Privacy policy
What we collect, why, how long we keep it, who helps us run the service, and what you can ask of us. Written to be read, and to say only what the product actually does.
The short version
- A hotel’s guest guide needs no app, no account and no cookies, and we never store a guest’s IP address.
- We count what is opened in a guide, not who opened it, and hotels only ever see totals.
- Questions typed to a guide’s concierge are kept for up to 30 days, then only their topic remains.
- We do not sell personal information, share it for advertising, or let our AI providers train on it.
- You can ask us for a copy of what we hold about you, to correct it, or to delete it: support@cgxpstudio.com.
1. Who we are, and whose data it is
CGXP Studio is operated by Compass Tech Labs LLC, a Massachusetts limited liability company based in Boston, Massachusetts, USA (“we,” “us”). This policy covers three places:
- This website, cgxpstudio.com.
- The guest guides we build and host for hotels, at cgxp.app or at a hotel’s own web address.
- The studio, app.cgxpstudio.com, where our team and hotel staff sign in to run a guide.
Who is responsible for your information depends on which of those you use:
- For this website and for studio accounts, we are responsible (in European terms, the “controller”).
- For a hotel’s guest guide, the hotel is responsible for the guide and its content, and we process the little a guide records on the hotel’s behalf and on its instructions (the “processor” or “service provider”). The hotel’s own privacy notice covers your stay. We will still answer any question you send us, and pass on a request that is the hotel’s to answer.
2. What we collect
On this website
- Inquiries. If you send us the contact form we keep what you typed (your name, work email, company, phone number if you gave one, the kind of property, how many, what you would like, when you said you were free, and your note), the page you sent it from, and the site that referred you. We use it to reply. We do not add you to a mailing list or send follow-up sequences.
- Blog reads. We count how often a post is read. To tell one reader from another within a day we combine your IP address and browser description with a secret value and keep only the resulting code. Your IP address is never stored, and the code changes daily, so your reading cannot be followed from one day to the next.
- Demonstrations. To show a hotel what its own guide could look like, we may read pages of that hotel’s public website and build a demonstration guide from them. Those pages can name the hotel’s staff or give a work email address. We keep them only until the demonstration becomes the hotel’s guide or is deleted, and never put a staff member’s own email address in a guide.
In a guest guide
- No account, no cookies. A guide needs no sign-up and sets no cookies. If you change the text size, the choice is stored in your own browser only.
- Usage counts. We record which pages, buttons and elements are opened or tapped, when, in which language, and whether the visit looks automated, so the hotel can see what is useful. A visit is identified only by a daily code made from your IP address and browser description, never the address itself. Hotels see totals, never an individual visit.
- Concierge questions. If you type to the concierge we keep the text of your question, its language, whether it was answered, and a topic. Anything that looks like a code or password is removed as soon as it arrives. The hotel sees topics and counts, never what an individual guest typed.
- Voice conversations. If you choose to speak to the concierge, your browser asks for the microphone first, and it is used only while you are talking. We keep how long the call lasted and how it ended; what you asked is kept as a typed question is.
- Codes and passwords. The Wi-Fi password a hotel sets is shown to every guest. A door or lock code is shown only through a private link the hotel gives you. Both are stored encrypted, and neither is ever written into usage counts, logs or anything else.
- Maps, videos and fonts. A map page loads Google Maps, so Google receives your IP address when it opens. If you tap to show where you are, your browser asks permission and your location is used on your device only; we do not receive or store it. Videos play through YouTube’s privacy-enhanced mode, and some hotels use typefaces served by Adobe Fonts.
- Contacting the hotel. Buttons that call or message the hotel open your own phone, messaging or WhatsApp app. We do not see or keep those messages.
In the studio
- Your account: name, email address, time zone, a profile picture if you add one, which hotels you can reach and in what role, and who invited you. Sign-in is by email link, one-time code, or Microsoft.
- What you do: a record of changes (publishing, editing, inviting, approving and so on), under your name. It never contains passwords, door codes, or the content of support messages.
- What you tell us about your hotel: the answers your team types on the Onboarding page and the photographs they add there, each under the name of whoever wrote it and the time. Your colleagues at the hotel see who answered what, and so do we. When an answer is changed we keep what it said before.
- Support threads you write and any files you attach, and whether you have confirmed reading your hotel’s team handbook.
- Hotels as customers: the billing details a hotel gives us (legal name, tax identifier, billing address), agreements, invoices and payments, and the names, titles and email addresses of the people a hotel asks us to send reports to.
For every part of the service
- Security and reliability. To stop automated abuse we count requests to the concierge, voice calls, sign-in codes, usage counts, blog reads and the contact form, as codes rather than IP addresses. Requests for a sign-in link are counted by IP address. When something goes wrong we record the error, after removing email addresses, IP addresses, tokens and anything resembling a code.
- Hosting logs. Our hosting provider keeps short-lived request logs, which include IP addresses, to operate and protect the service.
3. Why we use it, and our legal basis
We use personal information only to provide, secure and improve the service, to answer you, to run our business with the hotels we work for, and to meet legal obligations. Where the law of the European Union or the United Kingdom applies, our legal bases are:
| Purpose | Legal basis |
|---|---|
| Running studio accounts, support, billing and reports for hotels | Performing our contract with the hotel; our legitimate interest in serving its staff |
| A guide’s usage counts and concierge | Processed for the hotel, on its instructions; the hotel’s basis applies (usually its legitimate interest in helping guests) |
| The voice concierge’s microphone, and showing your location on a map | Your consent, given through your browser’s permission prompt, which you can withdraw at any time |
| Answering inquiries | Steps you asked for before a contract; our legitimate interest in replying |
| Security, abuse prevention, error records, the activity record | Our legitimate interest in a safe, accountable service |
| Tax, accounting and legal requests | Legal obligation |
We do not make decisions about anyone by automated means that have legal or similarly significant effects.
4. Artificial intelligence
The concierge, and the tools our team uses to draft, translate and check a guide, send text to AI providers: Anthropic for text, and OpenAI for voice. They process it to return an answer, under commercial terms that do not allow them to use it to train their models. The concierge answers only from the hotel’s own guide. We do not use guests’ questions, or a hotel’s content, to train any AI model.
5. Cookies and similar technology
This website and the guest guides set no cookies and use no third-party analytics, advertising or tracking tools. The studio uses only the cookies needed to keep you signed in. Because we do not track you across sites, there is nothing for a “Do Not Track” signal or Global Privacy Control to switch off; we treat both as a request not to sell or share your information, which we do not do anyway.
6. Who helps us run the service
We use these providers, each only for the part of the service named here:
| Provider | What for |
|---|---|
| Vercel | Hosting the website, the guides and the studio |
| Supabase | Our database, file storage and sign-in, including sign-in emails |
| Anthropic | Answering concierge questions; drafting, translating and checking guide text |
| OpenAI | Understanding and speaking in voice conversations |
| Resend | Sending our other email: invitations, reports, invoices and support notices |
| Microsoft | Our own email, and sign-in for people who choose Microsoft |
| Maps on a guide’s map page; looking up the addresses of places a guide lists | |
| MapTiler | Walking distances and address lookups, from our servers |
| Adobe Fonts | Typefaces, for hotels that license them from Adobe |
| YouTube | Videos a hotel places in its guide, in privacy-enhanced mode |
| Meta (Instagram) | Reading public posts of venues a guide recommends, from our servers |
Each receives only what its part needs and is bound to protect it. Beyond these providers we disclose personal information only: to the hotel whose guide or account it concerns; when the law requires it, or to respond to valid legal process; to protect the safety, rights or property of anyone, or to investigate abuse; or to a buyer or successor if our business is sold or merged, who must keep this policy’s promises.
We do not sell personal information, and we do not share it for cross-context behavioral advertising, as those terms are used in US state privacy laws.
7. Where it is processed
We are based in the United States, and our providers may process information in the United States and other countries. Where European or UK law requires it, transfers rely on the safeguards those laws recognize, such as the European Commission’s standard contractual clauses and the UK addendum to them, as offered in our providers’ data processing terms.
8. How long we keep it
| Information | Kept for |
|---|---|
| Text of a concierge question | 30 days, or less if the hotel chose; then only the topic and date |
| Individual guide usage events | 60 days at most; then only daily totals |
| Abuse-prevention counts | Under one hour (sign-in link requests: 15 minutes) |
| Error records | 90 days |
| Website inquiries | 24 months |
| Hotel website pages read for a demonstration | Until the demonstration becomes that hotel’s guide or is deleted |
| Studio accounts | While the account is open. A deleted account loses its email address and all access at once; the person’s name stays on the record of what they did |
| The activity record, onboarding answers and their history, support threads and their files | As part of a hotel’s history with us, including after it leaves, unless the hotel asks us to delete them |
| Agreements, invoices and payments | As long as tax and accounting law requires, and at least seven years |
Deleted information can remain in our encrypted backups until they are replaced; the automatic daily backups roll over after seven days.
9. How we protect it
Every connection is encrypted. Door codes and passwords are stored encrypted and never logged. Each hotel’s information is separated from every other hotel’s by rules enforced in the database itself, and staff reach only the hotels and the actions their role allows. Access is by invitation only and there are no passwords to steal. We keep a record of changes, test the separation between hotels automatically, and keep backups. No system is perfectly secure, but if a breach affecting your personal information happens, we will notify you, the hotel concerned and the authorities as the law requires, including under Massachusetts law (M.G.L. c. 93H).
10. Your rights
Wherever you live, you can ask us to tell you what personal information we hold about you and send you a copy, to correct it, to delete it, or to stop using it for a particular purpose, and you can withdraw any consent you gave. Depending on where you live (for example in the European Union, the United Kingdom, or a US state with its own privacy law), the law may give you further rights, such as to restrict processing or to receive your information in a portable form.
- How: email support@cgxpstudio.com. We answer within 30 days, and tell you if we need longer.
- Verification: we may ask you to confirm you are who you say you are, and ask for no more than we need to do so.
- Someone acting for you may make a request with your written permission.
- About a hotel’s guide: we act for the hotel, so we will work with it to answer, and tell you who is responsible.
- If we say no, we will explain why, and you can ask us to look again. You may also complain to your data protection authority or, in the US, your state attorney general.
- No penalty. Using any of these rights never changes the service you receive.
11. Children
The service is not directed at children. We do not knowingly collect personal information from anyone under 16. If you believe a child has given us information, contact us and we will delete it.
12. Changes and contact
When what we collect, keep or share changes, this page changes with it, and the date at the top says when. If a change is significant, we will also tell the hotels we work with before it takes effect. The terms of service and, for guests, the guest terms & privacy cover the rest.
Compass Tech Labs LLC, Boston, Massachusetts, USA · support@cgxpstudio.com