Legal
Privacy policy
Last updated: [DATE]
1. Who we are
The Brunch (thebrunch.org) is run by [LEGAL NAME OF THE BRUNCH OR ITS OWNER], [TAX NUMBER (NIF)], [REGISTERED ADDRESS], Portugal. We are the data controller for the personal data described here: we decide why and how it is used.
Contact for anything about your data: [PRIVACY EMAIL, e.g. privacy@thebrunch.org].
2. What we collect and why
| Data | Why | Legal basis (GDPR) |
|---|---|---|
| First name, email, city | To put you on the waitlist for your city and email you when it opens. | Steps you ask us to take before an agreement (Art. 6(1)(b)) |
| Languages you speak, whether you'd like the same or a different group | To seat you at a table where you can talk, with the group you prefer. | Steps you ask us to take before an agreement (Art. 6(1)(b)) |
| Neighbourhood, Instagram handle, what brings you, and the "About you" text (all optional) | To match you to a table of people with a similar rhythm. Your "About you" text is read only by the people who match tables. They are never shown to other guests or shared with anyone. | Your consent, given by filling these fields in (Art. 6(1)(a)) |
| Relationship status and whether you'd prefer to get to know women, men or both (optional) | To match tables. Together, these answers can say something about your sexual orientation, which the law treats as a special category of data. We only keep them if you tick the consent box, we use them for matching only, and they are never shown to other guests. | Your explicit consent (Art. 9(2)(a) and Art. 6(1)(a)) |
| Founding member choice and, if you save one, a payment card | To charge the founding price of the plan you chose (Brunch €14.90/month or Brunch + Wellness €39.90/month) once your city reaches 50. We email you at least 7 days before the first charge. Your card details go straight to Stripe; we never see or store the card number, only a reference to it. | Steps you ask us to take before an agreement, and the agreement itself (Art. 6(1)(b)) |
| A one-way hash of your IP address, kept for about 15 minutes | To limit how often a sign-up can be sent, which stops spam. | Our legitimate interest in keeping the service secure (Art. 6(1)(f)) |
We don't ask for health data and we don't sell your data. We don't use advertising or analytics cookies on this site.
3. Who processes it for us
- Cloudflare, Inc.: hosts the site and stores the waitlist database. It also runs the Turnstile spam check, which looks at signals from your browser to tell people from bots, without setting tracking cookies.
- Stripe Payments Europe, Ltd.: stores founding members' cards and processes payments. Stripe is also a controller for some data, for fraud prevention and legal duties, under its own privacy policy.
- Google (Google Fonts): serves the site's fonts, so your browser sends your IP address to Google when the page loads.
- WhatsApp (Meta): only if you choose to message us there.
- [EMAIL PROVIDER used to send launch emails, if any]
Some of these providers may process data outside the European Economic Area. When they do, they rely on the European Commission's adequacy decisions (including the EU–US Data Privacy Framework) or standard contractual clauses.
4. How long we keep it
We keep your waitlist details until your city opens and for [RETENTION PERIOD, e.g. 24 months] after you last hear from us, unless you ask us to delete them sooner. The IP hash used for spam protection is deleted after about 15 minutes.
5. Your rights
You can ask us to see, correct, delete, restrict or hand over a copy of your data, and you can object to how we use it. Where we rely on your consent, you can withdraw it at any time; we then delete those answers. This doesn't affect what we did before. Founding members can also cancel before the first charge, and any time after. To do any of this, email [PRIVACY EMAIL]. We reply within one month.
You can also complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at cnpd.pt.
6. Age
The Brunch is for adults. Please don't sign up if you are under 18.
7. Changes
If we change this policy, we'll update the date at the top. If the change matters for people already on the waitlist, we'll tell them by email.