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Privacy Policy

How Simple Guests collects, uses and protects personal data — for the businesses that use it and for their guests.

Last updated 25 September 2026·Operated by SMN Properties OÜ, Estonia

Terms of ServicePrivacy PolicyData Processing Agreement

Contents

  1. 1. Who is responsible for your data
  2. 2. Data we collect
  3. 3. How we use data
  4. 4. Optional face check (biometric data)
  5. 5. Storage, security and international transfers
  6. 6. Retention
  7. 7. Sub-processors
  8. 8. Your rights
  9. 9. Changes to this policy

Simple Guests (simpleguests.com) is a guest registration and police-compliance platform operated by SMN Properties OÜ, a company registered in Estonia ("we", "us"). This policy explains how we process personal data when accommodation providers in the European Union and their guests use Simple Guests.

1. Who is responsible for your data#

  • Staff users (the accommodation provider's team) — we are the controller for account, billing and support data.
  • Guests — the accommodation provider you are staying with is the controller of your registration data (ID details, document images, signature and, where the property uses it, the optional face check). We process it on their instructions to run check-in and submit the records the law requires, under our Data Processing Agreement. Questions about how a property uses your data should go to that property first.

2. Data we collect#

  • Account data: name, work email, role, organisation name, billing selections, Stripe customer references.
  • Guest check-in data: identity fields from document reading (MRZ/OCR) or manual entry, document images, signature, booking metadata and timestamps — as required by the property's jurisdiction.
  • Optional face check: only where the property has switched it on and the guest agrees — a selfie taken with the in-page camera and, for ID cards, a photo of the front of the card. See section 4.
  • Technical data: logs (request IDs, errors), IP address (for security and to limit abuse of public check-in links), email delivery events.

3. How we use data#

To provide the service, calculate usage billing, send transactional messages (check-in links, verification and login emails, payment confirmations), submit data to the authorities the property configures, keep the service secure, and improve its reliability. We do not sell personal data, and we do not use guest data for advertising.

4. Optional face check (biometric data)#

A property can choose to offer a face check at check-in. It is off by default and optional for every guest: guests can always skip it and show their ID at reception instead, and registration completes either way. Comparing a selfie with an ID photo is processing of biometric data (a special category under GDPR Article 9), so it only happens with the guest's explicit consent, given on the screen that explains it before any photo is taken.

  • What happens: the selfie is compared once with the portrait on the guest's document (the scanned passport page, or a photo of the front of an ID card) using Amazon Rekognition in the EU (Ireland). It is only offered after the document itself has been read successfully.
  • What we keep: the result (face verified, not matched, or skipped), a match score, the number of attempts, and when consent was given. This is kept with the guest's registration record and removed with it under section 6.
  • What we don't keep: the selfie and the ID-front photo are deleted from our storage immediately after the comparison; if a deletion ever fails, our storage removes the photo automatically after one day. We do not build face templates or face databases, or use the photos for any other purpose, and we have opted out of Amazon using them to develop or improve its services.
  • It is a comparison of two photos, not proof that a live person was present, and it is not used to make any automated decision about the guest: a mismatch only tells the property to check the ID in person.

5. Storage, security and international transfers#

  • Guest and account data is stored in the European Union: application processing and file storage on AWS in Ireland (eu-west-1), and the database with Supabase in an EU region.
  • Some providers we rely on are based outside the EU — for example Vercel (which hosts our web apps and routes requests through its global network), Postmark (email) and, if a property uses them, Twilio (SMS), Meta (WhatsApp) and Anthropic (the Receptionist Agent). These transfers are covered by the EU–US Data Privacy Framework and/or the European Commission's Standard Contractual Clauses. The full list, with locations and safeguards, is in our Data Processing Agreement.
  • Document images are held in private storage with access limited to the property's account; uploads use short-lived signed links, and raw images are removed automatically after one day.
  • Authority credentials, where an authority requires them (e.g. SES/Mossos passwords — some authorities, like France's fiche individuelle de police, require none), are protected with AES-256-GCM envelope encryption before being written to the database; plaintext secrets are never written to application logs.
  • Data is encrypted in transit (TLS) and at rest. Each customer's records are isolated at the database level, access is least-privilege, and sensitive actions are audit-logged. No system is perfectly secure; please report suspected incidents to us promptly.

6. Retention#

Guest and compliance records are kept for the period the property's jurisdiction requires (for example three years in Spain) and then anonymised automatically. Account data is kept while the subscription is active and for a limited period afterwards for legal and billing obligations. Deletion requests are handled subject to these statutory retention periods.

7. Sub-processors#

We use carefully selected providers, including AWS (hosting, storage, document reading and Amazon Rekognition for the optional face check, all in the EU), Supabase (database, EU), Vercel (web hosting), Stripe (payments), Postmark (email), and integration partners the property enables (PMS, WhatsApp, SMS, Receptionist Agent). See the Data Processing Agreement for the complete, current list.

8. Your rights#

Under GDPR you may request access to, correction or erasure of your data, or restrict or object to its use, and ask for a portable copy. Staff users can contact us directly; guests should normally contact the accommodation provider (the controller), and we will help them respond. A guest who agreed to the face check can withdraw consent at any time — before or during the check by skipping it — without affecting their registration. Contact: hello@simpleguests.com. You may also complain to your local data protection authority.

9. Changes to this policy#

We may update this policy as the service changes. The date at the top shows the latest version; material changes are announced to customers by email or in the dashboard.

SG

Simple Guests (simpleguests.com) is a platform operated by SMN Properties OÜ, a private limited company registered in Estonia.

Questions about this document: hello@simpleguests.com

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