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Privacy Policy

This policy describes how Lapland Host Oy processes personal data in the Turnlap application (web + iOS + Android). It is based on the EU General Data Protection Regulation (GDPR), the Finnish Data Protection Act (1050/2018), the Act on the Protection of Privacy in Working Life (759/2004), and Apple’s App Store Review Guidelines 5.1 requirements.

Summary (guests)

Lapland Host Oy (Rovaniemi, Finland) is the data controller. As a guest we process your name, contact details and booking dates received from the booking platform (Hostaway) to prepare the property, send door codes and handle your messages and orders in the guest portal. Data is stored in the EU. Some processing uses an AI assistant (Anthropic, USA) without your name; WiFi passwords and door codes are never sent to it. You have the right to access, correct and delete your data: [email protected].

1. Data controller

Lapland Host Oy
Pohjolankatu 12, 96100 Rovaniemi
Business ID: 3543315-6
For data protection matters: [email protected]
General contact: [email protected]

Processor (GDPR Art. 28): the Turnlap service is provided by Lepoku Oy (Business ID 3648958-1, Rovaniemi, Finland, [email protected]). Lapland Host Oy is the data controller and decides the purposes and means of processing; the service provider processes data on the controller’s behalf under the service agreement and a data processing agreement (DPA).

2. What personal data is collected

About cleaners (employees)

About guests (in connection with reservations)

About property owners and customers (including prospective customers)

3. Where the data comes from

4. Purposes of processing

5. Legal basis for processing

6. Retention periods

7. Who the data is disclosed to (third parties)

Turnlap uses the following technical providers (sub-processors):

The application also has the following services integrated, which are not currently in use (no API key / feature switched off). Before any of them is activated, this policy will be updated and a data processing agreement will be signed with the provider: OpenAI (knowledge-base search index, USA), Resend (email notifications, USA), Telegram (admin alert channel, outside the EU). Google Distance Matrix (driving-route durations) processes only property coordinates, not personal data.

Data is not sold to third parties. Data is not used for advertising or profiling.

8. Transfer of data outside the EU

All primary databases are located in the EU (Supabase: AWS eu-west-1, Ireland; server: Hetzner, Helsinki; error reporting: Sentry’s EU data location, Frankfurt). Data is transferred outside the EU to the following processors:

No other transfers outside the EU are made. Transfer impact assessments (TIAs) and processing agreements are available on request.

9. Data subject rights

Under the GDPR, you have the following rights:

10. Automated decision-making

The Turnlap shift algorithm suggests how cleanings are allocated among employees. Final confirmation is always made by a supervisor — the algorithm does not on its own make legal decisions concerning an employee. The algorithm uses as inputs the cleaner’s speed index, cluster skills, working-hour limits, and the MaRa collective agreement overtime threshold.

11. Data security

12. Children

Turnlap is intended for adult employees (aged 18 and over). The application is not marketed to children and does not collect data from anyone under the age of 16.

13. Use of mobile app permissions

14. Cookies and similar technology (web)

15. Changes to this policy

This policy may be updated as needed. Material changes are announced in the application, and users may be asked to acknowledge the new version. Earlier versions are archived and made available on request.


Updated: 12 September 2026 · Version 2026-09-12-v3
Related specific policy: Processing of location data