Legal Information

1. Introduction and Acceptance

These Terms of Service (“Terms”) govern access to and use of LumenChef (the “Services”), a restaurant-operations platform including, without limitation, reservation and table management, unified booking channels, an AI voice agent, customer relationship management (“CRM”), menu and ingredient management, ordering, point-of-sale (“POS”) integration, marketing tools, and analytics, together with any related websites, applications, APIs, and dashboards.

LumenChef is developed, owned, and operated by LumenIA S.r.l., an Italian limited liability company (Società a responsabilità limitata) with registered office at Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy, VAT/Tax Code IT02745940466, REA LU-270629, represented by its legal representative pro tempore (“LumenIA,” “we,” “us,” or “our”).

By creating an account, accessing, or using the Services, the restaurant, hospitality group, or other business entity entering into this agreement (the “Customer,” “you,” or “your”) accepts these Terms in full. If you accept these Terms on behalf of an organization, you represent that you have authority to bind that organization. If you do not agree, you must not access or use the Services.

These Terms incorporate by reference the following documents, each of which forms part of the agreement between you and LumenIA and is available on our website or upon request:

• Privacy Policy
• Cookie Policy
• Data Processing Agreement (“DPA”)
• Acceptable Use Policy (“AUP”)
• Credits, Billing & Refund Policy
• Telephony & Phone Number Policy

In the event of a direct conflict between these Terms and any incorporated document on a matter specifically addressed by that document, the incorporated document shall prevail solely as to that matter.

2. Definitions

2.1 “Services” means the LumenChef software-as-a-service platform, including all current and future modules made available to Customer, whether restaurant-specific or built on the underlying generic booking-and-resource-scheduling engine.

2.2 “LumenONE” means LumenIA’s proprietary artificial intelligence, voice, and automation engine that powers the AI Voice Agent and other AI-driven features within the Services. LumenONE is internal infrastructure of LumenIA and is not a third-party vendor; no separate data processing agreement with LumenONE is required, as LumenIA remains the sole data controller/processor counterparty under these Terms and the DPA.

2.3 “AI Voice Agent” means the LumenONE-powered conversational voice system that answers telephone calls, books, modifies, or cancels reservations, responds to guest inquiries, and escalates to restaurant staff as configured.

2.4 “Booking Credit” or “Credit” means the unit of consumption described in the Credits, Billing & Refund Policy, consumed upon each successful reservation processed through the Services.

2.5 “Customer Data” means data submitted, uploaded, or generated by Customer or its guests through the Services, including reservation records, guest profiles, menu data, order data, and communications.

2.6 “AI Outputs” means any content, suggestion, recommendation, transcription, summary, or decision generated by artificial intelligence features within the Services, including the AI Voice Agent, CRM insights, table-optimization suggestions, and analytics narration.

2.7 “Guest” or “Diner” means an individual who interacts with Customer’s restaurant through the Services, including via phone, chatbot, WhatsApp, or website.

2.8 “Beta Feature” means any feature designated as experimental, preview, early access, or beta.

3. Scope and Applicability

3.1 These Terms apply to all use of the Services by Customer, its personnel, and any authorized users. Customer is responsible for ensuring that its personnel and authorized users comply with these Terms.

3.2 The Services are built on a generic booking and resource-scheduling engine capable of representing tables, staff, rooms, equipment, or other schedulable resources. The current commercial launch of LumenChef is restaurant-focused; references to “reservations,” “tables,” “diners,” and similar restaurant-specific terms throughout these Terms should be read as illustrative of the current use case and do not limit the scope of “the Services” as LumenIA may extend, rebrand, or repurpose the underlying engine for other verticals over time, subject to separate commercial terms where applicable.

3.3 LumenIA reserves the right to unilaterally modify these Terms at any time, including to reflect changes in the Services, applicable law, or business practices. Material changes will be notified to Customer via email or in-app notice with reasonable advance notice, generally not less than thirty (30) days, except where changes are required to comply with law or to address security, fraud, or abuse concerns, which may take effect immediately. Continued use of the Services after the effective date of any change constitutes acceptance of the revised Terms. If Customer does not agree to a material change, Customer’s sole remedy is to terminate the agreement in accordance with Section 14.

3.4 If any provision of these Terms is found invalid or unenforceable by a competent court, that provision shall be modified to the minimum extent necessary to make it enforceable, or severed if modification is not possible, and the remaining provisions shall continue in full force and effect.

4. Eligibility and Registration

4.1 The Services are intended for use by businesses (including sole proprietors acting in a business capacity) operating in the hospitality and food-service sector, or other sectors as LumenIA may authorize. The Services are not directed to consumers acting outside a trade, business, or profession.

4.2 To use the Services, Customer must register for an account and provide accurate, current, and complete information, including business identity, VAT/tax details, and contact information, and must keep such information up to date.

4.3 Customer is responsible for all activity occurring under its account and for maintaining the confidentiality of login credentials, API keys, and access tokens, consistent with Section 11 (Security Responsibilities).

4.4 LumenIA may refuse registration, suspend, or terminate any account at its discretion where eligibility criteria are not met or where required by law or these Terms.

5. License Grant and Restrictions

5.1 Subject to Customer’s compliance with these Terms and payment of applicable fees, LumenIA grants Customer a limited, non-exclusive, non-transferable, non-sublicensable right to access and use the Services during the term of the agreement, solely for Customer’s internal business operations in connection with its restaurant(s) or hospitality venue(s).

5.2 Customer shall not, and shall not permit any third party to:

• reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code, underlying models, prompts, or architecture of the Services, LumenONE, or any AI Voice Agent component;
• scrape, crawl, harvest, or extract data from the Services using automated means not provided or authorized by LumenIA;
• attempt prompt injection, jailbreaking, adversarial manipulation, or other techniques intended to circumvent safety, content, or usage controls of any AI feature;
• resell, sublicense, rent, lease, or provide the Services to third parties as a standalone service without LumenIA’s prior written consent, except in the limited multi-brand scenario described in Section 5.4;
• use the Services to build a competing product or service;
• remove, obscure, or alter any proprietary notices;
• exceed usage limits, rate limits, or fair-use thresholds described in the Acceptable Use Policy;
• use the Services in violation of applicable law, including telecommunications, consumer protection, food safety, or data protection law.

5.3 Violation of this Section 5 constitutes grounds for immediate suspension or termination under Section 10 (Right to Suspend) without prejudice to other remedies available to LumenIA.

5.4 Multi-Brand and Restaurant Group Use. Where Customer is a restaurant group operating multiple venues or sub-brands, Customer may configure the Services across such venues under a single account or linked accounts as agreed with LumenIA. Where such configuration involves presenting the Services or the AI Voice Agent under Customer’s own branding to its guests (“white-label style deployment”), Customer remains solely responsible for the accuracy of guest-facing representations made under its brand, and LumenIA’s liability is governed by Section 13 regardless of the branding under which the Services are presented.

6. Acceptable Use

Customer’s use of the Services, and its guests’ interactions with AI-driven features, are subject to the Acceptable Use Policy, incorporated by reference. The Acceptable Use Policy addresses, among other things, prohibited content, abuse of AI agents (including excessive automation, spam, and robocalling), telephony abuse, scraping, and consequences of violation. LumenIA may suspend or restrict access for violations of the Acceptable Use Policy in accordance with Section 10.

7. Beta Features and Feature Availability

7.1 Beta Features. LumenIA may make Beta Features available for testing and feedback purposes. Beta Features are provided “as is,” may be modified or withdrawn at any time without notice, may not perform reliably, and are excluded from any uptime or support commitments otherwise applicable to the Services. Customer uses Beta Features at its own risk and should not rely on them for critical operations.

7.2 Feature Availability. Availability of specific features (including specific AI capabilities, telephony functionality, WhatsApp integration, or POS integrations) may vary depending on Customer’s subscription plan, country of operation, telephony or messaging provider coverage, and applicable regulatory constraints. LumenIA does not guarantee that all features described in marketing or product materials are available in every jurisdiction or on every plan.

8. Artificial Intelligence Features and Disclaimers

8.1 Nature of AI Outputs. The Services incorporate artificial intelligence and large language model technology, including LumenONE and third-party model providers, to power features such as the AI Voice Agent, CRM insights, table-occupancy optimization, lead scoring, and AI-narrated analytics. AI Outputs are generated probabilistically and may be incomplete, inaccurate, outdated, or entirely incorrect, including so-called “hallucinations.”

8.2 Human Responsibility. Customer is solely responsible for reviewing, verifying, and validating any AI Output before relying on it for operational, commercial, health-and-safety, or legal purposes, including but not limited to allergen information communicated to guests, menu pricing, reservation confirmations, and staffing decisions. LumenIA disclaims responsibility for decisions made by Customer or its guests in reliance on unverified AI Output.

8.3 Automated Decision-Making. Certain AI features (such as table-occupancy optimization or CRM lead scoring) involve automated processing of data. These features are designed as decision-support tools for Customer’s staff and are not intended to produce legal effects or similarly significant effects concerning a data subject without meaningful human oversight. Where applicable data protection law (including Article 22 of the GDPR) grants a data subject the right to object to or request human review of a decision based solely on automated processing, Customer shall route such requests to LumenIA in accordance with the Privacy Policy and DPA, and LumenIA will provide reasonable support to enable human review.

8.4 Alignment with Emerging AI Regulation. LumenIA develops and operates its AI features in a manner consistent with the principles of the EU Artificial Intelligence Act and other applicable AI governance frameworks, including transparency, human oversight, and risk-based design.

9. Telephony, Recording, and Messaging

Use of telephony features (including the AI Voice Agent, hosted or ported phone numbers, and call recording) and SMS/WhatsApp messaging is governed by the Telephony & Phone Number Policy, incorporated by reference. Customer acknowledges that call recording occurs for service delivery, quality assurance, compliance, and dispute-resolution purposes, and that Customer bears responsibility for informing its own callers and guests as required by applicable law, as further described in that policy.

10. Fees, Booking Credits, and Payment

10.1 Access to certain features of the Services is metered through Booking Credits, and other features may be subject to subscription fees, as described in the Credits, Billing & Refund Policy, incorporated by reference.

10.2 Customer authorizes LumenIA (directly or through its payment processor, Stripe) to charge applicable fees using Customer’s designated payment method, and to invoice Customer where manual invoicing applies (including during the current MVP phase of the Services).

10.3 All fees are exclusive of applicable value-added tax (“VAT”) and other taxes, which shall be added where legally due, as further described in the Credits, Billing & Refund Policy.

10.4 Non-payment may result in suspension of the Services in accordance with Section 10 of these Terms and the Credits, Billing & Refund Policy.

11. EU Consumer Right of Withdrawal

11.1 The Services are provided to Customer as a business customer for professional purposes. Where, notwithstanding the foregoing, a Customer qualifies as a “consumer” under applicable EU or Italian law, such Customer has a right to withdraw from the contract within fourteen (14) days of conclusion, without giving any reason, in accordance with Legislative Decree 206/2005 (Codice del Consumo) and Directive 2011/83/EU.

11.2 Where Customer requests that the Services begin before expiry of the withdrawal period, Customer acknowledges that, to the extent permitted by law, the right of withdrawal may be lost once the Services have been fully performed, or a proportionate amount may be due for services already supplied up to the point of withdrawal.

11.3 To exercise the right of withdrawal, Customer must notify LumenIA in writing to [email protected] or by PEC to [email protected] before expiry of the withdrawal period.

12. Intellectual Property

12.1 LumenIA Ownership. The Services, including all software, AI agents, prompts, workflows, APIs, generated system logic, documentation, and all underlying and related intellectual property rights, are and remain the exclusive property of LumenIA (or its licensors), whether or not specifically identified as such. Nothing in these Terms transfers ownership of any such intellectual property to Customer, except as explicitly agreed in a separate written agreement.

12.2 Customer Data. As between the parties, Customer retains ownership of Customer Data. Customer grants LumenIA a worldwide, non-exclusive license to host, process, transmit, and use Customer Data solely as necessary to provide, maintain, secure, and improve the Services, and as further described in the Privacy Policy and DPA.

12.3 AI Training on Anonymized Data. LumenIA may use Customer Data in anonymized or aggregated form, from which no individual guest or Customer can reasonably be identified, to train, improve, and validate its AI models and features, including LumenONE, unless Customer opts out through a mechanism made available by LumenIA.

12.4 Usage Analytics. LumenIA may collect and use anonymized or aggregated usage analytics regarding how the Services are used (e.g., feature adoption, performance metrics) for product improvement, benchmarking, and business intelligence purposes, without identifying Customer or its guests to third parties.

12.5 Feedback. If Customer or its personnel submit suggestions, ideas, or feedback regarding the Services, LumenIA may use such feedback without restriction or compensation to Customer, and Customer hereby assigns to LumenIA any rights it may have in such feedback to the extent necessary for LumenIA to use it freely.

12.6 Export and Data Portability. Where technically available within the Services, Customer may export Customer Data in formats offered by the Services from time to time. LumenIA is not obligated to preserve historical export formats indefinitely and may modify available export formats as the Services evolve. Upon termination, Customer may request an export of Customer Data as described in Section 14.

13. Warranty Disclaimer and Limitation of Liability

13.1 AS IS. Except as expressly stated in these Terms, the Services are provided “AS IS” and “AS AVAILABLE,” without warranties of any kind, whether express, implied, or statutory, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement. LumenIA does not warrant that the Services will be uninterrupted, error-free, or fully secure, and does not guarantee any specific uptime level except as separately agreed in a service-level agreement, if any.

13.2 Limitation of Liability. To the maximum extent permitted by applicable law, LumenIA’s aggregate liability arising out of or relating to these Terms or the Services, whether in contract, tort, or otherwise, shall not exceed the total fees paid by Customer to LumenIA in the twelve (12) months preceding the event giving rise to the claim.

13.3 Exclusion of Indirect Damages. To the maximum extent permitted by applicable law, in no event shall LumenIA be liable for indirect, incidental, special, consequential, exemplary, or punitive damages, including loss of profits, revenue, goodwill, data, or business opportunity, even if advised of the possibility of such damages.

13.4 Carve-Outs. Nothing in these Terms limits or excludes liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any other liability that cannot be limited or excluded under applicable law.

13.5 No Liability for Third-Party Integrations. The Services integrate with third-party providers, including Meta (WhatsApp), Telnyx (telephony), Stripe (payments), Google, OpenAI, and Anthropic (AI model providers), Vercel (hosting), Cloudflare (DNS/CDN), Resend (email), and restaurant POS vendors. LumenIA is not liable for outages, API changes, rate limiting, security incidents, or discontinuation of service by such third parties, though LumenIA will use commercially reasonable efforts to mitigate impact on Customer where feasible.

14. Term, Suspension, and Termination

14.1 Term. These Terms remain in effect for as long as Customer maintains an active account or subscription, unless terminated earlier in accordance with this Section.

14.2 Right to Suspend. LumenIA may suspend or restrict Customer’s access to the Services, in whole or in part, immediately and without prior notice where LumenIA reasonably believes suspension is necessary due to: (a) suspected fraud or illegal activity; (b) violation of the Acceptable Use Policy or these Terms; (c) non-payment of fees or a zero Booking Credit balance, as described in the Credits, Billing & Refund Policy; (d) security threats or vulnerabilities; or (e) requirements of applicable law or a competent regulatory or judicial authority. LumenIA will, where practicable, notify Customer of the suspension and the reason for it.

14.3 Termination. Either party may terminate the agreement for convenience by providing notice in accordance with the applicable subscription terms. LumenIA may terminate immediately for material breach that is not cured within a reasonable period after notice, or immediately in cases of fraud, illegal activity, or serious security risk.

14.4 Effect of Termination. Upon termination, Customer’s right to access the Services ceases. Customer may request export of Customer Data within a reasonable period following termination, as described in Section 12.6, after which LumenIA may delete Customer Data in accordance with its data retention practices and the Privacy Policy, subject to any legal retention obligations.

14.5 Survival. Provisions that by their nature should survive termination (including Sections 12, 13, 15, 16, and 18) shall survive.

15. Indemnification

Customer shall indemnify, defend, and hold harmless LumenIA and its officers, directors, employees, and agents from and against any claims, damages, liabilities, costs, and expenses (including reasonable legal fees) arising out of or relating to: (a) Customer’s use of the Services in violation of these Terms or applicable law; (b) Customer Data, including guest data processed through the Services; (c) Customer’s failure to comply with regulatory or disclosure obligations described in Section 17; or (d) disputes between Customer and its guests.

16. Force Majeure

Neither party shall be liable for any failure or delay in performance to the extent caused by circumstances beyond its reasonable control, including acts of God, war, terrorism, civil unrest, governmental action, pandemic, internet or telecommunications failures, failures of third-party providers (including cloud hosting, telephony, or payment infrastructure), or other events of force majeure. The affected party shall notify the other party and use commercially reasonable efforts to mitigate the impact.

17. Regulatory Compliance

Customer is solely responsible for compliance with all laws and regulations applicable to its own business, including but not limited to: food safety and hygiene regulations; allergen disclosure and labeling requirements; tax obligations, including VAT and local business taxes; telecommunications and call-recording disclosure obligations; consumer protection law applicable to Customer’s dealings with its guests; and any sector-specific licensing requirements. LumenIA provides tools that may assist with certain aspects of compliance (e.g., allergen fields in menu management, IVR recording notices) but does not act as Customer’s legal, tax, or regulatory advisor.

18. Data Protection

The processing of personal data in connection with the Services, including guest data collected through reservations, the AI Voice Agent, and marketing features, is governed by the Privacy Policy and the Data Processing Agreement, incorporated by reference. Customer acts as data controller with respect to its guests’ personal data, and LumenIA acts as data processor, except where otherwise specified in the DPA. Questions regarding data protection may be directed to [email protected] or to the Garante per la Protezione dei Dati Personali, Piazza Venezia 11, 00187 Roma, https://www.garanteprivacy.it, [email protected].

19. Security Responsibilities

Customer is responsible for: (a) protecting the confidentiality of account credentials, API keys, and access tokens; (b) assigning appropriate roles and permissions to its staff within the Services; (c) monitoring account activity for unauthorized use; and (d) promptly notifying LumenIA at [email protected] of any suspected security incident involving the Services. LumenIA implements technical and organizational security measures as described in the DPA but cannot guarantee absolute security.

20. No Exclusivity; Right to Modify the Platform

20.1 No Exclusivity. Nothing in these Terms grants Customer any exclusivity, and LumenIA remains free to provide the Services, LumenONE, or similar products to any other business, including Customer’s competitors.

20.2 Right to Modify. LumenIA may modify, update, add to, or remove features of the Services at its discretion, including to improve functionality, security, or performance, or to comply with law. Such modifications shall not be deemed a breach of these Terms, provided that LumenIA will not materially degrade core paid functionality that Customer has specifically contracted for during a committed term without providing reasonable notice or an equivalent alternative, respecting existing contractual commitments.

21. Assignment

LumenIA may assign or transfer these Terms, in whole or in part, without Customer’s consent, in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its relevant assets. Customer may not assign these Terms without LumenIA’s prior written consent, except to a successor entity in connection with a merger or sale of Customer’s business, provided the successor agrees to be bound by these Terms.

22. Governing Law and Jurisdiction

22.1 These Terms are governed by the laws of Italy, without regard to conflict-of-laws principles.

22.2 Any dispute arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the Court of Lucca, Italy, save for mandatory consumer-protection venue rules that may apply where Customer qualifies as a consumer.

22.3 EU consumers may also access the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr/.

23. General Provisions

23.1 Entire Agreement. These Terms, together with the incorporated documents referenced in Section 1, constitute the entire agreement between the parties regarding the Services and supersede any prior agreements or understandings on the same subject matter.

23.2 Waiver. No failure or delay by LumenIA in exercising any right under these Terms shall operate as a waiver of that right.

23.3 Severability. See Section 3.4.

23.4 Notices. Notices to LumenIA shall be sent to [email protected] or by PEC to [email protected]. Notices to Customer shall be sent to the contact details registered on Customer’s account.

23.5 Language. These Terms may be made available in multiple languages for convenience. In the event of any discrepancy, the Italian version, where available, shall prevail for interpretation purposes before Italian courts, unless otherwise agreed in writing.

23.6 Relationship of the Parties. The parties are independent contractors. Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between the parties.

23.7 No Third-Party Beneficiaries. These Terms do not confer any rights or remedies upon any person other than the parties, except as expressly stated.

24. Contact Information

LumenIA S.r.l. Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy VAT/Tax Code: IT02745940466 — REA: LU-270629 PEC: [email protected] Email: [email protected] Phone: +39 344 138 1927 Website: https://www.lumenia.net

1. Introduction and Data Controller Identity

This Privacy Policy describes how LumenIA S.r.l. (“LumenIA,” “LumenChef,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data in connection with the LumenChef platform (the “Service”).

• Legal name: LumenIA S.r.l., an Italian limited liability company (Società a responsabilità limitata)
• Registered office: Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy
• VAT/Tax Code: IT02745940466
• REA: LU-270629
• PEC (certified email): [email protected]
• Privacy/general email: [email protected]
• Phone: +39 344 138 1927
• Website: https://www.lumenia.net

For all matters relating to this Privacy Policy, or to exercise any of the rights described below, you may contact us using the details above.

2. Scope of Application — Controller vs. Processor

LumenChef is a vertical SaaS platform for restaurants that relies on LumenONE, an internal AI/voice/automation engine operated by the same legal entity, LumenIA S.r.l., as its underlying AI and voice processing component. LumenONE is not a separate external vendor; it is internal infrastructure. Because it processes personal data on LumenIA’s behalf and at LumenIA’s direction, it is nonetheless listed transparently among the categories of processing components and sub-processors described in Section 8.

This Policy applies differently depending on whose personal data is at issue and in what capacity LumenIA is acting:

• Where the restaurant (LumenChef’s paying customer, the “Restaurant”) is Data Controller: the Restaurant determines the purposes and means of processing its own guests’/diners’ personal data (“End User Data”), such as reservation details, dietary preferences, order history, and communications made through the Service. LumenIA acts solely as Data Processor for this End User Data, processing it strictly under the Restaurant’s documented instructions, pursuant to a separate Data Processing Agreement (DPA) executed with each Restaurant customer.
• Where LumenIA is Data Controller: LumenIA determines the purposes and means of processing personal data relating to (i) its website visitors, (ii) Restaurant account holders and staff who use the Service, (iii) billing contacts, and (iv) marketing leads and newsletter subscribers. For this data, LumenIA acts as Data Controller under the EU General Data Protection Regulation (GDPR — Regulation (EU) 2016/679) and applicable Italian data protection law.

In summary:

• Restaurant staff / account holders — Account & staff data — LumenIA’s role: Controller
• Billing contacts — Billing & invoicing data — LumenIA’s role: Controller
• Diners / guests of the Restaurant — Reservation, CRM, voice, chat, order data — LumenIA’s role: Processor (Restaurant is Controller)
• Website visitors — Technical & usage data — LumenIA’s role: Controller
• Marketing leads / newsletter subscribers — Contact & engagement data — LumenIA’s role: Controller

Where LumenIA acts as Processor, questions or requests regarding End User Data should generally be directed first to the Restaurant, which remains responsible as Data Controller. LumenIA will nonetheless honor direct requests from diners as described in Section 9.

3. Definitions

• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Processing” means any operation performed on personal data, whether automated or not.
• “Data Controller” means the entity that determines the purposes and means of processing personal data.
• “Data Processor” means the entity that processes personal data on behalf of, and under the instructions of, a Data Controller.
• “End User Data” means personal data of a Restaurant’s diners/guests collected through the Service.
• “Restaurant” means the business entity that has subscribed to LumenChef and is the Data Controller for its own diners’ data.
• “LumenONE” means LumenIA’s internal AI, voice, and automation engine that powers LumenChef’s AI Voice Agent and related automation features.

4. Categories of Personal Data We Process

A. Restaurant Account & Staff Data (LumenIA as Controller)

Name, email address, phone number, job role, restaurant name and VAT number, account credentials (hashed passwords, authentication tokens).

B. Billing Data (LumenIA as Controller)

Billing address, payment instrument metadata (note: card and payment credential data is held directly by our payment processor, e.g., Stripe, and is not stored by LumenIA), transaction history, invoices, and booking credit balance/usage.

C. Diner/Guest Data (LumenIA as Processor, on behalf of the Restaurant)

• Reservation contact details: name, phone number, email address
• Reservation details: party size, special requests, allergies, dietary notes
• CRM data: visit history, average spend, favorite dishes, birthdays, loyalty status
• Voice call recordings and transcripts generated by the AI Voice Agent
• Chat and WhatsApp conversation transcripts
• Order data (dine-in, takeaway, delivery)

D. Technical & Usage Data (LumenIA as Controller)

IP address, device and browser information, authentication logs, feature usage data, error and diagnostic logs.

E. AI-Specific Data

AI prompt history and model inputs, AI-generated outputs, embeddings/vector representations, and behavioral analytics tied to AI interactions. This data is processed on the Restaurant’s behalf (LumenIA as Processor), except where it has been anonymized or aggregated for platform improvement purposes, in which case LumenIA processes it as Controller on the basis of legitimate interest.

As LumenChef’s features evolve, the categories of data processed may expand to reflect new modules. Material changes will still be communicated in accordance with Section 12.

5. Purposes and Legal Bases for Processing

• Account creation, service delivery, reservations, AI processing — Legal basis: Performance of a contract (Art. 6(1)(b) GDPR)
• Billing, invoicing, tax compliance — Legal basis: Performance of a contract and legal obligation (Art. 6(1)(b)/(c) GDPR)
• Security, fraud prevention, abuse monitoring — Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) and legal obligation
• Service improvement and AI model performance analysis using anonymized/aggregated data — Legal basis: Legitimate interest (Art. 6(1)(f) GDPR)
• LumenIA’s own marketing and newsletters to Restaurant customers — Legal basis: Consent (Art. 6(1)(a) GDPR) and legitimate interest
• A Restaurant’s own marketing campaigns to its diners (e.g., WhatsApp, email) — Legal basis: the Restaurant, as Data Controller, is solely responsible for establishing and maintaining its own legal basis; LumenChef acts merely as the tool/processor facilitating such communications

Automated Decision-Making and Profiling

LumenChef’s AI features may involve automated processing for purposes such as table allocation optimization and lead scoring. This processing is carried out on the basis of legitimate interest and does not produce legal effects or similarly significant effects on individuals without human oversight. Where applicable, individuals retain the rights described in Section 9 with respect to automated decision-making, including under Article 22 GDPR.

6. Data Retention

LumenIA retains personal data only for as long as necessary for the purposes described in this Policy, or as required by law. Detailed retention periods are set out in the Data Retention & Deletion Policy, and in summary:

• Restaurant account & registration data: duration of the contract plus 10 years, in accordance with Italian tax and accounting law (D.Lgs. 82/2005)
• Billing/payment data: 10 years from the date of the transaction
• Reservation & CRM data (diner profiles): retained while the Restaurant account is active; deleted or anonymized within 30 days of Restaurant account closure, unless the Restaurant requests earlier deletion or a diner exercises erasure rights directly against LumenIA
• Voice recordings (AI Voice Agent): retained as necessary for service delivery, quality assurance, compliance, and dispute resolution; our telephony sub-processor, Telnyx, retains recordings for up to 1 year unless earlier deleted, per its own policy
• Chat/WhatsApp transcripts: retained until the Restaurant or diner requests deletion, or until account closure
• Security/authentication logs: 24 months
• Marketing data: until consent is withdrawn or an opt-out is received, plus a reasonable period to process the opt-out
• Backups: retained for up to 10 years in secure archival storage for disaster recovery and business continuity purposes

7. How We Share Personal Data — Recipients

We may share personal data with:

• Restaurant personnel authorized to access data relevant to their operations
• Service providers and sub-processors who process data on our behalf (see Section 8)
• Professional and legal advisors, where necessary
• Law enforcement authorities, regulators, or courts, where required by law
• A successor entity in connection with a merger, acquisition, or sale of assets

8. Sub-Processors and International Data Transfers

Our primary hosting infrastructure is located in the European Union. Certain sub-processors may process personal data outside the European Economic Area (EEA), including US-based AI providers and certain payment and telephony providers. Where this occurs, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (SCCs) and/or the EU-US Data Privacy Framework (DPF).

Categories of recipients and sub-processors include:

• Cloud hosting: Vercel, Supabase
• AI providers: OpenAI, Anthropic, Google, and our internal LumenONE engine
• Telephony: Telnyx
• Payments: Stripe
• WhatsApp messaging: Meta Platforms Ireland Limited
• CDN / DNS / security: Cloudflare
• Transactional email: Resend
• Legal / professional advisors
• Law enforcement / regulators, where legally required

A complete and current list of sub-processors is maintained in the Sub-Processor List, which is updated regularly as our vendor relationships evolve.

9. Your Rights Under the GDPR

If you are located in the European Union/EEA (or otherwise entitled to GDPR protections), you have the following rights with respect to your personal data:

• Right of access (Art. 15) — to obtain confirmation of whether we process your data and a copy of it
• Right to rectification (Art. 16) — to correct inaccurate or incomplete data
• Right to erasure / “right to be forgotten” (Art. 17) — to request deletion of your data, subject to applicable grounds and exceptions (e.g., legal retention obligations)
• Right to restriction of processing (Art. 18) — to request that we limit how we use your data in certain circumstances
• Right to data portability (Art. 20) — to receive your data in a structured, commonly used, machine-readable format
• Right to object (Art. 21) — to object to processing based on legitimate interest or for direct marketing purposes
• Right not to be subject to solely automated decision-making, including profiling, that produces legal or similarly significant effects (Art. 22)
• Right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal
• Right to lodge a complaint with a supervisory authority, in particular the Italian Garante per la Protezione dei Dati Personali:
• Address: Piazza Venezia 11, 00187 Roma, Italy
• Website: https://www.garanteprivacy.it
• Email: [email protected]

How to Exercise Your Rights

To exercise any of the above rights, contact us at [email protected]. We will respond within one month of receiving your request, extendable by a further two months where necessary, taking into account the complexity and number of requests. We may request additional information to verify your identity before acting on a request.

For deletion requests specifically, please use the subject line: “GDPR DATA DELETION REQUEST – LUMENCHEF”.

Where LumenIA acts as Processor for End User Data on behalf of a Restaurant, we will forward or coordinate the request with the relevant Restaurant as appropriate, unless the request is made and can be fulfilled directly.

10. Data Security

We implement technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration, including:

• Encryption of data in transit and, where applicable, at rest
• Role-based access controls restricting data access to authorized personnel
• Periodic security reviews and audits of our systems and sub-processors
• Authentication and monitoring controls, including logging of access to sensitive systems
• Contractual data protection obligations imposed on our sub-processors

No system can guarantee absolute security. We continuously evaluate and improve our security posture as the Service evolves.

11. Cookies

LumenChef’s website and application use cookies and similar tracking technologies. Full details on the categories of cookies used, their purposes, retention periods, and how to manage your preferences are set out in the Cookie Policy and Cookie Declaration, which form part of this Privacy Policy by reference.

12. Children’s Privacy

The Service is not directed at, and is not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at [email protected] so that we can take appropriate action.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. Material changes may be communicated through additional notice (e.g., email or in-app notification) where appropriate.

14. Contact Us

For any questions about this Privacy Policy or our data practices, please contact:

LumenIA S.r.l. Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy Email: [email protected] PEC: [email protected] Phone: +39 344 138 1927

1. Who We Are

This Cookie Policy is issued by LumenIA S.r.l., an Italian limited liability company with registered office at Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy, VAT/Tax Code IT02745940466, REA LU-270629 (“LumenIA,” “LumenChef,” “we,” “us”). It explains how we use cookies and similar technologies on our website and within the LumenChef application, in accordance with the GDPR, the ePrivacy Directive, and applicable Italian implementing rules, including the Garante per la Protezione dei Dati Personali’s cookie guidelines.

2. What Are Cookies

Cookies are small text files placed on your device (computer, tablet, or mobile) when you visit a website or use an application. They are widely used to make websites and apps work, or to work more efficiently, as well as to provide reporting and personalization functionality. Similar technologies (such as local storage, pixels, and tags) are addressed together with cookies in this Policy.

3. Categories of Cookies We Use

We use the following five categories of cookies. A detailed, itemized list of specific cookies is available in the Cookie Declaration.

3.1 Strictly Necessary Cookies

Used for authentication, security, session management, and load balancing. These cookies are essential for the website and application to function and cannot be switched off. - Legal basis: Legitimate interest — no consent required - Retention: Session-based or up to 30 days

3.2 Functional Cookies

Used to remember your preferences, such as language, UI settings, timezone, and theme. - Legal basis: Consent required - Retention: Up to 12 months

3.3 Analytics & Performance Cookies

Used to understand how visitors interact with our website and application, including page views, navigation paths, feature usage, error monitoring, and conversion tracking. Providers include Google Analytics and proprietary internal analytics tools. - Legal basis: Consent required - Retention: Up to 24 months

3.4 Marketing & Advertising Cookies

Used for retargeting, conversion tracking, and interest-based advertising. Providers include Google Ads, Meta Pixel, and LinkedIn Insight Tag. - Legal basis: Consent required - Retention: Up to 12 months, or as specified by the relevant third-party provider

3.5 Third-Party Integration Cookies

Used by embedded features such as social share buttons, embedded video, live chat widgets, and external iframes. - Legal basis: Consent required for non-essential integrations - Retention: Varies by provider

Summary

• Strictly Necessary — Consent required: No — Typical retention: Session – 30 days — Example providers: LumenChef
• Functional — Consent required: Yes — Typical retention: Up to 12 months — Example providers: LumenChef
• Analytics & Performance — Consent required: Yes — Typical retention: Up to 24 months — Example providers: Google Analytics, LumenChef
• Marketing & Advertising — Consent required: Yes — Typical retention: Up to 12 months (or third-party default) — Example providers: Google Ads, Meta Pixel, LinkedIn Insight Tag
• Third-Party Integration — Consent required: Yes (non-essential) — Typical retention: Varies — Example providers: Various

As LumenChef adds new modules and integrations, the specific cookies deployed within each category may expand or change. The authoritative, current list of individual cookies is maintained in the Cookie Declaration.

4. Consent Management

We use a Consent Management Platform (“CMP”) to manage cookie preferences in a manner consistent with GDPR and ePrivacy requirements. The CMP provides:

• Granular consent: you may accept or reject each non-essential category independently
• Accept All / Reject All / Customize options presented clearly at first visit
• Prior blocking: non-essential cookies are not set until you provide consent
• Withdrawal of consent: at any time, via the “Cookie Preferences” link in the website/application footer
• Persistence: your choices are stored and respected on subsequent visits, until you change them or clear your browser storage

5. Managing Cookies Through Your Browser

In addition to our CMP, you can manage or delete cookies directly through your browser settings. Instructions vary by browser; commonly referenced resources include the help documentation for Google Chrome, Mozilla Firefox, Apple Safari (macOS and iOS), and Microsoft Edge. Please note that blocking certain cookies through your browser may affect the functionality of the website or application.

6. Do Not Track

Some browsers offer a “Do Not Track” (DNT) signal. We do not currently respond to DNT signals, as no common industry standard for interpreting them has been adopted. However, we do respect the choices you make through our CMP, as described in Section 4.

7. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in the cookies and technologies we use, or in applicable law.

8. More Information

For more information on how we process personal data generally, please see the Privacy Policy. For the detailed, itemized list of cookies in use, please see the Cookie Declaration.

9. Contact Us

LumenIA S.r.l. Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy Email: [email protected] PEC: [email protected] Phone: +39 344 138 1927

1. Purpose of This Document

This Cookie Declaration provides an itemized list of the specific cookies (and similar technologies) used on the LumenChef website and application. It supplements the Cookie Policy, which describes the five categories of cookies and the legal basis for each, and the Privacy Policy.

2. Itemized Cookie List

• lc_session — Strictly Necessary — Maintains user session state and authentication during use of the application — Duration: Session — Provider: LumenChef
• lc_auth_token — Strictly Necessary — Stores authentication token to keep the user logged in securely — Duration: 30 days — Provider: LumenChef
• lc_csrf_token — Strictly Necessary — Protects against cross-site request forgery — Duration: Session — Provider: LumenChef
• lc_lb_affinity — Strictly Necessary — Maintains load balancing affinity across server requests — Duration: Session — Provider: LumenChef
• lc_lang_pref — Functional — Remembers the user’s preferred language — Duration: 12 months — Provider: LumenChef
• lc_ui_theme — Functional — Remembers UI theme (e.g., light/dark mode) preference — Duration: 12 months — Provider: LumenChef
• lc_timezone — Functional — Remembers the user’s selected timezone for reservation/scheduling display — Duration: 12 months — Provider: LumenChef
• _ga — Analytics & Performance — Distinguishes unique users for Google Analytics reporting — Duration: 24 months — Provider: Google
• _ga_XXXXXXX — Analytics & Performance — Persists session state for the Google Analytics 4 property — Duration: 24 months — Provider: Google
• _gid — Analytics & Performance — Distinguishes users for Google Analytics short-term reporting — Duration: 24 hours — Provider: Google
• lc_analytics_id — Analytics & Performance — Proprietary analytics identifier for feature usage and error monitoring — Duration: 24 months — Provider: LumenChef
• fbp — Marketing & Advertising — Meta Pixel; tracks conversions and enables retargeting — Duration: 12 months — Provider: Meta
• fr — Marketing & Advertising — Meta Pixel; used for ad delivery and measurement — Duration: 90 days (Meta default) — Provider: Meta
• _gcl_au — Marketing & Advertising — Google Ads conversion tracking — Duration: 12 months — Provider: Google
• li_sugr — Marketing & Advertising — LinkedIn Insight Tag browser identifier for analytics/ad tracking — Duration: 90 days (LinkedIn default) — Provider: LinkedIn
• lc_chat_widget — Third-Party Integration — Supports live chat widget session continuity — Duration: Session – 6 months — Provider: Varies by chat provider
• lc_embed_pref — Third-Party Integration — Remembers consent/preferences for embedded video or social share widgets — Duration: 12 months — Provider: Varies by provider

3. How to Read This List

• Cookie Name: the technical identifier of the cookie as set in the browser.
• Category: one of the five categories defined in the Cookie Policy (Strictly Necessary, Functional, Analytics & Performance, Marketing & Advertising, Third-Party Integration).
• Purpose: the functional reason the cookie is set.
• Duration: how long the cookie persists on the user’s device before expiring.
• Provider: the party that sets the cookie — LumenChef (first-party) or a named third party.

4. Maintenance and Accuracy

This list is reconciled against the live Consent Management Platform configuration: - Whenever a new analytics, advertising, or third-party integration is added or removed - On a periodic basis (at least every 6 months) as part of routine compliance review

5. More Information

For the categories, legal bases, and consent mechanisms applicable to these cookies, see the Cookie Policy. For general data processing practices, see the Privacy Policy.

6. Contact Us

LumenIA S.r.l. Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy Email: [email protected] PEC: [email protected] Phone: +39 344 138 1927

1. Introduction and Purpose

This Data Processing Agreement (“DPA”) is entered into between the customer identified in the applicable order form, subscription agreement, or account registration for LumenChef (the “Customer,” acting as Data Controller) and LumenIA S.r.l., an Italian limited liability company (Società a responsabilità limitata) with registered office at Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy, VAT/Tax Code IT02745940466, REA LU-270629 (“LumenIA,” “we,” “us,” or the “Data Processor”).

This DPA supplements and forms part of the LumenChef Terms of Service and Privacy Policy (together, the “Agreement”) and governs the processing of personal data carried out by LumenIA on behalf of the Customer in connection with the provision of the LumenChef platform (the “Services”). This DPA is intended to satisfy the requirements of Article 28 of Regulation (EU) 2016/679 (“GDPR”) and may be incorporated by reference into the Agreement or executed as a standalone annex.

In the event of any conflict between this DPA and the Agreement regarding the processing of personal data, this DPA shall prevail.

2. Definitions

Terms such as “personal data,” “processing,” “controller,” “processor,” “data subject,” “personal data breach,” and “supervisory authority” have the meanings given to them in the GDPR. Additional terms used in this DPA:

• “End Users” means the restaurant guests, diners, and other natural persons whose personal data is processed by LumenIA on behalf of the Customer through the Services.
• “Sub-Processor” means any third party (including LumenIA affiliates, where applicable) engaged by LumenIA to process personal data on behalf of the Customer in connection with the Services.
• “Sub-Processor List” means the current register of Sub-Processors maintained by LumenIA, as referenced in Section 8 below.
• “TOMs Annex” means the Technical and Organizational Measures Annex referenced in Section 6 below.

3. Roles of the Parties

3.1 The Customer is the Data Controller with respect to the personal data of its End Users processed through the Services. The Customer determines the purposes and means of such processing in its capacity as the restaurant operator responsible for its guests.

3.2 LumenIA is the Data Processor and processes End User personal data solely on behalf of, and in accordance with, the documented instructions of the Customer, for the purpose of providing the Services.

3.3 Nothing in this DPA prevents LumenIA from processing personal data as an independent controller where required to do so — for example, for its own billing, fraud prevention, legal compliance, or product-improvement purposes unrelated to End User data — as further described in the LumenChef Privacy Policy.

4. Subject Matter, Duration, Nature, and Purpose of Processing

4.1 Subject matter. The processing covered by this DPA concerns the provision of the LumenChef reservation, table management, CRM, ordering, and marketing Services to the Customer.

4.2 Duration. Processing shall continue for the term of the underlying subscription agreement between LumenIA and the Customer, plus any post-termination retention or deletion window specified in Section 12 of this DPA.

4.3 Nature and purpose of processing. LumenIA hosts, stores, retrieves, transmits, and performs AI-assisted processing (including voice and chat processing) of End User data in order to enable bookings, guest profiles, order management, and restaurant-initiated marketing communications.

4.4 Categories of data subjects. Restaurant guests and diners (End Users); and, secondarily, restaurant staff to the extent they interact with End Users through the platform.

4.5 Categories of personal data. Name, phone number, email address, party size, special requests, allergy and dietary information, visit history, spend data, birthdays, loyalty status, voice call recordings and transcripts, chat and WhatsApp transcripts, order data, and AI prompts/outputs generated in connection with an End User’s interaction with the Services.

4.6 No special categories of data are intentionally collected by the Services, save that allergy and dietary information may in some cases constitute health-related data. The Customer is responsible for ensuring it has an appropriate legal basis for collecting and instructing LumenIA to process any such data.

5. Processing Only on Documented Instructions

5.1 LumenIA shall process End User personal data only on the documented instructions of the Customer, including with regard to transfers of personal data to a third country, unless required to do so by Union or Member State law to which LumenIA is subject. In such a case, LumenIA shall inform the Customer of that legal requirement before processing, unless that law prohibits such disclosure on important grounds of public interest.

5.2 The Agreement, this DPA, and the Customer’s use of the standard configuration options within the Services constitute the Customer’s documented instructions. Any additional instructions outside the scope of the Agreement must be agreed in writing and may be subject to additional fees.

5.3 LumenIA shall immediately inform the Customer if, in its opinion, an instruction infringes the GDPR or other applicable data protection law.

6. Confidentiality and Security Measures

6.1 LumenIA shall ensure that persons authorized to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

6.2 LumenIA shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, as set out in full in the Technical and Organizational Measures Annex, which is hereby incorporated by reference into this DPA.

6.3 The Customer acknowledges having reviewed the TOMs Annex and considers the measures described therein appropriate to the risk associated with the processing described in this DPA.

7. Engagement of Sub-Processors

7.1 The Customer grants LumenIA a general written authorization to engage Sub-Processors to assist in providing the Services, subject to the conditions in this Section 7.

7.2 LumenIA maintains a current list of Sub-Processors in the Sub-Processor List, which identifies each Sub-Processor, its purpose, the categories of data involved, and the applicable transfer mechanism where relevant.

7.3 LumenIA shall notify the Customer (by posting an updated Sub-Processor List and, where practicable, by direct notice such as email or in-app notification) before authorizing any new Sub-Processor to process personal data in connection with the Services. The Customer shall have thirty (30) days from the date of such notice to object to the engagement on reasonable data-protection grounds. If the Customer does not object within that period, the new Sub-Processor shall be deemed approved. If the Customer objects on reasonable grounds and the parties cannot resolve the objection, either party may terminate the affected Services as its sole remedy.

7.4 LumenIA shall impose data protection obligations on each Sub-Processor that are substantially equivalent to those set out in this DPA, and shall remain liable to the Customer for the performance of each Sub-Processor’s obligations.

7.5 For clarity, LumenONE — LumenIA’s internal AI, voice, and automation engine that powers the LumenChef AI Voice Agent and chatbot — is not a separate legal entity or external Sub-Processor. It is an internal processing component operated by LumenIA itself and is described in the Sub-Processor List for transparency purposes only; it does not require a separate Article 28 sub-processing agreement.

8. Assistance with Data Subject Rights

8.1 Taking into account the nature of the processing, LumenIA shall assist the Customer, insofar as this is possible, by appropriate technical and organizational measures, for the fulfillment of the Customer’s obligation to respond to requests from End Users exercising their rights under Chapter III of the GDPR (access, rectification, erasure, restriction, data portability, and objection).

8.2 If LumenIA receives a request directly from an End User concerning their personal data processed on behalf of the Customer, LumenIA shall, without undue delay, redirect the request to the Customer and shall not respond to the request itself (other than to confirm receipt and redirect it), unless otherwise instructed by the Customer or required by law.

9. Assistance with Security, Breach Notification, and DPIA Obligations

9.1 LumenIA shall assist the Customer in ensuring compliance with the obligations set out in Articles 32 to 36 of the GDPR (security of processing, notification of personal data breaches to the supervisory authority, communication of breaches to data subjects, data protection impact assessments, and prior consultation), taking into account the nature of processing and the information available to LumenIA.

9.2 Personal data breach notification. In the event LumenIA becomes aware of a personal data breach affecting End User personal data processed under this DPA, LumenIA shall notify the Customer without undue delay, and in any event targeting notification within 48 to 72 hours of becoming aware of the breach. Such notification shall, to the extent known at the time, describe the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures taken or proposed to address the breach and mitigate its effects. LumenIA shall provide further information as it becomes available and shall reasonably cooperate with the Customer in meeting the Customer’s own breach-notification obligations.

9.3 Where relevant, LumenIA shall provide the Customer with reasonably available information necessary for the Customer to carry out a data protection impact assessment relating to the Services.

10. Audit Rights

10.1 LumenIA shall make available to the Customer all information reasonably necessary to demonstrate compliance with the obligations set out in this DPA and shall allow for and contribute to audits, including inspections, conducted by the Customer or an auditor mandated by the Customer.

10.2 Audits shall be conducted no more than once per calendar year, absent a documented cause (such as a suspected or actual personal data breach, or a binding order from a supervisory authority), and shall be carried out on reasonable prior written notice (no less than thirty (30) days, except in the case of a documented cause), during normal business hours, and in a manner designed to minimize disruption to LumenIA’s operations. LumenIA may, in its reasonable discretion, satisfy this obligation through the provision of independent third-party audit reports, certifications, or summaries in lieu of an on-site audit.

10.3 Any information obtained by the Customer or its auditor in connection with an audit, including audit findings, shall be treated as confidential and shall not be disclosed to third parties except as required by law.

11. International Data Transfers

11.1 LumenIA is established in Italy and processes personal data primarily within the European Union. Where LumenIA or a Sub-Processor transfers personal data outside the European Economic Area, such transfer shall be carried out on the basis of an adequacy decision of the European Commission or, in the absence thereof, on the basis of the European Commission’s Standard Contractual Clauses (“SCCs”) or another valid transfer mechanism recognized under Chapter V of the GDPR.

11.2 The current transfer mechanisms applicable to each Sub-Processor are described in the Sub-Processor List.

12. Deletion or Return of Data

12.1 Upon termination or expiry of the Agreement, and upon the Customer’s written request, LumenIA shall delete or return all End User personal data processed on behalf of the Customer, and shall delete existing copies, unless applicable law requires storage of the personal data.

12.2 Absent a specific instruction from the Customer to return the data, LumenIA shall, by default, delete End User personal data within thirty (30) days following the end of the provision of Services, except for data that LumenIA is legally required to retain (for example, billing and accounting records subject to statutory retention periods under Italian law), which shall be retained only for the duration required and solely for that purpose.

12.3 Backup copies retained in accordance with LumenIA’s standard backup and disaster-recovery procedures (see TOMs Annex) shall be deleted or rendered inaccessible in the ordinary course of LumenIA’s backup rotation cycle, unless legally required to be retained longer.

13. Liability

Each party’s liability arising out of or in connection with this DPA, including in relation to the processing of personal data, is subject to the limitations and exclusions of liability set out in the Terms of Service. Nothing in this DPA shall be construed to expand either party’s liability beyond what is set out in the Terms of Service, except to the extent such limitation is not permitted under applicable data protection law.

14. Term

This DPA shall remain in effect for as long as LumenIA processes End User personal data on behalf of the Customer under the Agreement, and shall automatically terminate upon the termination or expiry of the Agreement, subject to the survival of Section 12 (Deletion or Return of Data) and any other provisions which by their nature are intended to survive.

15. Governing Law and Jurisdiction

This DPA shall be governed by the laws of Italy. The parties submit to the exclusive jurisdiction of the Court of Lucca for any dispute arising out of or in connection with this DPA, without prejudice to any mandatory consumer-protection or data-protection forum rules that may apply.

16. Related Documents

This DPA should be read together with the Technical and Organizational Measures Annex, the Sub-Processor List, and the AI & Automation Policy.

17. Contact

Questions regarding this DPA may be directed to:

LumenIA S.r.l. Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy PEC: [email protected] Email: [email protected] Phone: +39 344 138 1927 Website: https://www.lumenia.net

This Annex describes the technical and organizational measures implemented by LumenIA S.r.l. to protect personal data processed in connection with the LumenChef platform, pursuant to Article 32 of the GDPR and Section 6 of the Data Processing Agreement, which incorporates this Annex by reference. Measures are described at a level of detail sufficient to demonstrate an appropriate standard of security without disclosing information that would itself create a security risk.

1. Encryption

1.1 All personal data transmitted between End Users, Customers, and the LumenChef platform is encrypted in transit using TLS/SSL.

1.2 Personal data at rest within LumenChef’s production data stores is encrypted using industry-standard encryption provided by LumenIA’s infrastructure and database providers.

1.3 Encryption keys and credentials are managed through the access-control mechanisms of LumenIA’s infrastructure providers and are not stored in plaintext within application code or repositories.

2. Access Controls and Role-Based Permissions

2.1 Access to systems processing personal data is restricted to personnel who require such access to perform their job functions (“least privilege”).

2.2 The LumenChef platform implements role-based access controls, allowing Customers to define staff roles and permission levels within their own restaurant account.

2.3 Internal administrative access to production systems is limited to authorized LumenIA personnel and is logged.

2.4 Access rights are reviewed periodically and revoked promptly upon a change in role or termination of employment or engagement.

3. Authentication

3.1 Access to the LumenChef platform requires authentication via credentials managed through LumenIA’s authentication provider.

3.2 LumenIA enforces reasonable credential policies (including password complexity requirements) for platform accounts.

3.3 Multi-factor authentication (MFA) is available and recommended for all Customer and staff accounts, and is required for internal administrative access to production systems where technically supported.

4. Logging and Monitoring

4.1 LumenIA maintains logs of relevant system and application activity, including authentication events and access to production infrastructure, to support security monitoring and incident investigation.

4.2 Logs are reviewed periodically and retained for a period reasonably necessary for security and operational purposes, consistent with applicable data minimization principles.

4.3 Automated monitoring and alerting mechanisms are used, where available through LumenIA’s infrastructure providers, to detect anomalous activity.

5. Backup and Disaster Recovery

5.1 LumenIA maintains regular backups of production data to support business continuity and disaster recovery.

5.2 Archival backups are retained for up to ten (10) years, consistent with LumenIA’s broader data retention and archival practices, unless a shorter period is required by an applicable deletion instruction or legal obligation.

5.3 Backup and recovery procedures are periodically tested to verify the ability to restore data in the event of loss, corruption, or a disaster-recovery scenario.

6. Employee Training and Confidentiality

6.1 Personnel with access to personal data are bound by confidentiality obligations, whether through employment agreements, contractor agreements, or equivalent contractual undertakings.

6.2 LumenIA provides personnel with training appropriate to their role regarding data protection principles, secure handling of personal data, and incident-reporting procedures.

7. Vendor and Sub-Processor Management

7.1 LumenIA performs due diligence on prospective Sub-Processors prior to engagement, considering their security posture, applicable certifications, and contractual data protection commitments.

7.2 LumenIA enters into data processing terms with each Sub-Processor that impose obligations substantially equivalent to those set out in the DPA.

7.3 The current register of Sub-Processors, including their role, data categories, and transfer mechanisms, is maintained in the Sub-Processor List.

8. Secure Development Lifecycle

8.1 Changes to the LumenChef codebase are subject to review prior to deployment to production.

8.2 Third-party software dependencies are monitored and updated as part of ordinary maintenance to address known vulnerabilities.

8.3 Access to source code repositories and deployment pipelines is restricted to authorized personnel.

9. Incident Response

9.1 LumenIA maintains an incident response process consisting of the following phases:

• Detect — identification of a suspected or confirmed security incident or personal data breach through monitoring, alerts, or internal/external reporting.
• Contain — immediate steps to limit the scope and impact of the incident.
• Assess — evaluation of the nature, scope, and likely consequences of the incident, including the categories and volume of personal data affected.
• Notify — notification to affected Customers in accordance with Section 9.2 of the DPA (targeting notification within 48 to 72 hours of becoming aware of a personal data breach), and, where legally required, notification to the competent supervisory authority and affected data subjects.

9.2 Following resolution of an incident, LumenIA conducts an internal review to identify remediation steps and, where appropriate, improvements to its technical and organizational measures.

10. Physical and Infrastructure Security

10.1 LumenIA does not operate on-premises servers for the LumenChef platform. Production infrastructure is hosted with reputable cloud infrastructure providers (including hosting, database, and edge-network providers identified in the Sub-Processor List).

10.2 Physical and environmental security of data centers (including access controls, environmental controls, and redundancy) is inherited from, and is the responsibility of, LumenIA’s underlying infrastructure providers, each of which maintains its own industry-standard physical security certifications and practices.

11. Related Documents

This Annex should be read together with the Data Processing Agreement, the Sub-Processor List, and the AI & Automation Policy.

1. Purpose

This document lists the Sub-Processors currently engaged by LumenIA S.r.l. to process personal data on behalf of Customers in connection with the LumenChef platform. It is referenced by, and forms part of, the Data Processing Agreement and the LumenChef Privacy Policy.

Under Section 7 of the DPA, the Customer has granted LumenIA a general authorization to engage the Sub-Processors listed below, subject to the notice and objection process described in the DPA. LumenIA will update this list when it adds, removes, or changes a Sub-Processor, and will provide notice of new Sub-Processors in accordance with the DPA.

2. A Note on LumenONE

LumenONE is LumenIA’s internal AI, voice, and automation engine. It is listed below for transparency because it powers the LumenChef AI Voice Agent and chatbot features and processes End User personal data as part of doing so. LumenONE is not a separate legal entity or an external vendor — it is the same legal entity, LumenIA S.r.l., operating shared internal AI infrastructure. Accordingly, LumenONE does not require its own separate Article 28 sub-processing agreement; it is governed directly by the DPA between LumenIA and the Customer. All other entries below are genuine third-party vendors and are treated as Sub-Processors requiring appropriate data protection terms (Standard Contractual Clauses, the EU-U.S. Data Privacy Framework, or equivalent, as applicable).

3. Current Sub-Processors

• LumenONE (internal) — Legal entity: LumenIA S.r.l. (same entity; internal AI/voice infrastructure) — Purpose: AI voice agent, chatbot, LLM orchestration — Data categories: Diner contact information, call/chat transcripts, AI prompts/outputs — Region / transfer mechanism: EU (internal — not a cross-border transfer)
• OpenAI — Legal entity: OpenAI, L.L.C. — Purpose: LLM provider — Data categories: AI prompts/outputs; commercial API usage, not used for model training — Region / transfer mechanism: US — Standard Contractual Clauses
• Anthropic — Legal entity: Anthropic PBC — Purpose: LLM provider — Data categories: AI prompts/outputs; commercial API usage, not used for training, processing segregated from consumer services — Region / transfer mechanism: US — Standard Contractual Clauses
• Google (Gemini API) — Legal entity: Google LLC — Purpose: LLM provider — Data categories: AI prompts/outputs; enterprise/API usage not used for training, may log for abuse-detection purposes — Region / transfer mechanism: US/EU — Standard Contractual Clauses
• Telnyx — Legal entity: Telnyx LLC — Purpose: Telephony, voice, SMS, and phone number provisioning — Data categories: Call metadata, call recordings (retained up to 1 year unless deleted), phone numbers — Region / transfer mechanism: US/EU
• Vercel — Legal entity: Vercel Inc. — Purpose: Frontend hosting and deployment — Data categories: Technical/usage data, logs — Region / transfer mechanism: US/EU edge network
• Supabase — Legal entity: Supabase, Inc. — Purpose: Authentication and database (primary datastore) — Data categories: All platform personal data — Region / transfer mechanism: EU
• Cloudflare — Legal entity: Cloudflare, Inc. — Purpose: DNS, CDN, and security services — Data categories: Technical/traffic data — Region / transfer mechanism: Global edge network
• Stripe — Legal entity: Stripe, Inc. (or applicable local Stripe entity) — Purpose: Payment processing — Data categories: Billing/payment metadata (card data held directly by Stripe) — Region / transfer mechanism: US/EU
• Resend — Legal entity: Resend, Inc. — Purpose: Transactional email delivery — Data categories: Email address, message content/metadata — Region / transfer mechanism: US
• Meta (WhatsApp Business) — Legal entity: Meta Platforms Ireland Limited — Purpose: WhatsApp booking channel and campaigns — Data categories: Diner phone number, message content — Region / transfer mechanism: EU/US — Meta Business Data Processing Terms
• Telegram — Legal entity: Telegram Messenger LLP / Telegram FZ-LLC — Purpose: Telegram booking/ordering channel (where enabled) — Data categories: Diner identifiers, message content — Region / transfer mechanism: Varies by integration
• Going Macro S.r.l. — Legal entity: Going Macro S.r.l. — Purpose: Development and technical support — Data categories: Depends on access scope granted — Region / transfer mechanism: Italy

4. How to Object to a New Sub-Processor

Customers who wish to object to the engagement of a new Sub-Processor should follow the process described in Section 7 of the DPA, including the thirty (30) day objection window following notice of the proposed change.

5. Update History

• 2026-07-13 — Initial list compiled — Establishment of the LumenChef Article 28 DPA framework

6. Related Documents

This document should be read together with the Data Processing Agreement, the Technical & Organizational Measures Annex, and the AI & Automation Policy.

1. Scope

1.1 This AI & Automation Policy (“Policy”) applies to all artificial intelligence and automation features made available through the LumenChef platform, including:

• the AI Voice Agent;
• the chatbot;
• table-allocation AI;
• CRM recommendation AI;
• marketing-generation AI; and
• analytics-narration AI.

1.2 These features are powered by LumenONE, LumenIA S.r.l.’s internal AI and automation engine, in combination with third-party large language model (“LLM”) providers identified in the Sub-Processor List.

1.3 This Policy supplements the Terms of Service, Privacy Policy, and Data Processing Agreement, and should be read together with those documents.

2. AI Limitations and Hallucination Disclaimer

2.1 AI features are provided to assist restaurant operations and are not infallible. Outputs generated by AI features — including responses from the AI Voice Agent or chatbot, suggested table allocations, CRM recommendations, generated marketing copy, and analytics narration — may occasionally be inaccurate, incomplete, or inconsistent with the restaurant’s actual data or intentions (“hallucinations”).

2.2 LumenIA does not guarantee the accuracy, completeness, or fitness for any particular purpose of AI-generated outputs.

3. Human Responsibility

3.1 The Customer (restaurant) is responsible for reviewing and verifying AI-generated outputs before relying on them operationally, including before communicating such outputs to End Users, making business decisions based on them, or using them in a manner that could affect an End User’s booking, order, or experience.

3.2 LumenIA recommends that Customers establish internal procedures for staff to review AI outputs where the output could materially affect an End User, particularly with respect to allergy, dietary, or safety-related information.

4. How the AI Agents Operate

4.1 AI Voice Agent. The AI Voice Agent handles inbound and outbound voice interactions with End Users (for example, reservation requests). Where the AI Voice Agent cannot resolve a request — due to ambiguity, complexity, or a request falling outside its configured scope — it is designed to escalate the interaction to restaurant staff.

4.2 Table-allocation AI. The Customer may configure table allocation in one of two modes:

• Assisted mode — the AI proposes a table allocation, but a manager or authorized staff member must confirm the allocation before it takes effect.
• Fully-automatic mode — the AI allocation takes effect without requiring staff confirmation.

The Customer selects which mode applies to its account and is responsible for that choice, including any operational consequences of using fully-automatic mode.

4.3 CRM, marketing-generation, and analytics-narration AI. These features generate recommendations, marketing content, or narrative summaries based on the Customer’s own data. Outputs are suggestions or drafts and remain subject to the Customer’s review before use, in accordance with Section 3 above.

5. Ownership and Use of AI-Generated Content

5.1 Ownership and permitted use of content generated by AI features (including marketing copy, analytics narration, and similar outputs) is governed by the intellectual property provisions of the Terms of Service. This Policy does not modify those provisions and should be read in conjunction with them.

6. Monitoring and Logging of AI Interactions

6.1 LumenIA monitors and logs AI interactions (including voice transcripts, chat transcripts, and AI prompts/outputs) for quality assurance, safety, abuse prevention, and service-improvement purposes, consistent with the Privacy Policy and the data categories described in the DPA.

6.2 Logged AI interactions may be reviewed by authorized LumenIA personnel in connection with troubleshooting, quality review, or investigation of reported issues.

7. No Solely-Automated Decisions Without Human Oversight

7.1 Consistent with Article 22 of the GDPR, LumenChef’s AI features are not intended to produce decisions based solely on automated processing that produce legal effects concerning an End User, or that similarly significantly affect an End User, without the possibility of human oversight.

7.2 Where a Customer configures a feature to operate in a fully-automatic mode (for example, fully-automatic table allocation) or relies on AI-generated lead scoring, the Customer may request human review of any specific automated outcome. LumenIA will provide reasonable technical support to enable such review upon request, but the primary responsibility for offering End Users a path to request human review of an outcome affecting them rests with the Customer, as the party operating the restaurant relationship with the End User.

8. Transparency and Regulatory Alignment

8.1 LumenIA aligns the design and operation of its AI features with the requirements of the EU Artificial Intelligence Act as they apply to LumenIA’s role and to the Services.

8.2 The Customer remains responsible for its own AI governance compliance obligations arising from its use of the Services, including any obligations specific to its jurisdiction, sector, or particular use case that go beyond LumenIA’s responsibilities as a technology provider.

9. Use of Data for AI Model Training and Improvement

9.1 Where LumenIA or its AI features use data to train, fine-tune, or otherwise improve AI models, such use is limited to anonymized or aggregated data only.

9.2 LumenIA does not use individually identifiable End User data for AI model training without the End User’s or Customer’s explicit consent, consistent with the corresponding AI-training provisions of the Terms of Service.

9.3 Third-party LLM providers engaged as Sub-Processors are contracted, where applicable, on terms that their commercial/API-tier processing of prompts and outputs is not used to train their own general-purpose models, as further described in the Sub-Processor List.

10. Related Documents

This Policy should be read together with the Data Processing Agreement, the Technical & Organizational Measures Annex, and the Sub-Processor List (AI-related Sub-Processors: LumenONE, OpenAI, Anthropic, Google).

1. Purpose and Scope

This Acceptable Use Policy (“AUP”) sets out the rules governing use of the LumenChef platform (the “Services”), operated by LumenIA S.r.l. (“LumenIA,” “we,” “us”). This AUP applies to Customer, its personnel, its authorized users, and any third party interacting with the Services on Customer’s behalf, including through Customer’s configuration of the AI Voice Agent, chatbot, or messaging channels.

This AUP is incorporated by reference into, and forms part of, the LumenChef Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service.

Violation of this AUP is a material breach of the Terms of Service and may result in suspension, restriction, or termination of access to the Services as described in Section 6.

2. Prohibited Content

Customer and its authorized users must not upload, transmit, configure, or generate through the Services any content that:

2.1 Is unlawful, defamatory, obscene, discriminatory, or infringes the intellectual property, privacy, or other rights of any third party;

2.2 Contains malicious code, malware, or is designed to disrupt, damage, or gain unauthorized access to any system;

2.3 Is fraudulent, deceptive, or intended to mislead guests, including false allergen, ingredient, pricing, or availability information knowingly submitted;

2.4 Violates applicable advertising, marketing, or telemarketing law, including unsolicited commercial communications sent without proper consent;

2.5 Constitutes hate speech, harassment, or incitement to violence, whether directed at guests, staff, or third parties;

2.6 Violates the rights of minors or exploits vulnerable individuals.

3. Prohibited Uses of the Platform

Customer and its authorized users must not:

3.1 Use the Services for any purpose that is illegal, fraudulent, or unauthorized under applicable law, including consumer protection, data protection, tax, or telecommunications law;

3.2 Use the Services to operate a business other than the one for which the account was registered, or to provide the Services as a sublicensed or resold product to unrelated third parties without LumenIA’s written consent;

3.3 Circumvent, disable, or otherwise interfere with security-related features of the Services, including rate limits, authentication mechanisms, or usage quotas;

3.4 Attempt to gain unauthorized access to any account, system, or network related to the Services;

3.5 Use the Services in a manner that could damage, disable, overburden, or impair LumenIA’s infrastructure or that of its sub-processors (including Supabase, Vercel, Cloudflare, Telnyx, Stripe, Meta, Resend, or AI model providers).

4. Abuse of AI Features

The Services embed artificial intelligence extensively, including the LumenONE-powered AI Voice Agent, chatbot, CRM insights, and analytics. To protect the integrity of these systems and the experience of other customers and guests, Customer and its authorized users (and any third party acting on their instruction) must not:

4.1 Attempt prompt injection, jailbreaking, adversarial prompting, or any other technique designed to bypass the safety, content, or operational guardrails of any AI feature;

4.2 Use the AI Voice Agent, chatbot, or messaging integrations to conduct excessive automated outbound calling, robocalling, or mass unsolicited voice or message campaigns beyond the legitimate reservation-confirmation, reminder, and marketing use cases contemplated by the Services and consented to by recipients;

4.3 Use the Services to generate spam, including bulk unsolicited SMS, WhatsApp, or email messages inconsistent with applicable anti-spam and electronic communications law (including consent and opt-out requirements);

4.4 Deliberately feed the AI Voice Agent or chatbot false, misleading, or malicious inputs intended to produce harmful, defamatory, or unlawful outputs, or to extract system prompts, model configuration, or other proprietary information;

4.5 Use automated scripts, bots, or scraping tools to interact with the AI Voice Agent, chatbot, or any API at volumes or frequencies inconsistent with genuine guest interactions or normal restaurant operations;

4.6 Use AI Outputs generated through the Services to train, fine-tune, or build a competing AI model or service.

5. Telephony-Specific Rules and Rate Limits

5.1 Numbers provisioned or ported for use with the AI Voice Agent must be used solely for legitimate restaurant-related communications, consistent with the Telephony & Phone Number Policy.

5.2 Customer must not use telephony features to place unsolicited outbound robocalls, engage in caller-ID spoofing, or otherwise violate telecom regulations applicable in its jurisdiction.

5.3 LumenIA may apply reasonable rate limits to calls, messages, API requests, or reservation submissions to protect platform stability, prevent abuse, and ensure fair access across customers. Rate limits may vary by subscription plan and will be applied in a manner intended to accommodate genuine business volume.

5.4 Sustained or automated call volume inconsistent with a restaurant’s genuine reservation demand (e.g., synthetic test traffic at production scale, load-testing without authorization, or denial-of-service-style call floods) is prohibited.

6. Consequences of Violation

6.1 Where LumenIA reasonably suspects a violation of this AUP, it may, at its discretion and proportionate to the severity of the issue: (a) issue a warning; (b) temporarily suspend the affected feature (e.g., disable the AI Voice Agent or messaging channel) while the issue is investigated; (c) suspend or terminate the account in accordance with the Terms of Service; or (d) report unlawful conduct to competent authorities where required or appropriate.

6.2 LumenIA will, where practicable and not contrary to legal or security requirements, attempt to notify Customer of the nature of a suspected violation before or promptly after taking action.

6.3 Repeated or severe violations may result in permanent termination of the account without refund of unused Booking Credits or subscription fees, except as required by mandatory consumer law.

7. Reporting Violations

Any person who becomes aware of a violation of this AUP, including misuse of the AI Voice Agent, suspected fraud, spam, or abuse originating from a LumenChef account, should report it to LumenIA at:

Email: [email protected]

LumenIA will review reports in good faith and take appropriate action consistent with this AUP and applicable law.

8. Relationship to Other Documents

This AUP should be read together with the Terms of Service, the Telephony & Phone Number Policy, the Privacy Policy, and the Data Processing Agreement. In the event of any conflict specifically regarding acceptable use, this AUP prevails over the Terms of Service solely as to that matter.

1. Purpose and Scope

This Data Retention & Deletion Policy describes how long LumenIA S.r.l. (“LumenIA,” “LumenChef,” “we,” “us”) retains personal data processed in connection with the LumenChef platform, the events that trigger deletion or anonymization, and the process by which Restaurants and individual diners can request export or deletion of data. It supplements the Privacy Policy and applies consistently across both:

• Data for which LumenIA is Data Controller (Restaurant account/staff data, billing data, technical/usage data, marketing data), and
• Data for which LumenIA is Data Processor acting on behalf of the Restaurant (End User/diner data), under the terms of the applicable Data Processing Agreement (DPA).

2. Retention Periods by Data Category

• Restaurant account & registration data: duration of the contract, plus 10 years (Italian tax/accounting law, D.Lgs. 82/2005)
• Billing/payment data: 10 years from the date of the transaction
• Reservation & CRM data (diner profiles): retained while the Restaurant account is active; deleted or anonymized within 30 days of Restaurant account closure, unless the Restaurant requests earlier deletion or a diner exercises erasure rights directly against LumenIA
• Voice recordings (AI Voice Agent): retained as necessary for service delivery, QA, compliance, and dispute resolution; our telephony sub-processor, Telnyx, retains recordings for up to 1 year unless earlier deleted, per its own policy
• Chat/WhatsApp transcripts: retained until the Restaurant or diner requests deletion, or until account closure
• Security/authentication logs: 24 months
• Marketing data: until consent is withdrawn or an opt-out is received, plus a reasonable period to process the opt-out
• Backups: up to 10 years in secure archival storage for disaster recovery and business continuity

These periods reflect the maximum retention absent an earlier deletion trigger described in Section 3, or an applicable legal exception described in Section 6.

3. Deletion and Anonymization Triggers

Data is deleted or anonymized upon the earliest applicable of the following triggers:

• Restaurant account closure: reservation and CRM (diner) data is deleted or anonymized within 30 days of account closure, unless a longer period applies under Section 2 (e.g., billing records) or an exception under Section 6 applies.
• Direct erasure request: a valid erasure request from a Restaurant (regarding its own account data) or from a diner (regarding their personal data, exercised directly against LumenIA) will be honored within the timelines in Section 8, subject to the exceptions in Section 6.
• Contract end: upon termination or expiry of the Restaurant’s subscription agreement, retention shifts to the post-contract periods specified in Section 2 (e.g., 10 years for account and billing records for tax/legal compliance), while diner CRM data not otherwise subject to a longer retention requirement is deleted/anonymized within 30 days.
• Expiration of a defined retention period: e.g., security logs are deleted after 24 months; billing records after 10 years.

4. Backup Handling

Backups are retained separately from production systems for disaster recovery and business continuity purposes, for up to 10 years, in secure archival storage. Because backups are typically immutable snapshots, an individual deletion request may not immediately purge data from historical backups; deleted data will be excluded from production systems and from any restoration, and will age out of backup retention according to the standard backup retention schedule.

5. Requesting Bulk Export or Deletion (Restaurants)

A Restaurant, as Data Controller for its diners’ data, may request:

• Bulk export of its diner/reservation/CRM data, in a structured, commonly used format, at any time during the contract term or upon account closure.
• Bulk deletion of its diner/reservation/CRM data, either during the contract term or in connection with account closure.

Requests should be submitted to [email protected]. We will verify the requester’s authority to act on behalf of the Restaurant before processing the request. Standard processing timelines are set out in Section 8.

6. Requesting Deletion Directly (Diners / Individuals)

An individual diner or guest may also request deletion of their personal data directly from LumenIA, even though the Restaurant is the Data Controller for that data. To do so, the individual should contact [email protected], using the subject line “GDPR DATA DELETION REQUEST – LUMENCHEF”, and provide sufficient information to locate their data (e.g., the Restaurant(s) involved, contact details used for reservations).

Where feasible, we will notify the relevant Restaurant of the request and coordinate accordingly, consistent with our obligations as Processor under the applicable DPA, while still honoring the individual’s rights.

7. Exceptions to Deletion

LumenIA may be required to retain certain data despite a deletion request, where retention is necessary to:

• Comply with a legal obligation (e.g., Italian tax and accounting record-keeping requirements, which mandate retention of billing/invoicing data for 10 years)
• Establish, exercise, or defend legal claims
• Comply with a legal obligation requiring processing under EU or Member State law
• Fulfil an overriding legitimate interest that has not been successfully objected to
• Complete an ongoing dispute resolution, fraud investigation, or security incident review

Where an exception applies, we will restrict further use of the data to the purpose of the exception and inform the requester of the basis for the exception, to the extent legally permitted.

8. Process and SLA for Handling Requests

• Acknowledgment: requests are acknowledged promptly upon receipt.
• Identity/authority verification: we may request additional information to verify the identity of the individual, or the authority of a Restaurant representative, before proceeding.
• Standard response time: requests are processed within 30 days of receipt.
• Extension: this period may be extended by up to two additional months where necessary, taking into account the complexity and number of requests; the requester will be informed of any extension and the reasons for it within the initial 30-day period.
• Outcome notification: the requester will be informed once the request has been completed, including confirmation of deletion/export or an explanation where an exception under Section 6 applies.

9. Relationship to Other Documents

This Policy should be read together with the Privacy Policy, Cookie Policy, Cookie Declaration, and the Data Processing Agreement (DPA) executed with each Restaurant customer. In the event of any inconsistency regarding End User Data specifically, the applicable DPA governs as between LumenIA and the Restaurant.

10. Changes to This Policy

We may update this Policy from time to time to reflect changes in our data practices, retention requirements, or applicable law.

11. Contact Us

LumenIA S.r.l. Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy Email: [email protected] PEC: [email protected] Phone: +39 344 138 1927

1. Purpose and Scope

This Telephony & Phone Number Policy (this “Policy”) governs the use of telephony features within the LumenChef platform (the “Services”), including phone numbers used by the AI Voice Agent, call recording, and SMS/WhatsApp messaging. This Policy is incorporated by reference into, and forms part of, the LumenChef Terms of Service, operated by LumenIA S.r.l. (“LumenIA,” “we,” “us”). Capitalized terms not defined here have the meaning given in the Terms of Service.

Telephony features are provided using Telnyx as LumenIA’s telephony infrastructure sub-processor, and messaging features rely on Meta’s WhatsApp Business platform, each subject to the terms described in this Policy.

2. Hosted vs. Customer-Owned Numbers

2.1 LumenChef-Hosted Numbers. LumenIA may provision a telephone number on Customer’s behalf, hosted on LumenIA’s telephony infrastructure (via Telnyx), for use with the AI Voice Agent and the Services generally (“Hosted Number”). Hosted Numbers remain associated with LumenIA’s telephony account and are made available to Customer for use during the term of the applicable subscription.

2.2 Customer-Owned or Ported Numbers. Customer may instead choose to use its own existing phone number by porting it into the Services’ telephony infrastructure, or by connecting an existing number through supported forwarding/SIP configurations (“Customer Number”). Porting is subject to the requirements of Customer’s originating and/or receiving carrier, applicable telecom regulations, and reasonable processing times that LumenIA does not fully control.

2.3 Number Selection Responsibility. Customer is responsible for selecting the option (Hosted Number or Customer Number) appropriate to its business needs, including any requirements to preserve an existing number that guests already recognize.

3. Call Recording

3.1 Recording for Service Delivery. Calls handled through the AI Voice Agent and other telephony features of the Services are recorded and/or transcribed as part of normal service delivery, including for quality assurance, AI training and improvement (in anonymized/aggregated form per the Terms of Service), compliance monitoring, and dispute resolution.

3.2 Customer’s Disclosure Obligation. Customer is solely responsible for informing its own callers and guests that calls to and from its restaurant may be recorded, and for obtaining any consent required under applicable law in Customer’s jurisdiction (including, where relevant, two-party or all-party consent requirements for call recording, and employee/staff notification obligations where staff calls may be recorded). LumenIA does not verify or assume responsibility for the adequacy of Customer’s disclosure practices under laws outside LumenIA’s control.

3.3 IVR Notice Support. To support Customer’s disclosure obligations, LumenChef’s interactive voice response (“IVR”) system supports the inclusion of a configurable recording-notice announcement (e.g., “this call may be recorded for quality and training purposes”) played to callers at the start of a call handled by the AI Voice Agent. Customer is responsible for enabling and correctly configuring this notice where required by applicable law, and for verifying that the notice satisfies Customer’s specific jurisdictional requirements.

3.4 Sub-Processor Retention. Call recordings are stored via Telnyx, LumenIA’s telephony sub-processor. Telnyx retains call recordings for up to twelve (12) months from the date of the call, unless deleted earlier in accordance with Telnyx’s own data retention and deletion policies, or unless a different retention period is agreed between LumenIA and Customer for a specific compliance purpose. Customer should refer to the Privacy Policy and Data Processing Agreement for further detail on sub-processor data handling.

3.5 Access to Recordings. LumenIA may make call recordings and transcripts available to Customer within the Services (e.g., for dispute resolution regarding a specific reservation) where technically supported by Customer’s plan.

4. SMS and WhatsApp Messaging

4.1 Permitted Uses. The Services support SMS and WhatsApp messaging for reservation confirmations, reminders, waitlist notifications, and, where separately enabled, marketing communications such as loyalty and win-back campaigns.

4.2 Consent and Opt-Out. Customer is responsible for ensuring that guests have provided any consent required under applicable law before receiving marketing messages, and for honoring opt-out requests promptly. Transactional messages (e.g., reservation confirmations) are generally permitted without separate marketing consent, but Customer remains responsible for compliance with applicable electronic communications law in its jurisdiction.

4.3 Meta Business Data Processing Terms. WhatsApp messaging is provided through Meta’s WhatsApp Business platform and is subject to Meta’s Business Data Processing Terms and WhatsApp Business Policy, in addition to this Policy and the Terms of Service. Customer’s use of WhatsApp features constitutes acceptance of the applicable Meta terms to the extent required by Meta for platform access.

4.4 Message Content Restrictions. Messages sent through the Services must not violate the prohibitions set out in the Acceptable Use Policy, including prohibitions on spam and excessive automated messaging.

5. Regulatory Compliance

5.1 Customer’s telecom regulatory obligations vary by jurisdiction and may include, without limitation, caller-ID/number display rules, call-recording consent laws, telemarketing and robocall restrictions, data localization requirements for call content, and obligations to register or verify business phone numbers with local regulators or carriers. Customer is solely responsible for compliance with such requirements applicable to its own use of telephony features.

5.2 LumenIA is responsible for the compliance of its own telephony infrastructure operations (via Telnyx) with applicable telecom regulations governing the provision of that infrastructure, but this does not extend to Customer’s specific regulatory obligations as the business placing and receiving calls with its guests.

6. Number Portability and Loss of Number on Termination

6.1 Hosted Numbers. Where Customer uses a Hosted Number, that number is provisioned as part of the Services. Upon termination or expiration of Customer’s subscription, LumenIA may reclaim, deprovision, or release the Hosted Number, and Customer should not rely on continued availability of a Hosted Number after termination. Where technically and contractually feasible, and subject to carrier rules and any applicable fees, Customer may request to port a Hosted Number out prior to termination; LumenIA will provide reasonable cooperation but does not guarantee successful porting, which depends on third-party carrier processes.

6.2 Customer Numbers. Where Customer has used its own Customer Number connected to the Services, Customer retains ownership of that number, and Customer may disconnect or reconfigure it upon termination, subject to any pending carrier processes.

6.3 No Guarantee of Number Continuity. LumenIA does not guarantee that any specific phone number will remain available indefinitely, whether due to carrier requirements, regulatory action, or discontinuation of the underlying telephony sub-processor relationship, and will provide reasonable advance notice to Customer where a material change affecting number continuity is anticipated.

7. Service Limitations

7.1 Telephony features depend on third-party infrastructure (including Telnyx and underlying carriers) and are subject to outages, latency, call-quality issues, and rate limits outside LumenIA’s control. LumenIA is not liable for such third-party telephony failures beyond the limitations set out in the Terms of Service.

7.2 Feature availability for telephony (including AI Voice Agent language support, number types, and SMS/WhatsApp availability) may vary by country and regulatory environment, consistent with the Feature Availability provisions of the Terms of Service.

8. Contact

Questions regarding telephony, call recording, or phone number configuration should be directed to [email protected] or LumenIA S.r.l., Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy.

1. Purpose

This Credits, Billing & Refund Policy (this “Policy”) describes how the Booking Credit commercial model works, how Customer is billed for use of the LumenChef platform (the “Services”), and the circumstances in which refunds may or may not be available. This Policy is incorporated by reference into, and forms part of, the LumenChef Terms of Service, operated by LumenIA S.r.l. (“LumenIA,” “we,” “us”). Capitalized terms not defined here have the meaning given in the Terms of Service.

2. The Booking Credit Model

2.1 Definition of a Credit. A “Booking Credit” (or “Credit”) is the unit of consumption used to meter certain features of the Services. One (1) successful reservation processed through the Services — whether initiated via the website, chatbot, WhatsApp, AI Voice Agent, or phone, and unified through the LumenChef reservation engine — consumes one (1) Credit.

2.2 What Counts as “Successful.” A reservation is considered successful, for billing purposes, when it is confirmed within the Services as a valid booking against Customer’s configured availability (i.e., it is not a duplicate, test, or rejected/failed booking attempt). Modifications to an existing confirmed reservation and legitimate cancellations do not themselves consume additional Credits, unless the modification effectively creates a new confirmed booking.

2.3 Credits Are Plan-Configurable. The manner in which Credits are allocated, bundled, auto-reloaded, or expired (if at all) depends on Customer’s specific subscription plan, as described on the plan or order form at the time of purchase. Not all plans include auto-reload or expiration; Customer should refer to its plan details for the applicable configuration.

3. Reference Pricing

3.1 Illustrative Reference Price. LumenIA references an indicative price of approximately €1.50 (excluding VAT) per Booking Credit, representing one successful reservation. This figure is provided for illustrative purposes only.

3.2 Actual Current Pricing. The actual, current pricing applicable to Customer’s account — including any plan-specific rates, bundle discounts, or promotional pricing — is published separately on LumenIA’s pricing page or in Customer’s order form/subscription agreement, and shall prevail over the illustrative reference price in this Policy in the event of any discrepancy.

3.3 Pricing Changes. LumenIA may change pricing for Booking Credits, subscription fees, or add-on features from time to time. Except where a different notice period is agreed in a specific order form, LumenIA will provide at least thirty (30) days’ advance notice of any pricing change via email or in-app notice before the new pricing takes effect for existing Customers. Continued use of the Services after the effective date of a pricing change constitutes acceptance of the new pricing.

4. Billing and Invoicing

4.1 Manual Invoicing During MVP Phase. During the current early-stage (MVP) phase of the Services, billing may be handled through manual invoicing issued by LumenIA, rather than fully automated in-platform billing. Customer agrees to pay invoices within the payment term stated on the invoice (absent other agreement, thirty (30) days from the invoice date).

4.2 Transition to Automated Billing. LumenIA intends to introduce automated payment processing (via Stripe) as the Services mature. Once automated billing is enabled for Customer’s account, this Policy and the applicable order form will govern automatic charging of Customer’s designated payment method for Credit purchases, subscription fees, and applicable taxes.

4.3 Payment Method and Authorization. By providing a payment method (including via Stripe) or by accepting a manual invoice, Customer authorizes LumenIA to charge or invoice, as applicable, all fees due for Credits purchased or consumed, subscription fees, and any applicable taxes. Customer is responsible for keeping payment method details current and valid.

4.4 Currency and Taxes. Unless otherwise stated, fees are quoted in Euro (€) and are exclusive of value-added tax (“VAT”) and any other applicable taxes, duties, or governmental charges, which will be added to invoices or charges where legally due based on Customer’s registered business location and applicable tax rules. Customer is responsible for providing accurate VAT/tax identification information.

5. Zero Balance and Service Impact

5.1 Blocking of New Reservations. If Customer’s Booking Credit balance reaches zero, the Services will block new reservation requests from being confirmed, and AI Voice Agent availability for new bookings will become unavailable, until the balance is replenished (via purchase, auto-reload, or plan renewal, as configured).

5.2 Existing Reservations Unaffected. A zero Credit balance does not cancel or affect reservations that were already confirmed prior to the balance reaching zero. Existing confirmed reservations remain visible and manageable within the Services to the extent the underlying subscription remains active.

5.3 Restoration of Service. Once Customer’s Credit balance is replenished, new reservation functionality and AI Voice Agent booking capability will resume without requiring a separate reactivation request, except where the account has also been suspended for a separate reason under the Terms of Service.

6. Refunds

6.1 General Rule: Non-Refundable. Except as set out in Section 6.2, Booking Credits and subscription fees, once purchased or invoiced, are non-refundable, including unused Credits remaining in Customer’s balance at the time of downgrade, cancellation, or termination.

6.2 Exceptions. Notwithstanding Section 6.1, a refund or credit adjustment may be issued: (a) where mandatory consumer protection law applicable to Customer requires a refund (e.g., valid exercise of the EU 14-day right of withdrawal described in the Terms of Service, to the extent applicable); (b) where LumenIA, in its reasonable discretion, determines that a verified service failure attributable to LumenIA (such as a platform outage that prevented Customer from using purchased Credits) warrants a partial or full credit adjustment; or (c) where required by a separate written agreement between the parties.

6.3 Requesting a Refund or Credit Adjustment. Refund or credit adjustment requests should be submitted to [email protected] with sufficient detail to allow LumenIA to investigate (e.g., dates, affected reservations, description of the issue). LumenIA will respond within a reasonable time.

7. Consequences of Non-Payment

7.1 Suspension. Failure to pay an invoice by its due date, or failure of an automated payment charge (e.g., expired card, insufficient funds), may result in suspension of access to the Services, including blocking of new reservations and AI Voice Agent functionality, in accordance with the Terms of Service.

7.2 Late Payment. LumenIA reserves the right to charge interest on overdue amounts at the statutory rate applicable under Italian law (Legislative Decree 231/2002 on late payments in commercial transactions), and to recover reasonable collection costs, without prejudice to any other remedy available.

7.3 Reinstatement. Upon full payment of overdue amounts, LumenIA will restore access to the Services, subject to any other applicable suspension or termination conditions under the Terms of Service.

8. Changes to This Policy

LumenIA may update this Policy from time to time, consistent with the change-notification provisions of the Terms of Service. The version in effect at the time of a given transaction governs that transaction, except where a change is required immediately by law.

9. Contact

Questions regarding billing, Credits, or refunds should be directed to [email protected] or LumenIA S.r.l., Via del Calzolaio 145, 55100, Località Saltocchio, Lucca (LU), Italy.