SCANwelcome · Legal information
Privacy Policy
How SCANwelcome processes personal data of users, visitors and people accessing digital guides.
Version SW-PUBLIC-2026-11-08-V2 · Effective from 8 November 2026
01
Controller and contact
For the website and business accounts, the controller is INITIO, spletne storitve d.o.o., Brnčičeva ulica 13, SI-1231 Ljubljana – Črnuče, Slovenia. Privacy enquiries: [email protected].
02
Controller and processor roles
SCANwelcome generally acts as controller for its website and business accounts. When an accommodation provider adds personal information about guests to its guide, SCANwelcome may act as processor under the provider agreement. The role depends on the actual processing.
03
Information we process
Depending on use, information may include names and business contact details, company information, user accounts, accommodation and guide content, support messages, security logs and billing records. SCANwelcome does not request payment card details through its ordinary forms.
04
Purposes and legal grounds
We process data to perform business agreements (GDPR Article 6(1)(b)), meet legal obligations (6(1)(c)), protect security and prevent abuse under legitimate interests (6(1)(f)), and conduct optional analytics solely with consent (6(1)(a)). Legitimate interests are assessed where required.
05
Recipients and services
Service providers include hosting and infrastructure providers, Cloudflare for network protection, Postmark for email delivery, Stripe for payments and Quibi for invoicing. When AI is used, selected text and instructions are sent to the AI provider used for that task. Google receives public-website analytics data only when analytics is configured and you have consented. We disclose information needed for each service; the recipient’s legal role depends on the activity.
06
Retention
Account and guide data are retained to perform the agreement and manage access. Setup materials and correspondence are retained while needed for delivery, support and claims. Invoices and transaction records follow applicable accounting and tax retention requirements. Security logs are limited to the needs of incident detection and handling; backups are replaced in the normal cycle. A specific dispute or legal obligation may require longer retention. For the retention period applicable to your data, contact [email protected].
07
Personal setup and AI
For personal setup we process the supplied information, photographs, logos, rules and instructions to prepare the agreed guide. Where these contain employees’ or other people’s personal data, the customer must have an appropriate legal basis for disclosure and publication. Materials are used to fulfil the order; selected text may be processed with AI for preparation and translation. Do not send guest data, identity documents or account passwords.
08
International transfers
Some providers may process data outside the European Economic Area. Such transfers require an appropriate basis under Chapter V GDPR, such as a valid adequacy decision or standard contractual clauses with supplementary safeguards where required. You can request information about the recipient, country and transfer basis for a particular processing activity, and how to access the safeguards, at [email protected].
09
Required data and automation
Information necessary for account creation, billing and ordered setup is a contractual or statutory requirement; without it we cannot perform the relevant service. Analytics is optional. AI assists with text preparation and translation; it does not itself make decisions with legal or similarly significant effects on individuals.
10
Your rights
Subject to GDPR conditions, you may request access, rectification, erasure, restriction, portability or object to processing. Consent may be withdrawn at any time without affecting earlier lawful processing. You may complain to the Slovenian Information Commissioner.
11
Security and updates
We apply technical and organisational safeguards, although absolute security cannot be guaranteed. Material updates will be reflected in a dated revision.