Privacy Policy

1. Who We Are and How to Contact Us

hoteo (“hoteo”, “we”, “us”, “our”) operates the hoteo hotel operations platform. We are the data controller for personal data collected through the platform.

For all privacy-related matters, contact us at: hello@hoteo.com

2. Scope of This Policy

This Privacy Policy applies to personal data we collect from: (a) hotel operators and staff who register and use the hoteo admin platform; (b) hotel guests who interact with a property's guest portal via QR code. It does not apply to third-party websites we may link to.

3. Personal Data We Collect

From hotel operators and staff:

• Name, email address, and password on registration
• Hotel name, property details, and billing information (payment data processed by Stripe)
• Usage data: actions performed in the platform, timestamps, device and browser information
• IP address and approximate location derived from IP
• Profile photo (if uploaded voluntarily)

From hotel guests:

• Name (optional — entered by guest or pre-filled by the hotel via QR code)
• Email address (optional — provided by guest to receive request status notifications)
• Room number and anonymous session token (created when a QR code is scanned)
• Content of service requests, orders, and messages submitted via the portal
• Language preference (stored via browser cookie)

We do not collect payment card data from guests. We do not collect location data beyond what is derived from IP address.

4. Lawful Basis for Processing (GDPR)

We rely on the following lawful bases under GDPR Article 6:

• Contract (Art. 6(1)(b)): Processing operator account data is necessary to deliver the subscribed service.
• Legitimate interests (Art. 6(1)(f)): We process usage data and security logs to operate, secure, and improve the platform. Our legitimate interests do not override your data protection rights.
• Consent (Art. 6(1)(a)): We rely on consent for optional guest email addresses and non-essential cookies. You may withdraw consent at any time without penalty.
• Legal obligation (Art. 6(1)(c)): Retaining billing records as required by applicable tax law (typically 7 years).

5. Cookies

We use the following categories of cookies:

• Strictly necessary: Session authentication (keeps you signed in) and language preference. These are required for the platform to function and do not require consent.
• Analytics (with consent): If you accept cookies, we may use anonymised analytics to understand usage patterns. No personal identifiers are shared with analytics providers.

We do not use advertising cookies, retargeting pixels, or cross-site tracking. You can withdraw analytics cookie consent at any time through the cookie banner or by clearing your browser cookies.

6. How We Use Your Data

We process personal data only for the following purposes:

• Providing, maintaining, and improving the hoteo platform
• Creating and managing accounts and subscriptions
• Processing payments and sending billing communications
• Sending transactional emails (email verification, password reset, guest request notifications)
• Responding to support requests and enquiries
• Detecting and preventing fraud, abuse, and security incidents
• Complying with legal obligations

We do not sell, rent, or trade personal data. We do not use data for automated decision-making that produces legal or similarly significant effects.

7. Per-Property Data Isolation

Each hotel property on hoteo operates in a fully isolated data environment. Guest data, tickets, staff records, and configuration for one property are never accessible to, shared with, or visible to any other property. This is enforced at the database query level, not merely in the UI.

8. Sub-Processors and Data Sharing

We share personal data only with the following trusted service providers who are contractually bound to protect it:

• Vercel Inc. — Cloud hosting infrastructure (USA; Standard Contractual Clauses apply)
• Neon / database provider — PostgreSQL hosting
• Stripe Inc. — Payment processing (USA; PCI-DSS Level 1 certified)
• Resend / email provider — Transactional email delivery

We may also disclose data where required by applicable law, court order, or regulation, or to protect the rights, property, or safety of hoteo, our users, or the public.

9. International Data Transfers

Some sub-processors operate in the United States. Where we transfer personal data from the European Economic Area (EEA) or United Kingdom to the USA, we ensure appropriate safeguards are in place — specifically Standard Contractual Clauses (SCCs) approved by the European Commission, or reliance on valid adequacy frameworks where applicable.

10. Data Retention

• Active accounts: Data is retained for as long as your account is active.
• After account deletion: Personal data is deleted or anonymised within 30 days, except where legal retention is required (e.g. invoices for 7 years).
• Guest sessions: Session tokens expire at checkout date. Associated ticket data is retained as part of the property's operational record.
• Security and access logs: Retained for up to 90 days.

11. Security

We implement the following security measures:

• TLS 1.3 encryption for all data in transit
• Encryption for data at rest
• bcrypt password hashing (passwords are never stored in plain text)
• Role-based access controls ensuring staff see only data relevant to their role
• Credentials stored in environment variables, never in source code

In the event of a personal data breach presenting a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected individuals without undue delay, in accordance with GDPR Articles 33–34.

12. Children's Data

hoteo is not directed at children under 16 years of age and we do not knowingly collect their personal data. If you believe we have inadvertently collected data from a child, contact us at hello@hoteo.com and we will delete it promptly.

13. Your Rights Under GDPR and Applicable Law

You have the following rights regarding your personal data:

• Right of access: Obtain a copy of the data we hold about you
• Right to rectification: Correct inaccurate or incomplete data
• Right to erasure: Request deletion of your personal data
• Right to restriction: Restrict how we process your data
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent at any time without affecting prior processing

To exercise any right, email hello@hoteo.com. We will respond within 30 days. If unsatisfied with our response, you have the right to lodge a complaint with your national data protection authority.

14. Changes to This Policy

We may update this Privacy Policy periodically. For material changes, we will notify registered users by email and update the date at the top of this page. Continued use of the platform after the effective date constitutes acceptance.