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.
Service
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 / EEA
Hosting e deployment
Railway
Railway Corp., 548 Market St PMB 68956, San Francisco, California 94104, USA
USA / EEA
AI services
OpenAI
OpenAI, L.L.C., 3180 18th Street, San Francisco, California 94110, USA
USA / EEA
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 / EEA
Monitoring
Axiom
Axiom, Inc., 1390 Market Street, Suite 200, San Francisco, California 94102, USA
USA / EEA
Email and accounts
Google Workspace
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, D04 E5W5, Irlanda
EEA (EU) / 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
