Data processing

What is processed, and why

• Subject matter: producing hotel revenue reports from uploaded reservation and player files.
• People concerned: hotel guests and casino players in those files; the hotel's staff who use the service.
• Data: name, postal code and, where present, email, phone, address, player number; stay dates, room type, rate, segment; theoretical win per player or per day where the hotel uploads it. No payment card data and no government identifiers are needed; the hotel should not upload them.
• Duration: names and contact details until matching has run (7 days after upload by default, and never more than 14 days beyond the period the property has set); uploaded files 30 days after a successful load; everything else for the life of the subscription plus 90 days.

Our commitments

• We process the data only to provide the service and only on the hotel's documented instructions, which are these terms and the settings and uploads made in the product.
• Everyone at our company who can reach the data is bound to confidentiality.
• Each property's data is separated from every other customer's by row-level security in the database. Our own staff access is limited by role, needs a second sign-in factor, and is logged.
• Data is encrypted in transit and at rest. Names and contact details are deleted after matching.
• We tell the hotel without undue delay, and within 72 hours of becoming aware of it, of a personal-data breach affecting its data, with what we know and what we are doing about it.
• We help the hotel answer requests from guests and from regulators, and with its own security and impact assessments, as far as the service is concerned.
• At the end of the contract we delete the data, or return it first if the hotel asks, as the Terms of service describe.
• We give the hotel the information it reasonably needs to check these commitments, and answer security questionnaires.

Subprocessors

The hotel agrees to the companies listed below. We add or replace one only after updating this list and telling organization admins by email at least 30 days ahead, unless an emergency leaves less time. A hotel that objects on reasonable grounds may cancel and is refunded the unused part of a prepaid period. We remain responsible for what our subprocessors do with the data.

The table below is the complete list.