Draft v0 · updated 20 October 2026

Privacy

There are two distinct responsibilities. We do not mix them up.

Hostly marketing and accounts website

Data controller: Icaro Nutrition SCP, CIF ESJ67511840, Calle Entença 134, unit 1, 08015 Barcelona. Email: info@hostly.org.es.

This includes: visits to hostly.org.es, the cookie notice, and business registration (name, email, billing details). The owner logs into the dashboard using Firebase Auth at https://hostly.org.es/app (locally, http://127.0.0.1:5173). Booking an appointment does not require an account. To view, change or cancel an appointment after closing the chat, the customer provides the email address associated with that booking: either a one-off code from the chat (1B.15), or the buttons in the confirmation email (1B.16). The artificial intelligence does not provide appointment details simply because someone mentions a name.

End-user chats

The business that contracts Hostly is responsible for its customers’ messages on Hostly’s web chat. The ‘WhatsApp’ button opens the business’s WhatsApp; those messages do not pass through Hostly. Icaro Nutrition SCP acts as a data processor. The contract for that role is in the data processing agreement.

What data and for what purpose?

• Visits to hostly.org.es, only if you accept analytics: Google Analytics measures page views, clicks, scroll, language, traffic source, the demo and whether you open the chat on this site. We do not send email, name, phone or message text. Google is outside the EU. If you decline, nothing is sent.
• Business contact details and account: to provide the service and issue invoices.
• Chats and inbox messages: the receptionist and a member of staff should reply.
• If the sender taps ‘Share’, a copy of those messages is created via a link that cannot be guessed. Anyone with the link can read it for 90 days. It is not indexed by search engines. The phone number or email address for a booking is not added unless it was entered in the chat.
• Profile (opening hours, prices, menu): make sure the AI doesn’t make up the venue.
• Booking (if the business turns it on): name, telephone number, email address, consent; a deposit if Stripe is on.
• A one-time code sent to your email (chat) and a signed link in the confirmation email to manage that appointment. SMS to your mobile, pending.
• Files the business uploads (PDFs, photos) for the profile: a private Cloudflare R2 bucket in the EU. If it is not configured, the server disk.
• ChatGPT ad measurement, only if you accept advertising in the cookie notice: account registration, the demo when it is ready and, from the server, the first subscription payment with the amount actually charged and the currency. Public pixel id 3gyYpDNQxtCCZsTqh81YDb. This is not Google Analytics and it does not use your customers’ chat messages. The data goes to OpenAI. If you do not accept, it is not sent.

Order managers and transfers

Product data in the European Union. The AI model v1 is OpenAI (GPT-5.6 Luna). If OpenAI does not respond, Hostly tries the same model via OpenRouter and then Gemini (Google). In those cases, messages and user profiles are processed outside the EU. If the visitor clicks the microphone icon, the audio from that note is sent to ElevenLabs (Scribe) only to turn it into text. If that does not answer, the same note goes to Groq (Whisper) and then to OpenRouter (Whisper). The audio is not stored; the text stays in the chat. ElevenLabs, Groq and OpenRouter are outside the EU. The product already utilises Firebase Auth (dashboard sign-in only; it does not store files), Cloudflare R2 (business-card PDFs, DOCX and photos, private EU bucket; the server disk if it is not configured) and Postgres (knowledge originals), Stripe (if the tenant charges fees) and email sending (booking confirmation and, where applicable, a one-off code). At a later stage, the business will be able to connect to Google Calendar; an encrypted token from their account will then be stored to create or delete appointment events; this is not the end customer’s calendar. If the business connects to Beauty Calendar, Hostly sends the booking details (name, email, telephone number, service and time) to Beauty to create or cancel the appointment there; Beauty is the actual calendar. Hosting: Render, in Frankfurt, in Hostly’s name. This page is a draft; the finalised DPA will be posted upon signing the contract.

Rights

Access, rectification, erasure, objection, restriction and portability: write to info@hostly.org.es (the owner is in the legal notice). You can also complain to the Spanish Data Protection Agency (aepd.es). If the data belongs to an end customer, the business must answer you; we help them.

Conservation

Each night, web and WhatsApp chats with customers are deleted once they are older than the period the business chooses in Settings: 3, 6, 12 or 24 months (12 if none is chosen). If that conversation has a booking, the appointment and the details needed for the invoice stay, and the chat text is cleared. The business can export or delete one conversation from the Inbox. The team assistant deletes, on its own period of the same months, team questions, votes and the technical log; documents are kept.