Peraxion is operated by PERAPOLE YAZILIM VE BİLİŞİM TEKNİK SAN. TİC. A.Ş., established at Philipp-Reis-Straße 10, 63128 Dietzenbach, Germany (“Peraxion”, “we”, “us”). We act as the data controller for the personal data described below, processed in accordance with Regulation (EU) 2016/679 (“GDPR”) and the Turkish Law on the Protection of Personal Data No. 6698 (“KVKK”). For KVKK-specific disclosures, please also read our Information Notice.
1. Who this policy applies to
Peraxion serves two groups of people, and we process their data differently:
- Hotel guests — people who scan a hotel’s QR code and chat with the hotel’s AI assistant, without creating an account.
- Hotel staff and administrators — people who hold an account to manage a hotel’s assistant, content and requests through the web panel.
2. Data we collect
2.1 From hotel guests
- Chat content — the messages you send to the assistant and the responses generated, including any information you choose to include.
- Service and technical data — the hotel/QR code scanned, approximate session information, device and browser type, IP address, language preference, and timestamps.
2.2 From hotel staff and administrators
- Account data — name, work email address, hashed password, role and the hotel you belong to.
- Content you provide— documents, Q&A, quick questions and other material you upload to train and configure the assistant.
- Usage and log data — actions taken in the panel, requests handled, IP address, device data and audit timestamps.
3. Why we process data (purposes & legal bases)
| Purpose | Legal basis (GDPR / KVKK) |
|---|---|
| Providing the assistant and answering guest questions | Performance of a contract; legitimate interests |
| Creating and securing staff accounts and the panel | Performance of a contract |
| Training and improving assistant quality | Legitimate interests; explicit consent where required |
| Security, fraud prevention and abuse detection | Legitimate interests; legal obligation |
| Billing, invoicing and subscription management | Performance of a contract; legal obligation |
| Sending service and, where permitted, marketing messages | Consent; legitimate interests |
4. AI processing
The assistant relies on third-party large language model providers (for example OpenAI) to generate responses. Messages needed to produce an answer are sent to these providers under contractual terms that restrict their use of the data. Please avoid sharing sensitive personal data (health, financial details, ID numbers) in the chat unless it is necessary for your request.
5. Sharing and sub-processors
We share personal data only with:
- Service providers (sub-processors) — cloud hosting, AI/LLM providers, email delivery, push notifications, search and analytics providers that process data on our behalf under written agreements.
- The relevant hotel — guest conversations are made available to the hotel whose assistant you used, so staff can follow up on your requests.
- Authorities — where required by law or to protect rights, safety and the integrity of the Service.
We do not sell personal data.
6. International transfers
Some sub-processors may process data outside Turkey or the European Economic Area. Where this happens, we rely on appropriate safeguards such as adequacy decisions, Standard Contractual Clauses, or your explicit consent, as required by the GDPR and KVKK.
7. Retention
We keep personal data only as long as necessary for the purposes above and for the periods required by law. Guest chat data is retained for the operational period set by the hotel and platform limits; quality/analytics logs are retained for a limited window (e.g. up to 30 days) and then deleted or anonymised; account and billing records are kept for the statutory period after the account is closed.
8. Your rights
Subject to the GDPR and KVKK, you may request to access, rectify, erase or restrict your data, object to processing, receive your data in a portable format, and withdraw consent at any time. Guests should note that requests about conversation content may also involve the relevant hotel as a joint or independent controller.
To exercise these rights, contact us at info@peraxion.com. You also have the right to lodge a complaint with a supervisory authority (in Turkey, the Personal Data Protection Authority — “KVKK Kurumu”).
9. Security
We apply technical and organisational measures appropriate to the risk, including encryption in transit, hashed passwords, role-based access control and audit logging. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. Children
The Service is not directed to children under the age required by applicable law. We do not knowingly collect their personal data; if you believe a child has provided data, contact us so we can delete it.
11. Changes
We may update this policy from time to time. Material changes will be reflected by updating the “Last updated” date above and, where appropriate, by additional notice.
12. Contact
PERAPOLE YAZILIM VE BİLİŞİM TEKNİK SAN. TİC. A.Ş.
Philipp-Reis-Straße 10, 63128 Dietzenbach, Germany
Email: info@peraxion.com
Website: peraxion.com
