1. Who we are

Xplai service, Vilnius, Lithuania. Legal entity details will be provided after the company is registered. [Draft, to be reviewed by a lawyer]

For the data of website visitors and our clients, we are the data controller (we decide why and how to process it). For guest data that passes through Xplai, the controller is the hotel, and we process the data on its behalf.

2. What data we collect

Website visitors: name, business name, WhatsApp number and other details you enter in the request form, as well as technical data about the site visit.

Clients: staff contacts, billing details, account settings.

Hotel guests: name, room number, dates of stay, messages and call recordings with the hotel, preferences the guest shares themselves.

3. Why we use data

To contact you, provide services under the contract, issue invoices, protect the service and comply with the law.

Guest data is used only to reply to guests and for the work of this hotel's staff. Guest conversations are not used to train general AI models.

4. Legal bases

We process data on the basis of a contract, legitimate interest, consent or a legal obligation, under Article 6 of the GDPR (EU General Data Protection Regulation). [Draft, to be reviewed by a lawyer]

5. Who we share data with

To contractors who help provide the service: hosting (servers), phone line operators, messengers (for example, Meta for WhatsApp), the AI model provider. A data processing agreement is in place with each. We will send the list of contractors on request.

We don't sell personal data.

6. Where data is stored

Data is stored on servers in the European Union. Transfers outside the EU are possible if required by the communication channel chosen by the hotel. In that case, the EU Standard Contractual Clauses apply.

7. How long we keep data

Website inquiries: 12 months. Customer data: while the contract is in force and 5 years after (for accounting). Guest data: the hotel sets the period in settings, by default 12 months after check-out. [Draft, to be reviewed by a lawyer]

8. Your rights

You can request access to your data, rectification, erasure, restriction of processing, data portability, and object to processing. Hotel guests should contact the hotel first.

You have the right to lodge a complaint with the data protection authority in your country. In Lithuania, this is the State Data Protection Inspectorate.

9. Cookies

This site uses necessary cookies (small files in your browser) to work and, with your consent, cookies for visit statistics.

10. Policy changes

We may update this policy. The new version is published on this page with the date of the change.

11. Contacts

Data questions: hello@xplai.eu. Phone and WhatsApp: +370 630 67364. Email: hello@xplai.eu.