1. The two capacities of innowi (merchant vs. end-customer)

To understand this policy, you must look at the capacity in which you interact with our platform:

Merchant: If you are a restaurant owner, operator, or employee using Innowi to run your business, we act as a Data Controller for your account management and billing data.

End-Customer: If you are a guest placing an order at a restaurant via an Innowi POS, Kiosk, QR code, or Online orders via website or mobile app, we process your transaction data primarily as a Data Processor on behalf of that Merchant, while we maintain data rules for our network infrastructure.

2. Information we collect

A. Information provided directly to us

Account & identity data: Names, email addresses, phone numbers, delivery physical addresses, usernames, and passwords when creating an online ordering profile or Merchant Portal account.

Transaction & payment data: Payment card numbers, expiration dates, CVVs, and billing histories. Note: All credit card processing is handled through PCI-DSS compliant third-party payment gateways (e.g., Elavon, Datacap, NMI, Authorize.NET, and Stripe Payments). Innowi does not store raw, unencrypted magnetic stripe or EMV chip data on its local servers.

Marketing & loyalty data: Phone numbers and email addresses provided when an End-Customer explicitly opts into a restaurant’s digital loyalty, rewards, or marketing program powered by Innowi.

B. Information collected automatically

Device & technical data: IP addresses, hardware models, unique device identifiers (UDID), operating system versions, browser types, and system performance metrics collected directly from physical Kiosks or online ordering portals.

Geolocation data: Precise or approximate physical location information derived from an End-Customer’s mobile device when using location-based QR code ordering or locating nearby restaurant storefronts, subject to the permissions granted on the device.

Usage & analytics data: Information regarding how users navigate our online portals, menu item interaction frequencies, shopping cart abandonments, and average checkout duration collected through cookies, web beacons, and tracking pixels.

3. How we use your information

We utilize collected information to deliver robust, secure, and revenue-generating services, specifically to:

Process transactions: Process point-of-sale transactions, authenticate payment methods, and securely inject digital orders into restaurant Kitchen Display Systems (KDS) and printer environments.

Build & maintain merchant platforms: Construct, host, and maintain custom-branded first-party online ordering websites and mobile applications for Merchants.

Marketing & loyalty services: Facilitate automated email and SMS marketing campaigns, search engine optimization (SEO) configurations, and loyalty reward programs selected by the Merchant.

Fraud prevention & security: Detect, investigate, and mitigate fraudulent credit card chargebacks, system breaches, malware deployment, and other unauthorized or unlawful activities.

System maintenance & optimization: Maintain, update, and optimize the performance, reliability, and security of Innowi’s full-stack hardware and cloud software infrastructure.

4. Sharing and disclosure of information

A. Sharing with Merchants

When an End-Customer places an order through an Innowi Online Ordering portal, POS, Kiosk, QR Code, or mobile application, their order details, name, phone number, and transaction history are shared directly with the specific Merchant operating that restaurant location to facilitate order fulfillment and maintain accurate business records.

B. Sharing with third-party integrations & service vendors

We share limited information with essential operational service providers to maintain the reliability and functionality of our ecosystem, including:

Payment gateways: To process credit card authorizations, payment settlements, and transaction clearing.

Aggregation nodes (KitchenHub): To securely map, synchronize, and process multi-channel third-party marketplace orders (including DoorDash, Uber Eats, and GrubHub) through the Innowi POS, Kiosk, and Tablet platforms.

Communication delivery vendors: Telecommunication providers and messaging platforms that deliver automated SMS notifications, order updates, and email receipts.

C. SMS privacy and data sharing policy

Non-subscribed customers: For guests using the platform solely to complete a transaction without opting into marketing communications, mobile information, SMS originator opt-in data, and consumer consent will not be shared with any third parties or affiliates for promotional or marketing purposes.

Subscribed / opted-In customers: For users who voluntarily enroll in a restaurant’s rewards or digital marketing program, Innowi will not share SMS opt-in status with third parties for purposes unrelated to delivering the requested messaging campaign. We may share limited information with authorized processing vendors (such as wireless carriers or cloud SMS providers) solely to facilitate the delivery of those communications.

D. Legal & corporate disclosures

We may disclose information when required by applicable law, governmental authority, tax audit, subpoena, or court order within the State of California, or in connection with a merger, acquisition, corporate restructuring, financing, or sale of all or substantially all assets of Innowi Inc.

5. Cookies, beacons, and digital tracking

Innowi and our digital marketing modules use cookies and similar pixel-tracking mechanisms to recognize a browser or returning guest on a Merchant’s online ordering storefront. This records customized menu configurations and preferences, aggregates site performance metrics, and optimizes targeted first-party marketing efforts. Users can adjust their browser privacy settings to decline cookies, though certain online ordering features may stop working as intended.

6. State-specific privacy rights (ccpa/cpra compliance)

Under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), California residents using our Services have specific legal rights regarding their personal information. These rights include:

The right to know: Request disclosure of the categories and specific pieces of personal information Innowi has collected, processed, used, or disclosed during the preceding twelve (12) months.

The right to elete: Request the deletion of personal information maintained directly by Innowi, subject to applicable legal, financial, security, and record-retention requirements.

The right to opt-out of sale or sharing: Innowi does not sell personal information or share consumer phone lists with third parties for independent commercial or marketing purposes.

Non-discrimination: Innowi will not deny services, reduce functionality, charge different prices, or otherwise discriminate against any individual for exercising their applicable privacy rights.

To exercise these rights, individuals may submit a verifiable consumer request by contacting us at care@innowi.com

7. Data security and retention

Innowi employs comprehensive administrative, physical, and technical safeguards designed to protect personal information against unauthorized access, modification, disclosure, loss, theft, or misuse.

Data retention: We retain transactional records and other applicable information only for as long as necessary to comply with payment network requirements, tax and financial regulations, fraud prevention obligations, legal record-retention requirements, and the duration of active Merchant service relationships.

8. Accessibility statement

At Innowi, we believe every restaurant operator, staff member, and customer deserves a seamless experience with our technology, regardless of physical or cognitive ability. We are committed to designing our systems in accordance with recognized digital accessibility standards and best practices.

Platform design: Our proprietary POS layouts, Self-Service Kiosks, QR Scan-and-Pay solutions, and digital storefronts are developed and continuously tested to minimize navigation barriers and improve usability.

Assistive integration: Our web interfaces are designed to work with standard operating system accessibility features, including screen readers, keyboard-only navigation, browser zoom, and device scaling capabilities.

Third-party boundaries: Certain components of our ecosystem, including maps, payment processing terminals, and third-party aggregation platforms, are operated by external providers and fall outside Innowi’s direct technical control. As a result, we cannot guarantee that these third-party services maintain the same accessibility standards as our own platforms.

Accessibility feedback: If you experience accessibility barriers or would like to provide feedback regarding the accessibility of our Services, please contact our support team at (510) 588-7102 or by email at care@innowi.com

9. Contact Information

For questions, compliance inquiries, or clarification regarding Innowi’s privacy systems, reach out to us at:

Innowi Inc.

Corporate headquarters: Santa Clara, California

Email contact: care@innowi.com

Phone / support text: (510) 588-7102

Website: www.innowi.com