Privacy Policy

• General enquiries: office@discontinue.dev
• Contact for data protection enquiries: datenschutz@discontinue.dev

There is no statutory requirement to appoint a data protection officer; for all data protection matters you can reach us at datenschutz@discontinue.dev.

When you access our website, our hosting provider processes technically necessary server log files:

• truncated IP address
• date and time of access
• page accessed / referrer URL
• browser type and operating system

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the stable and secure operation of the website). Retention period: 30 days, thereafter automatic deletion.

If you contact us via the contact form, by email, via a demo request or the waiting list, we process the data you provide (name, email, company, message content) to handle your request and, where applicable, to initiate a contractual relationship.

Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures) or Art. 6(1)(f) GDPR (legitimate interest in responding to enquiries). Retention period: until your request has been finally processed, at most 24 months, unless a contractual or statutory retention obligation exists.

Our website is hosted in Frankfurt (Germany) on the Oracle Cloud Infrastructure (region eu-frankfurt-1). Recipients of data are also the consent management platform Cookiebot (Usercentrics/Cybot A/S, Denmark, EU) for consent management, – subject to your consent – Google (analytics), and our email service provider when responding to enquiries. Cookiebot processes data exclusively in the EU; a transfer to third countries only takes place in the cases described above (Google) on the legal basis stated.

This part informs you about how Discontinue processes personal data when you use the Platform. We comply with the General Data Protection Regulation (GDPR) and the Austrian Data Protection Act (DSG).

The Platform is an AI-supported operations platform for hotels that builds on the connected source systems. Hotel operators independently configure reports and agents that access their own data from the connected systems. This results in a dual role:

For the data processed on behalf of the hotel, data subjects (e.g. guests) generally direct their requests to the respective hotel as the controller.

• Name and email address of the platform user (hotel staff)
• Password (stored exclusively as a cryptographic hash; bcrypt/Argon2)
• Role and permissions within the Platform
• Login times and IP address at the time of login (for security purposes)

Access takes place via the connection of the source system established by the hotel itself (OAuth), which the hotel can revoke at any time. On behalf of the respective hotel, we process the following data categories:

• Reservation data (booking number, check-in/-out, status)
• Guest master data (salutation, first and last name)
• Contact data of guests, where stored in the source system (in particular email address)
• Room/unit data, length of stay, rate, special requests
• Folios, refunds, invoices, revenue information

The legal basis in relation to the hotel is Art. 6(1)(b) GDPR in conjunction with Art. 28 GDPR (processing on behalf).

• Login times and IP address
• Platform usage (which reports created, which agents configured)
• Browser and device information (user agent)

To improve and stabilise the Platform, we analyse product usage with the help of Google Analytics 4 (GA4), integrated via Google Tag Manager (GTM). The usage behaviour of the platform users (hotel staff) is recorded, e.g. functions accessed, click and navigation events, approximate location (based on the truncated IP), device and browser information, and pseudonymous identifiers (client/session IDs). Important limitations:

• Data is collected exclusively after your consent via the consent banner (consent mechanism as in Part A: Cookiebot, Google Consent Mode v2, default “denied”). Without consent, no analytics cookies are set and no analytics data is transmitted to Google.
• No data from the connected systems and no guest data is transmitted to Google. The product analytics relate solely to the behaviour of the logged-in staff users in operating the Platform, not to content from the connected systems.
• GA4 uses IP addresses only temporarily (including for rough location determination) and does not store them; IP anonymisation is effective by default in GA4.
• There is no cross-device profiling for advertising purposes and no linking with Google advertising services; the “Google Signals” function is disabled.

Legal basis: your consent pursuant to Art. 6(1)(a) GDPR and – for the storage of and access to information on the terminal device – Section 165(3) TKG 2021. You can withdraw your consent at any time with effect for the future via the consent settings.

Recipients / third-country transfer: the provider is Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland); processing by Google LLC (USA) is possible. Google LLC is certified under the EU-US Data Privacy Framework (DPF) (adequacy decision (EU) 2023/1795); in addition, EU Standard Contractual Clauses apply within the Google data processing terms.

Retention period: the retention period for user and event data in GA4 is limited to 14 months; after this, automatic deletion/aggregation takes place. Consent records (consent logs) are stored in the EU via Cookiebot and retained for up to 12 months.

To provide the platform service, hotel data is transmitted to the AI model (Claude API by Anthropic PBC) insofar as this is necessary for the report or agent configured by the controller. Depending on the configuration, the transmitted content may include personal guest data including salutation, first and last name as well as contact, reservation and stay data. The following protective measures apply:

• AI models are used exclusively via API.
• The transmitted data is not used to train the AI models (no-training guarantee).
• The model provider stores the transmitted content only for a limited period (no more than 30 days, exclusively for abuse detection) and deletes it automatically thereafter (limited retention period).
• Multi-layered data minimisation: only the scopes released in the source system (read-only by default), granular and configurable tools with an allowlist per agent and tool/scope minimisation per task, tenant/integration scoping, and a run budget (€ cap).
• Tenant isolation: each API call is restricted to the respective hotel tenant; no consolidated data sets of multiple hotels.
• Transfer to the USA: on the basis of the EU Standard Contractual Clauses (SCCs, Module 2) pursuant to Art. 46(2)(c) GDPR together with a Transfer Impact Assessment (see Section B6).
• For each agent run, a complete internal AI trace is created and retained for 12 months.
• Write operations to the connected systems by default pass through an approval queue with human approval; only with explicit per-agent opt-in without individual approval. The proposal, approver, decision and result are logged.

Note on pseudonymisation: in operational use, Discontinue deliberately refrains from fully pseudonymising guest names, since operational hotel workflows (e.g. a “VIP arrivals briefing”) lose their function if the specific guest name is replaced by an anonymous identifier. Data minimisation is instead achieved through the multi-layered protective measures described above. Classic pseudonymisation is used where it is possible without loss of function (e.g. in aggregated statistical reports).

For contract and payment processing, we process company/invoice data, subscription and usage scope (plan/tier, agent slots, balance top-ups), and payment information via the payment service provider Stripe. No data from the connected systems and no guest data is processed in this context.

Processing

Legal basis

Account administration

Art. 6(1)(b) GDPR – performance of contract

Hotel data (from the connected systems)

Art. 6(1)(b) in conjunction with Art. 28 GDPR – processing on behalf

Platform operation / security

Art. 6(1)(f) GDPR – legitimate interest

Product analytics (Google Analytics 4 / GTM)

Art. 6(1)(a) GDPR – consent; Section 165(3) TKG 2021

AI processing

Art. 6(1)(b) GDPR – performance of contract

Billing

Art. 6(1)(b) and (c) GDPR

Statutory obligations (e.g. retention)

Art. 6(1)(c) GDPR

Type of data

Retention period

Account data

As long as the account is active; thereafter deletion within 30 days

Hotel data (from the connected systems)

Only during active processing; no permanent mirroring of the connected system’s database

Report artefacts (rendered reports)

90 days; thereafter automatic deletion

AI traces

12 months

Usage and log data

12 months

Google Analytics data (GA4)

14 months

Consent records (consent logs, via Cookiebot/EU)

up to 12 months

Invoice data

7 years (statutory retention obligation pursuant to Section 132 BAO – Austria)

A complete sub-processor list with data categories and transfer basis is Annex 1 to the DPA and available on request at datenschutz@discontinue.dev.

1. 1. AI processing (Anthropic, USA): the ongoing transfer of hotel data takes place on the basis of the EU Standard Contractual Clauses (SCCs, Module 2) pursuant to Art. 46(2)(c) GDPR – supplemented by a no-training guarantee and a contractually limited retention period (max. 30 days), transport encryption (TLS 1.2+), multi-layered data minimisation and tenant isolation. For this transfer, a Transfer Impact Assessment (TIA) pursuant to “Schrems II” (CJEU C-311/18) is additionally available, which can be requested at datenschutz@discontinue.dev.
2. 2. Product analytics (Google): processing by Google LLC in the USA may take place. Google LLC is certified under the EU-US Data Privacy Framework (adequacy decision (EU) 2023/1795); in addition, SCCs apply. The transfer only takes place after your consent.
3. 3. Stripe (billing): primary processing by Stripe Payments Europe Ltd. (Dublin); any group access to the USA is secured via SCCs.

On the Platform we use:

• Technically necessary cookies for session management, authentication and CSRF protection. These are required for operation and cannot be deselected (Section 165(3) TKG 2021 – no consent required).
• Analytics cookies/technologies (Google Analytics 4 / Tag Manager) – exclusively after your consent via the consent banner (see B2.4). The specific cookies set can be found in the cookie declaration provided via Cookiebot (“Cookie settings”).
• Consent management (Cookiebot): the consent banner and the documentation of consent take place via Cookiebot (Usercentrics/Cybot A/S, Denmark, EU). The CookieConsent cookie set for this purpose is technically necessary.

Automated decision-making within the meaning of Art. 22 GDPR does not take place. No marketing/advertising cookies and no cross-device advertising profiling are used.

We take appropriate technical and organisational measures pursuant to Art. 32 GDPR (including encryption at rest with AES-256-GCM for sensitive data, TLS 1.2+ in transit, role-based authorisation concept, multi-tenant isolation, daily backups, audit trail of AI processing). Details are set out in the document TOMs (Art. 32).

As a data subject, you have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent given (Art. 7(3) GDPR), e.g. for product analytics – with effect for the future

Please direct requests to datenschutz@discontinue.dev; we respond within one month (Art. 12(3) GDPR). Insofar as Discontinue processes data as a processor (Part B, hotel data), we forward the request without undue delay to the respective hotel operator (controller).

You have the right to lodge a complaint with the Austrian Data Protection Authority (DSB): Barichgasse 40–42, 1030 Vienna, dsb@dsb.gv.at, https://www.dsb.gv.at/.

We reserve the right to adapt this Privacy Policy as required. The current version is available on the website and in the Platform. We inform platform users of material changes to Part B (Platform) by email.