1. Introduction
QuartoVerde GmbH, located at Sinserstrasse 65, 6330 Cham, Switzerland, ("we," "us," or "our") provides a property management system (PMS) called LodgeHog (the "Service") to hotels and other accommodation providers ("Hotels," "you," or "your"). This Privacy Policy explains how we collect, use, disclose, and protect information when you use our Service, and when we process information about your guests ("Guests") on your behalf.
We are committed to protecting the privacy of both our clients (Hotels) and their Guests. This policy outlines our practices and your choices regarding your information and the information of your Guests.
2. Information We Collect
We collect two main categories of information:
a) Information about Hotels (Our Clients):
When you sign up for and use our Service, we may collect the following information about you and your business:
- Contact Information: Name, email address, phone number, physical address, billing address.
- Account Information: Username and password, which we store only in hashed form.
- Payment Information: Billing details and payment history. Card details are entered directly with our payment processor, Stripe, and never stored by us.
- Hotel Information: Hotel name, address, contact details, property details, room types, rates, and other information necessary to operate the PMS.
- Usage Data: Information about how you use the Service, including login times, features used, and interactions with the platform.
- Support Data: Information you provide when contacting our customer support team.
- Advertising Data: If you reach our website through an online ad, the identifier of that ad click (such as Google's gclid), which is stored with your account when you sign up.
b) Information about Guests (Processed on Behalf of Hotels):
As part of providing the Service, we process information about your Guests on your behalf. You, as the Hotel, are the data controller for this information, and we are the data processor. This information may include:
- Guest Identification Data: Full name, date of birth, gender, nationality, passport or ID card details, address.
- Contact Information: Email address, phone number.
- Reservation Information: Check-in/check-out dates, room type, room number, number of guests, rates, special requests.
- Payment Information: Payment card details (processed securely and may be tokenized).
- Stay History: Information about past stays at your Hotel.
- Communications: Records of communications between the Guest and the Hotel through the PMS.
3. How We Use Information
a) Information about Hotels:
We use information about Hotels to:
- Provide and Maintain the Service: Create and manage your account, process payments, provide customer support, and ensure the proper functioning of the PMS.
- Improve the Service: Analyze usage patterns, identify areas for improvement, and develop new features.
- Measure Our Advertising: Find out which of our ads bring in customers who sign up, use the Service and subscribe, as described in section 4.
- Communicate with You: Send important notices, updates, promotional offers, and respond to your inquiries.
- Comply with Legal Obligations: Meet legal and regulatory requirements.
We do this to perform our contract with you, to comply with legal obligations such as keeping accounting records, and, for improving the Service, measuring our advertising and sending promotional messages, on the basis of our legitimate interest in running and growing our business.
b) Information about Guests:
We use Guest information solely as instructed by you (the Hotel) to:
- Facilitate Reservations and Bookings: Manage bookings, allocate rooms, process payments, and generate booking confirmations.
- Enable Hotel Operations: Provide you with tools to manage check-ins, check-outs, guest requests, billing, and other essential hotel operations.
- Improve Guest Experience: Enable you to personalize guest interactions and provide better service.
We process Guest information as your processor, under the data processing terms in Article 10 of our Terms of Use. As the controller, you are responsible for having a legal basis for it and for informing your Guests.
4. How We Share Information
a) Information about Hotels:
- Third-Party Service Providers: We share information with service providers that process it on our behalf and are bound by contract to protect it: Google Cloud (hosting and database, United States), Cloudflare (file storage and delivery), SendGrid (email delivery, United States), Stripe (subscription payments), PostHog (product analytics, European Union) and Sentry (error monitoring, European Union).
- Advertising Partners: When you sign up, when you add reservations during your first week, and when you start a subscription, we send Google (Google Ads) and OpenAI (OpenAI Ads) the ad click identifier, if there is one, a hashed version of your email address and phone number, and the type and value of the event. Hashing (SHA-256) turns your email address and phone number into codes from which they cannot be read back, but which these providers can match against accounts they already know. We send this only so that they can tell us which of our ads bring in customers, and we tell Google not to use it for personalized advertising. Their use of the data is governed by the Google Privacy Policy and the OpenAI Privacy Policy.
- Legal Requirements: We may disclose information if required by law, such as in response to a subpoena, court order, or government request.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of the transaction. We will notify you of any such transfer and any choices you may have.
b) Information about Guests:
- With the Hotel: We share Guest information with you (the Hotel) as necessary to provide the Service and enable you to manage your operations and guest relationships.
- Our Sub-processors: To run the Service, Guest information is processed by Google Cloud (hosting and database, United States), Cloudflare (file storage), SendGrid (email delivery, United States) and Sentry (error monitoring, European Union). If you use the AI chatbot, Guest messages are also processed by OpenAI and Google (AI language models, United States) and, for WhatsApp conversations, by Meta. If you use our channel manager, reservations are exchanged with Channex and the booking channels you connect.
- Third-Party Service Providers (Under Hotel's Direction): We may share Guest information with third-party service providers that you integrate with the PMS, such as channel managers, payment gateways, or marketing automation platforms. We only do this at your direction and under your responsibility to ensure these providers comply with data protection laws.
- Authorities (Under Hotel's Direction): When you enable it, we send Guest and invoice information on your behalf to authorities, such as Brazil's National Guest Registration System (FNRH) and municipal electronic service invoicing (NFS-e).
- Legal Requirements: We may disclose Guest information if required by law, as outlined above.
- Aggregated or Anonymized Data: We may share aggregated or anonymized data about Guests that cannot be used to identify individuals for analytical or statistical purposes. This data is not considered personal data.
5. Cookies and Similar Technologies
Our websites and the Service use cookies and similar technologies, small files stored in your browser, for the following purposes:
- Essential: Keeping you logged in, protecting forms against forgery, and remembering your language. The Service does not work without them.
- Analytics: PostHog, hosted in the European Union, records how visitors use our websites and the Service, so that we can improve them.
- Advertising: Google Ads (through Google Tag Manager) and OpenAI Ads record which ad brought you to our website, so that a later sign-up or subscription can be attributed to it.
- Booking Pages: Hotels can add their own tags, such as Google Ads or the Meta Pixel, to their booking pages. Each Hotel is responsible for the tags it adds.
You can block or delete cookies in your browser settings. Blocking analytics and advertising cookies does not affect the Service.
6. Data Security
We implement appropriate technical and organizational security measures to protect both Hotel and Guest information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:
- Encryption: Data is encrypted in transit and at rest.
- Access Controls: Access to information is restricted to authorized personnel only.
- Infrastructure and Updates: The Service runs on managed cloud infrastructure, we keep our software dependencies up to date, and we monitor the Service for errors.
- Breach Notification: If a data breach affects your information or your Guests' information, we will notify you without undue delay.
7. Data Retention
- Hotel Information: We keep information about Hotels while your account is active, and delete it within 90 days after you close your account. We keep billing and accounting records for 10 years, as Swiss law requires, and anything we need for an ongoing dispute until it is resolved.
- Guest Information: While your account is active, we keep Guest information for as long as you keep it in the PMS, so you decide how long that is. We delete it within 90 days after you close your account, unless the law requires us to keep it longer.
8. Your Rights and Choices (Hotels and Guests)
a) Hotels:
- Access and Update: You can access and update your account information through the PMS.
- Correction, Deletion and Restriction: You can ask us to correct inaccurate information, delete information we no longer need, or restrict how we use it, subject to the retention periods in section 7.
- Data Portability: You can request a copy of your data in a structured, commonly used, and machine-readable format.
- Objection to Advertising Measurement: You can object at any time to your data being used to measure our advertising, as described in section 4, by contacting us.
- Promotional Messages: You can ask us at any time to stop sending you promotional messages.
- Account Closure: You can close your account at any time.
- Complaints: If you believe we handle your information unlawfully, you can complain to a data protection authority, such as the Swiss Federal Data Protection and Information Commissioner (FDPIC), the authority in your EU country, or Brazil's National Data Protection Authority (ANPD).
b) Guests:
- Guest Rights: Guests have certain rights regarding their personal data under applicable data protection laws (such as the Swiss Federal Act on Data Protection, the GDPR and Brazil's LGPD). These rights may include the right to access, rectify, erase, restrict processing, data portability, and the right to object to processing.
- Exercising Rights: Guests should direct any requests to exercise their rights to the Hotel they booked with, as the Hotel is the data controller. If a Guest contacts us instead, we forward the request to the Hotel and help the Hotel respond to it as required by law.
9. International Data Transfers
We are based in Switzerland, and the Service is hosted in the United States (Google Cloud). Some of the providers listed in section 4 also process data in the United States or other countries. For transfers from Switzerland, the European Economic Area or the United Kingdom to countries without an adequate level of data protection, we rely on the EU-U.S. Data Privacy Framework and its Swiss and UK extensions where the recipient is certified, and otherwise on Standard Contractual Clauses. For data from Brazil, we rely on the transfer mechanisms that the LGPD permits.
10. Children's Privacy
The Service is meant for businesses and is not directed at children, and our websites do not knowingly collect information from children. Hotels may record information about Guests who are minors, such as children travelling with their families, which we process on the Hotel's behalf like any other Guest information.
11. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on our website or through the Service. You are advised to review this Privacy Policy periodically for any changes.
12. Contact Us
QuartoVerde GmbH, Sinserstrasse 65, 6330 Cham, Switzerland, is responsible for the processing described in this policy, except for Guest information, which we process on behalf of Hotels. For questions about this policy or to exercise your rights, write to us at [email protected].