Privacy Policy

Last updated: September 2026 FLIP DIRECT PRIVACY POLICY Hospitality Analysts Pty Ltd (operating as Flip Direct) is committed to protecting the privacy of every guest, property manager, and agent who interacts with our platform. This policy explains what data we collect, how we use it, and the rights you have under Australian, New Zealand, European, and United States privacy laws. 1. Who we are Flip Direct is a product of Hospitality Analysts Pty Ltd. We help accommodation properties convert OTA (Online Travel Agent) bookings into direct bookings by capturing real guest contact details at check-in, delivering post-stay rebooking incentives, and tracking the OTA commission recovered on every flip. References to "we", "us" or "our" refer to Flip Direct and Hospitality Analysts Pty Ltd. 2. What personal information we collect Guest information: - Full name, email address, and phone number captured at check-in (replacing the masked OTA email with a real contact). - Stay dates, room type, booking source (OTA channel), and booking value. - Loyalty program membership and points balance. - Referral codes and feedback submissions. Property manager information: - Name, email, phone, and role at the property. - Property details including name, address, room count, and PMS connection credentials. - Rate plans, competitor rate data, and revenue forecasts. Agent information: - Name, email, phone, agency name, region, and sales experience submitted via the agent sign-up form. 3. How we collect your information - Directly from guests: when they check in (front desk or self-service QR), sign up for the loyalty program, or submit feedback. - From property staff: when they enter guest details into the registration card at check-in. - From integrated systems: bookings and rates pulled from the property's PMS or channel manager (Channex, SiteMinder, Cloudbeds, RMS Cloud, Little Hotelier, Guesty). - From the Flip Direct widget: when a guest interacts with the rate-comparison widget on the property's website. - From agent applications: when a sales agent submits the sign-up form. 4. How we use your information For guests: - To deliver the post-stay flip sequence (thank-you message, rebooking bonus, loyalty points). - To track OTA commission recovered on flipped bookings (the Flip Attribution Ledger). - To send rebooking incentives and loyalty program communications via in-app notifications. - To personalise the guest's next direct booking experience. For property managers: - To provide the Flip Direct dashboard, widget, QR cards, and compliance reporting. - To track subscription status and enforce the subscription gate server-side. - To generate commission recovery reports and ROI dashboards. For agents: - To review agent applications and contact approved agents about partnership opportunities. 5. Disclosure of your information We may share your information with: - The property you booked with (they are the primary controller of your guest data). - The property's PMS or channel manager (when integrated). - Law enforcement or regulatory bodies when required by law. We do NOT sell or licence guest data to third parties. We do NOT use one property's data to train shared models that benefit competitors. 6. Cross-border data transfers Flip Direct stores and processes data primarily within Australia. For properties in New Zealand, data may be transferred between Australia and New Zealand in compliance with both countries' privacy laws. For guests booking from the European Union, we comply with the General Data Protection Regulation (GDPR) — see Section 9 for your GDPR rights. For guests in the United States, we comply with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) where applicable, plus applicable federal privacy laws. 7. Data retention - Guest data: retained for the period the property uses Flip Direct, plus up to 7 years for tax and legal compliance. - The Flip Attribution Ledger is retained by the platform even if a property stops using Flip Direct — this is the platform's compounding data asset and powers commission recovery ROI reporting. - Agent application data: retained for 2 years after submission. - Usage and analytics data: retained for as long as necessary, then anonymised or deleted. 8. Data security We employ industry-standard security measures including encryption in transit (TLS) and at rest, robust access controls, and least-privilege access. We do not store full credit card numbers. 9. Your rights Australian and New Zealand residents: - Access your personal information held by us. - Request correction of inaccurate information. - Request deletion of your data, subject to legal retention obligations. - Opt out of marketing communications at any time. - Lodge a complaint with the OAIC (Australia) or the Office of the Privacy Commissioner (New Zealand). European Union residents (GDPR): - Right of access, rectification, erasure, and restriction of processing. - Right to data portability. - Right to object to processing and withdraw consent. - Right to lodge a complaint with your supervisory authority. United States residents (CCPA/CPRA): - Right to know what personal information is collected, sold, or shared. - Right to delete your personal information. - Right to opt out of the sale or sharing of personal information. - Right to non-discrimination for exercising your privacy rights. 10. Cookies and local storage We use cookies and local storage to keep you logged in, remember your preferences, and maintain session security. You can manage cookies through your browser settings. Disabling cookies may affect some features. 11. Children's privacy Flip Direct is not directed at children under 13. We do not knowingly collect personal information from children. 12. Changes to this policy We may update this policy from time to time. We will post the revised version on this page and update the "Last updated" date. Continued use of Flip Direct after changes constitutes acceptance. 13. Contact For privacy enquiries, contact the property you booked with directly, or reach out to Hospitality Analysts Pty Ltd via the Contact us page on our website.