Privacy policy.

Who we are, and what this covers.

HotelStack Pty Ltd (ACN 700 901 248, ABN 90 700 901 248) of Melbourne, Australia (“HotelStack”, “we”, “us”) runs hotelstack.ai and DRiP, the data room at drip.hotelstack.ai. We handle personal information in line with the Australian Privacy Principles in the Privacy Act 1988 (Cth).[SOLICITOR / JAMES: is HotelStack an APP entity, or covered by the small business exemption? If exempt, do we opt in under s 6EA, or say we follow the APPs voluntarily?]

This policy covers personal information we handle for our own purposes: visitors to this site, people who contact us, the people we deal with at customers and partners, and guests invited into a DRiP data room.

It does not cover the data hotels and owners put into our products (ViP, HiP, AiP, PiP and Boardroom). We handle that data on their behalf and on their instructions, under our agreement with them. Their own privacy policy applies to their guests and staff.[SOLICITOR: confirm this framing. No standard customer data processing terms are published yet.]

In a DRiP data room, we run the room on behalf of the room owner, who invites you. The terms of access you accept when you sign in say that HotelStack handles your personal information under this policy. The room owner can also see the record of your activity described below.[SOLICITOR: confirm how HotelStack and the room owner each stand towards the DRiP access record, and whether the room owner’s own privacy policy should also be named.]

What we collect, and how.

When you visit this site

Our analytics run on our own server (Umami, in our DigitalOcean Sydney account). They set no cookies. They count the pages viewed, where visitors came from, and the type of browser, device and country, and they are not used to identify you. No third-party trackers, no advertising pixels, no cross-site profiling.

Our hosting provider receives your IP address in order to deliver the page, and its edge network sets one short-lived bot-management cookie that carries no identity.[JAMES: confirm whether we can see or keep the hosting provider’s request logs, and for how long.]

When you write to us

The contact form asks for your name, your work email, your organisation (optional) and your message. Before it sends, Cloudflare Turnstile checks that you are not a bot; it receives your IP address and signals from your browser. Your message then becomes one email to [email protected], sent through Resend from our own domain. We keep no database of enquiries and use no marketing tool. The same applies if you email us directly: we hold what you send in our mailbox.

When we work with you

If you work for a customer, a prospective customer, a supplier or a partner, we hold your name, work contact details and our correspondence with you, so that we can do business with your organisation.

When you are invited into a DRiP data room

The room owner gives us your name, organisation and email address, so that we can invite you by name. We use your email address to send the invitation and each one-time sign-in code. There is no password. While you are signed in, a session cookie keeps you signed in to the room.

When you use a room, we record it against your name, organisation and email address: each sign-in code we send you, each sign-in and failed sign-in, your acceptance of the terms of access (the version and the time), each time you open the room’s index, view or download a document or download a zip, and any attempt the room refuses. Each record carries the time, your IP address and your browser, and, where it applies, the release and the reference stamped on the document. Each PDF you view or download is stamped with your name, organisation and email address, the time and a unique reference. More on this record is on our Trust page.

What we do not ask for

We do not ask for sensitive information, such as health information, and this site takes no payments. Please do not send sensitive information through the contact form.

Staying anonymous

You can read this site without telling us who you are, and you can write to us under a pseudonym if you prefer, though we need an email address to reply. A DRiP data room cannot be used anonymously: the room owner invites people by name, and the record of who has seen what is the reason the room exists.

Why we use it.

• To reply to you, and to deal with you and your organisation.
• To run this site, keep it secure and understand, in aggregate, how it is used.
• In DRiP: to invite you and sign you in, to control who sees which documents, to secure the room, to show the room owner who has seen what, and to trace a stamped document back to the view or download it came from.
• To meet our legal obligations, and to establish or defend a legal claim.

We do not sell personal information, and we do not add the people who contact us, or DRiP guests, to a marketing list.[JAMES: confirm both. If we will ever send marketing, the APP 7 consent and opt-out wording goes here.]

[SOLICITOR: automated decisions (APP 1.7 to 1.9, from 10 December 2026). DRiP refuses sign-in automatically after repeated wrong codes, and refuses requests over a rate limit. Do these need to be disclosed here? Suggested wording: “DRiP automatically blocks sign-in for a period after repeated wrong codes, to protect the room. A person can lift the block on request.”]

Who else receives it.

• The room owner. The room owner’s administrators can see and export the record of your activity in their DRiP data room.
• Our service providers, listed below, who host, deliver and protect our systems for us.
• Authorities, where the law requires or authorises it.
• [SOLICITOR / JAMES: any others to name, such as professional advisers, insurers, or a buyer of the business.]

Overseas.

The data stored in our own systems, including the DRiP access record, is stored in DigitalOcean’s Sydney region. Some of our providers process personal information outside Australia, as follows.

DigitalOcean, LLC

Hosts this site, the contact form function, our analytics server and DRiP, including the DRiP access record.

Stored in Sydney, Australia. The company is incorporated in the United States.

Resend, Inc.

Delivers email: contact-form messages to our inbox, and DRiP invitations and sign-in codes to you.

United States [JAMES: confirm the Resend account’s configured region]

Cloudflare, Inc.

Turnstile, the bot check on the contact form. It receives your IP address and browser signals.

United States and Cloudflare’s global network

Google LLC (Google Workspace)

Our email. Messages you send us, by the form or directly, are held in our mailbox.

To be confirmed [JAMES: where Workspace stores our mail (a data region, if one is set)]

[SOLICITOR: the APP 8 position for each provider, and whether a US-incorporated provider holding data in Sydney needs saying more plainly than this.]

Security.

Every request to this site and to DRiP is served over HTTPS. The site runs under a Content Security Policy that only allows scripts from us, our own analytics and the bot check on the contact form. DRiP is open only to people invited by name, signs them in with one-time codes sent to their email address, stamps each PDF with the viewer’s identity, and keeps its access record append-only, so that it cannot be edited or deleted in the normal running of the room. What we can prove today, and what we are still building, is set out on our Trust page.

If a data breach is likely to cause serious harm to you, we will tell you and the Office of the Australian Information Commissioner, as the Notifiable Data Breaches scheme requires.[SOLICITOR: this follows from the APP-entity answer above.]

How long we keep it.

We keep personal information only while we need it for the purposes above or the law requires it, and then delete or de-identify it. Our published retention schedule is still in progress.

• Messages you send us: [JAMES: period.]
• The DRiP access record: kept after the room closes.[JAMES / SOLICITOR: period. Seven years has been suggested and is not confirmed.]
• DRiP guest details (name, organisation, email):[JAMES: period after the room closes.]
• Analytics: [JAMES: period.]

Seeing and correcting what we hold.

You can ask for the personal information we hold about you, including the DRiP record of your activity, and ask us to correct it. Write to [email protected]. We will confirm who you are before we release anything, and reply within[JAMES: 30 days]. There is no charge for asking. If we refuse, we will tell you why and how to complain.

The DRiP access record is append-only, so an entry cannot be edited. If you show us that an entry is wrong, we will add a note to it that says so.[JAMES: confirm the app can attach such a note, or say how a correction will be recorded.]

Complaints.

If you think we have mishandled your personal information, write to us first at [email protected]. We will look into it and reply in writing within[JAMES: 30 days].

If you are not satisfied with our answer, you can complain to the Office of the Australian Information Commissioner (OAIC): oaic.gov.au, or 1300 363 992.

Contact.

Privacy questions, requests and complaints: [email protected].[JAMES: the named person or role who handles privacy, and a postal address.]

We may update this policy. The version and date at the top say which one you are reading.