UMAI
UMAI is a restaurant reservation, guest management and marketing platform operated from Malaysia. Its booking widget is embedded on a restaurant website so diners can check availability and reserve a table, collecting personal data such as name, contact details, party size and reservation history. The widget stores booking details in first party cookies and localStorage and, through connected marketing and analytics tools, sets non essential cookies. The booking itself can rely on contract, but those marketing and analytics cookies may only be set after the diner has given consent.
What does UMAI do?
What UMAI is
UMAI is a restaurant reservation, guest management and marketing platform operated by UMAI Restaurant Software from Kuala Lumpur, Malaysia. It gives restaurants a booking widget that is embedded on their website, along with table management, a guest CRM and marketing automation. A diner uses the embedded widget to check real time availability, choose a date, time and party size and confirm a reservation without leaving the restaurant website.
What data and cookies UMAI collects
When a diner makes a reservation, the widget collects personal data such as name, email address, telephone number, party size, special requests and, over time, a history of past reservations, preferences and no shows that builds a guest profile in the UMAI CRM. To operate the booking flow, UMAI stores booking details in first party cookies and browser localStorage. Through connected marketing and analytics integrations such as Google Tag Manager, Google Analytics and the Meta Pixel, the widget can also set non essential cookies that measure widget performance and support remarketing to diners.
GDPR and ePrivacy implications
The diner details and the identifiers UMAI processes are personal data under the GDPR, because they relate to identifiable individuals. Storing and reading identifiers on the diner device also falls within Article 5(3) of the ePrivacy Directive. The strictly necessary booking session is exempt from prior consent, but the marketing and analytics cookies are not, and the CNIL in France, the German authorities under the TDDDG and the AEPD in Spain all enforce a strict prior consent obligation for such non essential trackers.
When consent is required and when contract applies
The booking transaction itself can rest on the performance of a contract or on steps taken at the request of the diner under Article 6(1)(b) GDPR, so the strictly necessary booking session may run without prior consent. The non essential marketing and analytics cookies set through the widget are different: they require prior, freely given, specific, informed and unambiguous consent under Article 6(1)(a) GDPR, and it must be as easy to refuse as to accept. Until the diner accepts, those marketing and analytics cookies should not be set.
Transfers of data outside the European Economic Area
UMAI is operated from Malaysia and hosts its platform in the Asia Pacific region, so diner data is transferred outside the European Economic Area. Malaysia is not covered by a European Commission adequacy decision, so the transfer requires the EU Standard Contractual Clauses 2021/914 within the UMAI data processing agreement and a documented Transfer Impact Assessment, in line with the Schrems II ruling and the guidance of the European Data Protection Board. Where the widget also loads Google and Meta tools, data may additionally reach the United States under the same clauses.
Practical steps for compliant use
Gate the non essential UMAI cookies behind your consent management platform so that Google, Meta and other marketing and analytics tags fire only after the relevant category is accepted, while keeping the booking session available so diners can always reserve. Provide clear information about UMAI in your cookie policy, including the booking and marketing cookies it sets and their lifetime. Sign the UMAI data processing agreement, complete a Transfer Impact Assessment and apply the shortest workable retention on guest records. Collect only the diner data you need to manage the reservation.
UMAI and the GDPR
UMAI is classified as “Analytics”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.
- Legal basis
- Two legal bases apply. The booking transaction itself, meaning taking and managing a diner reservation, can rest on the performance of a contract or on steps taken at the request of the diner under Article 6(1)(b) GDPR, so the strictly necessary booking session may run without prior consent. The non essential marketing and analytics cookies set through the widget require prior, freely given, specific, informed and unambiguous consent under Article 6(1)(a) GDPR, because they read from and write to the diner terminal for purposes that are not necessary to complete the booking. Article 5(3) of the ePrivacy Directive 2002/58/EC, transposed as Article 82 of the French Loi Informatique et Libertes and the CNIL trackers guidelines, section 25 of the German TDDDG and Article 22.2 of the Spanish LSSI CE, makes prior consent mandatory before those non essential cookies are set.
- Risk level
- medium
- Applicable regulations
- GDPR, ePrivacy Directive 2002/58/EC, French TDDDG and CNIL guidelines on trackers, German TDDDG, Spanish LSSI CE and AEPD cookie guide, EDPB Schrems II Transfer Impact Assessment, EU Standard Contractual Clauses 2021/914
Impact assessment (DPIA)
A Data Protection Impact Assessment is advisable when the UMAI booking widget is used at scale or combined with marketing profiling of diners. Document the diner data collected by the widget, meaning name, contact details, party size, special requests and reservation history, the booking cookies and localStorage entries, the non essential marketing and analytics cookies set through the Google and Meta integrations, the transfer of data to Malaysia and potentially the United States, and the retention period applied to guest records. Configure the widget so that non essential cookies load only after consent and keep the booking session limited to what is necessary to complete the reservation.
Sample text for your banner
We use UMAI, a restaurant reservation and guest management service operated by UMAI Restaurant Software (Malaysia), to take your booking. The reservation itself is processed to fulfil your request. UMAI and connected tools also use marketing and analytics cookies that are not necessary for the booking, and your data may be transferred outside the European Economic Area under the EU Standard Contractual Clauses. These non essential cookies will only be set if you click Accept.
What UMAI sets and contacts
- Tracking method
- Asynchronous JavaScript booking widget loaded from reservation.umai.io and embedded on the restaurant website. The widget lets a diner search real time availability, choose a date, time and party size and submit a reservation, collecting name, email address, telephone number, party size, special requests and reservation history. UMAI stores booking details in first party cookies and browser localStorage for convenience and, through connected marketing and analytics integrations such as Google Tag Manager, Google Analytics and the Meta Pixel, sets additional non essential cookies that measure widget performance and support remarketing. Guest records feed the UMAI guest management CRM used by the restaurant.
- Server location
- Malaysia and Asia Pacific. UMAI Restaurant Software is operated from Kuala Lumpur, Malaysia, and hosts its reservation and guest management platform on cloud infrastructure in the Asia Pacific region. There is no documented European Economic Area data residency option, so diner data submitted through the booking widget is processed outside the EEA by default. Connected analytics and marketing services such as Google and Meta may additionally process data in the United States.
- Data transferred outside the EU
- UMAI Restaurant Software is a company incorporated in Kuala Lumpur, Malaysia, and processes reservation and guest data on Asia Pacific based cloud infrastructure. Malaysia is not covered by a European Commission adequacy decision, so diner data is transferred to a third country and must be covered by a data processing agreement incorporating the EU Standard Contractual Clauses 2021/914, together with a Transfer Impact Assessment as required by the Schrems II ruling. Where the booking widget also loads Google and Meta tools, personal data may additionally be transferred to the United States under the same clauses.
Cookies set (4)
| Name | Type | Duration | Purpose |
|---|---|---|---|
| umai_booking_session | HTTP cookie (first party) | Session | Maintains the reservation session in the UMAI booking widget so the diner steps, selected date, time and party size and submitted details are grouped together during a single booking. Strictly necessary for the booking to work. |
| umai_widget_storage | localStorage | Persistent (until cleared) | Stores booking widget state and the diner details entered in the reservation form, such as name and contact information, so the form is convenient to reuse and can resume where the diner left off. |
| _ga | HTTP cookie (first party) | 13 months | Set through the UMAI Google Analytics and Google Tag Manager integration to distinguish diners and measure how the booking widget and pages are used. Non essential analytics cookie that requires consent. |
| _fbp | HTTP cookie (first party) | 3 months | Set through the UMAI Meta Pixel integration to identify browsers for advertising measurement and remarketing to diners on Meta platforms. Non essential marketing cookie that requires consent. |
Third-party domains contacted (5)
umai.ioreservation.umai.ioletsumai.comgoogletagmanager.comconnect.facebook.net
Frequently asked questions about UMAI
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What cookies and storage does UMAI set?
The UMAI booking widget stores booking details in a first party session cookie and in browser localStorage so the reservation form and guest information persist during a visit. Through its marketing and analytics integrations it can also set non essential cookies, such as the Google Analytics identifiers and the Meta Pixel cookie, for measurement and remarketing.
Do I need consent before UMAI sets cookies?
You do not need consent for the strictly necessary booking session, which is exempt because it is required to deliver the reservation the diner requested. You do need prior consent before the non essential marketing and analytics cookies set through UMAI, so those should stay blocked until the diner accepts.
What is the legal basis for UMAI?
Two bases apply. Managing the reservation rests on contract under Article 6(1)(b) GDPR, so the booking session can run without consent. The non essential marketing and analytics cookies rely on consent under Article 6(1)(a) GDPR combined with Article 5(3) of the ePrivacy Directive. Legitimate interest cannot cover those trackers.
Does UMAI transfer data outside the EEA?
Yes. UMAI is operated from Malaysia and hosts data in the Asia Pacific region, and Malaysia has no EU adequacy decision, so diner data leaves the European Economic Area. Where the widget loads Google and Meta tools, data may also reach the United States. You need the EU Standard Contractual Clauses and a Transfer Impact Assessment to cover both.
Do I need a DPIA for UMAI?
A Data Protection Impact Assessment is recommended when UMAI is used at scale or when guest data is combined with marketing profiling. Assess the diner data collected, the booking and marketing cookies, the guest CRM enrichment and the transfer to Malaysia and potentially the United States.
How do I implement UMAI compliantly?
Keep the booking session running so diners can always reserve, but load the non essential marketing and analytics cookies only through your consent management platform after the relevant category is accepted. Describe UMAI in your cookie policy, sign the data processing agreement, complete a Transfer Impact Assessment and apply a short retention period on guest records.
Are there alternatives to UMAI?
Alternatives include TheFork, OpenTable, SevenRooms, Resy, Formitable and Zenchef. They raise similar consent, cookie and transfer questions, so evaluate each provider's hosting location and data processing terms before assuming any of them is lighter on privacy.
How do I update my cookie policy for UMAI?
Add a dedicated entry that names UMAI as the provider, separates the strictly necessary booking cookies from the non essential marketing and analytics cookies, lists each cookie with its lifetime, explains the diner data collected, and discloses the transfer to Malaysia and potentially the United States and its safeguard. Keep the entry in step with your consent categories.
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