Privacy Policy

1. Who We Are

This Privacy Policy explains how CharlieCookLive Ltd (“we”, “us”), trading as Concierge 24, handles personal data. We are registered in Ireland (company number 813096), with registered office in Kilkenny, Ireland. Contact: hello@concierge24.ie.

2. Scope

This policy covers personal data we process when (a) hotel staff and business contacts use our website or admin dashboard, and (b) hotel guests use the Concierge 24 chatbot at participating properties.

3. Data We Collect About Hotel Customers

• Contact details (name, email, phone, business address) provided by you or your colleagues during onboarding.
• Account credentials (email and password hash for the staff portal).
• Billing information processed by Stripe (we do not store full card numbers).
• Content you upload to the knowledge base.

4. Data We Collect About Hotel Guests Using the Chatbot

• The text of messages sent by the guest and the AI's reply.
• A randomly generated session identifier.
• IP address and browser user agent (used for rate limiting and abuse prevention).
• Room number and request description, only if the hotel has enabled the optional Guest Requests feature.

We do not ask guests for their name, email address, or payment details. Guests should not enter sensitive personal information into the chatbot. Hotels are required by our Terms of Service not to use the chatbot to collect sensitive personal data.

5. Legal Basis for Processing

• Contract: to provide the service to hotel customers.
• Legitimate interests: to operate, secure, and improve the service, including rate limiting and fraud prevention.
• Consent: where the law requires it (for example, optional analytics cookies, if added in future).
• Legal obligation: to comply with tax and accounting law.

6. How Long We Keep Data

• Hotel customer accounts and knowledge base content: kept for the life of the account, deleted within 30 days of account closure.
• Guest chat messages, IP addresses, user agents, and guest request logs: automatically deleted after 90 days.
• Billing records: kept for 7 years to comply with Irish tax law.

7. Who We Share Data With

We share data only with service providers who help us operate Concierge 24:

• OpenAI (Ireland) Ltd: chatbot responses are generated using OpenAI models. Guest message text is sent to OpenAI for processing. OpenAI does not retain this data for model training under our API agreement.
• Supabase Inc: hosts our database and file storage.
• Vercel Inc: hosts the website and serves the application.
• Stripe Payments Europe Ltd: processes subscription payments.
• Resend Inc: sends notification emails.

We do not sell personal data to anyone.

8. International Transfers

Some of our service providers process data outside the European Economic Area. Where this happens, we rely on Standard Contractual Clauses approved by the European Commission to protect the data.

9. Your Rights Under GDPR

You have the right to: access the personal data we hold about you, correct inaccurate data, request deletion, restrict processing, port your data to another provider, and object to processing based on legitimate interests. To exercise any of these rights, email hello@concierge24.ie. We will respond within 30 days.

10. Cookies

Concierge 24 currently does not use tracking cookies or third-party analytics. The chatbot uses a session identifier stored in memory only (not in a persistent cookie) for the duration of a guest's chat session.

11. Security

We use industry-standard measures to protect personal data, including HTTPS encryption, password hashing, and access controls. No system is perfectly secure. We will notify affected parties and the Data Protection Commission of any qualifying breach in line with our legal obligations.

12. Complaints

If you are unhappy with how we handle your personal data, please contact us first at hello@concierge24.ie. You also have the right to lodge a complaint with the Irish Data Protection Commission at dataprotection.ie.

13. Changes to This Policy

We may update this policy from time to time. The “Last updated” date at the top will reflect the most recent change. Material changes will be notified to hotel customers by email.