Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is all data with which you can be personally identified. Detailed information on data protection can be found in our privacy policy listed below this text.

Data Collection on this Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section "Notice on the responsible party" in this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us directly — for example, data you enter into a contact form. Other data is collected automatically or with your consent when you visit the website by our IT systems. This includes in particular technical data (e.g. internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyse your user behaviour.

What rights do you have regarding your data?

You have the right at any time to receive free information about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

For this purpose and for further questions on the subject of data protection, you can contact us at any time.

2. Hosting

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website is stored on the host's servers. This may include in particular IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

The use of the host serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device.

Our host will only process your data to the extent necessary to fulfil its service obligations and follow our instructions with regard to this data.

We use the following host: Amazon Web Services (AWS). The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg.

For details, please refer to the AWS privacy policy: https://aws.amazon.com/de/privacy/.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Disclosures

Privacy Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. It is not possible to completely protect data from access by third parties.

Note on the Responsible Party

The party responsible for data processing on this website is:

Stellar Tourism Innovations GmbH
Torstrasse 105-107
10119 Berlin

Telefon: +49 30 41738487
E-Mail: hello@myxentra.com

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Storage Duration

Unless a more specific storage period has been stated in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will take place after these reasons cease to apply.

General Information on Legal Bases for Data Processing

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of § 25(1) TDDDG. Consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if it is necessary to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following sections of this privacy policy.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out prior to the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED, UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data which we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

SSL and TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Access, Erasure, and Rectification

Within the scope of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of data processing and, if applicable, the right to correct or delete this data. For this and further questions on the subject of personal data, you can contact us at any time.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
• If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

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4. Data Collection on this Website

Cookies

Our websites use so-called "cookies". Cookies are small data packages and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted after your visit ends. Permanent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies serve to evaluate user behaviour or to display advertising.

Cookies that are necessary for carrying out the electronic communication process, for providing certain functions that you have requested (e.g. for the shopping cart function) or for optimising the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be restricted.

Insofar as cookies from third-party companies or cookies for analysis purposes are used, we will inform you of this separately within this privacy policy and, if necessary, request your consent.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• Browser type and browser version
• operating system used
• Referrer URL
• hostname of the accessing computer
• time of the server request
• IP address

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Contact Form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, if your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you entered in the contact form will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions — in particular retention periods — remain unaffected.

Inquiries by Email, Phone, or Fax

If you contact us by email, telephone or fax, your enquiry, including all personal data resulting from it (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, if your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested.

The data you send us via contact requests will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been fully processed). Mandatory legal provisions — in particular statutory retention periods — remain unaffected.

5. Social Media

Social Media Elements with Shariff

This website uses elements of social media (e.g. Facebook, Twitter, Instagram, Pinterest, XING, LinkedIn, Tumblr).

When you visit one of our social media profiles (e.g. Facebook), the operator of the social media platform is responsible for the data processing that takes place there. We would like to point out that your data may also be processed outside the EU or EEA and that there may not be a comparable level of data protection in those countries.

Data Processing by Social Networks in Detail

We maintain publicly accessible profiles on social networks. The specific social networks we use can be found below. Social networks such as Facebook, Twitter, etc. can generally analyse your user behaviour comprehensively when you visit their website or a website with integrated social media content. Visiting our social media presences triggers numerous data protection-relevant processing operations.

In particular: if you are logged into your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, your personal data may also be collected if you are not logged in or do not have an account with the respective social media portal. In this case, data collection takes place, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you inside and outside the respective social media presence. If you have an account with the respective social network, interest-based advertising can be displayed on all devices on which you are or were logged in.

Please also note that we cannot trace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and privacy policies of the respective social media portals.

Legal Basis

Our social media profiles are intended to ensure the most comprehensive presence possible on the internet. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which must be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6(1)(a) GDPR).

Controller and Assertion of Rights

When you visit one of our social media profiles, we are jointly responsible with the operator of the social media platform for the data processing operations triggered by that visit. You can generally assert your rights (access, rectification, erasure, restriction of processing, data portability and complaint) both against us and against the operator of the respective social media portal.

Please note that, despite joint responsibility with the social media portal operators, we do not have full influence over the data processing operations of the social media portals. Our options are largely determined by the corporate policy of the respective provider.

Storage Duration

Data collected directly by us via the social media presence will be deleted from our systems as soon as you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory legal provisions – in particular retention periods – remain unaffected.

We have no influence over the storage period of your data stored by the operators of the social networks for their own purposes. For details, please enquire directly with the operators of the social networks (e.g. in their privacy policy, see below).

7. Newsletter

Newsletter Data

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form is carried out exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You can revoke your consent to the storage of your data, your email address and its use for sending the newsletter at any time, for example via the "unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.

The data stored with us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6(1)(f) GDPR.

Data stored with us for other purposes remains unaffected by this.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

8. Plugins and Tools

YouTube with Enhanced Privacy

This website embeds videos from the YouTube website. The operator of the pages is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the transfer of data to YouTube partners is not necessarily excluded by the extended data protection mode. Thus, YouTube – regardless of whether you watch a video – establishes a connection to the Google DoubleClick network.

As soon as you start a YouTube video on this website, a connection to YouTube's servers is established. The YouTube server is told which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, after starting a video, YouTube may store various cookies on your device or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve user-friendliness and prevent fraud attempts.

If applicable, further data processing operations may be triggered after starting a YouTube video, over which we have no influence.

The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device. Consent can be revoked at any time.

For more information about privacy at YouTube, please see their privacy policy at: https://policies.google.com/privacy?hl=de.

Google Web Fonts

This page uses so-called web fonts provided by Google for the uniform display of fonts. When you open a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google's servers. This allows Google to learn that this website was accessed via your IP address. The use of Google Web Fonts is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's device. Consent can be revoked at any time.

If your browser does not support web fonts, a default font from your computer will be used.

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9. eCommerce and Payment Providers

Processing of Customer and Contract Data

We collect, process and use personal customer and contract data to establish, design and modify our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

Data Transfer upon Contract Conclusion for Services and Digital Content

We transmit personal data to third parties only when this is necessary in the context of contract processing, for example to the credit institution commissioned with payment processing.

Further transmission of data does not take place or only if you have explicitly consented to the transmission. Your data will not be passed on to third parties without your explicit consent, for example for advertising purposes.

The basis for data processing is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

Payment Services

We integrate payment services from third-party companies on our website. When you make a purchase with us, your payment data (e.g. name, payment amount, bank account details, credit card number) will be processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The use of payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a payment process that is as smooth, convenient and secure as possible (Art. 6(1)(f) GDPR). Where your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent can be revoked at any time for the future.

Stripe

The provider is Stripe Payments Europe Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://stripe.com/de/privacy.

Details can be found in the Stripe privacy policy: https://stripe.com/de/privacy.

Chekin Soluciones Digitales

For digital guest registration and identity verification, we use the service of Chekin Soluciones Digitales S.L., Avda. República Argentina, 24 – 7, 41011 Seville, Spain.

Within the scope of using Chekin, the following data is processed: name, date of birth, nationality, ID data (document number, date of issue, expiry date, country of issue), length of stay, address data and, if applicable, a photo of the identity document.

Processing is based on Art. 6(1)(b) GDPR (contract fulfilment) and Art. 6(1)(c) GDPR (fulfilment of a legal obligation – e.g. registration requirement under the Federal Registration Act or corresponding state regulations).

You can reach Chekin's data protection officer at: dpo@chekin.com

Further details can be found in the Chekin privacy policy: https://chekin.com/en/privacy-policy/.

10. Audio and Video Conferences

Data Processing

For communication with our customers, we use, among other things, online conferencing tools. The tools we use in detail are listed below. When you communicate with us via video or audio conference over the internet, your personal data will be collected and processed by us and the provider of the respective conferencing tool.

The conferencing tools record all data that you provide/use for the tools (email address and/or your telephone number). Furthermore, the conferencing tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other "context information" in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required for handling online communication. This includes in particular IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.

If content is exchanged, uploaded or otherwise provided within the tool, this is also stored on the servers of the tool providers. Such content includes in particular cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared during use of the service.

Please note that we do not have full influence over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider.

Purpose and Legal Bases

The conferencing tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Where consent has been requested, the use of the tools in question is based on this consent; consent can be revoked at any time with effect for the future.

Storage Duration

Data collected directly by us via video and conferencing tools will be deleted from our systems as soon as you request deletion, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your terminal device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence over the storage period of your data stored by the operators of the conferencing tools for their own purposes. For details, please contact the operators of the conferencing tools directly.

11. Third-Party Services

Supabase

We use Supabase (Supabase Inc., USA) as our backend infrastructure. The database is hosted on AWS in the eu-central-1 region (Frankfurt).

All data is stored encrypted (AES-256) and encrypted in transit (TLS 1.2+).

Twilio (SMS delivery)

For sending SMS to guests, we use Twilio Inc. (USA). Phone number and message content are transmitted.

Twilio privacy policy: https://www.twilio.com/legal/privacy.

Resend (email delivery)

For email delivery, we use Resend Inc. (USA). Email address, name, and message content are transmitted.

Google Gemini (AI processing)

For AI-powered features, we use the Google Gemini API. Personal data is anonymized before transmission.

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Channex (channel manager)

For booking synchronization, we use Channex Ltd. (EU). Booking data is transmitted.

Seam (smart lock integration)

For smart locks, we use Seam Labs Inc. (USA). No personal guest data is transmitted.

Chargebee (subscription management)

For subscription management, we use Chargebee Inc. (USA). Account and payment data are transmitted.

11. Own Services

Handling of Applicant Data

We offer you the opportunity to apply to us (e.g. by email, post or via an online application form). In the following, we inform you about the scope, purpose and use of your personal data collected during the application process. We assure you that the collection, processing and use of your data will be in accordance with applicable data protection law and all other legal provisions, and that your data will be treated in strict confidence.

Scope and Purpose of Data Collection

When you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes made during job interviews, etc.) to the extent necessary for the decision on establishing an employment relationship. The legal basis for this is Section 26 BDSG under German law (initiation of an employment relationship), Art. 6(1)(b) GDPR (general contract initiation) and – if you have given consent – Art. 6(1)(a) GDPR. Consent can be revoked at any time. Your personal data will only be passed on within our company to persons involved in processing your application.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6(1)(b) GDPR for the purpose of carrying out the employment relationship.

Data Retention Period

If we are unable to make you a job offer, you decline a job offer or withdraw your application, we reserve the right to retain the data you submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. Retention serves in particular as evidence in the event of legal disputes. If it is apparent that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further retention no longer applies.

Longer retention may also take place if you have given appropriate consent (Art. 6(1)(a) GDPR) or if statutory retention obligations preclude deletion.

The role in which we process data

For the data of our customers — the hosts who use Xentra — as well as prospects and visitors to our website, we are the controller within the meaning of the GDPR. This policy describes exactly that processing.

By contrast, we process the data of our customers' guests, owners and service providers exclusively on behalf of and on the instructions of the respective host. The host is the controller there; the basis is our data processing agreement. If you are a guest and want to know what happens to your data, please contact your host — we forward requests but may not answer them on our own authority.

Hosting and technical infrastructure

The application, guest pages and booking flow are delivered by Vercel Inc. (USA); this involves connection data such as IP address, time and the address requested. Database, authentication, file storage and server functions run at Supabase Inc. on servers in Frankfurt am Main. Invoice PDFs and electronic invoice formats are generated by a service we operate at Google Cloud in Frankfurt am Main. Updates to our mobile app are delivered via Capgo (Digital Shift OÜ, Estonia), which transmits device and version details.

AI-assisted features

For AI features we use two providers: Google LLC (Gemini API) and Anthropic PBC, both based in the USA. Transfers take place on the basis of the European Commission's standard contractual clauses. Depending on the feature, the data processed includes draft texts, guest messages, voice messages, uploaded documents, property and booking data, and conversations with our assistant. Under contract, neither provider uses the transmitted data to train its models.

A detailed overview of which feature sends which data to which provider is available in the AI privacy notice under "AI privacy". The legal basis is our legitimate interest in a functional and efficient service (Art. 6 (1) (f) GDPR) or the performance of the contract (Art. 6 (1) (b) GDPR); where consent is required, we obtain it separately.

Guest communication, translation and voice messages

Depending on the channel, messages between hosts and guests are routed via Resend (email), Twilio (SMS and WhatsApp), the WhatsApp Business Platform of Meta Platforms Ireland, a relay service operated by our partner HostU, or the inboxes of connected booking portals. Content, sender, recipient and time are transmitted to the respective provider and stored in Xentra. In the HostU relay, content is deleted there after 48 hours according to the provider.

If automatic translation is enabled, the content of incoming and outgoing messages is transmitted to our AI provider for translation; the translation is stored alongside the original. Voice messages are transmitted to the same provider for transcription; the transcript is stored with the message. Both can be switched off in the settings.

Check-in, guest registration and tourist tax

On behalf of our customers we transmit registration and guest data to the portals and bodies selected by the respective host: Chekin S.L. (Spain), AVS GmbH (Germany), Feratel Media Technologies AG (Austria), WINTOP (Germany/Austria) and the Spanish registration system SES Hospedajes of the Ministry of the Interior. Depending on the destination, this includes names, dates of birth, nationality, addresses, identity document data, travel dates and signatures. The legal basis is compliance with a legal obligation of the host (Art. 6 (1) (c) GDPR).

We collect identity document numbers only where registration law permits; under German registration law this concerns foreign guests only. The transmission logs to the registration portals contain the full registration record and are automatically stripped of that content 30 days after confirmed transmission. Identity verification against an identity document only takes place if the host explicitly enables it; it is carried out by Stripe.

Access systems and access logs

If a host has connected a locking system, we transmit to its manufacturer the details required to issue an access code — typically a label for the code (often the guest name), the validity period and the device identifier. The providers involved are Nuki (Austria), Tedee (Poland), Salto (Spain), Seam and Ring (USA), TTLock (China), igloohome (Singapore) and SwitchBot (Hong Kong). Standard contractual clauses are in place for providers outside the EEA.

For some manufacturers we retrieve events from individual locks — such as when a door was opened, with which code or by which route — and store them in the host's account so that a log remains viewable there over a longer period. We likewise log when a shared door link was opened and by whom. The host is responsible for these logs and for informing the persons concerned.

Mobile app and push notifications

If you use our app or enable browser notifications, we store a device identifier (push token) together with your account. Delivery takes place via the Apple Push Notification service (Apple Distribution International, Ireland) or Firebase Cloud Messaging (Google Ireland). This transmits the identifier as well as the title and body of the notification, which may contain names or message excerpts. You can disable notifications at any time on your device or in the settings; the token is then deleted.

The app asks for access to the camera and photo library so that identity documents and photos can be captured for check-in or for tasks. Access takes place only after you grant it and only at the moment you use such a feature. You can withdraw the permission in your system settings at any time.

Error diagnostics and operational security

If an error occurs, we generate an error report and transmit it to Sentry (Functional Software Inc.). Such a report contains the error message, the affected function and identifiers such as user, booking or connection ID; known credentials are stripped beforehand. Its sole purpose is to detect and remedy malfunctions. The legal basis is our legitimate interest in secure and error-free operation (Art. 6 (1) (f) GDPR).

Support, screen recordings and account access

When you report a problem to us, you can create a screenshot or a screen recording — with audio if you wish. We store technical context alongside it: the last console messages, network requests and errors of your session, your identifier, the window size and the build version. We delete such recordings after 30 days unless we need them longer to handle a case that is still open.

To handle support cases, our staff can temporarily switch into your account and see what you see. Such sessions are time-limited, logged and visibly marked in the account. We use them only in response to a specific occasion, never for observation.

Appointments, consultations and meeting records

Appointments for consultation, onboarding and feedback calls are booked via Cal.com (EU instance); this processes name, email address, time zone and the requested slot. We mirror appointments into our company calendar at Google.

Video calls with us may be recorded and transcribed automatically; for this we use Fireflies.ai Inc. (USA). From the transcript we generate a summary with the help of an AI provider and file it with the respective customer or prospect contact. We point out the recording at the beginning of a call. You may object at any time; the call then takes place without recording. The legal basis is your consent (Art. 6 (1) (a) GDPR).

Internal working tools

For internal handling we use Slack (Salesforce Inc., USA) for notifications about new accounts and billing events, and Linear (USA) for handling bugs and improvement requests. This may process name, email address, property details and excerpts from support requests or error reports. We limit these transfers to what is necessary for the handling.

Accounting, tax and invoice transmission

At the host's request we hand invoice records over to Lexware Office (Haufe-Lexware, Germany) and transmit electronic invoices for Italy via Fatture in Cloud to the state interchange system SdI. To validate VAT identification numbers we query the European Commission's VIES service and store the result. Subscription and commission billing run through Chargebee, payments through Stripe.

Content loaded from third parties

On some pages — in particular guest pages, online check-in and the booking widget — content is loaded from third-party servers. The respective provider thereby learns your IP address and technical details about your browser and device. This concerns fonts from Google Fonts, map tiles from CARTO, the check-in module from Chekin, imagery from Unsplash, embedded videos from YouTube and Vimeo and — if the host has set it up — a review widget from Trustindex.

Origin of your registration

When you register, we additionally store how you came to us: the referring address and — where present — campaign parameters in the address you called up. We use this solely to understand which of our activities are effective. The legal basis is our legitimate interest in running our offering economically (Art. 6 (1) (f) GDPR). You may object to this processing under Art. 21 GDPR.

Guest pages, websites and booking widget of our customers

When a guest opens a guest page, a website built with Xentra or a booking widget, the respective host is the controller for that page; we provide it on their behalf. To operate the page we process connection data and — in the case of a booking or enquiry — the contact and booking details entered. The legal notice and privacy policy of such a page are the host's responsibility; templates we provide are non-binding samples.

Interface and outgoing webhooks

If a host sets up interface access or an outgoing webhook, we transmit data from their account to the target system they designate on their instruction — including booking, contact and invoice data of their guests. The recipient and purpose are determined solely by the host. We log interface access for abuse detection and delete the logs after 30 days.

Automated processes and decisions

Some processes run without human involvement: sending messages and AI replies to guests, issuing and deleting access codes, withholding an access code while check-in obligations are outstanding, authorising a deposit before departure, payment reminders for tourist tax, and publishing a guest review. Whether and how these processes apply is decided by the respective host through their settings.

We do not take automated decisions within the meaning of Art. 22 GDPR that produce legal effects concerning you or similarly significantly affect you. No profiling for advertising purposes takes place.

How long we store data

As a rule we store data for as long as the account exists and it is necessary for the purpose, and thereafter until statutory retention periods expire — for tax-relevant records in Germany generally eight to ten years. Shorter, technically enforced periods apply to specific categories of data:

• Registration data in the transmission logs to registration portals: 30 days after confirmed transmission
• Screen and audio recordings from support: 30 days
• Logs of the interface, incoming webhooks and synchronisations: 30 days
• Execution logs of scheduled background jobs: 7 days
• Push identifiers: until notifications are switched off or the device is deregistered

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