Orapera Privacy Center

1. Overview & Operational Scope

Orapera (“Orapera”, “we”, “us”, or “our”) provides a specialised B2B cloud operating system engineered for Destination Management Companies (DMCs), MICE companies, incoming tour operators, and bespoke travel designers. Our software suite encompasses Client & Trip CRM (All Tickets), Approved Destination Inventory, AI-Assisted Itinerary Assembly, Digital Proposal Generation, Interactive Client Portals, Supplier Dispatch, and Costing & Invoicing engines.

Because travel businesses handle complex webs of confidential commercial rates, multi-country passenger records, and proprietary destination knowledge, we have built Orapera around principles of absolute tenant segregation, zero data leakage, and rigorous compliance with international privacy frameworks including the General Data Protection Regulation (EU GDPR), the UK Data Protection Act 2018 (UK DPA), and the California Consumer Privacy Act (CCPA/CPRA).

2. Data Roles: Controller vs. Processor

Data protection laws distinguish between the entity that determines the purposes of processing (“Data Controller”) and the entity that executes processing strictly on the controller’s behalf (“Data Processor”):

• You as Data Controller: When you input passenger manifests, corporate client attendee lists, traveller passport details, rooming lists, or bespoke travel preferences into Orapera, your organization acts as the Data Controller. You retain exclusive authority over what data is gathered, how long it is kept, and the legal basis (such as contract fulfillment or traveller consent) under which it was obtained.
• Orapera as Data Processor: In respect of all Customer Data and Passenger PII processed within your workspace, Orapera functions strictly as a Data Processor pursuant to Article 28 of the GDPR. We process such data solely in accordance with your documented instructions and the provisions of our Data Processing Agreement (DPA). We never monetize, rent, aggregate, or repurpose your data.
• Orapera as Independent Controller: We act as an independent controller only with respect to your workspace account administrators’ direct business contact details (e.g., billing email, subscription management information) for the purpose of servicing your commercial contract.

3. Strict Supplier Net Rate Isolation & Commercial Secrecy

In the inbound and luxury travel sectors, negotiated supplier net rates (hotel contract tariffs, private yacht charter fees, licensed guide per diems, and transport day-rates) represent a travel company’s most sensitive commercial intellectual property. A leak or exposure of net supplier costs destroys agency margins and breaches vendor confidentiality agreements.

Orapera provides the following binding architectural and contractual commitments regarding Supplier Net Rates:

4. Passenger Personal Data & Travel Manifests (PII)

To deliver bespoke itineraries, vouchers, rooming manifests, and transport dispatches, Orapera allows operators to collect and manage passenger personal data. We categorize and protect this data under stringent standards:

• Traveller Identification: Legal name, nationality, date of birth, passport number, passport expiry, and issue country (frequently required by ground authorities, national parks, and international hotel check-in regulations).
• Flight & Transit Details: Inbound and outbound flight numbers, airline identifiers, arrival times, and luggage counts used for automated airport transfer coordination.
• Special Category Data (Health & Dietary Preferences): Food allergies, mobility accommodations, and dietary restrictions provided by travellers. Under GDPR Art. 9, this data is treated with heightened safeguards, encrypted at rest, and accessible only to users with operational dispatch credentials.
• Corporate MICE Attendee Rosters: Group manifests containing company affiliations, badge titles, and multi-hotel rooming assignments for incentive programmes and conferences.

All passenger data entered into Orapera is encrypted both in transit using Transport Layer Security (TLS 1.3) and at rest using AES-256 encryption.

5. AI Itinerary Engine & Zero-Model Training Guarantee

Orapera includes an AI Itinerary Builder designed to draft multi-day corporate incentive programmes and leisure itineraries in seconds. Because operators routinely feed proprietary client briefs, executive guest preferences, and budget targets into our prompts, we enforce strict model usage hygiene:

• Strict Retrieval-Augmented Grounding (RAG): Our AI does not generate fictitious hotel recommendations. It matches prompts strictly against your own curated, approved Destination Inventory database and historical day templates.
• No Model Retraining: We contractually prohibit our LLM infrastructure providers from retaining, caching, or using any Customer Data, itinerary text, prompt inputs, or generated output for foundational model training, weight adjustment, or algorithmic fine-tuning.
• Zero Data Persistence at Model Endpoints: Prompts sent to model inference APIs are processed statelessly under enterprise agreements with zero data logging (ZDL) guarantees.
• Human Specialist Oversight: Orapera’s AI acts solely as an drafting accelerator. Every itinerary proposal remains fully editable by your travel designers prior to client presentation or vendor booking dispatch.

6. Subprocessors & Cloud Infrastructure

To provide high-availability SaaS infrastructure, Orapera engages vetted third-party service providers (“Subprocessors”). Each subprocessor undergoes rigorous security vetting, enters into comprehensive data processing agreements, and maintains independent compliance certifications (SOC 2 Type II, ISO 27001):

7. Cross-Border Transfers & Standard Contractual Clauses (SCCs)

Inbound travel is an inherently international commerce: an agency based in the United Kingdom or Germany may orchestrate an itinerary for an American corporate group travelling through Italy, Japan, or South Africa. Data necessarily travels across borders.

Where passenger data originates in the European Economic Area (EEA), the United Kingdom, or Switzerland and is accessed from or transferred to a country that has not received an adequacy decision from the European Commission, Orapera incorporates the European Commission’s Standard Contractual Clauses (SCCs) (Module 2: Controller-to-Processor) and the UK Information Commissioner’s International Data Transfer Addendum into our standard DPA.

8. Security Architecture, Encryption & Access Controls

We employ defense-in-depth security principles to safeguard your workspace from unauthorized access, breach, or loss:

• End-to-End Encryption: All HTTP communications are forced over HTTPS via TLS 1.3 with strict HSTS headers. All persistent database records, snapshots, and attached files (e.g., supplier contracts, passport scans) are encrypted using AES-256 keys.
• Role-Based Access Control (RBAC): Granular permissions permit administrators to segregate duties between Sales, Operations, Dispatch, and Accounting personnel.
• Continuous Monitoring & Audit Logging: Activity logs trace proposal creation, voucher generation, price model modifications, and export requests for enterprise security auditing.
• Automated Backups: Point-in-time database snapshots are performed daily and distributed across geographically separate cloud availability zones with automated disaster recovery procedures.

9. Data Retention, Portability & Deletion

Your data belongs entirely to you. You retain full freedom to export your itineraries, supplier catalogs, client records, and proposal histories at any time in industry-standard formats (CSV, JSON, and formatted PDF).

Upon account termination or subscription expiry:

• 30-Day Retrieval Grace Window: Your workspace remains accessible in read-only mode for 30 calendar days to enable your team to download all historical archives, booking manifests, and supplier rosters.
• Irreversible Cryptographic Deletion: After 60 calendar days following termination, all tenant database records and stored passenger records are permanently purged and overwritten across active databases in compliance with NIST SP 800-88 guidelines.

10. Data Subject Rights & Contacting our DPO

Under the GDPR, UK DPA, and other global data privacy regulations, data subjects (including your travellers and staff) maintain rights to access, rectify, port, restrict, or erase their personal data.

Because you are the Data Controller of passenger information, any direct passenger inquiry received by Orapera will be promptly forwarded to your registered workspace administrator for resolution. We provide self-service tooling within Orapera to assist you in fulfilling erasure or export requests within the statutory 30-day window.