1. Sub-processors for all customers
- Contabo GmbH – STRYK server hosting – all Processed Data – Processing area: European Union (provider default region).
- Hetzner Online GmbH – encrypted backups – all Processed Data in encrypted form – Processing area: European Union (Germany or Finland).
- Cloudflare group of companies (contracting party: Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, US) – DNS, delivery, TLS termination, protection against abusive traffic and connection of the hotels’ own domains – connection and network data and the content transmitted during transmission – Location: global network including the USA – Basis: EU-US Data Privacy Framework and standard contractual clauses.
- Nextpulse / STRATO GmbH – dispatch of the hotels’ e-mails to guests – recipient addresses, message content, delivery data – Location: Germany – Basis: Art. 28 EU 2016/679.
- 1blu GmbH, Riedemannweg 60, 13627 Berlin, DE – Nextpulse ID – User, profile and sign-in data – Germany; Art. 28 EU 2016/679; 1blu.de.
2. Sub-processors where certain functions are used
- Anthropic PBC (USA) – main provider of the AI functions: guest AI, support assistant, receipt recognition, management analyses and website analysis – message content, guest and booking context, receipts and documents, insofar as required for the function – Location: USA and further Anthropic locations – Basis: EU-US Data Privacy Framework and standard contractual clauses. Only where AI functions are used.
- OpenAI (OpenAI Ireland Ltd., IE) – fallback provider for the AI functions if Anthropic is unreachable, and embeddings for the hotel knowledge search – message content, guest and booking context, receipts and documents, insofar as required for the function – Location: USA and further OpenAI locations – Basis: EU-US Data Privacy Framework and standard contractual clauses. Only where AI functions are used.
- Channex (Channex.io LTD, Castell Pigyn Lodge, Abergwili, Carmarthen, SA31 2JL, UK; support@channex.io) – channel manager: transmission of availability, prices and reservations between STRYK and booking platforms – reservation and guest data of bookings received via booking platforms – Location: European Union – Basis: Art. 45/46 EU 2016/679; EU-SCC 2021/914. Only where the channel manager is used. The contracts with the booking platforms themselves are concluded by the hotel.
3. Services operated by Nextpulse itself
Nextpulse operates Nextpulse ID itself with 1blu. The processing area is listed under the hosting provider. Uploaded files are scanned for malware by a self-operated component, without transfer to third parties.
Nextpulse sends guest emails through its own mail server hosted by STRATO GmbH in Germany.
4. Service providers for Nextpulse’s own purposes
The following service providers support Nextpulse in its own processing as controller, for example in contract administration, billing and communication with customers. They do not process Processed Data, unless the customer transmits such data in a support request by e-mail.
- Odoo S.A., Belgium – customer management, offers, contracts, billing and ticket management – customer, contact, contract and billing data – Location: Odoo Online (SaaS), European cloud region; existing environments may retain additional backups in Canada during the transition described by Odoo; access by Odoo affiliates under its privacy policy – Basis: processing within the EEA or safeguards under Art. 44 et seq. GDPR.
- IONOS SE, Germany – e-mail service of Nextpulse GmbH for enquiries and business communication – contact data and message content – Location: EEA.
- Anthropic (main provider) or OpenAI (fallback provider if Anthropic is unreachable) – support assistant on staystryk.com and in the product – content of support requests – Location and basis as stated in section 2.
5. Independent contracting parties of the hotel
The following providers are not sub-processors of Nextpulse. The hotel concludes its own contracts with them or uses its own official channels; they process data under their own terms and data protection roles. STRYK merely provides the technical connection.
- Mollie B.V., Netherlands – the hotel’s payment service provider for online payments by guests, on the basis of the merchant agreement between the hotel and Mollie.
- Booking platforms and online travel agencies – contracting parties of the hotel for the distribution of rooms.
- feratel or Deskline, as well as authority and tourism portals – transmission of guest registrations and local or tourism levies on behalf of and under the responsibility of the hotel.
- Cash register, locking, telephone and other systems selected by the hotel.
- GoCardless SAS, France – account information service for the optional bank connection. GoCardless processes account data as an independent controller under its Bank Account Data terms. The account holder authorises account access directly with GoCardless. Privacy and data subject rights: gocardless.com/privacy/.
6. Changes
Nextpulse informs customers in accordance with the Data Processing Agreement at least 30 days before engaging new sub-processors or replacing existing ones. The current version of this list is available here.