Privacy Policy for Partners
Last Updated: January 20, 2026
TIIN S.R.L. ("Flevario", "we", "us") operates the Flevario Merchant/Barista application. This policy applies to our **Partner Cafés, Business Owners, and their Staff** ("Partners" or "you").
We are committed to protecting the personal data of our business partners and their employees in compliance with the EU General Data Protection Regulation (GDPR) and Romanian legislation.
1. Who We Are (Data Controller)
- Company Name: TIIN S.R.L.
- Fiscal Code (CUI): RO52329821
- Registered Address: București Sectorul 3, Strada NERVA TRAIAN, Nr. 27-33
- Contact Email: partners@flevario.com
2. The Data We Collect
We collect data necessary to manage your cafe's presence on Flevario and process payouts. This includes:
A. Business & Representative Information
- Representative Data: Name, email address, and phone number of the business owner or manager.
- Legal Entity Details: Company Name, CUI/CIF, Reg. Com., and Registered Address (publicly available data).
- Financial Data: IBAN bank account details for processing monthly payouts/invoices.
- Staff Accounts: Names and PINs/Logins for baristas utilizing the app (if applicable).
B. Information We Collect Automatically
- Store Device Security: To prevent unauthorized access to your merchant dashboard, we log the Device ID and IP address of tablets/phones used to scan codes.
- Redemption Logs: We record every interaction between your staff and a customer (timestamp, item sold, discount applied) to calculate your revenue.
- App Performance: Crash reports (via Sentry/Firebase) to ensure the Merchant App remains stable during business hours.
3. Why We Process Your Data
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Contract Management | Rep. Name, CUI, Signatures | Contract Performance |
| Payouts & Invoicing | IBAN, Transaction Logs | Legal Obligation (Fiscal) |
| Fraud Monitoring | Redemption patterns, Device Logs | Legitimate Interest |
| Public Display | Store Name, Address, Photos | Contractual Necessity |
4. How We Share Your Data
- Flevario Users (Customers): Your Store Name, Address, Opening Hours, and Products are displayed publicly on the Flevario Client App to drive traffic to your location.
- Service Providers:
- Microsoft Azure: Hosting infrastructure.
- Banking Partners / Stripe: For processing payouts to your bank account.
- Google/Apple: For distributing the Merchant App to your devices.
- Legal Authorities: Reporting to ANAF (Romanian Tax Authority) as required for B2B invoicing and fiscal reporting.
5. Data Retention
- Contract Duration: We retain your business profile while our partnership is active.
- Fiscal Records: Invoices and payout records are kept for **10 years** as required by Romanian accounting law.
- Redemption Logs: Retained for 5 years for audit and dispute resolution purposes.
6. Rights of Individuals
While legal entities (companies) do not have GDPR rights, the individuals (representatives, staff) whose data we process do:
- Right to Access & Rectification: Update your contact details or staff lists via the Merchant Dashboard.
- Right to Erasure: You may request the deletion of specific personal data (e.g., a former staff member's account), subject to our fiscal retention duties.
To exercise these rights, please email us at partners@flevario.com.
7. Security
We secure your Merchant account using strict access controls. Staff accounts are isolated to ensure they can process sales but cannot alter critical business settings (like IBANs) without Admin authorization.
Contact & Support
For partnership inquiries or privacy concerns, contact us at partners@flevario.com.