Is UpsellGuru GDPR
compliant?
Yes, UpsellGuru is GDPR compliant. UpsellGuru is a data
processor for hotel companies and hotel companies are the data controllers who control
the transfer to UpsellGuru for processing. UpsellGuru processes guests’ personal
data as defined by GDPR.
Can UpsellGuru send
offer emails directly to guests without consent?
Yes. The hotel has the authority to contact the customer
under ‘soft opt-in’ principles, which means that UpsellGuru emails as viewed as
transactional and not marketing emails. UpsellGuru is simply acting as an agent
of the hotel by sending these transactional emails.
What does “Transactional
email” & “Legitimate interest” mean?
The guest email was obtained from a reservation with the
hotel company, the email relates to similar products and services, and the
guest is an existing customer. An email to a guest to personalize their
experience during their stay is considered as part of the hotel stay and falls
under “Legitimate interest” which can be sent without consent.
Is there an GDPR Data
Processing Addendum?
Yes, if you have not signed our GDPR Data Processing
Addendum yet, please contact your account manager to request one.
Is there anything else
the hotel company must do?
We would suggest updating your Privacy Policy on your
website and make sure it informs your users how you process their personal data
and for which purposes.
Suggestion:
We may share your personal data with third parties offering
services to us. These third-party companies act as a data processor of your
personal data on behalf of us:
UpsellGuru GmbH: We may use their services to email you specific
services and upgrades that relate to your stay with us.
We require all third party service providers to respect the
security of your personal data, to treat it in accordance with the law and to
process your personal data only in accordance with our instructions.
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