Data Processing Agreement (DPA)

Standard Contractual Terms Governing Hotelier Data Controllers & Sovereign Cloud Processing

Executive Scope & Controller Warranties

This Data Processing Agreement (“DPA”) supplements the Grandeur Royal Master Services Agreement. It applies to all processing of Personal Data performed by Grandeur Royal on behalf of the Hotelier (“Customer” or “Controller”) through our cloud PMS, offline edge terminals, and direct booking engine.

1. Technical & Organizational Measures (TOMs)

Grandeur Royal implements and maintains state-of-the-art security safeguards designed to protect guest records against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure:

Cryptographic Isolation

Tenant-level row isolation and unique cryptographic database encryption keys per property.

Encryption In Transit & At Rest

Enforced TLS 1.3 for all REST API endpoints and AES-256-GCM for all cloud & local SQLite databases.

Role-Based Access Control (RBAC)

Strict staff authorization scopes (Front Desk, Night Audit, Concierge, Master Operator).

Immutable Audit Logging

Cryptographically signed audit trails for every keycard issued, rate plan altered, or folio charged.

2. Authorized Sub-processors

Controller grants general written authorization to engage the following sub-processors to deliver core cloud capabilities. All sub-processors are bound by data protection obligations no less stringent than those in this DPA:

Sub-processor	Corporate Entity	Role / Purpose	Data Center Region
Amazon Web Services (AWS)	AWS EMEA SARL	Encrypted Cloud Hosting & S3 Vaults	Frankfurt & Zurich (EEA/CH)
Cloudflare Inc.	Cloudflare Inc.	Global Anycast CDN, DDoS Defense & Edge SSL	Global Edge (310+ Cities)
Stripe Payments Europe Ltd.	Stripe Ireland Ltd.	PCI-DSS Level 1 Payment Tokenization	Dublin, Ireland (EEA)
Resend Inc.	Resend Technologies	Transactional Guest Email Delivery (SMTP/DKIM)	Frankfurt & US (SCCs)

3. 24-Hour Security Breach Notification

Grandeur Royal shall notify Controller without undue delay and, in any event, within twenty-four (24) hours of becoming aware of any confirmed Personal Data breach affecting Controller's hotel records. The notification shall detail the nature of the breach, affected key counts, and remediation actions deployed.

4. Return & Deletion of Personal Data

Upon termination of the Master Services Agreement, Grandeur Royal shall, at the choice of the Controller, delete or return all guest dossiers and reservation folios in standardized formats within 30 days, unless applicable European Union or Member State law requires perpetual archiving of tax records.