Acroya B.V. trading as SOUS | Last updated: July 2026
Version 1.2 | Full Privacy Policy available at: poweredbysous.com/privacy/full
This notice explains how SOUS collects and uses your personal data. It applies to visitors to our website, merchants who use the SOUS platform, and end-customers who shop through a SOUS-powered storefront. A full Privacy Policy with complete technical and legal detail is available at poweredbysous.com/privacy/full.
1. Who We Are
SOUS is a trading name of Acroya B.V., a company incorporated in the Netherlands. We are the data controller for personal data processed in connection with our website and platform services.
Legal entity | Acroya B.V. (trading as SOUS) |
Address | Vijzelstraat 77A, 1017 HG Amsterdam, The Netherlands |
Chamber of Commerce | KvK 85080276 |
Contact |
2. Who This Notice Applies To
This notice covers three groups of people:
Website visitors - anyone who browses poweredbysous.com, requests a demo, signs up for our newsletter, or purchases a subscription online.
Merchants - food and beverage businesses that use the SOUS Merchant Portal, including our Spotlight listing management service.
End-customers - individuals who place orders through a merchant's SOUS-powered online shop.
Where SOUS processes end-customer data on behalf of a merchant, the merchant is the data controller for that data and SOUS acts as a processor under a Data Processing Agreement (DPA) found at poweredbysous.com/legal/dpa.
3. What Data We Collect
Website visitors
Contact details you provide (name, email, company, phone) when submitting a form or booking a demo.
Subscription and billing data if you purchase a plan online. Payment card processing is handled by our payment provider - we do not store card numbers.
Usage and device data collected automatically: IP address, browser type, pages visited, and similar technical data.
Merchants
Business identity and KYC data collected during onboarding (legal entity name, address, VAT number, KvK number, and identity verification carried out by our payment processor).
Platform and configuration data, including product catalogues, pricing, logistics settings, and financial records.
Business listing data for Spotlight subscribers: your business profile (name, address, hours, menus, images) published to directories such as Google Maps, Apple Maps, and TripAdvisor.
End-customers
Order data - name, delivery address, order contents, delivery preferences, and order status.
Payment metadata - transaction references. Full payment processing is handled by our payment provider.
Communication preferences - opt-in status for merchant communications.
We do not intentionally collect special category data (such as health or biometric data) or data about children under 16.
4. Why We Process Your Data and Our Legal Basis
We process personal data for the following main purposes:
To operate and deliver the platform - including processing orders, handling payments, and managing merchant accounts. Legal basis: contract performance (Art. 6(1)(b) GDPR).
To manage business listings (Spotlight) - publishing and synchronising your business profile across directories and managing reviews. Legal basis: contract performance and legitimate interests.
To send newsletters and marketing - only with your opt-in consent. Legal basis: consent (Art. 6(1)(a) GDPR). You can unsubscribe at any time.
For B2B sales outreach - to business contacts in the food and beverage sector. Legal basis: legitimate interests. You can opt out at any time.
For analytics and platform improvement - using aggregated, anonymised data. Non-essential analytics cookies require your consent. Legal basis: consent or legitimate interests.
For security and fraud prevention - protecting the platform and our users. Legal basis: legitimate interests and legal obligation.
To comply with legal obligations - such as tax and accounting requirements. Legal basis: legal obligation (Art. 6(1)(c) GDPR).
5. Who We Share Your Data With
We share personal data only as necessary to deliver our services. We work with trusted service providers in the following categories, all engaged under data protection agreements:
Payment and financial services providers - for payment processing, payouts, and merchant KYC/KYB verification.
Cloud infrastructure and hosting providers - for storing and processing platform data.
Logistics and delivery providers - for fulfilling orders and shipments.
Business directory and review platforms - for publishing and managing your business listings (Spotlight).
AI and analytics tools - for platform performance monitoring and AI-assisted features such as review response suggestions.
Email and communication tools - for transactional and marketing communications.
Security and fraud prevention tools - for DDoS protection, vulnerability scanning, and web security.
A full list of named processors and sub-processors, including their locations and data transfer safeguards, is set out in our Data Processing Agreement at poweredbysous.com/legal/dpa.
We do not sell your personal data. We do not allow third parties to market their products directly to you through our platform without your consent.
6. International Transfers
Some of our service providers are located outside the European Economic Area (EEA), primarily in the United States. Where we transfer personal data outside the EEA, we ensure appropriate safeguards are in place - typically Standard Contractual Clauses (SCCs) approved by the European Commission, or, where applicable, the EU-US Data Privacy Framework adequacy decision. Details of the transfer safeguards for each provider are set out in the full Privacy Policy.
7. Google User Data
Where a merchant connects a Google account to our Spotlight service, we access Google Analytics metrics via Google OAuth, on a read-only basis and limited to the scope the merchant authorises.
We use this data solely to provide visibility, search, and performance insights within the Merchant Portal.
We use this data solely to provide and improve these merchant-facing features. We do not sell Google user data, use it for advertising, or use it to train or improve generalised artificial intelligence or machine learning models. A merchant can revoke our access at any time through their Google account settings.
SOUS's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.
8. How We Protect Your Data
We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include:
Encryption - data is encrypted in transit using TLS 1.2 or higher, and sensitive data is encrypted at rest using AES-256.
Access controls - role-based access limits personal data to authorised personnel on a need-to-know basis; credentials are managed via a secrets manager, and access is logged and reviewed.
Infrastructure security - our platform runs on Google Cloud with DDoS mitigation and a web application firewall; inbound requests are validated to prevent forged events.
Monitoring and response - access is centrally logged, systems are continuously scanned for vulnerabilities, and we maintain an incident response process with breach notification.
No method of transmission or storage is completely secure, but we review our security practices on an ongoing basis. Where we become aware of a personal data breach, we notify affected parties and the relevant supervisory authority as required by law.
9. How Long We Keep Your Data
Website enquiries and demo records: up to 24 months after last contact, or earlier on request.
Merchant account data: for the duration of the contract and 7 years thereafter (statutory accounting and tax obligations).
End-customer order and transaction data: 7 years (tax and consumer law obligations).
Analytics data: 14 months (rolling).
Marketing subscriptions: until you unsubscribe. We retain suppression records indefinitely to honour opt-outs.
10. Your Rights
Under the GDPR, you have the right to:
Access the personal data we hold about you.
Rectification of inaccurate or incomplete data.
Erasure of your data in certain circumstances.
Restriction of processing in certain circumstances.
Data portability for data you have provided to us, where processing is based on consent or contract.
Object to processing based on legitimate interests, including direct marketing (which is an absolute right).
Withdraw consent at any time, where processing is based on consent.
To exercise any of these rights, contact us at [email protected]. We will respond within one month.
You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl, or with your local supervisory authority if you are based in another EU member state or the UK.
11. Cookies
We use cookies and similar technologies on our website. Strictly necessary cookies (required for the website to function, including payment security cookies) are used without your consent. Non-essential cookies - such as analytics cookies - are only activated with your prior consent. You can manage your preferences at any time via the Cookie Settings link in our website footer.
12. Changes to This Notice
We may update this notice from time to time. The date at the top shows when it was last revised. Material changes will be highlighted on our website and, where appropriate, communicated directly to merchants and registered users.
13. Contact Us
For any questions about this notice or how we use your data:
Email: [email protected]
Post: Acroya B.V. (SOUS), Vijzelstraat 77A, 1017 HG Amsterdam, The Netherlands
Website: www.poweredbysous.com