Last updated: 06/25/2026

Contract appointing the external Data Processor for the processing of personal data

AI KOSMO SRL

Sub-processors

The Processor is authorized to subcontract part of the processing operations to the following Sub-processors. The following table lists the Sub-processors engaged by the Processor.

Services not provided by the Processor and subject to separate agreements between the Sub-processor and the Controller are excluded. The Sub-processor table will be updated from time to time, and the Controller will be notified accordingly so that it may object to the use of new Sub-processors.

Sub-processors	Sub-processor	Address	Place of processing
Application server / hosting (cloud infrastructure)	Google Cloud	Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, D04 E5W5, Irlanda	EEA (Netherlands)
Database service (DB)	Supabase	Supabase, Inc., 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513	EEA (Germany)
Hosting e deployment	Vercel	Vercel Inc., 340 S Lemon Ave #4133, Walnut, California 91789, USA	USA / SEE
Hosting e deployment	Railway	Railway Corp., 548 Market St PMB 68956, San Francisco, California 94104, USA	USA / SEE
AI services	OpenAI	OpenAI, L.L.C., 3180 18th Street, San Francisco, California 94110, USA	USA / SEE
AI services	Groq	Groq, Inc., 2700 Zanker Road, Suite 150, San Jose, California 95134, USA	USA
Hosting	OpenRouter	OpenRouter, Inc., 169 Madison Ave #2404, New York, NY 10016, USA	USA / SEE
Monitoring	Axiom	Axiom, Inc., 1390 Market Street, Suite 200, San Francisco, California 94102, USA	USA / SEE
Email and accounts	Google Workspace	Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, D04 E5W5, Irlanda	SEE (UE) / USA

Types / Purposes of processing

Product	Type of processing	Purpose of processing	Type of personal data processed	Category of data subjects
Intelligent Chatbot	Collection, recording, storage, and consultation of conversations Analysis of conversation content, aggregated / anonymized where possible Security and technical maintenance	Responding to user requests, assisting navigation, and providing information about services Improving the accuracy / effectiveness of the service, including specific fine-tuning at the Controller’s request Preventing abuse and ensuring operational continuity	Data actively provided by the user, such as name, surname, contact details, stay preferences Conversation content Technical session data, such as IP address, browser, operating system	Users of the Client’s website who use the Intelligent Chatbot
QR Concierge	Collection, recording, storage, and consultation of conversations Analysis of conversation content, aggregated / anonymized where possible Security and technical maintenance	Responding to user requests, providing information about services, booking services, and managing charges to the room account, where applicable Improving the accuracy / effectiveness of the service, including specific fine-tuning at the Controller’s request Preventing abuse and ensuring operational continuity	User identification and contact data Data actively provided by the user, such as name, surname, contact details, stay preferences Conversation content Technical session data, such as IP address, browser, operating system	Guests who use the QR Digital Concierge

Product

Type of processing

Purpose of processing

Type of personal data processed

Category of data subjects

Intelligent Chatbot

Collection, recording, storage, and consultation of conversations
Analysis of conversation content, aggregated / anonymized where possible
Security and technical maintenance

Responding to user requests, assisting navigation, and providing information about services
Improving the accuracy / effectiveness of the service, including specific fine-tuning at the Controller’s request
Preventing abuse and ensuring operational continuity

Data actively provided by the user, such as name, surname, contact details, stay preferences
Conversation content
Technical session data, such as IP address, browser, operating system

Users of the Client’s website who use the Intelligent Chatbot

QR Concierge

Collection, recording, storage, and consultation of conversations
Analysis of conversation content, aggregated / anonymized where possible
Security and technical maintenance

Responding to user requests, providing information about services, booking services, and managing charges to the room account, where applicable
Improving the accuracy / effectiveness of the service, including specific fine-tuning at the Controller’s request
Preventing abuse and ensuring operational continuity

User identification and contact data
Data actively provided by the user, such as name, surname, contact details, stay preferences
Conversation content
Technical session data, such as IP address, browser, operating system

Guests who use the QR Digital Concierge

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