Data processing agreement

Article 1. Parties and roles

The restaurant that opens a Full Floor account (the restaurant) is the controller of its guests' personal data. MCHLBLLN BV (Full Floor) is the processor.

Processor: MCHLBLLN BV, Gulden Bodem 45/302, 3800 Sint-Truiden, company number BE0772.728.625. Contact: michiel@michielbellen.be.

Data of the guest network (guest accounts, reviews and the city guide) is outside this agreement: for that data MCHLBLLN BV is itself the controller.

Article 2. Subject matter and duration

Full Floor provides the restaurant with a platform: its website, bookings, guest file, mail, phone receptionist and payment links. Processing guest data on the restaurant's behalf is part of that service.

This agreement lasts as long as the subscription, the free trial included, plus the grace period of 30 days after it ends, until the data has been deleted under article 13.

Article 3. Nature and purpose of the processing

Full Floor stores and retrieves the data, sends confirmations and reminders, transcribes calls (only if the restaurant switches the phone receptionist on), translates and exports. The purpose is to run the restaurant's bookings and guest relations.

Full Floor processes personal data only on the restaurant's documented instructions: the settings it makes in the product, and this agreement.

If Full Floor believes an instruction infringes the law, it tells the restaurant.

Article 4. Data subjects and data categories

The data subjects are:

guests who book or visit
people who send a group request
callers
people on the waitlist
visitors of the website chat
the restaurant's own staff users

The data categories are:

guest names
contact details (email, mobile number, language)
booking history
call transcripts, and recordings only if the restaurant switches recording on
chat transcripts
feedback and consents
allergy and dietary information that guests give

Allergy and dietary information can be health data. It is processed only because the guest supplied it with consent when booking, and the restaurant answers for the legal basis.

Full Floor holds the status of a payment, not card numbers. Card data stays with Mollie.

Article 5. The restaurant's responsibilities

The restaurant makes sure it has a lawful basis for the processing it instructs.

The restaurant informs its guests about the processing, as the law requires.

The restaurant answers for the consents it records in the product, and keeps them accurate.

Article 6. Confidentiality

Everyone at Full Floor with access to the data is bound by confidentiality, and access is limited to those who need it to provide the service.

Article 7. Security measures

Full Floor takes these measures to protect the data:

connections are encrypted;
sign-in is by a one-time code sent to the owner's email address, stored only as a hash, and sessions are signed;
roles (owner, admin, member) are enforced on the server, not only hidden in the screen;
exports and erasures of personal data are recorded in a log of who did what, how many and when, never of the data itself;
requests for sign-in codes and attempts to enter them are limited;
one restaurant's data is kept apart from every other restaurant's.

Article 8. Sub-processors

The restaurant gives Full Floor general authorisation to use the sub-processors in the table below.

Sub-processors of Full Floor
Name	What they do for Full Floor	Data they handle	Whose data	Plan or feature	Location	In use	Privacy statement
Hosting Hetzner Online GmbH	Runs the servers and the database that hold your website, bookings and guest file.	Everything Full Floor stores for you	Both	All plans	Germany	Yes	Privacy statement of Hetzner Online GmbH
Payments Mollie B.V.	Takes deposits, card guarantees and gift card payments, only once you connect your own Mollie account. Mollie also has its own agreement with you as the account holder.	Payment status and amounts; Guest name and email for the payment	Your guests	All plans	Netherlands	Not yet in use	Privacy statement of Mollie B.V.
Telephony Not yet chosen	Connects the phone line to the AI receptionist, only if you switch it on.	Caller's number; Call audio while the call lasts, transcript; recording only if you switch recording on	Your guests	Complete only	To be named before it is used	Not yet in use	None yet
AI language model Anthropic PBC	Translation, reading a photographed menu, the website chat and the receptionist's conversation.	The text, menu photo or call transcript being processed	Your guests	All plans	United States	Not yet in use	Privacy statement of Anthropic PBC
Help chat Anthropic PBC	Answers the restaurant owner's questions in the help chat, when it is switched on.	What the owner types or sends in the help chat, which may include guest data if the owner includes it	Both	All plans	United States	Yes	Privacy statement of Anthropic PBC
Mail delivery Postmark (ActiveCampaign LLC)	Delivers sign-in codes, confirmations, reminders and other mail sent on your behalf.	Recipient's name and email address; The mail itself	Both	All plans	United States	Yes	Privacy statement of Postmark (ActiveCampaign LLC)

Sub-processors last changed on October 16, 2026.

Guest accounts, reviews and the city guide are not processed on a restaurant's behalf: MCHLBLLN BV runs them as controller. They are therefore not in this list.

A row marked "Not yet in use" is a provider for a feature that is not switched on or not yet available. No data goes to it until it is in use.

Full Floor emails the owner at least 30 days before it adds or replaces a sub-processor. The owner may object in writing.

Full Floor imposes the same obligations on each sub-processor and remains liable for them.

Article 9. Transfers outside the EEA

Data leaves the European Economic Area only on a legal basis under article 45 or 46 of the GDPR, such as the EU-US Data Privacy Framework or the European Commission's standard contractual clauses. The Location column of the table shows where each sub-processor processes data.

Article 10. Assistance

Full Floor helps the restaurant answer guests who ask to see or erase their data, with the export and erasure tools in the product where they exist, and otherwise on request at michiel@michielbellen.be.

Full Floor helps the restaurant with security, breach notification and impact assessments (articles 32 to 36 of the GDPR).

Article 11. Personal data breach

Full Floor tells the owner, at the owner's email address, without undue delay and in any event within 48 hours of becoming aware of a personal data breach. The notice states:

what happened;
the categories and approximate numbers of people and records affected;
the likely consequences;
the measures taken or proposed;
a contact for questions.

Article 12. Information and audits

Full Floor gives the restaurant the information needed to show that it complies with this agreement.

The restaurant may audit Full Floor on reasonable notice, at most once a year.

Article 13. Deletion or return at the end

When the contract ends, the restaurant can obtain an export of its account and a CSV of its guests, from the product where it offers them and otherwise on request at michiel@michielbellen.be, during the grace period of 30 days.

After the grace period, Full Floor erases the restaurant's guest records, bookings, call content and site.

Until then, where the restaurant has switched on call transcripts or recordings, the retention period it set for them applies.

Data of the guest network, for which MCHLBLLN BV is the controller, is not erased by this.

Article 14. Governing law, precedence and language

The law and the courts are those of the terms.

On personal data, this agreement prevails over the terms.

This agreement is published in several languages. If the translations differ, the Dutch text prevails.

Article 15. Changes

Full Floor announces a new version by email to the owner at least 30 days before it applies.

The version and the date it takes effect are shown at the top of this page.