1. Privacy Roles
Hotel / property: For guest, visitor, employee, vendor and operational records, the subscribing hotel / property generally determines why personal data is collected and therefore normally acts as the Data Fiduciary. CYVERNA: generally acts as a Data Processor/service provider when it processes that data solely to provide the PMS under Hotel instructions. CYVERNA may separately act as a Data Fiduciary for its own subscription account, support, billing, security, fraud/abuse-prevention and service-administration data.
2. Data Categories
- Guest identity and KYC information, contact details, nationality, stay/room data, companions, preferences, service requests and communications.
- Reservation, channel/source, folio, GST invoice, payment status and payment metadata. CYVERNA should not be configured to store prohibited full card authentication data/CVV.
- Restaurant/table orders, dietary preferences or allergy notes entered by the Hotel/guest, banquet/MICE and transport requests.
- Employee/user account, role/permission, attendance/task/audit/security log data.
- Technical data such as IP address, device/browser identifiers, login/audit events, connector/webhook logs and service diagnostics.
3. Purposes
- Reservation, check-in, stay management, guest service, billing, restaurant/POS/KOT, housekeeping, maintenance and checkout.
- Legal/statutory reporting configured by the Hotel, including KYC/police/foreigner/tax records where applicable.
- Security, audit, fraud/leakage detection, troubleshooting, backup and business continuity.
- Guest communication and service recovery. Marketing must use a separate lawful basis/consent and must not be bundled with essential hotel service.
- CYVERNA account administration, licensing, subscription validation and technical support.
4. Notice, Consent & Choice
The Hotel should provide a clear privacy notice describing the personal data collected and the specified purpose. Consent, where used, should be specific, informed, unambiguous and withdrawable with comparable ease. Essential stay/service processing should not be conditioned on unrelated marketing consent. CYVERNA Direct Booking Engine records acknowledgement of the booking/privacy notice and keeps marketing consent separate.
5. Sharing & Processors
Data may be shared only as necessary with the Hotel’s authorised users and configured processors/connectors such as payment gateways, OTA/channel partners, messaging providers, KYC/OCR providers, hosting/cloud providers, accounting systems, smart locks/IoT and authorities where legally required. The Hotel is responsible for choosing and authorising its third-party providers; CYVERNA is responsible for its own subprocessors within the scope of the signed service.
6. Security Safeguards
CYVERNA is designed to support role-based access, audit trails, protected server-side secrets, session security, backups and operational logs. The Hotel must also use HTTPS, strong unique credentials, least privilege, supported software, protected hosting accounts, endpoint security, backup testing and restricted KYC access. Security is a shared responsibility; configuration or credential failures at the Hotel are outside CYVERNA’s direct control.
7. Retention & Deletion
The Hotel must define retention periods by data category based on purpose and applicable legal requirements. KYC, invoices and statutory guest registers may require different retention from marketing or convenience data. CYVERNA should not erase records that the Hotel is legally required to preserve. Once purpose and legal retention end, data should be securely erased or anonymised under the Hotel’s approved retention SOP.
8. Data Principal Rights & Grievance
Subject to applicable law and identity verification, individuals may request access to information about processing, correction/update, erasure where applicable, withdrawal of consent, and grievance redressal. The Hotel should verify the requester before disclosing or altering guest records. CYVERNA provides workflow tools but the Hotel remains responsible for deciding and responding to Hotel-controlled requests.
9. Children / Minors
Where personal data of a child is processed, the Hotel must apply the requirements of the DPDP framework and other applicable child-protection rules, including verifiable parental/guardian consent where required. CYVERNA should not be used for behavioural tracking or targeted advertising directed at children. Hotel staff must avoid collecting unnecessary minor data.
10. Breach Handling
The Hotel and CYVERNA must cooperate according to their respective legal roles and the Data Processing Addendum. The Hotel should maintain a breach register, containment plan and communication owner. The DPDP Rules provide for prompt notice to affected Data Principals and notice to the Board, with additional details within 72 hours (or longer if permitted by the Board) when the applicable provisions are in force.
11. International / Cross-Border Processing
Cross-border processing, if used, must comply with restrictions notified by the Government of India and the Hotel’s contracts/policies. The Hotel should identify where each third-party connector or cloud service processes data before enabling it.
12. Contact & Policy Updates
The Hotel should maintain current privacy contact details in CYVERNA Legal & DPDP Centre. CYVERNA may update this Platform Privacy Policy when services or law change. Material updates should carry a new version date and, where appropriate, renewed Customer acceptance.