Privacy Policy

1. Who We Are

CrewBase is operated by Create Entrance B.V., a company registered in the Netherlands, providing restaurant staff management software for businesses operating in Europe.

Address: Binderij 7Hbis, 1185 ZH Amstelveen, the Netherlands
KvK (Chamber of Commerce): 56248644
Contact: info@create-entrance.com
Website: create-entrance.com

For data protection matters, please contact us at the email address above with the subject line "Data Protection".

2. What Data We Collect

When you use CrewBase, we collect and process the following categories of personal data:

• Account data: email address, name, role within your organisation
• Work records: clock-in/clock-out timestamps, GPS location at time of clock-in (if enabled), shift schedules
• HR data: visa/residence permit expiry dates, skill levels (entered by your employer)
• Financial data: tip allocation records, register closing figures (entered by managers)
• Usage data: log entries for system actions (for security and audit purposes)
• Communication data: messages submitted via our demo request or contact form

3. Legal Basis for Processing

We process personal data on the following legal bases under GDPR Article 6:

• Contract performance (Art. 6(1)(b)): Processing necessary to provide the CrewBase service to your organisation.
• Legitimate interests (Art. 6(1)(f)): Security logging, fraud prevention, and improving service reliability.
• Legal obligation (Art. 6(1)(c)): Where retention is required by applicable law (e.g., employment records).
• Consent (Art. 6(1)(a)): For optional analytics cookies and marketing communications — you may withdraw consent at any time.

4. How We Use Your Data

• Providing and operating the CrewBase platform
• Calculating tip distribution and payroll-related summaries
• Sending service-related notifications (account setup, password reset)
• Maintaining system security and audit logs
• Responding to support and demo requests

We do not sell personal data to third parties.

5. Data Retention

• Account data: Retained for the duration of your subscription + 30 days after cancellation
• Work records / timeclock: 2 years (aligned with Dutch employment record requirements)
• Financial records: 7 years (Dutch bookkeeping law — Boekhouding)
• System logs: 90 days
• Demo / contact enquiries: 12 months

6. Data Sharing and Sub-processors

We use the following sub-processors to operate CrewBase:

All sub-processors are bound by Data Processing Agreements and comply with GDPR Chapter V requirements for international data transfers.

7. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right of access (Art. 15): Request a copy of the data we hold about you
• Right to rectification (Art. 16): Correct inaccurate data
• Right to erasure (Art. 17): Request deletion of your data ("right to be forgotten")
• Right to data portability (Art. 20): Receive your data in a machine-readable format
• Right to restriction (Art. 18): Restrict how we process your data in certain circumstances
• Right to object (Art. 21): Object to processing based on legitimate interests
• Right to withdraw consent: Where processing is based on consent, withdraw at any time

To exercise any of these rights, email info@create-entrance.com with subject line "GDPR Request". We will respond within 30 days.

8. Cookies

CrewBase uses the following cookies:

Essential cookies cannot be disabled as they are required for the service to function. We do not currently use advertising or tracking cookies.

9. Supervisory Authority

If you are located in the Netherlands and believe we have not handled your data correctly, you have the right to lodge a complaint with the Dutch Data Protection Authority:

Autoriteit Persoonsgegevens (AP)
www.autoriteitpersoonsgegevens.nl

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For significant changes, we will notify active users by email.