Keystay
DRAFT: skeleton pending legal review. Structure per compliance checklist; final wording requires a lawyer before first sale.

Privacy Policy

Last updated: [DATE]. Data controller: [LEGAL NAME, ADDRESS, EMAIL].

1. Whose data we process

Hosts (our customers): the content you put in your guidebook, your contact details shown to guests, your order and activation records, and support emails.

Guests: we collect no guest data. Guest pages set no analytics, no tracking scripts, and no forms. The only cookie is an optional, functional PIN cookie on PIN-protected guidebooks, used solely to remember that the correct PIN was entered.

2. What we process and why

Guidebook content (contract performance), activation and claim records (fraud prevention and contract performance), the email you optionally leave in the free wifi tool (consent, revocable), support correspondence (legitimate interest).

3. Processors

Cloudflare (hosting, storage, AI processing), Lemon Squeezy (checkout, Merchant of Record), Etsy (marketplace orders). Each under their own DPA.

4. Retention

Guidebook data: 5 years from purchase plus a grace period, then deletion. Activation and claim logs: as long as needed for fraud prevention and legal obligations. Leads: until you unsubscribe.

5. Your rights (GDPR)

Access, rectification, erasure, restriction, portability, objection. Write to [EMAIL]. You can complain to your supervisory authority (in Italy: Garante per la protezione dei dati personali).

6. Transfers

Processors may process data outside the EU under appropriate safeguards (SCCs, adequacy decisions). [VERIFY PER PROCESSOR]