Privacy Policy

1. Controller

The controller responsible for processing personal data on this website and within the “Bilnaro” service is:

WP - UG (haftungsbeschränkt)
represented by its managing director Gang Wu
Am Molkenbrunnen 21
64287 Darmstadt
Deutschland
Email: service@bilnaro.com

No data protection officer has been appointed; the conditions of § 38 BDSG are not met.

2. Overview

Bilnaro is an AI voice assistant that takes phone orders for restaurants. This creates three situations that must be assessed separately under data protection law, and they are treated separately here:

• You visit this website — sections 3 to 5.
• You call the demo number to try the assistant — section 6. We are the controller.
• You place a phone order with a restaurant that uses Bilnaro — section 7. The restaurant is the controller; we process the data on its behalf.

3. Visiting this website (server log files)

When you access this website, the web server automatically stores the following information in log files:

• IP address of the requesting device
• date and time of access
• requested address and amount of data transferred
• HTTP status code
• referring page
• browser, browser version and operating system (user agent)

The purpose is technical operation, stability and security of the service, in particular defending against automated and abusive access. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in a secure and functioning service. This data is not combined with other data sources. Log files are deleted after 14 days.

The website is hosted on Oracle Cloud Infrastructure, data centre region Frankfurt am Main (eu-frankfurt-1), Germany. A data processing agreement under Art. 28 GDPR is in place with the provider.

Traffic is transmitted exclusively over encrypted HTTPS (TLS).

4. Cookies and analytics (Google Analytics)

This section applies to this website only (bilnaro.com). The management portal at app.bilnaro.com embeds no analytics — see section 9.

Unless you have explicitly consented, this website sets no cookies that are not required for operation, and loads no analytics services.

On your first visit a banner appears. Your decision is stored exclusively in your own browser (localStorage, key cookie-consent); no cookie is set for this and nothing is transmitted to us.

• Decline or no decision — Google Analytics is not loaded, no analytics cookies are set.
• Accept — Google Analytics 4 is loaded.

The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics sets cookies and processes, among other things, the truncated IP address, device and browser information, the referring page, the pages visited and the time spent, in order to analyse the use of this website statistically. We use these statistics in aggregated form only.

The legal basis is your consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG. A transfer to Google LLC in the United States cannot be ruled out; Google LLC is certified under the EU-US Data Privacy Framework, and standard contractual clauses under Art. 46(2)(c) GDPR apply in addition.

You can change your decision at any time with effect for the future. Withdrawing is as easy as giving consent:

Change cookie settings

5. Waiting list and contact form

There is one form on this website: the request for a call back. The waiting list, which used to let you be notified when the service launches, no longer exists, and the addresses collected through it have been deleted (section 5.1).

5.1 Waiting list (closed)

Until 22 August 2026 you could sign up on this website for a waiting list, in order to be notified when the service launches. That form no longer exists; new sign-ups are not possible. For the people who signed up before then, we stored the email address and the language version of this website they used. The legal basis is your consent under Art. 6(1)(a) GDPR.

We are no longer sending the launch notification we had announced. The purpose you gave us your address for has therefore ceased: on 31 August 2026 we deleted every waiting-list entry. No data from this form remains, and there is nothing left for you to withdraw. This does not affect the lawfulness of the processing carried out before then.

5.2 Contact form (“request a call back”)

You can use the contact form to ask us to call you back. We process the details you enter: name of the restaurant, name of the contact person, phone number, email address and an optional message. We also store the language version of this website you used and the time of your enquiry.

The sole purpose is to answer your enquiry and to discuss with you whether Bilnaro is a fit for your restaurant. The legal basis is Art. 6(1)(b) GDPR (steps taken at your request prior to entering into a contract).

Your details are also forwarded to us by email, using the email service provider named in section 8. We do not use this data for advertising beyond your enquiry and do not pass it on to third parties. You may object to further processing at any time by an informal email to service@bilnaro.com; we will then delete your enquiry.

6. Live demo: calling the demo restaurant

The home page shows the phone number +49 6151 7074228, which you can call to try the assistant yourself. For these calls we are the controller.

The following data is processed:

• your phone number, insofar as it is transmitted (not applicable if withheld)
• your speech — solely in order to convert it into text, see section 8
• the conversation text and the test order derived from it
• time and duration of the call

The legal basis is your consent under Art. 6(1)(a) GDPR, which you give by voluntarily calling for the purpose of testing, and additionally Art. 6(1)(f) GDPR (our interest in demonstrating the service).

Public display of test orders: so that you can recognise your own order, the most recent test orders are displayed on the home page. The phone number is shown truncated (example: +4917*****34); name and address are never displayed.

Please do not state any personal data in the demo beyond what the test requires — a made-up name is enough.

7. Phone orders with a restaurant that uses Bilnaro

If you call a restaurant that uses Bilnaro, the restaurant is the controller. We process the data solely on its behalf and on its instructions (processing on behalf of a controller under Art. 28 GDPR). The restaurant informs you about purposes, storage periods and your rights. The following is provided for transparency about the technical process.

These calls are not recorded either. No voice or speaker recognition takes place, no profiles are created, and there is no automated decision-making within the meaning of Art. 22 GDPR. The restaurant's legal basis is normally Art. 6(1)(b) GDPR — the data is necessary to accept and fulfil your order.

8. Processors used and transfers to third countries

To turn a phone conversation into text and a spoken reply, we use specialised service providers. They process the data solely on our instructions and not for their own purposes. Data processing agreements under Art. 28 GDPR are in place with every provider listed below.

We call speech recognition and speech synthesis through their respective EU endpoints, so processing takes place predominantly within the European Union. For ongoing operations, security and support, the providers may also access the data from outside the EU to a limited extent.

For the United Kingdom, where Speechmatics is established, an adequacy decision by the European Commission under Art. 45 GDPR is in place (renewed on 19 December 2025, valid until 27 December 2031), so a transfer there requires no additional safeguards. For providers established in the USA — Soniox and, depending on routing, Telnyx and Google — an adequacy decision applies only to companies certified under the EU-US Data Privacy Framework; otherwise we rely on the European Commission's standard contractual clauses under Art. 46(2)(c) GDPR.

Despite these safeguards, it cannot be ruled out that authorities in those countries demand access to the data under their national laws. We therefore transfer only the data required for the respective processing step. We store an audio recording of your call only for calls to the demo number and only for 5 days (section 6); calls to a restaurant using Bilnaro are not recorded.

9. Management portal for restaurants

For restaurants using Bilnaro we operate a management portal at app.bilnaro.com. There we process the name, email address and password of authorised users. The password is stored exclusively as a cryptographic hash (bcrypt), never in plain text.

After signing in, a session token as well as name, email address and role are stored in your browser's local storage for display purposes. This is strictly necessary to operate the portal (§ 25(2) TDDDG); the data is deleted when you sign out. The legal basis is Art. 6(1)(b) GDPR.

The management portal embeds no analytics: Google Analytics is not loaded there, not even after you consented on bilnaro.com. It sets no cookies and loads no third-party content — your browser only requests files from app.bilnaro.com. There is therefore no consent banner either.

10. Storage periods

• Call recordings — demo number only, 5 days. Calls to a restaurant are not recorded.
• Server log files — 14 days.
• Connection data for billing — for every incoming call we store the number that was called and when the call started and ended, because our prices are billed per call. Your own number is deleted from that entry after 90 days; the entry itself remains as a billing record and can no longer be linked to you.
• Waiting list (closed) — the entries were deleted on 31 August 2026; no data is retained.
• Enquiries sent through the contact form — until your enquiry has been dealt with or you object to the processing.
• Test orders from the demo — 30 days.
• Orders placed with a restaurant — as instructed by that restaurant. Retention obligations under commercial and tax law (§ 147 AO, § 257 HGB) may prevent earlier deletion.
• Delivery logs of our emails — one month, at the email service provider.
• Portal account data — for the duration of the contractual relationship.

11. Your rights

You have the right to

• access to the data we process about you (Art. 15 GDPR),
• rectification of inaccurate data (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• object to processing based on a legitimate interest (Art. 21 GDPR), and
• withdraw consent with effect for the future (Art. 7(3) GDPR).

An informal message to service@bilnaro.com is sufficient.

If your request concerns an order placed with a restaurant, please contact that restaurant — it is the controller. Should such a request nevertheless reach us, we will forward it without delay.

12. Right to lodge a complaint

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement (Art. 77 GDPR). The authority responsible for us is:

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Wilhelmstraße 7
65185 Wiesbaden
Germany
Phone: +49 611 1408-0
Email: poststelle@datenschutz.hessen.de
datenschutz.hessen.de

You can also submit a complaint online: Beschwerde übermitteln.

13. Changes to this policy

We update this policy when the legal situation, our services or the processors we use change. The version published on this page applies. The German version is authoritative; the English translation is provided for convenience only.