Privacy
Policy

1. Personal Data We Collect

Depending on how you interact with HDS Index, we may collect the following categories of personal data:

• First name and surname
• Business email address
• Phone number (if provided)
• Company name
• Job title
• Property name and website URL
• Billing and payment information
• Information included in messages submitted through contact forms

When you visit our website, we may automatically collect technical information, including:

• IP address
• Browser type and version
• Operating system
• Device information
• Website interaction data
• Pages visited and time spent on the website
• Cookie identifiers and similar technologies

To generate an HDS Index assessment, we may process publicly available business and digital information relating to the hospitality property or website being analyzed, including:

• Property name and website URL
• Website content and publicly available website information
• Website performance and digital presence indicators
• Search visibility information
• Public distribution channel information
• Public social media information
• Online reputation and review information
• Other publicly accessible information relevant to the HDS Index methodology

Such information primarily relates to the relevant hospitality business rather than to an identified or identifiable individual. However, publicly available information may, in certain circumstances, incidentally contain personal data relating to individuals associated with the business — such as names, professional contact details, professional profiles, photographs, reviews, or other information published online. HDS Index does not seek to assess individuals themselves; such information is processed only to the extent necessary to analyze the digital presence and commercial positioning of the relevant hospitality business.

This information is processed primarily to generate HDS Index scores, reports, analyses and recommendations, and, where applicable, to operate, secure, maintain and improve the Service.

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2. Purposes and Legal Basis of Processing

We process personal data for the following purposes:

3. HDS Index Analysis Methodology and Data Processing

The HDS Index evaluates digital sales performance through the analysis of multiple publicly available digital indicators.

The assessment is based primarily on publicly available information and does not require access to the customer’s private systems.

The information analyzed is primarily used to:

• Calculate the HDS Index score

• Generate performance reports

• Identify improvement opportunities

• Provide strategic recommendations

HDSI assessments are not used to make decisions concerning the employment, creditworthiness, eligibility, access to services or other legal or similarly significant matters relating to individuals.

HDS Index does not seek to assess individuals or make decisions about individuals based on publicly available information. The analysis is focused on the digital presence and commercial performance indicators of the relevant hospitality business.

4. Data Retention

Personal data is stored only for the period necessary to achieve the purposes for which it was collected or for such longer period as may be required or permitted by applicable law.

Contact requests: stored for the time necessary to manage the request and related communications.

Customer account data: stored for the duration of the contractual relationship and subsequently for the period required by applicable legal obligations.

Marketing data: stored until consent is withdrawn or according to applicable retention rules.

Technical and analytics data: retained for the period necessary for the relevant operational, security, analytics and compliance purposes and in accordance with applicable provider retention periods.

HDS Index analysis request data: the IP address associated with an HDS Index analysis request and the Submitted URL may be retained for up to ninety (90) days from the date of submission for purposes including fraud prevention, abuse detection, enforcement of applicable usage and submission limits, security and service integrity.

After the applicable retention period, such information will be deleted or anonymized, unless a longer retention period is required or permitted by applicable law.

5. Data Sharing, Processors and Service Providers

Personal data may be processed by trusted third-party providers that support our operations.

Depending on the nature of the services provided and the applicable processing activities, such providers may act as Data Processors pursuant to Article 28 GDPR or in another capacity permitted under applicable data protection law.

These providers may include:

• Hosting and cloud infrastructure providers

• Customer relationship management platforms

• Analytics providers

• Payment service providers

• Communication and email service providers

• IT and security providers

• Artificial intelligence and machine-learning providers, including OpenAI, Anthropic and Google, where applicable to the Service

We select service providers appropriate to the relevant processing activities and, where required by applicable law, enter into appropriate contractual arrangements and implement appropriate safeguards governing the processing of personal data.

We do not sell, rent or trade personal data to third parties.

5.1 Artificial Intelligence and Technology Providers

HDS Index may use third-party artificial intelligence, machine-learning, cloud and other technology providers, including OpenAI, Anthropic and Google, where applicable to the Service, to process publicly available website and digital information in order to generate HDSI assessments, scores, reports and recommendations.

Depending on the service used, information processed by such providers may include the Submitted URL and publicly accessible website content and digital information associated with that URL.

Where required by applicable law, appropriate contractual and technical safeguards are implemented in connection with the processing of personal data by such providers.

Where third-party providers process personal data outside the European Economic Area, the applicable international transfer safeguards described in Section 6 apply.

6. International Transfers

Some service providers may process personal data outside the European Economic Area (EEA).

Where personal data is transferred outside the EEA, HDS Index ensures that appropriate safeguards are implemented, including:

• Adequacy decisions issued by the European Commission

• Standard Contractual Clauses approved by the European Commission

• Other safeguards permitted under GDPR

7. Additional Privacy Rights for Certain Jurisdictions

United Kingdom

Where applicable, HDS Index processes personal data of individuals in the United Kingdom in accordance with the UK General Data Protection Regulation (“UK GDPR”) and applicable UK data protection legislation.

Where applicable, individuals in the United Kingdom may exercise rights equivalent to those described in Section 10 of this Privacy Policy, subject to applicable legal limitations.

California

Where applicable, HDS Index processes personal information of California residents in accordance with applicable provisions of the California Consumer Privacy Act, as amended (“CCPA”).

California residents may have additional rights regarding their personal information, including rights to know or access, correct, delete and opt out of certain processing or disclosures, subject to applicable legal exceptions and limitations.

HDS Index does not sell personal information and does not share personal information for cross-context behavioral advertising as defined under applicable California privacy law.

To exercise applicable privacy rights, California residents may contact us using the contact details provided in Section 12 of this Privacy Policy.

We may take reasonable steps to verify the identity of the person making a request before responding.

8. Data Security

We adopt appropriate technical and organizational measures to protect personal data against:

• Unauthorized access

• Accidental loss

• Alteration

• Disclosure

• Destruction

Security measures are regularly reviewed according to technological developments and operational requirements.

9. Cookies and Tracking Technologies

Our website and Platform may use cookies and similar technologies to:

• Ensure website functionality

• Analyze website traffic

• Improve user experience

• Measure marketing effectiveness

For more information about the cookies used and how to manage your preferences, please refer to our Cookie Policy.

10. Your Rights Under GDPR

According to Articles 15–22 GDPR, you may have the right to:

• Obtain confirmation whether your personal data is being processed

• Access your personal data

• Request correction of inaccurate or incomplete data

• Request deletion of your personal data

• Request restriction of processing

• Object to processing based on legitimate interest

• Request data portability where applicable

• Withdraw consent at any time where processing is based on consent

To exercise your rights, please email info@hdsindex.com.

We will respond within the timeframe required by applicable law.

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our services, legal requirements or processing activities.

The updated version will always be published on this page with the relevant revision date.

12. Contact

For any questions regarding this Privacy Policy or our privacy practices, please contact:

HDS Index
Via San Fabiano, 9
00165 Rome, Italy

Email: info@hdsindex.com

Privacy enquiries: info@hdsindex.com