1. Data controller
In its capacity as data controller under the KVKK, personal data is processed by PERAPOLE YAZILIM VE BİLİŞİM TEKNİK SAN. TİC. A.Ş. (“Peraxion”), established at Philipp-Reis-Straße 10, 63128 Dietzenbach, Germany. Where a hotel determines the purposes and means of processing its guests’ data, that hotel acts as data controller and Peraxion may act as data processor on its behalf.
2. Personal data processed
- Identity & contact — name, work email, phone (staff accounts).
- Transaction & usage — chat messages, requests, panel activity, subscription and billing records.
- Technical — IP address, device/browser data, log records, cookies and similar identifiers.
3. Purposes of processing
- delivering the hotel-assistant service and responding to guest requests;
- creating and securing accounts and managing access;
- training and improving the quality of the assistant;
- fulfilling billing, invoicing and financial obligations;
- ensuring information security and preventing abuse;
- meeting legal obligations and responding to authorities.
4. Legal grounds (Articles 5 & 6 KVKK)
- the processing is necessary for the performance of a contract;
- compliance with a legal obligation to which we are subject;
- it is necessary for our legitimate interests, provided your fundamental rights are not overridden;
- your explicit consent, where none of the above applies.
5. Recipients and transfers
Personal data may be shared, to the extent necessary and in line with Articles 8 and 9 of the KVKK, with: the relevant hotel; our authorised service providers and sub-processors (cloud hosting, AI/LLM, email, push notification, search and analytics providers); and competent public authorities where legally required. Some providers may be located abroad; transfers are made under the safeguards permitted by the KVKK, including your explicit consent where required.
6. Method of collection
Personal data is collected by electronic means through the website, mobile applications, QR-code chat sessions, the staff panel, and related systems and integrations.
7. Your rights (Article 11 KVKK)
Under Article 11 of the KVKK, you have the right to:
- learn whether your data is processed and request information about it;
- learn the purpose of processing and whether it is used accordingly;
- know the third parties to whom data is transferred at home or abroad;
- request correction of incomplete or inaccurate data;
- request erasure or destruction of data where the grounds for processing no longer exist;
- request that corrections/erasures be notified to third parties to whom data was transferred;
- object to results arising solely from automated analysis of your data;
- claim compensation for damage arising from unlawful processing.
8. How to apply
You may submit your requests in writing or by the methods permitted by the KVKK and secondary legislation to Philipp-Reis-Straße 10, 63128 Dietzenbach, Germany or by email to info@peraxion.com. We will conclude your request within thirty (30) days at the latest, free of charge unless it entails an additional cost, in which case the tariff set by the Personal Data Protection Board may apply.
