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Privacy Policy

Last updated 14 October 2026

This policy explains what personal data frunt handles, why, who we share it with, how long we keep it, and the rights you have over it. It covers both the manager web dashboard and the staff mobile app — both run on the same backend.

Who we are

frunt is a service operated by MGKCodes Ltd (the “service”, “we”, “us”), a company registered in England and Wales (company number 17035502) with registered office at 96 High Street, Reigate, RH2 9AP. ICO data-protection registration number: ZC173549.

We provide a preparation system for restaurant teams — onboarding, training, compliance documentation, operational briefs, scheduling, and a chat surface where staff can ask questions about their workplace's documents.

If you have questions, write to us at privacy@frunthospitality.com (or our postal address above).

Our role: who controls your data

The short version. For almost everything about your restaurant — your staff list, the documents you upload, training results, rotas, briefs — your employer (the restaurant) is the data controller. They decide what to collect and why. frunt is their data processor: we hold and process that data on their instructions, for their benefit.

We are the controller only for a narrow set of things we decide ourselves: your account credentials, billing data (for the account holder), and any support correspondence you send us.

This matters for your rights (below). Where your employer is the controller, the fastest route for access, correction, or deletion is usually through them — they can action most of it directly in the product. We help fulfil those requests on their behalf.

What personal data we handle

Data you give us directly:

WhatWhenOur role
Email addressAccount creation, invitation acceptanceController (auth) / Processor (tenant membership)
Password (hashed — we never see the plain text)Account creationController
Display nameProfile setupProcessor (on behalf of your employer)
Role within the restaurant (owner, manager, floor, kitchen, etc.)Assigned by your employer on invitationProcessor
Documents you upload, briefs you post, messages you send and questions you ask, in the app or on WhatsAppWhenever you use the productProcessor
Mobile number, if you link WhatsAppWhen you link it, so you can message frunt on WhatsAppProcessor
Billing details (account holders only)Paid-plan checkoutController (held by Stripe — see below)
Enquiries and support messages, including on WhatsApp (your name, restaurant, email or phone number)When you contact usController

Staff operational data your employer asks us to hold:

WhatWhy
Pay rate and pay typePayroll export and rota costing — visible to managers, never to other staff
Contracted / min / max hours, availability, leave and holiday datesBuilding and publishing the rota
Shifts assigned to youShowing you your schedule; shift-cover requests
Capabilities / stations (e.g. barista, floor)Matching you to shifts
Training records — attestations, quiz attempts, course completions and expiry datesProving the team is trained on safety-critical documents (a legal duty of your employer)
Acknowledgements, replies and reactions on briefsConfirming staff have seen operational updates
Ask questions and chat historyAnswering your questions and helping managers see where the team needs clearer documentation

Compliance evidence (special handling):

Your employer may store right-to-work evidence and certificates (food hygiene, allergen, personal/alcohol licence, first aid) against your record. These files are kept in a private, encrypted store, segregated per restaurant. They are never sent to any AI model and are never read by our chat or retrieval systems. A manager labels them by hand; we store them and track their expiry, nothing more.

Data we generate automatically:

  • Activity timestamps (last sign-in, when you acknowledged a brief, when you completed a course) — for service operation and to help your employer manage the team.
  • Mobile push-notification token — so the app can deliver alerts about briefs, shift changes, and training due. Stored against your device; stale tokens are removed automatically.
  • IP address and basic device/request information — short-lived, for security and to operate the service.
  • Session cookies — essential only, to keep you signed in.
  • Product-analytics events in the signed-in dashboard (which pages and features you use, tied to your account id) — to understand what's useful and improve the product. Our public website uses only cookieless, aggregate visitor counts; neither includes your name or your message content.

What we do NOT do:

  • We do not use advertising, marketing, or cross-site tracking cookies. Our public website sets no analytics cookies at all (visitor analytics there are cookieless); the signed-in dashboard stores a product-analytics identifier, disclosed above and covered by this policy.
  • We do not sell your data, ever.
  • We do not use your restaurant's content to train AI models. AI processing happens only to serve that same restaurant, within its own data.
  • We do not collect your date of birth, national insurance number, or home address.

How we use AI, and what it never sees

frunt uses AI (large language models) as infrastructure, not as a place your data is exposed. Specifically:

  • Document content you upload is sent to our AI providers to extract, structure, and classify it, to answer questions (in the app and on WhatsApp), and to generate personalised training from your own menus and policies.
  • Document text is sent to an embeddings provider to build the private search index used to answer questions.
  • Operational briefs are deliberately kept out of the AI knowledge base — they are short-lived comms, not queryable knowledge.
  • Pay rates, certificate files and right-to-work evidence are never sent to any AI model.
  • When a manager uses the rota's AI features (describing a change in plain words, or drafting a week) or imports past training records from a spreadsheet or export, staff go to Anthropic as codes that mean nothing outside that one request, with only the work details the job needs (role, hours, availability, leave, shift times). Names are put back on our side. Two exceptions: a photo or scan of a paper rota or training record is read as an image, names included; and anything we can't recognise as one of your team's names (a misspelling, or someone who isn't on your team), or any name inside your documents, is read along with the rest.

AI helps managers prepare their team. Final decisions about training, employment, or compliance are always made by people — we do not make decisions about you that have legal or similarly significant effects based solely on automated processing.

Why we handle this data (lawful basis)

PurposeLawful basis
Operating your account (auth, sign-in, password reset)Contract (Art 6(1)(b)) — providing the service you signed up for
Storing documents and serving them to your teamContract; legitimate interest (Art 6(1)(f)) of your employer in operational continuity
Recording attestations and training to compliance documentsLegal obligation of your employer (Art 6(1)(c)) — food safety, allergen, employment law
Essential service emails (security, invites, account changes)Contract
Billing and tax recordsLegal obligation (HMRC retention)
Security monitoringLegitimate interest
Product analytics in the signed-in app (which features are used)Legitimate interest (Art 6(1)(f)) — understanding usage to improve the service
Error monitoring and service-usage / AI-cost meteringLegitimate interest — reliability, security, and operating/budgeting the service

We do not process personal data for marketing without your separate consent.

Who we share data with

We use the sub-processors below. Each is contractually bound to data-protection terms at least as protective as ours and only processes data on our instructions. We notify account-holding restaurants before adding or replacing a production sub-processor.

Sub-processorWhat they processWhereTransfer
SupabaseDatabase, file storage, and authentication for all restaurant content and account recordsEU regionUK adequacy
VercelWeb hosting and edge compute (IPs and request metadata, transient); cookieless, aggregate website traffic analyticsGlobal edgeSCCs in DPA
Anthropic (Claude)Document extraction, classification, answers (in the app and on WhatsApp), training generation, and the rota and training-record requests a manager makes (staff as codes, with the work details the job needs; a photo of a paper record is read as an image, names included)United StatesUK IDTA / EU SCCs
OpenAIDocument text sent for vector embedding (search index)United StatesUK IDTA / EU SCCs
InngestBackground-job metadata: IDs, status, file names and page counts, and the note a manager adds when asking for a course to be rewritten. Never a document's textUnited StatesUK IDTA / EU SCCs
StripePayment and billing details (account holders only)US / EUStripe SCCs
ResendOutbound transactional emails (invites, password reset, account changes)United StatesResend DPA / SCCs
Meta (WhatsApp Business Platform)Messages sent to and from frunt on WhatsApp (questions, answers drawn from your documents, and enquiries) and the phone numbers they come from; Meta keeps messages for up to 30 days to provide the serviceGlobal (Meta data centres)WhatsApp Business UK Data Transfer Addendum
Google (Firebase Cloud Messaging)Mobile push delivery, onward through Apple's push service for iPhones: the device token and the notification's text, which can include titles, message previews and first names (never surnames, email addresses or document contents)Google CloudGoogle SCCs
PostHogProduct analytics — which pages and features are used in the signed-in dashboard (tied to your account id, never names or message content); cookieless visitor counts on the public websiteEU regionUK adequacy
SentryError and performance diagnostics (stack traces, request metadata) to keep the service reliableEU region (Frankfurt)SCCs in DPA

We do not share your personal data with any other third party, except when required by law, to protect rights or safety, or in connection with a corporate transaction (we would notify affected restaurants beforehand).

International transfers

Some sub-processors (Anthropic, OpenAI, Inngest, Stripe, Resend, Google, Meta) are based in or route through the United States. Those transfers rely on the UK International Data Transfer Agreement (IDTA) and EU Standard Contractual Clauses, with data encrypted in transit and at rest.

How long we keep your data

CategoryRetention
Active account dataWhile your account with a restaurant is active
Document content and version historyWhile the restaurant remains a customer; removed after offboarding
Documents we prepared before a restaurant subscribedDeleted three months after the set-up period ends if the restaurant doesn't subscribe; sooner on request
Files a restaurant sends us to set up its accountDeleted as soon as we've sorted them into its documents, and at the latest when set-up ends. Personal records we don't need, such as passports or payslips, are deleted straight away without being used
Attestation, training, and audit recordsRetained for the compliance period set by your employer (a manager record proving who was trained on what), then pseudonymised — your identity is replaced with a one-way hash while the event survives
Right-to-work evidenceRetained for the legal window after employment ends, then deleted
Billing and tax recordsAs required by HMRC
Security and request logsShort-lived
BackupsRolling window — deleted data may persist briefly in backups

When you leave a restaurant, your access is revoked immediately. Your records are archived, not deleted — they remain in that restaurant's compliance history per the schedule above, until full erasure is requested.

Your rights

You have the following rights under UK GDPR. Because your employer is usually the controller of your work data, the quickest route is often to ask them — they can action most requests directly in the product. You can also contact us and we will help fulfil the request.

RightHow to exercise
Access — a copy of your personal dataAsk your employer, or email us
Rectification — correct inaccurate dataUpdate your profile, ask your employer, or email us
Erasure (right to be forgotten)Request via your employer or us. Some records may be retained in pseudonymised form where there is a legal obligation
Restriction of processingEmail us
Portability — your data in a machine-readable formatEmail us or ask your employer
Objection to legitimate-interest processingEmail us, naming the processing
Complaint to the ICOico.org.uk — though we'd appreciate the chance to fix it first

We respond to verified requests within one calendar month (extendable by two months for complex requests, and we'll tell you). There is no fee unless a request is manifestly unfounded or excessive.

How we keep your data secure

  • All data in transit is encrypted (TLS 1.2+).
  • All data at rest is encrypted at the database and storage layers.
  • Each restaurant's data is isolated by row-level security on every table, so one restaurant can never see another's.
  • Compliance evidence and staff PII sit in a private store that AI systems never read.
  • Access to production systems is restricted and logged.

If a personal-data breach occurs, we will notify affected restaurants without undue delay and within 72 hours where Article 33 requires it.

Children

frunt is a workplace service for adults. We do not knowingly collect data from anyone under 16. If you believe a child has provided us data, contact us.

Changes to this policy

We update this policy when our practices change; the “last updated” date above shows when. Material changes are notified to account-holding restaurants by email and in the product.

Contact

Privacy questions: privacy@frunthospitality.com. You can also contact the UK Information Commissioner's Office at ico.org.uk or 0303 123 1113.

See also our Terms & Conditions.