# GreetScribe Data Protection Addendum **Effective date:** 2026-05-17 **Version:** 1.0 **Operator:** Qevinto Oy This Data Protection Addendum forms part of the agreement between Qevinto Oy and the Customer for the use of GreetScribe. This Addendum applies when GreetScribe processes personal data in connection with the Customer’s use of the Service. --- ## 1. Parties The service provider is: **Qevinto Oy** Business ID: 3583823-3 Sarkakatu 3 F23 96460 Rovaniemi Finland Contact: contact@qevinto.com The customer is the business customer that orders, accesses, or uses GreetScribe. --- ## 2. Relationship to other documents This Addendum supplements the GreetScribe SaaS Customer Terms. If there is a conflict between this Addendum and the SaaS Customer Terms about personal data processing, this Addendum controls for the conflicting data protection matter. If there is a signed written agreement between Qevinto Oy and the Customer, that agreement controls where it expressly changes this Addendum. The GreetScribe Privacy Policy describes Qevinto Oy’s public privacy practices. The Subprocessor List may identify service providers used to operate GreetScribe. --- ## 3. Definitions In this Addendum: **“Addendum”** means this GreetScribe Data Protection Addendum. **“Applicable Data Protection Laws”** means privacy, data protection, electronic communications, and similar laws that apply to the relevant processing. **“Customer”** means the business customer using or ordering GreetScribe. **“Customer Content”** means content, data, text, images, accommodation information, activity information, policies, provider data, and other materials provided by the Customer or connected through the Customer’s systems. **“Guest”** means an end user, traveller, visitor, hotel guest, or other person interacting with GreetScribe through the Customer’s website, widget, or service channel. **“Personal Data”** means information relating to an identified or identifiable person. **“Service”** means GreetScribe and related hosted features, integrations, support, and customer-facing functionality provided by Qevinto Oy. **“Subprocessor”** means a third-party service provider used by Qevinto Oy to process personal data in connection with GreetScribe. --- ## 4. Scope This Addendum applies to personal data processed through GreetScribe. This may include: - Guest chat and booking-assistance data; - Customer account and admin data; - provider integration metadata; - technical logs and session data; - support and privacy request data; - subscription billing data. This Addendum does not apply to a third-party provider’s independent processing outside GreetScribe. Examples include a hotel’s own booking engine, a payment provider checkout, a provider’s own form, or a Customer-managed system. --- ## 5. Data roles For guest chat and booking-assistance data, Qevinto Oy and the Customer may act as joint controllers. This applies where both parties determine relevant purposes or means of processing in connection with the Customer’s GreetScribe setup. For some processing, Qevinto Oy may act as a processor for the Customer. This may apply where Qevinto Oy processes personal data only on documented Customer instructions. For Qevinto Oy’s own business operations, Qevinto Oy acts independently. Examples include Qevinto Oy account administration, SaaS billing, service security, support handling, and internal business records. The applicable role may depend on the Customer setup, integration design, order, configuration, and written agreement. --- # Part A: Joint Controller Terms ## 6. Joint controller scope Part A applies where Qevinto Oy and the Customer act as joint controllers. This may include Guest chat, booking-assistance flows, recommendation flows, and customer-managed booking guidance through GreetScribe. The parties may agree a different role allocation in writing. --- ## 7. Customer responsibilities under joint controller use The Customer is responsible for: - ensuring that it may use GreetScribe on its website or service channel; - providing appropriate guest-facing privacy information where required; - explaining how Guests can contact the Customer about privacy questions; - ensuring that Customer Content is accurate and lawful; - ensuring that provider data shown to Guests is accurate and lawful; - managing its own booking terms, cancellation terms, payment terms, and guest communications; - managing its own provider accounts and provider integrations; - avoiding intentional collection of sensitive personal data unless agreed in writing; - handling Customer-side privacy requests relating to its own systems; - maintaining the privacy and security of Customer accounts and credentials. The Customer must not configure GreetScribe to request personal data that is unnecessary for the agreed use. The Customer must not configure GreetScribe to mislead Guests. --- ## 8. Qevinto responsibilities under joint controller use Qevinto Oy is responsible for: - operating the GreetScribe platform; - maintaining service-side access controls; - maintaining technical security measures for the Service; - maintaining the GreetScribe Privacy Policy; - handling privacy requests sent to Qevinto Oy; - managing Qevinto-controlled Subprocessors; - supporting Customer requests relating to GreetScribe data where reasonably possible; - applying the agreed retention approach for GreetScribe-controlled records; - maintaining support and error-handling processes for the Service. Qevinto Oy is not responsible for Customer websites, Customer booking engines, Customer payment flows, Customer privacy notices, or Customer-managed provider systems. --- ## 9. Guest requests under joint controller use If either party receives a Guest privacy request relating to GreetScribe, that party should assess the request and notify the other party where cooperation is needed. The parties will cooperate in good faith to answer requests relating to GreetScribe data. The Customer remains responsible for requests relating to the Customer’s own website, booking terms, payment flow, provider account, or non-GreetScribe systems. Qevinto Oy remains responsible for requests relating to Qevinto-controlled systems and records. Neither party must delete, alter, or disclose data in a way that would breach law, security duties, accounting duties, dispute requirements, or other valid retention needs. --- ## 10. Guest-facing information The Customer should provide or link appropriate privacy information on the Customer’s website or booking channel. Qevinto Oy may provide the GreetScribe Privacy Policy and related public legal pages. The Customer is responsible for ensuring that its own guest-facing disclosures match the Customer’s actual use of GreetScribe. If the Customer uses analytics, marketing pixels, or cookies on its own website, the Customer is responsible for its own cookie notice and consent process. --- ## 11. Joint controller cooperation The parties will cooperate reasonably on: - privacy requests; - security incidents involving GreetScribe; - correction or deletion requests; - Customer Content corrections; - provider integration corrections; - data export requests where technically available; - Subprocessor or integration questions; - regulator or authority communications relating to GreetScribe. Each party will bear its own costs unless the parties agree otherwise or the issue was caused by the other party’s breach. --- # Part B: Processor Terms ## 12. Processor scope Part B applies where Qevinto Oy processes personal data as a processor for the Customer. This may apply where the Customer gives documented instructions and Qevinto Oy processes personal data only to provide the Service. If the parties agree in writing that Qevinto Oy is not a processor for a specific processing activity, Part B does not apply to that activity. --- ## 13. Customer instructions The Customer instructs Qevinto Oy to process personal data as needed to: - provide GreetScribe; - configure the Customer account; - operate Guest chat and booking-assistance flows; - support provider integrations; - provide support; - maintain security; - troubleshoot errors; - process subscription billing; - comply with the agreement. Qevinto Oy may refuse an instruction if it reasonably believes the instruction is unlawful, unsafe, technically unreasonable, or outside the Service. --- ## 14. Customer obligations under processor use The Customer is responsible for: - determining whether its instructions are lawful; - providing required privacy notices; - obtaining required permissions or consents; - ensuring that personal data submitted to GreetScribe is lawful; - ensuring that Customer Content is accurate; - ensuring that provider integrations are authorized; - managing Guest relationship duties outside GreetScribe; - handling Customer-side data protection obligations; - avoiding unnecessary personal data collection. The Customer must not instruct Qevinto Oy to process sensitive personal data unless Qevinto Oy has agreed to that processing in writing. --- ## 15. Qevinto processing limits Qevinto Oy will process Customer personal data only as needed to provide, secure, maintain, support, improve, and administer GreetScribe. Qevinto Oy may also process data where needed to comply with law, protect security, prevent abuse, handle disputes, or enforce agreements. Qevinto Oy will not sell Guest personal data. Qevinto Oy will not use Guest chat data to accept or reject bookings or payments through an LLM. --- ## 16. Personnel confidentiality Qevinto Oy will limit access to personal data to personnel and service providers who need access for the Service. Qevinto Oy will require personnel with access to personal data to protect confidential information. --- ## 17. Security measures Qevinto Oy will maintain technical and organizational measures intended to protect personal data processed through GreetScribe. Current measures may include: - TLS/HTTPS; - Supabase Auth; - access controls; - admin roles; - 2FA; - FIDO/passkeys; - server-side service-role key handling; - no service-role secrets in frontend code; - tenant/domain validation; - signed widget/session tokens; - rate limiting; - backups; - controlled provider integrations. Security measures may change as the Service develops. Qevinto Oy may replace a measure with another measure that provides a comparable or better protection level. --- ## 18. Subprocessors The Customer authorizes Qevinto Oy to use Subprocessors to provide GreetScribe. Qevinto Oy may maintain a separate Subprocessor List. Qevinto Oy may add, replace, or remove Subprocessors where needed to operate the Service. Qevinto Oy will use reasonable efforts to ensure that Subprocessors process personal data only for the relevant service purposes. Customer-controlled integrations may not be Qevinto-controlled Subprocessors. Examples include a Customer’s own Bokun, Hostaway, Hospitable, Stripe, booking engine, payment provider, PMS, CRM, or booking platform account. --- ## 19. Current service providers The Service may use the following providers or provider categories. | Provider | Function | Notes | |---|---|---| | UpCloud | Application and website hosting | Finland | | Supabase | Database and related backend services | Sweden | | OpenAI | Chat assistance and recommendations | EU or global depending on customer configuration | | Stripe | Qevinto subscription billing | Used for GreetScribe SaaS billing | | Google/Gmail | Company email and privacy requests | Provider region may vary | | Hostinger | Domain hosting | Provider region may vary | | Make.com | Technical error alert automation | Used for technical alerts | | WhatsApp / Meta | Technical error alerts | Used for error notifications | | Google Analytics | Analytics | Subject to cookie and consent configuration | | Meta Pixel | Marketing measurement | Subject to cookie and consent configuration | | TikTok Pixel | Marketing measurement | Subject to cookie and consent configuration | | LinkedIn Insight Tag | Marketing measurement | Subject to cookie and consent configuration | | Bokun | Customer-controlled activity/provider integration | Enabled where Customer uses it | | Hostaway | Customer-controlled accommodation/provider integration | Enabled where Customer uses it | | Hospitable | Customer-controlled accommodation/provider integration | Enabled where Customer uses it | A separate Subprocessor List may replace or supplement this table. --- ## 20. International processing GreetScribe’s primary application hosting is in Finland through UpCloud. GreetScribe’s database hosting is in Sweden through Supabase. Some service providers may process personal data outside Finland or outside the EU/EEA. This may depend on Customer configuration, vendor settings, provider infrastructure, contractual terms, and selected integrations. The Customer acknowledges that international processing may occur when using global providers, analytics tools, marketing tools, LLM providers, payment providers, email providers, or customer-selected provider integrations. --- ## 21. Assistance Where Qevinto Oy acts as processor, Qevinto Oy will provide reasonable assistance to the Customer for: - privacy requests; - correction or deletion requests; - security incident assessment; - service-related data exports where technically available; - information about Subprocessors; - information about relevant security measures; - Customer audits or reviews conducted through written information. Qevinto Oy may charge reasonable fees for assistance outside the standard Service or outside normal support. --- ## 22. Security incidents Each party must notify the other party without undue delay after becoming aware of a confirmed or suspected security incident involving personal data processed through GreetScribe. The notice should include available information that reasonably helps the other party assess the issue. The parties will cooperate reasonably to investigate, contain, mitigate, and document the incident. Qevinto Oy may delay or limit details where disclosure would create security risk, breach law, or harm an investigation. --- ## 23. Audit and information rights Qevinto Oy may satisfy Customer audit requests by providing written information about relevant security, privacy, Subprocessor, and processing practices. On-site audits require prior written agreement. Audits must not compromise security, confidentiality, other customers’ data, provider systems, or Qevinto Oy operations. The Customer must bear its own audit costs. Qevinto Oy may charge reasonable costs for extensive audit support. --- ## 24. Return and deletion At the end of the Service, Qevinto Oy may delete, return, anonymize, or retain personal data according to the agreement, Privacy Policy, retention schedule, backup process, legal requirements, accounting needs, security needs, and dispute needs. Backups may remain for a limited period before deletion under normal backup rotation. Qevinto Oy is not required to delete data that it must retain for legal, accounting, security, dispute, or legitimate operational reasons. --- # Schedule 1: Processing Details ## 25. Subject matter The subject matter is the provision of GreetScribe to the Customer. GreetScribe provides chatbot, guest-assistance, booking-guidance, provider-integration, AI-assisted recommendation, support, and related SaaS functionality. --- ## 26. Duration The processing continues during the Customer’s active subscription. Certain data may be retained after termination according to the retention section of this Addendum, the Privacy Policy, the SaaS Customer Terms, and legal or operational needs. --- ## 27. Processing purposes Processing purposes may include: - providing the chatbot; - answering Guest questions; - collecting booking-related details; - showing accommodation and activity options; - providing recommendations; - supporting customer/provider API integrations; - operating admin and Customer accounts; - providing subscription billing; - sending technical error alerts; - maintaining security; - preventing abuse; - troubleshooting errors; - using analytics and marketing tools where enabled; - handling privacy and support requests. --- ## 28. Data subjects Data subjects may include: - Guests; - Customer staff; - Customer admin users; - Customer contacts; - support requesters; - business representatives; - website visitors where relevant. --- ## 29. Categories of personal data GreetScribe may process: - Guest name; - Guest email address; - booking dates; - number of adults; - number of children; - selected accommodation; - selected activities; - chat messages; - chat transcripts; - booking and session data; - admin account data; - Customer account data; - provider integration metadata; - provider/API secrets; - subscription billing data; - privacy and support request emails; - cookies; - sessionStorage; - localStorage; - session identifiers; - technical logs; - security-related request data; - IP addresses where needed for security, abuse prevention, rate limiting, or server operation. GreetScribe does not intentionally collect Guest phone numbers, Guest addresses, Guest payment card data, or precise GPS location. --- ## 30. Sensitive data GreetScribe does not intentionally request sensitive personal data. Users may technically enter sensitive information into free-text chat. The Customer must not configure GreetScribe to request sensitive data unless Qevinto Oy agrees in writing. --- ## 31. Children-related information GreetScribe is not directed to children. GreetScribe may collect the number of children only for accommodation occupancy or booking-capacity purposes. GreetScribe does not intentionally collect child names, child contact details, or child dates of birth. Third-party provider systems may request their own information outside GreetScribe. --- ## 32. Retention Unless another period is agreed or required, Qevinto Oy currently applies a 24-month retention period to retained GreetScribe data categories. This may include: - chat transcripts; - technical logs; - session and booking-flow data; - admin/customer account data; - provider integration metadata; - provider/API secrets; - backups; - privacy/support request emails; - Stripe/SaaS billing records. Some data may be deleted earlier when no longer needed. Some data may be retained longer where needed for legal, accounting, security, dispute, backup, or compliance reasons. --- # Schedule 2: Customer-Controlled Integrations ## 33. Customer-controlled systems Customer-controlled integrations may include: - Bokun; - Hostaway; - Hospitable; - Stripe; - booking engines; - payment providers; - PMS systems; - CRM systems; - customer-owned booking platforms; - customer websites; - other external APIs selected by the Customer. The Customer is responsible for its own provider accounts and provider contracts. The Customer is responsible for ensuring that it may connect those systems to GreetScribe. The Customer is responsible for data processed inside those systems outside GreetScribe. --- ## 34. Provider payments Guest booking payments are handled by the Customer, booking provider, payment provider, or third-party booking system. Qevinto Oy does not receive hotel Guest booking payments unless separately agreed in writing. Guest booking payments are separate from GreetScribe SaaS subscription billing. --- # Schedule 3: AI and LLM Processing ## 35. AI use GreetScribe may use OpenAI or another LLM provider for chat assistance and recommendations. OpenAI may receive Guest chat messages. OpenAI is not intended to receive full chat transcripts. OpenAI is not intended to receive Guest names, Guest emails, or Guest phone numbers. OpenAI processing may use EU or global processing depending on Customer configuration and service settings. Enterprise customers may use alternative or self-hosted LLM arrangements where separately configured. --- ## 36. AI boundaries AI or LLM features may assist with answers or recommendations. AI or LLM features do not accept or reject bookings. AI or LLM features do not accept or reject payments. The Customer must review AI-assisted outputs before relying on them for business decisions. The Customer must not use AI outputs as legal, tax, financial, medical, emergency, or safety advice. --- # Schedule 4: Final Provisions ## 37. Updates Qevinto Oy may update this Addendum when the Service, law, providers, integrations, or processing practices change. Where a signed agreement applies, updates are handled according to that agreement. --- ## 38. Survival Sections that by their nature should continue after termination will continue. This includes confidentiality, security, deletion, retained data, liability allocation, provider responsibilities, and cooperation duties. --- ## 39. Contact Questions about this Addendum may be sent to: **Qevinto Oy** Sarkakatu 3 F23 96460 Rovaniemi Finland contact@qevinto.com