VERBLIJFMAKERS · DATA PROCESSOR AGREEMENTS
Provisions regarding personal data in customer content
Version dated October 4, 2026. These terms constitute a data processing agreement to the extent that Verblijfmakers processes personal data in Verblijfmakers Content or Guest folder exclusively on behalf of a business customer.
1. Roles and scope
Verblijfmakers is the independent data controller for accounts, payments, security, support and its own statutory record-keeping. For personal data relating to guests, staff or other data subjects that the customer includes in uploads or instructions, and which we use solely to create customer content, the customer is the data controller and Verblijfmakers is the data processor.
2. Assignment and instructions
We process the data solely on the basis of documented instructions from the client for the purposes of planning, generating, designing, delivering and managing content. The processing continues for the duration of the Content Agreement and the download and deletion period. This may include names, images, voice or video recordings, location data, preferences and other data provided by the customer. If we believe an instruction to be unlawful, we will inform the customer before carrying it out, unless prohibited by law.
Guest folder: processing on your behalf
At Guest folder, you are responsible for your guests’ data, and we process this on your behalf for booking management, personalised guest links, pre-registration, communication and data exports. The data subjects are lead bookers and their travelling party. The data includes names, contact and booking details, room, dates of stay, meal preferences, contact messages and the information requested on the relevant country form. Please only use data that is necessary for your services and administration.
A separate deletion procedure applies to this data: temporary pre-registration data is purged as soon as the departure took place more than 30 days ago; archive copies follow the country policy confirmed by the operator and, in the absence of a confirmed policy, are also temporary; Italian official receipts are retained separately for five years from the date of issue; messages are deleted 30 days after departure; meal preferences after check-out; log versions in the private test environment 30 days after creation. Deletion takes place during the next scheduled deletion task. The retention period for Content set out in Article 8 does not apply to this registration data. Verblijfmakers provides encrypted archiving and export, but does not carry out identity checks, require signatures or automatically report to government authorities. The operator determines and confirms the applicable retention policy. A statutory retention period is not automatically shortened upon termination. Download the archive before the subscription expires. Restoring access may require support afterwards. You must export your data in good time and retain your own mandatory records and originals.
Personal data relating to bookings, contact messages and registration details are stored in encrypted form. Archive files are not publicly accessible; access, exports and policy changes are logged. Access to the administration panel is linked to the owner’s account. Data entered is not publicly accessible and does not appear in the general room PDF or hardcover. We will assist you with access, correction, deletion and data breaches in accordance with the sections below. For enquiries, please contact privacy@verblijfmakers.nl.
3. Confidentiality and security
Access is restricted to authorised personnel who are bound by a duty of confidentiality. We implement appropriate measures, including account- and role-based access, encrypted transmission, secure sessions, logging where appropriate, restricted administrative access and recovery measures. The customer is responsible for securing their own accounts, devices and shared exports.
4. Sub-processors
The customer grants general consent for necessary sub-processors. Currently, these are Sites/Cloudflare for hosting, databases and storage, Resend for email, and OpenAI for content support. For Guest folder, DeepL is also used for the translation of guest information and contact messages, the push services provided by Apple, Google or Mozilla for optional mobile notifications, and PrintAPI for the ordered hardcover and delivery details. Personal registration details are not included in the room PDF or hardcover. Mollie processes payment data as an independent data controller and is not a sub-processor for customer content. In the event of a material change, we will inform active customers in advance and provide them with a reasonable opportunity to raise a reasoned objection. We stipulate at least the same data protection obligations with sub-processors.
5. Outside the EEA
If a sub-processor processes data outside the EEA, we ensure that there is a valid legal basis, such as an adequacy decision or EU model contract clauses, and that appropriate additional measures are in place where necessary.
6. Customer support
We assist the client – taking into account the nature of the processing – with requests from data subjects, security, data breach notifications, data protection impact assessments and consultations with a supervisory authority. Any additional work beyond our standard services may be charged at a reasonable rate, subject to prior agreement.
7. Data breaches
We shall report any breach relating to customer content without undue delay once we become aware of it. The report shall include, where available, the nature of the breach, the data and individuals concerned, the likely consequences, the measures taken and a point of contact. As the data controller, the customer shall decide on whether to report the breach to the supervisory authority and the data subjects.
8. Removal and return
After the payment due date, customer content remains available in read-only mode for export for 60 days. We then remove it from active systems; backups expire no later than 30 days thereafter. We will remove data earlier on request, unless retention is required by law. Data for which Verblijfmakers is solely responsible is covered by the privacy statement.
9. Control
Upon reasonable request, we shall make available the information necessary to demonstrate compliance. An audit shall take place no more than once a year, during office hours, with appropriate confidentiality and without undue disruption, unless an incident or a regulatory authority requires more frequent investigations. The client shall bear reasonable external audit costs, except where a material deficiency on the part of Verblijfmakers is identified.
10. Precedence
These terms form part of the Content Agreement. In the event of a dispute regarding the processing of customer content, these data processor terms shall take precedence. The other general terms and conditions remain in force.