Data processing agreement

Who is responsible for what

The hotel is the controller of its guests' and staff's personal data: it decides why the data is processed. Clefs is the processor: it processes that data only to run the services the hotel has chosen, and only on the hotel's documented instructions.

Where Clefs collects data for itself, such as an enquiry through this website or the free OTA audit, Clefs is the controller of that data and the privacy notice shown at that point applies.

Processing only on instructions

Clefs uses hotel data only to provide the services in the contract. It does not sell it, does not use it for advertising, and does not use one hotel's guest data to serve another hotel.

Anonymized, aggregated benchmarks are produced only for hotels that opt in, and a hotel only ever sees its own position.

Security measures

Role-based access with masking of guest details, an append-only audit log verified every night, encryption in transit, separate consent records, and automatic retention limits. The measures are described on the security page.

Everyone at Clefs with access to hotel data is bound by confidentiality.

Sub-processors

The hotel authorises the providers on the sub-processors page. Clefs gives notice before adding or replacing a provider that receives personal data, and the hotel may object. Clefs remains responsible for its sub-processors.

International transfers

Today our database runs in Singapore and AI processing runs in the United States. Regional hosting is available when your contract requires it. Moving the database does not move AI processing out of the United States, so guests are asked to consent to that transfer before the assistant starts.

Transfers rely on the guest's explicit consent, collected before the assistant starts, and on the contractual safeguards with each provider.

For UK and EU hotels, a version with standard contractual clauses and the UK Addendum is available on request.

Helping with guest rights

Clefs gives the hotel the tools to answer requests to access, correct, erase, restrict, object or move data: a request queue with due dates, data bundles for access and portability, and erasure that anonymizes operational records. Guests can use the privacy request form, and requests are passed to the hotel.

Personal data incidents

Clefs tells the hotel without undue delay after becoming aware of a personal data breach affecting its data, with what is known at the time, and follows up as the investigation continues, so the hotel can meet its own notification duties.

At the end of the contract

The hotel can export all of its data at any time from the console. At the end of the contract Clefs returns or deletes the hotel's personal data, as the hotel chooses, except where the law requires it to be kept, and confirms the deletion in writing.

Getting the signed agreement

The signed DPA is sent with every contract and pilot agreement. To review it earlier, book a call and we will send it ahead of the meeting.