SOFT DEV FZ LLC · Dubai, United Arab Emirates
Privacy Policy
Last updated: 15 October 2026 — This Privacy Policy explains how SOFT DEV FZ LLC processes personal data in connection with BrainyPOS (https://pos.brainy.ae).
1. Data controller
- Controller: SOFT DEV FZ LLC, Dubai, United Arab Emirates.
- Product: BrainyPOS (https://pos.brainy.ae).
- Contact: pos@brainy.ae
2. Data we process
- (a) Account data: Name, email address, role, and login details.
- (b) Restaurant data uploaded or received by the customer: Menu, orders, stock, recipes, purchases, supplier invoices, cash closes, and team members.
- (c) Diner data inside those orders: Name, phone number, delivery address, order contents, and notes such as allergies. For this data, the restaurant is the data controller and we process it on the restaurant's behalf.
- (d) Communications with us: Emails, WhatsApp messages, and calls with our virtual assistant (including recording and transcription of the conversation, notified at the beginning of the call).
- (e) Research interviews: Research interviews that a participant agrees to conduct through the Expertise platform (expertlore.com), with their explicit permission.
- (f) Website usage: Analytics (Google Analytics / Google tags) and technical logs.
3. Why we process data
- To provide and operate the BrainyPOS service.
- To provide customer and technical support.
- For security and abuse prevention.
- To improve the product (research interviews are used anonymously unless permission is given otherwise).
- For billing and invoicing.
- For B2B commercial communications (with an unsubscribe option in every message).
- To comply with applicable law.
4. Legal bases
- Contract: To deliver the service agreed with the restaurant.
- Consent: For research interviews, call recordings, and marketing where applicable.
- Legitimate interest: For security, product improvement, and B2B outreach to publicly available business data.
- Legal obligation: To comply with applicable laws and regulations.
5. Service providers that process data on our behalf
Delivery apps receive and send order data only if the restaurant connects them.
- Google Cloud and Firebase: Hosting and database (me-central1 region, Doha, Qatar, and global Google services).
- Google Gemini: AI features.
- Resend: Email delivery.
- Twilio: Call transport.
- Meta: WhatsApp Business messaging.
- Expertise (expertlore.com): Research interviews.
6. International transfers & no sale of personal data
Data may be processed outside the United Arab Emirates (including Qatar, the United States, and the European Union) under the contractual safeguards of those providers.
We do not sell personal data. We do not use diner data for our own marketing.
7. Data retention
We retain data while the account is active and afterwards for as long as required by the laws of the United Arab Emirates (for example, tax records).
Conversation recordings and transcripts are kept for the time necessary to provide and improve the service, and are deleted upon request.
8. Your rights (UAE Federal Decree-Law No. 45/2021, PDPL)
Under UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), you have the rights of access, correction, erasure (deletion), restriction, objection (including to marketing), portability, and to withdraw consent.
To exercise any of these rights, write to pos@brainy.ae. We respond within a reasonable timeframe.
9. Security, minors & changes
- Security: We use encryption in transit, role-based access controls, and audit logs; no system is 100% secure.
- Minors: The service is for businesses and is not directed at minors.
- Changes: When we update this policy, we publish the new version with its updated date on this page.
SOFT DEV FZ LLC
Dubai, United Arab Emirates · pos@brainy.ae