Data Processing Agreement

This page is a public overview of Cnykra’s Data Processing Agreement (“DPA”), not the executed contract itself. The DPA is a legal document entered into as part of, and annexed to, the Terms of Service governing a hotel’s subscription to the Cnykra platform — it is not published as website prose.

Roles

As explained in our Privacy Policy, Cnykra plays two different roles under the Digital Personal Data Protection Act, 2023, depending on whose data is at issue. For hotel guest data, the hotel is the Data Fiduciary (the party that decides why and how guest data is processed) and Cnykra is the Data Processor (processing that data only on the hotel’s documented instructions, to provide the Services). The DPA is the contract that governs this relationship for every hotel on the platform.

What the DPA covers

The executed DPA sets out, among other things:

• the scope and purpose of processing guest personal data through the Services (reservations, booking confirmations, guest messaging, channel distribution, statutory reporting, and related functionality);
• Cnykra’s obligations as Processor — processing only on instruction, confidentiality, security measures, and assistance with data-principal rights requests;
• sub-processor engagement and cross-border transfer disclosure (DPDP Act Section 16);
• breach notification timelines between Cnykra and the hotel;
• data return/deletion at the end of the relationship, subject to statutory retention.

Sub-processors

Cnykra engages a small number of specialist sub-processors to deliver the Services (infrastructure, WhatsApp messaging, AI model providers, and payment processing). The current sub-processor register is maintained separately and kept up to date without re-issuing this page — contact connect@cnykra.com for the current list.

Requesting the executable DPA

Every hotel that subscribes to Cnykra is entitled to the executable DPA, annexed to our Terms of Service. To request a copy, or to discuss its terms, email connect@cnykra.com.

See also: Privacy Policy · Trademarks