Compliance

Data protection, in practice

Last updated 1 September 2026

Before you launch: the postal address and the grievance officer’s name and email below are placeholders. They are legally required to be real and reachable. Replace them, and have a lawyer read this page — it describes the system accurately, which is not the same as being legal advice.

The privacy policy says what we collect. This page says how the system actually enforces it, because a policy nothing implements is a sentence, not a protection.

Who is responsible for what

Role	Who
Data Fiduciary — for guest data	The resort. They decide what to collect and why.
Data Processor	MyBills Technologies. We act on the resort’s instructions.
Data Fiduciary — for account data	MyBills Technologies, for the details of the staff who hold accounts with us.

Consent, where it is actually required

An identity document cannot be stored without the guest agreeing at the moment of capture. The consent is recorded with the document, not buried in terms accepted elsewhere, and an upload without it is refused by the server rather than the screen.

Purpose limitation

Guest data is reachable only within the resort that collected it.
Our own operators cannot read guest data at all. The console shows counts, statuses and money — never a guest name, phone number or document.
A support session is read-only, lasts fifteen minutes, requires a stated reason, carries no access to phone numbers or documents, and is recorded in both our audit trail and the resort’s own.

Storage limitation

Identity documents carry an expiry stamped on each one and are swept automatically. Deletion removes the stored file, not just the row pointing at it.

Rights, and how they are served

Right	How
Access	A resort can export its data at any time. A guest asks the resort, or us.
Correction	Editable in the app; write to us for account details.
Erasure	Documents are deleted on request, with a reason recorded. Records law requires us to keep are named in the privacy policy.
Grievance	Our Grievance Officer, named on the privacy page, answering within 30 days.

Breach

If personal data is exposed we notify the Data Protection Board and the people affected as the Act requires. Monitoring runs every five minutes and alerts on state change; a monitor that has stopped reporting is itself treated as a failure.