1Who we are

Gustave (“we”, “us”) is an AI concierge platform for boutique hotels and short-term rental operators.

This policy explains how we handle personal data under the EU General Data Protection Regulation (GDPR) and applicable national law.

2Our two roles

Gustave serves two groups of people, and our responsibilities differ for each.

Operators (our customers)

Hotels, rental managers and their staff who hold an account. For this data we are the controller.

Guests (our customers’ customers)

People who chat with a Gustave concierge during a stay. For guest data, the operator is the controller and Gustave is the processor, acting on the operator’s documented instructions under a data processing agreement (Art. 28 GDPR). Guests should direct privacy requests to the property they booked with; we will assist the operator in responding.

Sensitive information. Guests may mention health, dietary or religious needs in chat. We do not seek this information and process it only to answer the guest’s request, on the operator’s instructions. Operators should tell guests not to share more than necessary.

3AI processing and insights

• Concierge replies are generated by third-party AI models from Google (Gemini) and Anthropic (Claude) using the operator’s knowledge base and the guest’s booking context.
• Guest chat content is not used to train general-purpose AI models.
• To produce insights, we analyse conversations in aggregate and remove direct identifiers before trends are shown. Data that can still be linked to a person remains personal data and is protected as such. Insights shown to an operator are limited to that operator’s own property.
• Replies are generated automatically but do not produce legal or similarly significant decisions about guests (Art. 22 GDPR). Guests can ask the property for a human at any time.

4International transfers

Some providers, and guests travelling outside the EU/EEA, may involve processing outside the EU/EEA. Where data leaves the EU/EEA we rely on an adequacy decision, the EU Standard Contractual Clauses, or another mechanism permitted by Chapter V GDPR, with supplementary measures where needed.

5How long we keep data

• Operator account data: for the life of the account, then twelve months after it closes.
• Guest chats and preference records: as set by the operator, by default twelve months after the stay ends, then deleted or irreversibly anonymised.
• Security and access logs: twelve months.
• Aggregated, anonymised statistics may be kept without limit because they no longer identify anyone.

6Your rights

You have the right to access, rectify, erase, restrict or object to processing of your personal data, to data portability, and to withdraw consent at any time (without affecting earlier processing). You can object at any time to processing based on legitimate interests.

Operators can contact us directly at [privacy@…]. Guests should contact the property first; if you write to us, we will forward your request to the operator and help them respond. We aim to reply within one month.

7Security

We use measures appropriate to the risk, including encryption in transit [and at rest], access controls limited to need, separation between operators’ data, logging, and a process for handling incidents. We will notify affected operators without undue delay after becoming aware of a personal data breach, so they can meet their own 72-hour obligation to authorities.

8Cookies

Our website uses strictly necessary cookies. Analytics or marketing cookies are set only with your consent, which you can change at any time. The guest chat link uses only what is needed to keep a session working [confirm].

9Children

Gustave is a business service and is not directed at children. Guests under 16 should use it only with a parent or guardian’s involvement.

10Changes

We will update this policy as the product evolves and show the date above. For material changes we will notify operators by email.