Last updated: 4 November 2026
The short version: your guests' data belongs to you. Here is the legal framework that guarantees it.
This Data Processing Agreement is incorporated by reference into the Valiris Terms of Service and forms part of the contract between the operator and Valiris SAS. It is accepted automatically when an operator accepts the Terms of Service at signup, and no further signature is required for it to take effect.
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This Agreement is entered into between the operator using Valiris to manage guest communications ("the operator", acting as data controller for its guests' and its own team members' personal data) and Valiris SAS ("Valiris", acting as data processor). Together, the operator and Valiris are "the Parties".
Subject matter: the processing of personal data by Valiris on the operator's documented instructions, in order to deliver AI-assisted guest message handling and related platform features (Knowledge Base retrieval, Extras and payment flows, escalations and approvals, analytics).
Duration: this Agreement applies for as long as Valiris processes personal data on the operator's behalf, that is, for the duration of the underlying service agreement between the Parties, and it terminates automatically when that agreement ends, subject to the deletion and return provisions in clause 10.
Nature of the processing: automated and, where applicable, manual operations, including collection, storage, retrieval, organisation, use, transmission, and deletion of personal data through the Valiris platform.
Purpose: to enable the operator to automate and manage communications with its guests, including AI-generated replies where the operator's plan includes them, to operate the associated features it has configured on the platform, including the guest portal, and to produce operational reporting for the operator from those communications, namely knowledge base gap analysis and the classification of guest messages escalated to its team.
Guests (data subjects)
Name, contact details (email, phone), booking dates and references, message content exchanged with the AI or the operator's team, requested Extras and payment status, the service date and time and any guest-written note attached to an extras request (which may contain flight numbers and addresses), and, for extras that need approval, the status of a reserved amount on the guest's card (reserved, charged, released; card data held by Stripe only), where the operator uses Val's Midas Touch, a log of each extra offered to the guest and its outcome, the practical topic of each guest message (for example parking or wifi), and, where the operator uses Iris's Sixth Sense, a log of each info message sent to the guest and its outcome.
Operator staff (data subjects)
Name, email address, and role or permission level within the operator's Valiris account.
Recipients designated by the operator (local partners)
Where the operator has an active agreement with a local partner (for example a restaurant) and a guest shows a perk voucher or stay code, or a visit is recorded, the partner receives the guest's first name and stay dates, and nothing else. The partner is a recipient designated by the operator, not a sub-processor of Valiris, and acts as an independent controller for what it does with the visit.
Valiris does not knowingly process special categories of personal data (Article 9 GDPR). The operator agrees not to include such data in its Knowledge Base documents, instructions, or other content it provides to the Service.
Valiris processes personal data only on the operator's documented instructions. Those instructions consist of this Agreement, the Terms of Service, and, critically, the configuration the operator sets on the platform itself: AI Settings, Knowledge Base content, Extras, the approval workflow, and per-property configuration. The operator's own settings ARE its instructions to Valiris.
The operator instructs Valiris to disclose a guest's first name and stay dates to a local partner with which the operator has an active agreement, at the moment the guest redeems a perk or shows a stay code, or a visit is recorded, and for that purpose only. Valiris derives these two items when the partner views the voucher, stay code or visit and does not store them on records the partner can read. No other guest data is disclosed to partners.
Where the operator adds team members or contacts (for example cleaners or maintenance staff) with a WhatsApp number and switches on the matching options, the operator instructs Valiris to send them WhatsApp messages through Meta's WhatsApp Business Platform: the cleaning schedule, extras approval requests, a short summary of a cleaning or maintenance problem a guest reported at a property they look after, and an urgent alert when Valiris flags an emergency. These messages carry the property name and a short summary of the problem, never the guest's name, phone number or email address, and never access codes. The operator's own notifications are unchanged. Meta is listed as a sub-processor in our Privacy Policy.
Where the operator switches on Val's Midas Touch for a property (Pro plan), the operator instructs Valiris to choose when to offer each extra to guests with a confirmed booking, and to keep a log of each offer: the booking, the extra, the moment, when it was sent, the message text if one was drafted, and the outcome (bought, declined or no reply). The log is kept and deleted with the booking, under clause 10. The guest's conversation mood, from the sentiment analysis Valiris already runs, is used to hold offers when the guest seems unhappy or a problem is open. The operator also instructs Valiris to add its offer and sale counts for each type of extra and each moment to statistics pooled across all customers, and to use those statistics to time offers for every customer. The pooled statistics hold counts only: no guest data and nothing that identifies the operator. Weekly summaries of what Val learned are generated by Anthropic from those counts and the names of the extras only. Messages are written by Anthropic, already listed as a sub-processor. This feature adds no new sub-processor.
The operator instructs Valiris to sort every guest message into practical topics (access codes, check-in, parking, wifi, how the property works, check-out, directions, local tips) and to keep a record of each topic asked and when. Valiris does this with fixed word rules in its own software, without AI and without any sub-processor. These records are kept and deleted with the guest messages, under clause 10. Where the operator switches on Iris's Sixth Sense (Pro plan), the operator instructs Valiris to send guests with a confirmed booking the practical messages of the stay (welcome, arrival heads-up, access codes, settling in, check-out reminder, goodbye), to choose when to send each one, and to keep a log of each message: the booking, the message, the moment, when it was sent, the message text if one was drafted, and the outcome (whether the guest still asked about the same topic). The log is kept and deleted with the booking, under clause 10. Access codes are sent only at the instant the guest portal unlocks them. The notice that an AI may be answering is sent with the first AI message of the conversation, as for every AI reply. The operator also instructs Valiris to add, for each message and each moment, its counts of messages sent and of questions still asked to statistics pooled across all customers, and to use those statistics to time messages for every customer. The pooled statistics hold counts only: no guest data and nothing that identifies the operator. Messages are written by Anthropic, already listed as a sub-processor. This feature adds no new sub-processor.
Where a direct booking has no message thread at the operator's booking system, the operator instructs Valiris to use the guest's email address on that booking to send, in the operator's name, one invitation to the guest portal and short "new message" emails (at most one an hour) when notifications are off. Messages for that stay are delivered in the guest portal. These emails carry no access codes and no message text.
If Valiris considers that an instruction infringes the GDPR or another applicable data protection provision, it will inform the operator without delay.
Valiris ensures that any person it authorises to process personal data under this Agreement, employees and contractors alike, is bound by an appropriate confidentiality obligation, whether contractual or statutory, and processes that data only as instructed.
Valiris implements appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage, appropriate to the risk presented by the processing. The measures currently in place are set out in full in the Annex to this Agreement, Technical and Organisational Measures (TOMs), which forms an integral part of this Agreement. Valiris may update these measures over time, provided any update does not materially decrease the overall level of protection.
The operator gives Valiris a general written authorisation to engage sub-processors to help deliver the service. The current list of sub-processors, together with the purpose of each engagement, the categories of personal data involved, and their location, is published and kept up to date in our Privacy Policy. This Agreement does not repeat that list, so the Privacy Policy is the authoritative reference.
Before engaging a new sub-processor, or replacing an existing one, Valiris will give the operator at least 30 days' notice by email or in-app notification. If the operator has a reasonable, documented objection grounded in data protection law, it may raise it within that period; the Parties will discuss the objection in good faith and, if it cannot be resolved, the operator may terminate the affected part of the service without penalty.
Valiris imposes on every sub-processor data protection obligations that are at least equivalent to those set out in this Agreement, and remains fully liable to the operator for each sub-processor's performance of those obligations.
Valiris assists the operator, insofar as reasonably possible given the nature of the processing, in responding to requests from data subjects, guests or team members, exercising their rights under the GDPR. This includes tools available directly on the platform, such as data export and deletion, and forwarding to the operator any request Valiris receives directly from a data subject.
Valiris also assists the operator in meeting its obligations under Articles 32 to 36 of the GDPR: the security of processing, notification of personal data breaches, data protection impact assessments, and prior consultation with the CNIL or another competent supervisory authority, where required, taking into account the information available to Valiris and the nature of the processing.
Valiris notifies the operator without undue delay after becoming aware of a personal data breach affecting personal data processed under this Agreement. The notification includes, to the extent known at the time: the nature of the breach; the categories and approximate number of data subjects and personal data records concerned; the likely consequences of the breach; and the measures taken or proposed to address it and mitigate its effects, in line with Article 33(3) of the GDPR. Valiris cooperates with the operator and provides further information as it becomes available, to support any notification the operator is required to make to a supervisory authority or to affected data subjects.
On termination of the service agreement between the operator and Valiris, the operator has 30 days to export its data, including guest message history, booking records, and Knowledge Base documents, using the platform's export tools or by written request to contact@valiris.io. Once that 30-day window has passed, Valiris permanently deletes all personal data processed under this Agreement from its production systems and instructs its sub-processors to do the same, except to the extent EU or French law requires Valiris to retain specific data, for example billing and accounting records.
Valiris makes available to the operator all information reasonably necessary to demonstrate compliance with this Agreement, including this DPA, its Annex, and relevant security documentation and certifications. Where that documentation does not sufficiently address the operator's concerns, the operator, or an independent auditor it appoints who is itself bound by confidentiality, may conduct an on-site audit of Valiris's relevant processing activities. Such audits are limited to once per calendar year, unless triggered by a personal data breach or a binding request from a supervisory authority, require at least 30 days' prior written notice, must take place during normal business hours without disrupting Valiris's operations or other customers' data, and are carried out at the operator's cost.
Some Valiris sub-processors are established outside the European Economic Area, principally in the United States. Where personal data is transferred to such a sub-processor, Valiris relies on a valid transfer mechanism recognised under the GDPR: the European Commission's Standard Contractual Clauses and, where the recipient participates, the EU-US Data Privacy Framework, together with supplementary technical and organisational measures such as encryption in transit and at rest. The transfer mechanism relied on for each sub-processor is listed alongside it in our Privacy Policy.
Where the operator uses Valiris to communicate with guests through an AI system, the operator is the deployer of that AI system for the purposes of Regulation (EU) 2024/1689 (the AI Act) and is responsible for guest-facing AI transparency in line with its obligations, which apply from 2 August 2026 under Article 50 of that Regulation. To help the operator meet this obligation, Valiris sends an automatic notice in the first reply of every conversation informing guests that an AI may be answering. This notice cannot be switched off, and its wording is set by Valiris and cannot be edited by the operator. The operator may add one short line of its own after it, which is sent only to guests answered in the operator's account language. The operator remains responsible for its use of the Service and for any line it adds.
This Agreement is governed by French law. Any dispute arising from or in connection with this Agreement is submitted to the exclusive jurisdiction of the courts of Paris, France.
These are the measures Valiris has in place at the date of this Agreement, referenced in clause 6.
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