Data Processing Addendum

Roles

For personal data you submit to RateOwl in order to use the service, you are the data controller and RateOwl is the data processor. In practice the data you put into RateOwl is mostly business information — hotel names and public booking-site URLs — and contains little or no personal data. Where it does, this addendum governs how we handle it.

(Separately, for the personal data of your own account — your email and sign-in details — RateOwl acts as controller; see our Privacy Policy.)

Scope and purpose

We process this data only to provide the service to you: storing the properties and competitors you configure, and producing the rate comparisons, demand signals, and alerts you request. We process it on your documented instructions, which are given through your use of the app, and not for our own purposes.

Our commitments

• Confidentiality — staff with access are bound to keep the data confidential.
• Security — we apply appropriate technical and organisational measures, including encryption in transit, encrypted off-site backups, access controls, and monitoring.
• Assistance — we will help you respond to requests from individuals exercising their rights, and with your own obligations under the Personal Data Protection Act 2010 (Malaysia), so far as the service allows.
• Breach notice — we will tell you without undue delay after becoming aware of a personal-data breach affecting your data.
• Deletion — on termination, or on your request, we delete the personal data we process for you, except where law requires retention. Account deletion erases this data within 7 days.

Sub-processors

We use the sub-processors listed in our Privacy Policy to deliver the service. Each is bound to data-protection obligations consistent with this addendum. We will give notice of material changes to that list so you can object.

International transfers

Your application data is hosted in Singapore. Where a sub-processor processes data in another region, we take reasonable steps to ensure a comparable standard of protection.

Term

This addendum lasts as long as we process personal data on your behalf under the Terms of Service.

Contact

For data-processing questions, email support@rateowl.io.