Data Processing Agreement
Short summary. The full text is being prepared with counsel and will replace this page before the activation flow ships. This stub reflects the behaviour the system actually implements.
Version 1.0-2026-10
What FeelPass does
FeelPass is a guest registration and arrival identification service for hospitality properties. The product coordinates a single in-person or live-video arrival check at the property, and coordinates reporting on a separate duty. Identification is not the same as reporting.
What we process
- Identity fields the guest enters on their own device before arrival.
- Metadata about the check itself — method, timestamps, duration, participants.
- The Alloggiati Web reporting receipt, kept for five years.
What we do not do
- We do not record video, audio, or frames of the arrival check.
- We do not make automated biometric decisions. A human reviewer with multi-factor authentication confirms identity.
- We do not place names, document numbers, or booking references in URLs.
Retention
Identification data is deleted when the reporting duty is accepted. A watchdog enforces the maximum retention window for abandoned flows and alerts when overdue. Only the Alloggiati receipt is kept for the five-year audit window.
Tenant isolation
Data is scoped to your organization. API keys are hashed at rest, scoped by environment and permission, and revocable. Cross-tenant access is blocked at the application layer.
Acceptance
By activating a FeelPass account, the customer agrees to this agreement. The acceptance timestamp and the DPA version are stored alongside the organization record for the audit trail.