Data processing agreement

1. Parties and subject

The controller is the hotel (customer). The processor is hantha GmbH as operator of geowatt. Subject is the processing of personal data when using geowatt under the terms of service.

2. Agencies

If an agency uses geowatt for a hotel, the agency is the hotel's processor and geowatt the agency's subprocessor. The agency ensures a corresponding agreement with the hotel exists.

3. Data and data subjects

Data of the customer's staff and contractors: name, email, position, profile picture, activity in the tool, comments, files. Guest data is not needed for geowatt; the customer does not upload any.

4. Instructions

geowatt processes data only on the customer's documented instructions, given through use of the tool and this agreement. If geowatt considers an instruction unlawful, it informs the customer.

5. Confidentiality

All persons with access are bound to confidentiality.

6. Technical and organisational measures

Encrypted transport (HTTPS, HSTS).

Tenant separation in the database: row-level access rules check hotel membership on every query.

Roles and permissions (admin, member, agency access), revocable by the hotel admin.

Private file storage with time-limited links.

Log of all automatic changes (autopilot) and task events.

Protection against framing, security headers, regular security checks.

Backups by the hosting provider.

7. Subprocessors

The customer approves the following subprocessors. geowatt announces new ones at least 30 days in advance; the customer may object.

Lovable Labs Inc. (inkl. Supabase Inc., Cloudflare Inc.): Hosting, database, sign-in, file storage (EU/USA).

OpenAI (ChatGPT): AI queries about hotels (no guest data) (USA).

Google (Gemini): AI queries about hotels (no guest data) (USA/EU).

Anthropic (Claude): AI queries about hotels (no guest data) (USA).

Google Ireland Ltd. (Google Analytics): Website analytics, only after consent (EU/USA).

8. Assistance

geowatt assists the customer with data subject requests (e.g. export and deletion functions in the tool) and impact assessments, and reports personal data breaches without undue delay, at the latest within 48 hours of becoming aware.

9. Deletion and return

After termination or deletion of the hotel by its admin, hotel data is deleted unless a statutory retention duty applies. Before that the customer can export its data.

10. Audits

geowatt provides the information needed to demonstrate compliance and allows audits after reasonable notice.