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Entwurf, nicht anwaltlich geprüft · Draft, not reviewed by a lawyer.

Privacy and security overview

Version
0.1.0
Effective
Status
Draft, not reviewed by a lawyer
Owner
support@freestays.app
Contact
support@freestays.app
Checksum (SHA-256 of the text file)
4aa18f9ea15edbded66345b7b1e9eb435cf08c13930a97af8fcb7271574eb3ee

Status of the platform

freestays is a platform on which travel creators exchange content for a hotel stay. In addition, an expense allowance is agreed, which is paid outside the platform. The platform is pre-launch. There is no production system with real data yet. This page therefore describes what exists in the program code and what is planned. It does not describe live operation.

The operator is SnapNext GmbH & Co. KG. The address and further details are on the page "Provider and contact".

Who processes what

Party Role Data
Operator Controller for accounts, profiles and applications Account and profile data, channels with reach figures, applications, agreements, consents, data requests
Hotel (property) Independently responsible, from receipt of an application, for the data received with it The creator's application, profile and channels, data on the agreement
Creator Data subject Own account, profile and application data
Service providers Support operations, see the page "Subprocessors" Depending on the service

This allocation of roles is the currently assumed position. It will be reviewed legally.

After an application is received, a property sees the creator's full profile and all channels. The property does not receive the creator's email address.

Hosting and regions

Service Purpose Region
Vercel Operation of the website and scheduled calls Function region Frankfurt (fra1); the scope of the region setting is being checked
Supabase Database, file storage, sign-in EU (Ireland); a move to Frankfurt is being considered

Further services are planned and not yet in use. The full list is on the page "Subprocessors".

Measures at a glance

The following measures exist in the program code. They have not been verified in operation, because there is no production system. "Partial" means the measure exists only in part. There is no certification and no independent audit.

Area Measure Status
Access control Row-level access protection for the tables on consents, log and data requests partial, present in code, not verified in operation
Authentication Sign-in through an authentication service with its own user management and an internal identifier present in code, not verified in operation
Authentication Session cookie not readable by script, transmitted only encrypted, with same-site protection present in code, not verified in operation
Authentication Session renewal on the server; the server determines the redirect target after sign-in present in code, not verified in operation
Application security Security headers against embedding, type misinterpretation and data leakage, plus HSTS partial, present in code, not verified in operation
Application security Rate limiting of sign-in partial, present in code, not verified in operation
Access control Protection of the scheduled calls by a secret token present in code, not verified in operation
Application security Time limit for calls to the database and the authentication service present in code, not verified in operation
Encryption Transport encryption (HSTS) in production present in code, not verified in operation
Data subject rights Deletion safety: lock per request, deletion in a single transaction, log with identifiers only partial, present in code, not verified in operation
Access control Check of the file path when a media entry is created: only files in the person's own folder or in a folder of a property of their own organization partial, present in code, not verified in operation

This list shows a selection. It is not a complete description of the security position. Measures that do not yet exist or are not documented are not listed here as present.

What is missing or still pending

  • No independent security test or certification exists, and none is stated here.
  • The provider contracts and the basis for transfers to third countries will be clarified and reviewed legally before launch.
  • Retention periods for agreements and logs have not yet been set in the platform.

Rights and incidents

How data subjects exercise their rights is on the page "Data subject rights". The planned procedure for security incidents is described on the page "Security incidents". Questions about data protection go to support@freestays.app.

All documentsDeutsche Fassung