TIPSY

Tipsy ("Tipsy," "we," "us," or "our") is a software-as-a-service platform that automates tip pool calculation, payroll reporting, and labor data management for food and beverage operators. Tipsy is operated by Callidus Food & Beverage Holdings and related entities ("Callidus") and is accessible at tipsyapp.io and related domains.

This Privacy Policy explains how Tipsy collects, uses, stores, shares, and protects information when you use our platform. It applies to:

• Venue operators and their management teams who subscribe to Tipsy ("Customers");
• Restaurant and hospitality employees whose employment data is processed through the platform ("End Users");
• Guests and patrons of subscribing venues whose reservation, event, or visit information is processed on behalf of the venue ("Guests"); and
• Visitors to our website and marketing materials.

By accessing or using Tipsy, Customers agree to this Privacy Policy and, to the extent applicable, agree to provide any required notices to their employees, Guests, and other End Users whose data will be processed through the platform.

Because Tipsy processes employee and Guest data on behalf of subscribing venues, it is important to distinguish between two roles:

Data Controller. The subscribing venue operator (Customer) who determines the purposes and manner in which employee and Guest data is collected and used. Customers control which employees are enrolled, what POS system is connected, which guest-facing features (reservations, event inquiries, guest history) are enabled, and how outputs are used.

Data Processor. Tipsy processes employee and Guest data solely on behalf of and under the direction of each Customer. Tipsy does not independently determine the purposes for which employee or Guest personal data is used.

For data we collect about our Customers and their authorized users (account credentials, billing information, platform usage), Tipsy acts as the Data Controller.

3.1 Customer Account Data

When a venue operator creates a Tipsy account, we collect:

• Business name, venue name(s), and operating addresses;
• Account administrator name, email address, and phone number;
• Payment and billing information (processed via third-party payment providers; Tipsy does not store full card numbers);
• Subscription plan and configuration preferences; and
• API credentials for integrated point-of-sale systems (e.g., Lightspeed / Upserve).

3.2 Employee and Staff Data

Tipsy processes the following categories of employee data on behalf of subscribing Customers. This data is provided by the Customer or imported automatically from connected POS systems:

• Employee identifiers: full name, assigned POS user ID, role/position (e.g., bartender, server, host, barback);
• Employment data: start date, employment status, and assigned venue;
• Labor and time data: clock-in and clock-out punches, hours worked per shift, and role worked per punch;
• Compensation-related data: net sales attributed to shift, cash tips, credit card tips, auto-gratuity amounts (itemized separately for FICA tax credit purposes), and service charges;
• Performance variables: test scores (knowledge assessments), quarterly performance appraisal ratings, and tenure-based multipliers; and
• Calculated outputs: Tip Share Ratio (TSR) and allocated tip amounts per employee per shift.

Tipsy does not collect Social Security Numbers, government-issued ID numbers, bank account information, or direct deposit details. Payroll execution is handled by third-party payroll providers (e.g., QuickBooks Payroll, ADP, Paychex) outside of the Tipsy platform.

3.3 Point-of-Sale Integration Data

When a Customer connects their Lightspeed (Upserve) account, Tipsy ingests transaction-level data via the approved Lightspeed API. This includes check-level sales data, revenue category classifications, tip line items, and employee time punches. Tipsy maps this raw data to its internal schema to compute daily sales totals, tip pools, and labor hours. Raw check-level data is stored temporarily during processing and then aggregated. Individual check records are not retained beyond processing, except for the per-visit Guest records described in Section 3.4, which are retained as set out in Section 7.

3.4 Guest and Patron Data

Where a Customer enables Tipsy's guest-facing features, Tipsy processes the following categories of Guest data on the Customer's behalf:

• Reservations and event inquiries: when a Guest submits a reservation request or private-event inquiry through a venue's website or booking form, we collect the name, email address, phone number, party size, requested date and time, occasion, and any notes the Guest provides, together with subsequent correspondence between the Guest and the venue and basic technical data (browser type and referring page) used to help the venue understand where bookings come from;
• Guest visit records ("Guestbook"): derived from card payment records on POS checks, Tipsy processes the cardholder name as presented by the payment network and computes a one-way pseudonymous identifier from that name and the last four digits of the card. Full payment card numbers are never received or stored by Tipsy, and the last-four digits are discarded after the identifier is computed. Each visit record contains the visit date, check amounts, tip and service-charge amounts, sales tax, party size, and the serving staff member; and
• Visit and booking association: at the venue's direction, Tipsy associates reservation and event contact information with visit records that carry a matching name, so the venue can recognize returning Guests and their visit history.

Cash payments and payments without a cardholder name cannot be attributed and produce no Guest record. Customers are responsible for providing Guests any notices required by applicable law regarding this processing, including on the venue's own website and booking pages.

3.5 Automated Data Synchronization

The platform runs an automated data synchronization job daily at 5:00 AM (local time for the venue) to pull the prior trading day's POS data. Management users may view, verify, and approve the day's data through the dashboard. Tipsy logs sync timestamps and approval events for audit purposes.

3.6 Usage and Technical Data

When users interact with the Tipsy platform, we automatically collect:

• Log data: IP address, browser or client type, pages accessed, and timestamps;
• Device information: operating system, screen resolution, and session identifiers; and
• Feature usage analytics: which dashboard features are used, error events, and performance metrics.

3.7 Communications

If you contact Tipsy for support or send us an inquiry, we retain records of that correspondence including your email address and any information you include in the message.

4.1 To Provide and Operate the Service

We use the information collected to:

• Ingest and process POS data for daily tip pool calculations;
• Compute each employee's Tip Share Ratio based on tenure, test scores, and performance appraisal inputs;
• Present daily and weekly payroll summary dashboards to authorized management users;
• Generate exportable payroll reports (Excel/CSV) for use with third-party payroll providers; and
• Maintain audit logs of management approvals for each trading day.

4.2 To Provide Guest Management Features

Where the Customer enables them, we use Guest data to:

• Receive, confirm, and manage reservation requests and private-event inquiries, including sending transactional emails (confirmations, quotes, contracts, and replies) at the venue's direction;
• Present the venue's own guest history — visit counts, spend, gratuity, visit times, and matched bookings — to the venue's authorized staff so they can recognize and serve returning Guests; and
• Compute venue-level aggregate statistics (busiest day parts, average visit length, retention segments).

Tipsy does not use Guest data to build profiles across venues: a Guest's visit records at one venue are never shown to, combined with, or matched against another venue's records.

4.3 To Manage Customer Accounts

We use account data to authenticate users, process subscription payments, communicate about service changes, and provide customer support.

4.4 To Improve the Platform

Aggregated and de-identified usage data may be used to identify technical issues, improve feature design, and prioritize product development. Tipsy does not use individual employee data for product analytics without anonymization.

4.5 Legal and Compliance Obligations

We may process or retain data as required to comply with applicable law, respond to lawful government requests, enforce our Terms of Service, or protect the rights, property, or safety of Tipsy, its Customers, or the public.

For Customers and their authorized users located in jurisdictions requiring a legal basis for processing personal data (including the EU/EEA, UK, and applicable U.S. state laws):

• Contract performance: Processing necessary to deliver the services Customers have subscribed to;
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement;
• Legal obligation: Processing required by applicable employment, tax, or labor law; and
• Consent: Where separately obtained for specific processing activities (e.g., future employee-facing features).

For employee data processed on behalf of Customers, Tipsy relies on the Customer's lawful basis for such processing. Customers are responsible for ensuring they have the appropriate legal basis to enroll employee data in the platform, including providing any required notices to employees under applicable labor and privacy laws.

6.1 We Do Not Sell Personal Data

Tipsy does not sell, rent, or trade personal data to third parties for marketing or any other commercial purpose.

6.2 Service Providers and Subprocessors

Tipsy may share data with trusted third-party vendors who assist in operating the platform, including:

• Cloud infrastructure and hosting providers (data stored within the United States);
• Payment processors (for subscription billing only; employee financial data is not shared);
• Transactional email delivery providers (for reservation confirmations, event correspondence, and platform notices sent at the Customer's direction);
• Error monitoring and application performance tools; and
• Customer support software.

All service providers are contractually required to process data only as directed by Tipsy and to maintain appropriate security standards.

6.3 POS and Payroll Integrations

Tipsy connects to Lightspeed (Upserve) and similar POS systems using API keys provided and authorized by the Customer. Tipsy does not share data back to the POS system beyond what is required to authenticate the connection. Exported payroll reports (CSV/Excel) are generated at the Customer's request and transmitted directly to the Customer's authorized user; Tipsy does not transmit data to payroll providers on the Customer's behalf.

6.4 Advertising Platforms (Customer-Directed and Optional)

Tipsy may offer Customers the option to connect their own advertising accounts (for example, Meta Custom Audiences or Google Customer Match / offline conversion measurement). This capability is off by default and operates only where a Customer explicitly enables it for their venue. When enabled:

• Tipsy transmits only Guest contact identifiers the venue already holds (email address and/or phone number), hashed with SHA-256 before transmission, and — where the Customer enables conversion measurement — visit event data (date and spend amount) tied to those hashed identifiers;
• Transmission is solely to build the Customer's own advertising audiences or measure the Customer's own campaigns; Tipsy receives no data back from advertising platforms and does not use these platforms to enrich Guest profiles;
• Card-derived pseudonymous identifiers, cardholder names, and payment details are never transmitted; and
• The Customer is the business responsible for that disclosure under applicable privacy law, including providing any required notices to Guests, honoring opt-outs of targeted advertising, and maintaining a lawful basis for the transfer. Tipsy acts as the Customer's service provider and transmits only at the Customer's documented direction.

6.5 Legal Requirements

Tipsy may disclose data if required by law, court order, or governmental authority, or if disclosure is necessary to prevent imminent harm or enforce our legal rights.

6.6 Business Transfers

If Tipsy or Callidus Food & Beverage Holdings is acquired, merges with another entity, or transfers substantially all of its assets, customer and user data may be transferred as part of that transaction. We will provide notice to Customers of any such transfer and any material changes to data handling practices.

Tipsy retains data for the following periods unless a shorter period is required by law or requested by the Customer:

Upon subscription termination, Tipsy will delete or anonymize Customer and associated employee data within 90 days, unless a longer retention period is required by law or the Customer requests an earlier deletion.

Tipsy implements industry-standard technical and organizational measures to protect the data entrusted to us, including:

• Encryption of data in transit using TLS 1.2 or higher;
• Encryption of sensitive data fields at rest;
• Access controls limiting data access to authorized personnel on a need-to-know basis;
• API key management practices that restrict POS integration access to authorized Customer accounts;
• Audit logging of management approvals and system access events; and
• Regular review of security practices as the platform scales.

No system is completely secure. While we take reasonable precautions, Tipsy cannot guarantee the absolute security of information transmitted over the internet or stored in our systems. Customers are responsible for maintaining the confidentiality of their account credentials and API keys.

Because Tipsy processes employee and Guest data as a processor on behalf of subscribing venue operators, requests regarding that personal data (access, correction, deletion) should be directed to the venue (the Customer and Data Controller). The venue operator is responsible for responding to such requests in accordance with applicable law.

Tipsy will assist Customers in fulfilling verified data rights requests to the extent technically feasible and consistent with our contractual obligations. If you are an employee or a Guest and the venue is unresponsive to a data rights request, you may contact us at privacy@tipsyapp.io and we will use reasonable efforts to assist. A Guest deletion request covers the Guest's visit records, reservation and event records, and any associated correspondence held for that venue.

Data rights that may apply depending on jurisdiction include:

• Right to access: Know what personal data is held and how it is used;
• Right to correction: Request correction of inaccurate records;
• Right to deletion: Request deletion of data, subject to legal retention obligations;
• Right to portability: Receive a copy of your data in a structured format; and
• Right to object: Object to specific processing activities.

10.1 California (CCPA/CPRA)

California residents whose data is processed through Tipsy may have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). As noted above, Tipsy acts as a Service Provider (as defined under CCPA) with respect to employee and Guest data processed on behalf of subscribing venue operators. Tipsy itself does not sell or share personal information as defined under the CCPA. Where a Customer directs the transmission of hashed Guest contact identifiers to an advertising platform (Section 6.4), that disclosure is made by the Customer as the responsible business, and the Customer is responsible for honoring applicable opt-out rights, including any "Do Not Sell or Share" requests.

California residents may submit data rights requests to their employing venue operator or to Tipsy at privacy@tipsyapp.io. We will not discriminate against individuals for exercising CCPA rights.

10.2 Other U.S. State Laws

Residents of states with comprehensive consumer privacy laws (including but not limited to Colorado, Connecticut, Virginia, Texas, and Missouri) may have similar rights regarding their personal data. To the extent Tipsy is subject to these laws, we will honor applicable rights as described in Section 9 above.

10.3 Employees, HR Data, and Guest Data

Employee data processed through Tipsy is business-to-business HR and payroll data. Tipsy's Customers are responsible for maintaining appropriate employment privacy notices and obtaining any required consents under applicable state employment and labor law before enrolling employee data in the platform. Customers are likewise responsible for providing Guests any notices required by applicable law for the guest-facing features they enable — including reservation and event forms on the venue's own website and any advertising integrations under Section 6.4.

Tipsy is a business-to-business platform intended for use by venue operators and their adult employees. We do not knowingly collect personal information from individuals under the age of 16. If we learn that we have inadvertently collected data from a minor, we will take prompt steps to delete it. If you believe a minor's data has been submitted to Tipsy, please contact us at privacy@tipsyapp.io.

The Tipsy platform integrates with third-party services including Lightspeed POS, may link to payroll providers such as QuickBooks, ADP, and Paychex, and — where a Customer enables it — connects to advertising platforms such as Meta and Google as described in Section 6.4. These third parties have their own privacy policies and data practices. Tipsy is not responsible for the privacy practices of third-party services. We encourage Customers to review the privacy policies of any third-party integrations they enable.

Tipsy may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. When we make material changes, we will:

• Post the updated policy at tipsyapp.io/privacy with a new effective date;
• Notify subscribed Customers via email or in-platform notification at least 30 days prior to the effective date of material changes; and
• Where required by law, obtain renewed consent for new processing activities.

Your continued use of the Tipsy platform after the effective date of any changes constitutes acceptance of the revised policy.

For questions, concerns, or requests related to this Privacy Policy or the handling of personal data, please contact:

For urgent security concerns, please include "SECURITY" in the subject line of your inquiry.