Ativya·Terms·Privacy·Refunds·Data processing

Privacy policy

Effective [Effective date]

Draft. Not yet complete: OPERATOR_NAME, OPERATOR_ADDRESS, OPERATOR_EMAIL, OPERATOR_GRIEVANCE, OPERATOR_JURISDICTION, LEGAL_EFFECTIVE_DATE are still to be set by the operator. This text has not yet been reviewed by the operator’s lawyer, and no hotel other than the operator’s own should rely on it until it has.

This policy explains what personal data passes through Ativya, whose it is, why it is processed and for how long. It is written for three readers: the hotels that use the service, the people who work at them, and the guests whose stays are managed on it. It is governed by the Digital Personal Data Protection Act, 2023 and the rules under it.

1. Who is responsible for what

  • The hotel is the data fiduciary for its guests and its staff. It decides what to collect and why, and it is the hotel you deal with about your data as a guest or an employee.
  • [Operator’s legal name] is a data processor for the hotel: we process guest and staff data only on the hotel’s instructions, to provide the service, under the Data Processing Agreement that forms part of our terms with every hotel.
  • We are the data fiduciary only for the hotel’s own account with us — the administrator’s name and email, billing details, support correspondence.

2. What is processed, and why

Guests. Name, contact details, nationality and — where the hotel collects it — an identity document, for the stay itself and for the hotel’s legal duties (the Foreigners’ Registration Form C for foreign nationals; tax invoices). Bookings, bills, requests made during the stay, and messages exchanged with the hotel on WhatsApp if the hotel has connected it. Photographs of identity documents submitted through online check-in are deleted thirty days after the check-in link closes.

Staff. Name, work email, role, hours worked, leave and — for payroll — pay, bank details and statutory identifiers, held for the hotel’s employment and statutory obligations. Every action a person takes in the system is recorded against their account, which is the audit trail the hotel’s books depend on. Where the hotel has staff check themselves in, the times they check in and out are kept, and — if the hotel has set its location — the phone’s position at the moment of pressing, to confirm they were on the premises. The position is read only then, never in the background.

Payments. Online payments are taken inside Razorpay’s own payment page. Card numbers and UPI handles never reach this service; we receive only the payment’s reference, amount and status.

AI assistance, if the hotel switches it on with its own provider key: the questions guests type into the help screen and summaries of the hotel’s own figures are sent to the provider the hotel chose. Guest names, room numbers, identity documents and card details are never sent; people, companies and functions are anonymised before anything leaves the system. There is one exception, which is off unless the hotel turns it on: Read guest ID photos sends a photo of a guest’s ID to the provider to fill in the registration, and the photo is not kept. Aadhaar’s QR code is read on the hotel’s own device and is not sent anywhere, and only the last four digits of an Aadhaar number are stored. The hotel’s choice of provider is shown on its AI settings screen.

3. Where it is kept, and who else touches it

  • The database and backups are hosted by Supabase (on Amazon Web Services) and the application by Vercel. [Confirm region(s) before launch.]
  • Email is sent through the mail service the hotel or operator configures (for example Google Workspace). WhatsApp messages go through Meta’s WhatsApp Business Platform under the hotel’s own account.
  • Online payments: Razorpay. AI assistance: the provider the hotel selects. Each of these is a sub-processor acting on the hotel’s instructions; a current list is kept at the end of the Data Processing Agreement.
  • We do not sell personal data, and we do not use a hotel’s data to train anything.

4. How long

  • Operational records (bookings, bills, the books) for as long as the hotel keeps its account, and thirty days after it closes, after which they are deleted from the live database and fall out of backups on their cycle. Indian tax law requires a business to keep certain records for years; that duty is the hotel’s and it meets it with the export it can take at any time.
  • Identity-document photographs from online check-in: thirty days after the link closes.
  • The text of WhatsApp messages: one year, after which only the fact of the message is kept. Pictures, files and voice notes sent on WhatsApp: thirty days. A hotel may send an automatic greeting or an out-of-hours reply to a message; nothing in a conversation is read by an AI unless a member of staff asks for a draft reply.
  • The exact position of a staff check-in: ninety days, after which only its distance from the hotel is kept.
  • Server error records: thirty days. Sign-in codes: ten minutes.

5. Security

  • Every connection is encrypted in transit. Passwords are stored as salted hashes; API keys and tokens the hotel supplies are stored encrypted with a key held only on the server.
  • Each hotel’s data is isolated from every other hotel’s at the database layer, and that isolation is tested automatically before every release.
  • Access inside the hotel is by role; nobody sees a screen their role cannot open, and payroll and the books reach only those entitled to them.
  • Backups are taken regularly and the restore of a backup is tested, not assumed.
  • If we become aware of a breach affecting a hotel’s data we will tell the hotel without undue delay, and in any case within seventy-two hours, with what we know and what we are doing.

6. Your rights

As a guest or an employee, your rights under the Act — to know what is held about you, to have it corrected or erased, to withdraw consent where processing rests on it, and to a grievance process — are exercised with the hotel, which decides about your data. The hotel can see, correct and delete your record in the system. If you contact us instead, we will pass your request to the hotel and help it respond.

As a hotel administrator, you can export the whole of the hotel’s data from Settings at any time and close the account from the same place.

7. Cookies

One cookie, to keep you signed in. It is set only after you sign in, carries no tracking, and goes when you sign out or the session ends. A guest using the hotel’s pages from a QR code gets a similar short-lived cookie that remembers which stay they confirmed. There is no advertising or analytics tracking on the site.

8. Children

Guest records may include children travelling with their family, entered by the hotel for the stay. The service is not offered to children directly and no account can be created by one.

9. Changes

We will show changes to this policy here, with the date at the top, and tell the hotel’s administrators about anything material before it takes effect.

10. Contact and grievances

[Operator’s legal name], [Registered address]. Email [contact email]. Grievance officer: [Grievance officer’s name and email]. We acknowledge a grievance within seven days and resolve or answer it within thirty.

[Operator’s legal name] · [Registered address] · [contact email]