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Privacy Policy

Last updated: 31 October 2026

Draft — to be reviewed by a lawyer before launch. This policy is not in force yet.

This policy explains what we do with personal data when you use WhenBy: the app, the web app, our website and the booking pages of the businesses that use us. It applies to clients who book, to business owners and staff, and to visitors of our website. It follows the EU General Data Protection Regulation (GDPR) and the UK GDPR.

On this page

  1. 1. Who we are
  2. 2. Two roles: ours and the business's
  3. 3. What we collect
  4. 4. Why we use it, and our legal basis
  5. 5. Analytics, only with your consent
  6. 6. Who we share data with
  7. 7. International transfers
  8. 8. How long we keep data
  9. 9. Security
  10. 10. Your rights
  11. 11. Complaints
  12. 12. Children
  13. 13. Changes to this policy

1. Who we are

The controller is [COMPANY NAME], [REGISTERED ADDRESS], company number [COMPANY NUMBER] ("WhenBy", "we", "us"). For anything about your data, write to [CONTACT EMAIL]. We have not appointed a data protection officer, because the law doesn't require one for us; the same address reaches the person responsible for privacy. Our UK representative is [UK REPRESENTATIVE].

2. Two roles: ours and the business's

  • We are the controller for your WhenBy account, your own bookings and settings, the accounts of business owners and staff, billing, our website, and analytics.
  • Each business is the controller of its own client records: the notes, allergies, photos and visit history it keeps about its clients, and any contact list it imports. We store and process them only on the business's instructions, as its processor, under our Data Processing Addendum. For that data, the business's own privacy notice applies, and requests should go to the business (we help it answer them).
  • When you book, the business receives your name, contact details and booking, and keeps them in its records under its own responsibility.

3. What we collect

If you book (clients and guests)

  • Account: email address, name, phone number (optional), language, and the date you signed up. We never use passwords: you sign in with a code sent to your email.
  • Bookings: the business, location, services, staff member, time, price, status, your note to the business, and whether you cancelled.
  • For home visits: the address you give and its point on the map.
  • Favourite businesses, and your reminder and notification settings.
  • As a guest: name, email, phone number (optional) and language, with the booking.

If you run a business or work for one

  • Owner and staff accounts: email, name shown to clients, role, profile photo (optional), the calendar colour you pick.
  • The business: name, description, category, logo and photos, locations and their addresses, services, prices, tax rates, working hours, time off, booking rules, links to WhatsApp or Instagram.
  • Billing: legal name, billing address, VAT number, tax code (codice fiscale), SDI code, PEC address, billing email, your Plan and its history. Card details are taken by Stripe and never reach us.

About the business's clients (as a processor)

  • Client records: name, email, phone, notes, allergies, tags, no-shows, marketing consent, before-and-after photos, and what was paid at the visit.

From your device and browser

  • Push notification tokens, if you allow notifications.
  • Technical data our providers log for security: IP address, browser or device type, time of the request. We don't use them to identify you.
  • Analytics, only if you agree (section 5).

We don't collect payment card numbers, we don't use advertising identifiers, and we don't sell or rent your data.

4. Why we use it, and our legal basis

PurposeDataLegal basis
Create your account and sign you inAccount dataContract (GDPR Art. 6(1)(b))
Make, change and cancel bookings; pass them to the businessAccount, bookings, address for home visitsContract
Send confirmations, reminders and changes by email and pushEmail, push token, bookingContract
Run the business's calendar, page and client recordsBusiness data, client recordsContract with the business; for client records, the business's own basis
Bill Plans and keep invoicesBilling dataContract; legal obligation (Art. 6(1)(c)) for tax records
Keep WhenBy secure, stop fraud and abuse, fix errorsTechnical data, bookingsLegitimate interests (Art. 6(1)(f))
Understand how WhenBy is used, to improve itAnalytics dataConsent (Art. 6(1)(a))
Answer your messages and requestsWhat you send usContract or legitimate interests
Meet legal duties and defend legal claimsAny relevant dataLegal obligation; legitimate interests

Health information. Some businesses note allergies or skin conditions in their client records. That is health data. The business is responsible for asking your explicit consent; we keep it inside that business's records only, and never use it for analytics or put it in notifications.

5. Analytics, only with your consent

We use Google Analytics 4 on our website, booking pages and web app, and Google Analytics for Firebase in the iPhone and Android apps, to count visits and see which features are used. Both are made by Google Ireland Limited.

  • They are off until you say yes: on the web through our cookie banner, in the apps through the privacy choice. Saying no changes nothing else.
  • When they are on, Google receives your IP address (which Google Analytics does not store), device and browser details, the pages and screens you view, and a random identifier. We don't send your name, email, phone, client records or booking notes.
  • We switch off Google signals, ad personalisation and advertising features, and we keep analytics data for 14 months.
  • You can change your mind at any time: Cookie settings at the bottom of every web page, or the privacy settings in the app. Details are in our Cookie Policy.

6. Who we share data with

  • The business you book with receives your booking and contact details, and keeps them in its records.
  • Service providers who process data for us, under contract and only on our instructions: hosting and database, email, push notifications, maps and travel times, payments, analytics. They are listed, with what they do and where, on our sub-processors page.
  • Stripe processes payments for Plans and, where a business asks for it, prepayments and deposits. For some purposes, such as fraud prevention and legal duties, Stripe is a controller in its own right (Stripe privacy policy).
  • Authorities, when the law requires it.
  • A buyer, if our company is sold or merged; this policy keeps applying to your data.

7. International transfers

Our database and files are stored in the EU (Ireland). Some providers are based in, or have staff or systems in, the United States or elsewhere. When data leaves the EU or the UK, we rely on an adequacy decision (such as the EU–US Data Privacy Framework, for certified companies), or on the European Commission's Standard Contractual Clauses with the UK Addendum, plus extra safeguards where needed. You can ask us for a copy.

8. How long we keep data

DataHow long
Your client accountUntil you delete it. Then we delete it at once, and your name and contact details are removed from the bookings we keep.
BookingsKept for the business's records while the business uses WhenBy; anonymised on your side when you delete your account.
Home visit addressDeleted 30 days after the visit.
Guest booking contact detailsAnonymised 24 months after the last booking.
Notification log (what we sent, when)90 days.
Push tokenUntil you sign out, turn off notifications, or the token stops working.
Business data and client recordsUntil the business deletes its account, then a 30-day grace period.
Invoices and billing recordsAs long as tax law requires (up to 10 years).
Analytics data14 months.
Security logs at our providersA few days to a few weeks.
BackupsUp to 30 days.

9. Security

Data is encrypted in transit and at rest. Each business's data is kept apart from every other business's by rules in the database, client photos are stored privately and shown only through short-lived links, and access is limited to people who need it. No system is perfectly secure: if a breach puts your data at risk, we tell you and the authority as the law requires.

10. Your rights

You can ask us to:

  • give you a copy of your data, or send it to another service (in the app: Account → Download my data);
  • correct it (most of it you can change yourself in the app);
  • delete it (in the app: Account → Delete account);
  • restrict or object to how we use it, including anything based on legitimate interests;
  • withdraw your consent at any time, for example to analytics, without affecting what we did before.

Write to [CONTACT EMAIL]. We answer within one month. We may ask you to confirm who you are. If you are a business owner or staff member, you can't delete your own account while you own or work for a business: write to us and we will help.

For a business's client records, ask the business directly. If you ask us, we pass your request to the business and help it answer.

11. Complaints

If you are unhappy with how we handle your data, tell us first. You can also complain to a supervisory authority, in particular where you live or work:

  • Ireland: Data Protection Commission
  • Italy: Garante per la protezione dei dati personali
  • United Kingdom: Information Commissioner's Office

12. Children

WhenBy accounts are for people aged 16 and over. A parent or guardian can book for a child. If you think a child under 16 has an account, tell us and we will delete it.

13. Changes to this policy

When we change this policy, we update the date at the top. If a change matters, we tell you by email or in the app before it applies.

Other legal documents

  • Terms for Businesses
  • Terms for Clients
  • Cookie Policy
  • Sub-processors
  • Data Processing Addendum

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