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Terms of Service for Popcorn

Last updated: March 15, 2026 Β· Version 1.2

These terms ("Terms") apply between you ("Customer", "you") and InsightsHub ("we", "us"), org. no. 931 538 982, registered in Norway. By creating an account, you agree to these Terms.

1. The Service

Popcorn is a digital platform for collecting and analyzing guest feedback via QR codes. The Service is provided "as is" and includes:

2. Account and Responsibility

3. Plans and Pricing

4. Data and Ownership

Your data ("Customer Data"):

Our right to aggregated data:

Guest feedback:

5. Data Processing Agreement (DPA)

By accepting these Terms, you also enter into the Data Processing Agreement attached as Appendix A. In the relationship between you and your guests:

6. Acceptable Use

You agree not to:

7. Availability and Support

8. Limitation of Liability

9. Termination

10. Changes to Terms

11. Governing Law and Dispute Resolution

12. Contact

InsightsHub
Email: support@popcornfeedback.com
Privacy inquiries: privacy@popcornfeedback.com

Appendix A β€” Data Processing Agreement

Under GDPR Art. 28 Β· Version 1.2 Β· Effective 2026-05-21

1. Parties

2. Background

This agreement governs the Processor's processing of personal data on behalf of the Controller in connection with the Popcorn service, in accordance with GDPR Art. 28.

3. Nature and Purpose of Processing

AspectDescription
PurposeCollection, storage, and structuring of guest feedback via QR-based forms
Nature of processingAutomated collection, storage, aggregation, display in dashboard
DurationDuration of the service agreement + 30 days post-termination retention (see section 7b)

4. Categories of Data Subjects

5. Types of Personal Data

CategoryData
Guest feedbackRatings, multiple choice answers, free text responses (may potentially contain personal data)
Technical dataIP address (temporary), device type, language setting
Account dataName, email, business details

6. Processor's Obligations

The Processor shall:

  1. Process personal data only in accordance with the Controller's documented instructions and these Terms.
  2. Ensure that persons authorized to process personal data have committed to confidentiality obligations.
  3. Implement appropriate technical and organizational security measures per Art. 32, including encryption in transit (TLS) and at rest, role-based access control, regular security reviews, and incident response procedures.
  4. Not engage sub-processors without the Controller's approval. Approved sub-processors are listed in the Privacy Policy. The Processor shall notify changes to sub-processors with 30 days' advance notice. The Controller may object β€” if the objection cannot be accommodated, the Controller has the right to terminate the agreement.
  5. Assist the Controller in fulfilling obligations regarding data subject rights (Art. 15-22).
  6. Without undue delay (within 48 hours) notify the Controller of personal data breaches.
  7. Assist the Controller with data protection impact assessments (DPIA) where relevant.
  8. Upon termination, return or delete all personal data (at the Controller's choice) within 30 days and confirm the return/deletion in writing upon request (Art. 28(3)(g)).
  9. Provide the Controller with all information necessary to demonstrate compliance with Art. 28 obligations, and allow for and contribute to audits.
  10. Immediately inform the Controller if, in the Processor's opinion, an instruction infringes the GDPR or other applicable data protection law (Art. 28(3)).

7. Approved Sub-processors

Sub-processorPurposeLocation
RailwayWeb hosting, database (PostgreSQL)EU (Amsterdam)
Cloudflare R2File storage (image uploads)EU
ResendTransactional emailEU/US
Google (Places API)Restaurant searchEU/US
UpstashRedis (sessions, rate limiting)EU
SentryError tracking, performance monitoring (PII scrubbed)EU/US
Anthropic (Claude)AI assistant for venue insights (Copilot). SCC applied per Anthropic Commercial Terms.US
Self-hosted AI (Ollama)On-platform AI analytics and diagnostics β€” no third-party data transferEU (Railway, europe-west4)

The Processor ensures all sub-processors are bound by agreements with at least equivalent protection.

7b. Data Retention and Deletion

Data typeRetentionDeletion method
Account data (venue PII)Duration of contract + 30 daysSoft-delete immediately, hard-delete after 30-day restore window
Guest feedback (responses)Retained as anonymised platform dataForeign keys to deleted venues are nullified; response content preserved anonymously
Audit trail (deletion logs)3 yearsAutomatically purged after 3 years
AI interaction logs (CopilotLog)90 daysAuto-purged after 90 days
Encrypted backups30 days rollingOverwritten by rotation schedule
Email suppression listIndefiniteRetained to prevent re-mailing deleted accounts

Upon account deletion, personal data is removed from live systems immediately. Encrypted copies may persist in backups for up to 30 days before being overwritten.

8. International Transfers

Personal data is primarily stored within the EU (Railway, europe-west4, Amsterdam, NL). Where sub-processors process data outside the EU/EEA β€” specifically Anthropic (US inference, SCC per Commercial Terms) and Resend (US routing) β€” adequate protection is ensured through EU Standard Contractual Clauses (SCCs) pursuant to Commission Implementing Decision (EU) 2021/914.