Privacy Policy
— Haliblu Reception App

Last updated: February 2026

1. Data Controller

HALIBLU GmbH Goetenkamp 30 22927 Grosshansdorf Germany

2. Overview

The Haliblu Reception App (“App”) is used for digital capture of guest documents as part of the check-in process. This privacy policy informs you about what data the App collects and how it is processed.

3. What Data Is Processed?

3.1 Document Scans

The App captures photos of the following documents when requested by the accommodation provider:

Passport / ID card
Dive certificates
Medical certificates
Insurance documents

These images may contain personal data (name, date of birth, photograph, document number).

3.2 Technical Data

QR code contents: Stay number and document type (from the QR code provided by the establishment)
Upload status: Timestamps and transfer status, stored locally on the device

3.3 Data NOT Collected

No location data
No device identifiers or advertising IDs
No usage analytics (no analytics, no tracking)
No data shared with third parties (no Firebase, no Google Analytics)

4. Purpose and Legal Basis

Purpose

Legal basis (GDPR)

Compliance with registration obligations under German Federal Registration Act (BMG)

Art. 6(1)(c) (legal obligation)

Performance of the accommodation contract

Art. 6(1)(b) (contractual necessity)

Verification of qualifications (e.g., dive certification)

Art. 6(1)(f) (legitimate interest in guest safety)

5. Data Processing in Detail

5.1 On-Device Processing

QR code recognition: Performed entirely on the device using Google ML Kit Barcode Scanning. No image data is transmitted to Google.
Document scanning: Performed entirely on the device using Google ML Kit Document Scanner. Edge detection, perspective correction, and image enhancement all run locally. No image data is transmitted to Google.

5.2 Local Storage

Scanned documents are temporarily stored in the App’s internal storage until the upload to the server is completed. After successful upload, the local file is automatically deleted.

5.3 Data Transmission

Document scans are transmitted via encrypted connection (HTTPS) to the servers of Haliblu GmbH. The server is located within the European Union. No transfer to third countries takes place.

6. Retention Period

Data

Retention period

Local photo file on the device

Until successful upload (automatic deletion)

Upload queue (device)

Until processed; completed entries can be manually deleted

Documents on the server

In accordance with the accommodation provider’s retention policy and legal requirements

7. Permissions

Permission

Purpose

Camera

QR code scanning and document scanning

Internet

Uploading scanned documents to the server

8. Your Rights

You have the following rights regarding your personal data vis-a-vis Haliblu GmbH:

Access (Art. 15 GDPR)
Rectification (Art. 16 GDPR)
Erasure (Art. 17 GDPR)
Restriction of processing (Art. 18 GDPR)
Data portability (Art. 20 GDPR)
Objection (Art. 21 GDPR)

Contact: datenschutz@haliblu.com

You also have the right to lodge a complaint with a data protection supervisory authority.

9. Changes

We reserve the right to update this privacy policy to reflect changes in the law or changes to the App. The current version is always available within the App and on the Google Play Store.

​​

Privacy Policy — Haliblu Reception App