Art. 70 VAT Act) |
| App operational records (room checks, stock movements, shifts) | Duration of contract; personal identifiers removed earlier on the schedule in the App Privacy Notice | Service operation and hotel reporting |
| Guest names | 30 days, then anonymized | Billing accuracy, then data minimization (GDPR Art. 5(1)(e)) |
| Crash reports and performance metrics | Up to 90 days (managed by Google) | Debugging and service stability |
| Website analytics (GoatCounter) | Aggregated statistics only; no personal identifiers are stored | Understanding website usage |
| Scheduling data (Cal.com) | Duration of relationship + 1 year | Business follow-up |
Legal retention periods apply to records, not to identities. The statutory 10 year archiving obligations (Art. 958f CO, Art. 70 VAT Act) cover accounting records: for MinibarFlow, that means our own invoices to our hotel customers. MinibarFlow does not invoice guests; guest charges are billed by the hotel, and the guest invoice is issued and archived by the hotel in its own systems, where the hotel's archiving obligations apply. Where a record we hold is subject to a legal retention period, we keep the record for that period but remove the personal identifiers the law does not require as soon as they are no longer needed. An anonymized record satisfies the record-keeping obligation while it can no longer be linked to a person.
Upon termination of the contract, we delete or anonymize all associated personal data within 30 days, except records subject to a statutory retention period, which are kept for that period with personal identifiers removed where the law does not require them.
7. Your Rights
Under both the GDPR and the Swiss nLPD, you have the following rights regarding your personal data:
- Right of access (GDPR Art. 15, nLPD Art. 25): Request a copy of your personal data
- Right to rectification (GDPR Art. 16, nLPD Art. 32): Correct inaccurate or incomplete data
- Right to erasure (GDPR Art. 17, nLPD Art. 32): Request deletion of your data ("right to be forgotten")
- Right to restriction of processing (GDPR Art. 18): Limit how we use your data in certain circumstances
- Right to data portability (GDPR Art. 20, nLPD Art. 28): Receive your data in a machine-readable format
- Right to object (GDPR Art. 21): Object to processing based on legitimate interest
- Right to withdraw consent (GDPR Art. 7(3), nLPD Art. 6(6)): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing
To exercise any of these rights, contact us at contact@minibarflow.com. We will respond within 30 days.
7.1 Right to Lodge a Complaint
If you believe your data protection rights have been violated, you have the right to lodge a complaint with:
- Switzerland: Federal Data Protection and Information Commissioner (FDPIC/PFPDT): edoeb.admin.ch
- EU: Your national data protection authority (see EDPB member list)
8. Cookies and Tracking
The MinibarFlow website (minibarflow.com) does not use advertising cookies or social media trackers. For visitor statistics we use GoatCounter, which works without cookies and without storing IP addresses or any tracking identifier, so no cookie consent banner is required. We use only essential technical cookies required for the website to function (e.g., session management).
The MinibarFlow mobile application collects crash and performance data through Firebase Crashlytics and Performance Monitoring only with the user's explicit consent, as described in Section 2.4 above and in the App Privacy Notice.
9. Automated Decision-Making
MinibarFlow does not use automated decision-making or profiling as defined by GDPR Art. 22 or nLPD Art. 21. All decisions that affect users are made by human administrators.
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encryption at rest (AES-256) and in transit (TLS 1.2+)
- Role-based access control within the application
- Firebase security rules restricting data access by user role
- Regular security reviews and code audits
- Automatic guest data anonymization after retention period
11. Data Breach Notification
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will:
- Notify the FDPIC (Swiss Federal Data Protection Commissioner) as soon as possible, in accordance with nLPD Art. 24
- Notify the relevant EU supervisory authority within 72 hours where required by GDPR Art. 33
- Inform affected individuals without undue delay if the breach is likely to result in a high risk to their rights (GDPR Art. 34, nLPD Art. 24(4))
12. Data Processing Agreement
When MinibarFlow processes personal data on behalf of a hotel (in particular guest data), MinibarFlow acts as a data processor and the hotel acts as the data controller. The relationship is governed by a Data Processing Agreement (DPA) in accordance with GDPR Art. 28 and nLPD Art. 9, which is provided to hotel customers as part of the service agreement.
13. Changes to This Policy
We may update this privacy policy from time to time. We will notify active users of significant changes via email at least 30 days before they take effect. The "last updated" date at the top reflects the most recent revision.
14. Contact
For any questions about this privacy policy, your personal data, or to exercise your rights, contact us at:
Louis Bienaimé
La Ruai 1
2738 Court, Switzerland
Email: contact@minibarflow.com