Privacy policy Holidu

Introduction and general information

Thank you for your interest in our website. The protection of your personal data is very important to us. In the following, you will find information on how we handle your data that is collected through your use of our website, as well as information on how we handle your data if you are a customer, interested party or business partner. Your data will be processed in accordance with the legal regulations on data protection.

Controller within the meaning of the GDPR

Holidu GmbH
Riesstraße 24
80992 Munich
service@holidu.com

Contact details of the data protection officer

Proliance GmbH / www.proliance.ai
Data Protection Officer
Leopoldstrasse 21
80802 Munich
datenschutzbeauftragter@proliance.ai
When contacting the Data Protection Officer, please state the company to which your enquiry relates. Please refrain from enclosing sensitive information, such as a copy of an ID card, with your request.

Definitions

Our privacy policy is intended to be simple and understandable for everyone. In this privacy policy, the official terms of the General Data Protection Regulation (GDPR) are generally used. The official definitions are explained in Art. 4 GDPR.

General information on data transfers to third countries

Your data may, where applicable, also be processed in countries outside the European Union (EU) and the European Economic Area (EEA).
For data transfers to certain third countries, an adequacy decision of the European Commission pursuant to Art. 45(1) GDPR may exist. Such a decision establishes that an adequate level of data protection exists in the third country. A list of the adequacy decisions adopted to date can be viewed at the following link: Data protection adequacy for non-EU countries.
The scope of an adequacy decision may also be limited to a specific group of recipients or made subject to further conditions.
For example, the adequacy decision for data transfers to the USA applies only to companies certified under the EU-U.S. Data Privacy Framework. The certification status of a participating company can be viewed at the following link: Participant Search (dataprivacyframework.gov).
When your data is transferred to recipients in third countries for which no adequacy decision exists, there is a risk that authorities there may access your data for security and surveillance purposes without you being informed or being able to seek legal remedies.
To safeguard an adequate level of data protection when transferring your data to recipients in such third countries, we therefore ensure that appropriate safeguards within the meaning of Art. 46 GDPR are in place.
As a rule, either we or the service providers we engage conclude Standard Contractual Clauses of the European Commission pursuant to Art. 46(2)(c) GDPR. They oblige the recipient of the data in the third country to process it in accordance with the European level of protection. The clauses can be viewed at the following link: Publications on the Standard Contractual Clauses (SCCs) - European Commission. If you require further information on the modules of the Standard Contractual Clauses we have concluded in individual cases or on supplementary measures, we will gladly provide you with a copy. In this case, simply contact us using the contact details given above under Controller.
In the case of certain recipients, data transfers may also be based on binding corporate rules (BCR) approved by the supervisory authorities pursuant to Art. 46(2)(b) GDPR. These can be viewed at the following link: Approved Binding Corporate Rules | European Data Protection Board.
Where the Standard Contractual Clauses or binding corporate rules are not sufficient to ensure the level of protection, additional technical, contractual or organisational measures are taken to safeguard the data transfer. In addition, it is regularly reviewed and assessed whether these additional measures continue to ensure a sufficient level of data protection or whether further supplementary measures need to be taken.
Further information on data transfers to third countries can be found, where relevant, below in the sections on data processing or the services used, under "Data Processing in Third Countries".

Access to and storage of information in terminal equipment

By using our website, information (e.g. IP address) may be accessed or stored (e.g. cookies) in your terminal equipment. This access or storage may involve further processing of personal data within the meaning of the GDPR.
In cases where such access to information or such storage of information is absolutely necessary for the technically error-free provision of our services, this is done on the basis of § 25 Abs. 2 Nr. 2 TDDDG.
In cases where such a process serves other purposes (e.g. the needs-based design of our website), this will only be carried out on the basis of § 25 Abs. 1 TDDDG with your consent in accordance with Art. 6(1)(a) GDPR. The consent can be revoked at any time for the future.
For further information on the processing of your personal data and the relevant legal bases in this context, please refer to the section "Cookies" below and the following sections on the specific processing activities on our website.

Web hosting

This website is hosted by an external service provider (Amazon Web Services). This website is hosted in Ireland. Personal data collected on this website is stored on the host's servers. This may include, but is not limited to, IP addresses, contact requests, meta and communication data, website traffic and other data generated by this website.
We collect the listed data in order to be able to guarantee a smooth connection setup of the website and a technically error-free provision of our services. The processing of this data is absolutely necessary to provide you with the website. The legal basis for the processing of the data is our legitimate interest in the correct presentation and functionality of our website in accordance with Art. 6(1)(f) GDPR.
We have concluded an order processing contract with the external service provider in accordance with the requirements of Art. 28 GDPR, in which we oblige the external service provider to protect our customers' data and not to pass it on to third parties.

Server log files

When you access our website, it is technically necessary for data to be transmitted to our web server via your internet browser. The following data is recorded during an ongoing connection for communication between your internet browser and our web server:
  • Date, time and duration of the request
  • Name of the requested file
  • Page from which the file was requested
  • Access status
  • Web browser and operating system used
  • (Complete) IP address of the requesting computer
  • Transmitted data volume
  • Http referrer and http-method
We collect the listed data in order to be able to guarantee a smooth connection setup of the website and a technically error-free provision of our services. The processing of this data is absolutely necessary to provide you with the website. The log files are used to evaluate system security and stability as well as for administrative purposes. The legal basis for the processing of the data is our legitimate interest in the protection and functionality of our website in accordance with Art. 6(1)(f) GDPR.
For reasons of technical security, in particular to defend against attempted attacks on our web server, we store this data for a short period of time. After 7 days at the latest, the data is anonymised by shortening the IP address at domain level, so that it is no longer possible to establish a link to the individual user.
In addition, the data is processed anonymously for statistical purposes, if necessary. This data is never stored together with other personal data of the user, compared with other data or passed on to third parties.

Registration

On all of our websites, you have the option to register a customer account in order to search for and book holiday homes. When you create a customer account, we enable you to use a unified login (Single Sign-On) across various websites of our company. In this process, your booking data from all our websites is centrally consolidated. This serves to provide you with a more convenient user experience, simplify the login process, and give you an overview of all bookings you have made on our websites.
If you would like to register as a host, you can do so via Holidu Hosts GmbH at https://www.holidu.de/host.
As part of the regular registration and setup for the services of Holidu GmbH, we collect and use the following personal data:
  • First and last name or nickname
  • Email address
  • Date and time of registration
  • Password
As soon as you make a booking, information regarding your bookings and stays, as well as additional data where applicable, may also be displayed in your customer account.
The registration and consolidation of your booking data for Single Sign-On are based on your consent pursuant to Art. 6(1)(a) GDPR. Your data will be deleted as soon as you withdraw your consent, the user account on our website is deleted, and insofar as no statutory retention obligations exist. You may request a modification and/or deletion of your user account, including the data you provided, by sending a corresponding message to the controller named at the beginning of this privacy policy.

Facebook, Apple, Google and Microsoft Sign-In

If you wish to log in or register on our website via Facebook, Google or Microsoft, you will be redirected to the provider's website, where you can enter your credentials and thus log in. In this process, the personal data you use for your account, as well as further profile information, is linked with our service.
We automatically receive the following personal data via Facebook:
  • Your Facebook name
  • Your stored email address
  • Your place of residence and your chosen language
  • Your profile picture
We automatically receive the following personal data via Google:
  • Email address
  • First and last name
  • Your Google ID
  • Your profile picture
  • Gender
We use this data exclusively to complete your user profile and insofar as the information is necessary to identify you. The registration/login data is passed on to us on the basis of the consent you give when you click the sign-in button of the respective provider, in accordance with Art. 6(1)(a) GDPR; where information is stored on or accessed from your terminal equipment in connection with the sign-in, this is done on the basis of § 25 Abs. 1 TDDDG. You can withdraw your consent at any time with effect for the future, for example by removing the access you granted to us in your account with the respective provider or by contacting us using the contact details above. The lawfulness of the processing carried out until the withdrawal remains unaffected. Use of this registration and login option is voluntary; you can alternatively register directly with us at any time.
As the providers have their headquarters in the USA and personal data may be transferred to the USA, further safeguards are required to ensure the level of data protection of the GDPR. The transfer is based on the European Commission's adequacy decision for the EU-US Data Privacy Framework (DPF) pursuant to Art. 45(1) GDPR; the providers are certified under the DPF, which can be verified at the following link: https://www.dataprivacyframework.gov/s/participant-search.
Further information on Google Sign-In and on data protection at Google can be found in the provider's privacy policy: https://business.safety.google/privacy/
Further information on Facebook Sign-In and on data protection at Facebook can be found in the provider's privacy policy: https://www.facebook.com/privacy/policy
Further information on Microsoft Sign-In and on data protection at Microsoft can be found in the provider's privacy policy: https://privacy.microsoft.com/privacystatement

Data Processing When Booking Accommodation

When you book accommodation, we process your personal data in order to handle your booking and fulfill the contract with you as well as with the respective accommodation provider and, where applicable, additional intermediaries. The processed data (booking data) may include, in particular, the following categories of data:
  • Name
  • Email address
  • Telephone number
  • Booking information (booking period, booked accommodation, etc.)
  • Information regarding accompanying persons (e.g. information about the age of accompanying persons)
  • Payment and banking information

Description of the Data Processing and Purpose

We process your personal data (e.g. name, contact details, booking details, payment information) for the purpose of handling the booking, communicating with you and the accommodation provider and, where applicable, additional intermediaries, processing payments, and, if necessary, handling cancellations or inquiries.
The processing of your data is carried out for the performance of a contract pursuant to Art. 6(1)(b) GDPR (processing of your booking). Where necessary and legally permissible, we process your data beyond the actual contractual purposes in order to fulfill legal obligations pursuant to Art. 6(1)(c) GDPR (e.g. compliance with statutory retention obligations or fulfillment of local reporting obligations at the location of your accommodation).
Furthermore, processing may take place in order to safeguard our legitimate interests or those of third parties, as well as for the defense and assertion of legal claims pursuant to Art. 6(1)(f) GDPR. Where legally required, we will inform you separately, stating the legitimate interest concerned.

Recipients

Your data will be transferred to the following recipients:
  • Accommodation providers with whom you have booked (for the performance of the contract) and additional intermediaries where required for the processing of the booking (e.g. agencies representing multiple accommodation providers/hosts)
  • Payment service providers (for payment processing)
  • Where applicable, IT service providers or processors supporting us in the technical provision of the portal as described in this privacy policy
  • Where applicable, additional recipients where necessary to fulfill contractual or legal obligations
The accommodation providers process your data under their own responsibility for the fulfillment of the rental agreement existing between you and the accommodation. In this context, the accommodation providers may further process your data, for example in order to organize/prepare your arrival and departure. To provide additional services or fulfill local regulations, accommodation providers may request further information from you where applicable. Please read the privacy policies of the accommodation provider to obtain information about the processing of your data.
Should the provider of your accommodation change during the period between booking and the start of your trip, we will forward your booking data to the new accommodation provider.

Data Processing in Third Countries

As a general rule, your data will not be transferred to third countries outside the EU/EEA unless this is necessary for the performance of the contract or you have expressly consented to it (e.g. if the booked accommodation is located in a third country).
Should a transfer to third countries take place, we ensure that an adequate level of data protection is guaranteed, for example through EU Standard Contractual Clauses or an adequacy decision of the European Commission.

Storage Period

We store your personal data for the duration of the contractual processing and beyond in accordance with statutory retention periods. After the expiry of these periods, your data will be deleted unless further processing is required for other purposes stated in this declaration.

Digital Check-in – Chekin.io

On our booking platform, we integrate the service “Chekin.io” provided by Chekin S.L., Calle de la Innovación 3, 41020 Seville, Spain. Chekin.io is a digital platform for the automated guest registration and management of legal reporting obligations for accommodation businesses. If you book a Holidu accommodation (Holidu Homes) via our booking platform or one of our partner portals, you can use the service provider to check in digitally to your accommodation.

Description of the Data Processing and Purpose

Within the scope of using Chekin.io, personal data of guests (e.g. name, contact details, ID data, stay-related data) are processed. The purpose of the data processing is the digital collection, management, and transmission of guest data for the handling of your booking, as well as the fulfillment of statutory reporting obligations towards authorities and the optimization of internal administrative processes within the accommodation business.
The processing is carried out for the performance of a contract pursuant to Art. 6(1)(b) GDPR as well as for the fulfillment of legal obligations (Art. 6(1)(c) GDPR), particularly in connection with reporting obligations under the respective national laws.

Recipients

The recipient of the data is Chekin S.L. as a processor. As a processor pursuant to Art. 28 GDPR, Chekin is obliged to process your data exclusively in accordance with instructions and not for its own purposes. Depending on legal obligations, data may be forwarded to competent authorities (e.g. police, registration authorities).
Further information on the handling of personal data by Chekin.io can be found at: https://chekin.com/en/privacy-policy/

Data Processing in Third Countries

As a general rule, processing takes place within the European Union (EU). Should a transfer to a third country nevertheless occur in individual cases, this will only take place in compliance with the legal requirements, in particular through the conclusion of Standard Contractual Clauses or on the basis of an adequacy decision by the European Commission.

Storage Period

The data are stored for the duration of the statutory retention periods and subsequently deleted unless further statutory retention or documentation obligations exist. Any further storage only takes place if this is necessary for the fulfillment of additional contractual or legal obligations.

Zendesk for answering customer queries

If you send us a request via the Website or by email, we use the ticketing system "Zendesk" to process these requests, a service provided by Zendesk Inc, 989 Market Street 300, San Francisco, CA 94102.
The data you initially provided in your enquiry will be recorded in Zendesk. This is at least your first and last name, your email address and/or your telephone number. If you have also provided us with your address and other personal data in the course of your enquiry, these will also be processed in the ticketing system. The legal basis for the processing of your data in Zendesk is Art. 6(1)(f) GDPR), our legitimate interest in the efficient processing of customer enquiries.
In principle, your personal data is processed in the EU, but since Zendesk is a provider with headquarters in the USA, a transfer of personal data to the USA cannot be ruled out. Accordingly, further protection mechanisms are required to ensure the level of data protection of the GDPR. To ensure this, we have agreed standard data protection clauses with the provider in accordance with Art. 46(2)(c) GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient in the USA.
For more information about Zendesk's data processing, please see Zendesk's privacy policy at: http://www.zendesk.com/company/privacy.

Communication via Chat

In order to efficiently respond to customer inquiries, we provide our guests with an AI-based chat function on our website and in the app. Artificial Intelligence (AI) automatically responds to simple inquiries. For more complex matters or upon request, a customer service employee will be involved. Within the scope of communication via chat, your account data are processed (only for registered users), and personal data communicated through your messages are collected. If you are not registered or logged in, you may also use the chat anonymously (provided that you do not include any personal data in your text entries).
As a general rule, we respond to your inquiry within the chat tool. However, you may also voluntarily provide your email address and/or telephone number so that your inquiry can be processed through these channels.
The legal basis for processing the data is our legitimate interest in efficiently responding to inquiries submitted at the initiative of the user pursuant to Art. 6(1)(f) GDPR. If the inquiry or messages relate to the performance of a contract or the implementation of pre-contractual measures, the legal basis for processing is Art. 6(1)(b) GDPR.
If you book accommodation via Holidu, you may contact the host and Holidu customer service directly through our chat function and communicate regarding your booking. Your chat messages will be shared with the host. You can access the chat history at any time in your conversations within the messaging section. Within the scope of the chat, personal data may be processed, in particular:
  • Contact and booking data (e.g. name, contact details, booked accommodation, travel dates)
  • Content data: text messages that you compose in the chat, including all personal information contained therein (e.g. information regarding arrival and departure, inquiries, complaints, etc.)
  • Metadata: time of the message, chat history, assignment to your user account
  • Technical data: IP address, device and browser information
Please refrain from sharing sensitive content via the chat (e.g. health data, photos of identification documents, etc.). If you do not wish to use the chat, you may contact your host at any time using the contact details provided in the booking confirmation (e.g. by telephone or email).
The legal basis for processing the data is the performance of our contract pursuant to Art. 6(1)(b) GDPR (responding to your inquiries and facilitating communication between you and your host). If your inquiry expressed in the chat does not relate to our contract, the legal basis is our legitimate interest in centralized and efficient communication between Holidu, guest, and host pursuant to Art. 6(1)(f) GDPR.
The chat contents may also be used to continuously improve the quality of the automated responses. If an inquiry is escalated by you to a human service employee or if an issue is identified within the chat history, our customer service team may review the relevant chat histories between you, the host, and the AI assistant. The purpose of this review is, on the one hand, the processing and resolution of the specific issue and, on the other hand, the evaluation of the chat histories to improve the instructions (prompts) of the AI assistant. The legal basis for this is our legitimate interest in improving our services and customer service pursuant to Art. 6(1)(f) GDPR.
The data will be deleted as soon as they are no longer necessary for achieving the purpose for which they were collected, i.e. once the reason for the inquiry has been conclusively resolved. Chat histories related to your booking are stored for the duration of the business relationship and thereafter until the expiry of statutory retention periods. Chat contents used within the scope of AI training are stored for as long as they are required to improve the AI model. Where possible, they are stored in anonymized form.

Communication via WhatsApp Business

We use WhatsApp Business, a service provided by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, for communication purposes.
You can contact us, for example, via a button on the website. In doing so, your contact data in the form of your telephone number will be processed, as well as meta/communication data (e.g. device information, IP addresses).
We would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by WhatsApp Ireland Limited itself. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.
However, we would also like to point out that although the messenger providers cannot view the content, they can find out that you are communicating with us and when, as well as technical information about the device used and, depending on the settings of your device, location information (so-called metadata) is processed.
If we ask you for permission before communicating with you via Messenger, the legal basis for our processing of your data is consent pursuant to Art. 6(1)(a) GDPR. Otherwise, if we do not ask for permission and you contact us, for example, of your own accord, we use WhatsApp in relation to our contractual partners and in the context of initiating a contract as a contractual measure pursuant to Art. 6(1)(b) GDPR and in the case of other interested parties on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR in fast and efficient communication.
We have concluded an order processing contract with the service provider in which we oblige them to protect our customers' data and not to pass it on to third parties.
As a transfer of personal data to the USA takes place, further protection mechanisms are required to ensure the level of data protection of the GDPR. To ensure this, we have agreed standard data protection clauses with the provider in accordance with Art. 46(2)(c) GDPR. These oblige the recipient of the data in the USA to process the data in accordance with the level of protection in Europe. In cases where this cannot be ensured even through this contractual extension, we endeavour to obtain additional regulations and commitments from the recipient.
WhatsApp's terms of use and information on data protection can be accessed via the following links:
You can revoke any consent given and object to communication with us and WhatsApp at any time. In this case, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information you may have provided, if no reference back to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Finally, we would like to point out that we reserve the right not to answer enquiries via WhatsApp for reasons of your security. This is the case if, for example, internal contractual information requires special confidentiality or an answer via WhatsApp does not meet the formal requirements. In such cases, we will refer you to more adequate communication channels.

Sending applications

If you apply to us via our careers page or by e-mail, we collect personal data. This includes, in particular, your contact details (such as first and last name, telephone number and user email address) as well as other data you provide about your background (e.g. curriculum vitae, qualifications, degrees and work experience) and yourself (e.g. covering letter, personal interests). This may also include special categories of personal data (e.g. information on a severe disability).
As a rule, your personal data will be collected directly from you as part of the application process and encrypted during electronic transmission. The primary legal basis for this is Section 26 (1) BDSG. In addition, consent pursuant to Art. 6(1)(a) GDPR in conjunction with § 26 Para. 2 BDSG can be used as a data protection permission provision. If the processing of your data is based on consent, you have the right to revoke your consent at any time with effect for the future.
Within our company, only those persons and departments (e.g. Human Resources) that absolutely need it to carry out the application process or to fulfil our legal obligations have access to your personal data. If necessary, your applications will be forwarded to the relevant responsible persons for examination. Under no circumstances will your personal data be passed on to third parties without authorisation.
We use the order processor "Personio" from Personio GmbH & Co. KG, Rundfunkplatz 4, 80335 Munich, to view and process applications. We have concluded an order processing agreement with this company in accordance with Art. 28 GDPR to ensure that the security of your personal data is guaranteed.
Your data relating to an application for a specific job advertisement will be stored and processed by us or in the Personio platform during the current application process. After completion of the application process (e.g. in the form of an acceptance or rejection), the application process including all personal data is deleted from the system no later than six months after completion of the application process. The data of selected applicants will be stored securely for up to 2 years, provided the applicants have given their consent to this in accordance with Art. 6(1)(a) GDPR in conjunction with § 26 para. 2 BDSG. You can revoke your consent at any time with effect for the future. An informal e-mail to the contact details of the responsible person listed above is sufficient for this purpose. In the event of an acceptance, your application documents will be transferred to the personnel file.

Writing reviews

On our website you have the possibility to leave reviews for the offered holiday homes. For this, we need your name or a pseudonym and your e-mail address (which will not be published). Furthermore, your IP address and the time of publication will be logged and stored for up to 7 days. This storage of the IP and email address is done for security reasons and in case the person concerned violates the rights of third parties or posts illegal content through a submitted comment.
Reviews can be submitted in such a way that it is not possible for other website users to identify you. It is up to you to decide whether you wish to provide personal details over and above the mandatory information. Please note that when choosing your pseudonym, as well as within the free text fields and when uploading photos, it is also possible to provide information that makes it possible to identify you personally. We recommend that you write your review text without providing personal data and design photos accordingly. We reserve the right not to publish or to (partially) anonymise reviews that contain personal data.
If the review contains personal data, the processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke your consent at any time. For this purpose, an informal communication by e-mail to us is sufficient. The legality of the data processing operations already carried out remains unaffected by the revocation. In the event of revocation of your consent, we will delete or anonymise the review.
The storage of additional information (IP address) is based on our legitimate interest pursuant to Art. 6(1)(f) GDPR in the possibility of assigning the reviews to the authors. We reserve the right to delete comments if they are objected to by third parties as unlawful. The collected IP and email addresses are deleted after 7 days.

Telephone Contact – AirCall

We use the software “AirCall” (Aircall SAS, 11-15 rue Saint Georges, 75009 Paris) for the purpose of telephone communication. Aircall is a cloud-based telephony solution that is used in particular for the management and execution of telephone calls as well as integration with other communication and CRM systems.
Within the scope of using Aircall, the following personal data are processed:
  • Telephone numbers, names, and other contact details of the communication partners
  • Call histories, call times, connection data
  • Where applicable, call recordings (if activated and legally permissible)
  • Technical usage data (e.g. IP address, device information)
The purpose of the data processing is the efficient handling and documentation of telephone communication with customers, prospective customers, and business partners, as well as the improvement of service processes and integration into existing CRM and support systems.
The processing is carried out on the basis of Art. 6(1)(b) GDPR (performance of a contract or implementation of pre-contractual measures), insofar as the communication takes place for the initiation or execution of a contractual relationship. Where consent is required (e.g. for call recordings), the processing is carried out on the basis of your consent pursuant to Art. 6(1)(a) GDPR. Consent may be withdrawn at any time with effect for the future. Otherwise, processing is carried out on the basis of Art. 6(1)(f) GDPR (legitimate interest), in particular for answering general telephone inquiries that do not fall under the above-mentioned cases, as well as, where necessary, for the defense and assertion of legal claims. Where legally required, we will inform you separately, stating the legitimate interest concerned.
We have concluded a data processing agreement with the service provider in which we oblige it to protect our customers’ data and not to pass them on to third parties. Aircall may use subprocessors outside the EU/EEA, in particular in the United States, to provide its services. For data transfers to third countries, Aircall is obliged to provide appropriate safeguards pursuant to Art. 44 et seq. GDPR, in particular by concluding EU Standard Contractual Clauses and, where applicable, implementing additional protective measures. The U.S.-based Aircall, Inc. is certified under the EU-U.S. Data Privacy Framework.
Personal data are generally stored only for as long as necessary to achieve the stated purposes. Call data and connection data are deleted by Aircall after the expiry of the contractually agreed periods, unless longer statutory retention obligations exist. Call recordings are stored only for as long as necessary for the respective purpose and where consent has been provided.
Further information on data protection at AirCall can be found at: https://aircall.io/privacy-faqs/ and https://aircall.io/privacy/

Newsletter and transactional messages (Sendgrid)

When you subscribe to our newsletter, we use the so-called double opt-in procedure. This means that we will only send you our newsletter by email once you have expressly confirmed to us that you consent to receiving newsletters. In the first step, you receive an email with a link through which you can confirm that, as the owner of the email address concerned, you wish to receive newsletters in future. By confirming, you give us your consent pursuant to Art. 6(1)(a) GDPR to use your personal data for the purpose of sending the requested newsletter.
When you subscribe to the newsletter, in addition to the email address required for sending, we store the IP address from which you subscribed to the newsletter and the date and time of subscription and confirmation, so that any misuse can be traced at a later date. The legal basis for this is our legitimate interest pursuant to Art. 6(1)(f) GDPR.
You can unsubscribe from the newsletter at any time via the link included in every newsletter or by emailing the controller named above. After you have unsubscribed, your email address will be removed from our newsletter distribution list without delay, unless you have expressly consented to the continued use of the data collected or the continued processing is otherwise permitted by law.
In addition to the newsletter, you receive so-called transactional messages and push notifications. These are information on bookings, payments and check-ins that are necessary for communication within the contractual relationship. The legal basis for sending this type of message is Art. 6(1)(b) GDPR, the performance of the contract between you, Holidu GmbH and the hosts.
Our email newsletters and transactional messages are sent via a technical service provider (Sendgrid), to which we pass on your data.
Sendgrid is used to send the transactional messages and push notifications mentioned above within the framework of your contractual relationship. Where necessary, information about your interaction with the Holidu website is also processed for this purpose.
Furthermore, if you have consented, newsletters are statistically evaluated. For this evaluation, the emails sent contain so-called web beacons or tracking pixels. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked. Conversion tracking can also be used to analyse whether a predefined action has taken place after a link in the newsletter was clicked. In addition, technical information is recorded (e.g. time of access, IP address, browser type and operating system). The data is linked to your other personal data, i.e. your email address. This data is used for the statistical analysis of newsletter campaigns and for retargeting the recipient. The results of these analyses can be used to better tailor future newsletters to the interests of the recipients. If you wish to withdraw your consent to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.
We have concluded a data processing agreement with our email service provider in which we oblige it to protect our customers' data.
Service provider: Sendgrid (by Twilio)
Address: SendGrid, Inc., 1801 California Street, Suite 500, Denver, CO 80202, United States
Third-country transfer: Sendgrid Inc. is certified under the EU-U.S. Data Privacy Framework and has accordingly committed to complying with appropriate data protection standards, which can be verified at the following link: https://www.dataprivacyframework.gov/s/participant-search.

Conducting Competitions and Giveaways

We occasionally organize competitions and promotional campaigns in which customers and interested parties may participate. When participating in a competition or campaign, we process the data you provide in the registration form or email. These may include the following data: email address, first and last name, address, content data (e.g. text entries, photos, videos). Your data will not be shared with third parties unless such disclosure is necessary for conducting the competition or sending the prize.
The processing of your personal data is carried out for the purpose of handling the competition or campaign, in particular for determining and notifying the winners. For the purpose of sending and delivering prizes, we may subsequently collect and process additional data (e.g. your postal address).
The data processing is carried out for the performance of the competition agreement pursuant to Art. 6(1)(b) GDPR.
If winners are published within the scope of the competition, we point out that participants’ names may also be published in this context. Participants may object to this at any time.
The processed data will be deleted after the completion or expiry of the competition or campaign and the dispatch of the prizes. As a general rule, the data will be deleted within 7 days after participation. If you consented to receiving advertising information when registering for the competition, the further processing of the data and information covered by this consent will take place in accordance with the statutory provisions – generally until you withdraw your consent.

Processing of Photo and Video Recordings at Events

As part of our events, we regularly create photo and, where applicable, video recordings in which participants may be wholly or partially identifiable. The legal basis for processing these recordings is Art. 6(1)(f) GDPR. The legitimate interest of Holidu GmbH lies in documenting the event as well as in external and internal communication and public relations activities.
This may include, in particular, the publication of recordings on the following channels:
  • The Holidu GmbH website
  • The social media channels of Holidu GmbH (Instagram, LinkedIn)
  • As well as in newsletters or other publications of Holidu GmbH
The recordings are used exclusively for the aforementioned purposes.
If participants do not wish to be photographed or have recordings published, they may inform the photographer or the persons responsible for the event at any time on site.
The recordings will be deleted as soon as they are no longer necessary for the stated purposes or if a justified objection pursuant to Art. 21 GDPR is raised. Further information on exercising your rights as a data subject can be found in the section “Your Rights.”

Customer.io

We use the service Customer.io, provided by Peaberry Software Inc. (Customer.io), based in the USA. Customer.io is used to manage, automate and analyse email, in-app and push notifications and to optimise our marketing communications and advertising measures.
Where you have given us your consent pursuant to Art. 6(1)(a) GDPR, we process the following personal data:
  • First and last name
  • Email address
  • Device and browser identification number, IP address, MAC address and, where applicable, other IDs and the associated information and telemetry data
  • Interactions with emails (open rates, clicks, unsubscribes)
  • Usage behaviour within our services (e.g. in the Property Management Platform)
This data is processed so that we can send you personalised messages based on your interactions and your use of the Holidu services, and carry out automated marketing campaigns. We also analyse your data to create so-called "lookalike audiences", in order to identify and specifically address similar target groups based on existing customer data. Wherever possible, your data is aggregated, pseudonymised or anonymised.
As the use of Customer.io may involve a transfer of personal data to countries outside the EU and the EEA (USA), further safeguards are required to ensure the level of data protection of the GDPR. For the USA, an adequacy decision of the European Commission pursuant to Art. 45(1) GDPR exists in respect of companies certified under the EU-U.S. Data Privacy Framework. Customer.io is certified under the EU-U.S. Data Privacy Framework and has accordingly committed to complying with appropriate data protection standards, which can be verified at the following link: https://www.dataprivacyframework.gov/s/participant-search
The data is stored only for as long as is necessary for the respective communication purpose. As soon as the data is no longer needed for sending or you withdraw your consent, it is deleted.
Further information can be found in Customer.io's privacy policy: https://customer.io/legal/privacy-policy

Adyen

On our website, we offer you the option of completing your payment via Sofortüberweisung (Klarna) and PayPal. To do this, we work with the payment service provider Adyen N.V. (hereinafter "Adyen"), Simon Carmiggeltstraat 6-50, 1011 DJ, Amsterdam, Netherlands. Adyen is a payment service provider that handles the processing of payments for us.
Depending on the payment method you have chosen, the data required for that payment method is transmitted to Adyen, unless it is collected directly by the payment service. This concerns the following data:
  • First and last name
  • Address
  • Payment data
  • Invoice amount
  • Transaction data
  • Information about your order
This is necessary to verify your identity and process the payment. The legal basis for the processing of your personal data is Art. 6(1)(b) GDPR, the necessity of the payment for the conclusion of a contract with us, as well as Art. 6(1)(f) GDPR, our legitimate interest in using a payment service provider to simplify the administration of payments on our website.
In the context of an identity and credit check based on your data, Adyen and we have a legitimate interest in the transmission of the personal data of the user concerned. Adyen and we require this data in order to obtain information from credit reference agencies for the purpose of identity and credit checks (Art. 6(1)(f) GDPR). We delete the data arising in this context once storage is no longer required, or restrict the processing if statutory retention obligations apply.
You have a right to object on grounds relating to your particular situation, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (Art. 21(1) GDPR). However, Adyen remains entitled to process and transmit the customer data where this is necessary for the contractual processing of payments or required by law or by an authority or court. Adyen can be contacted at https://www.adyen.com/en_GB/contact
Further information on the processing of your data by Adyen can be found at: https://www.adyen.com/en_GB/privacy-policy
Social networks (Instagram, Facebook, LinkedIn, Google, Github) are only integrated on our website as links to the corresponding services. After clicking on the embedded text/image link, you will be redirected to the page of the respective provider. User information is only transferred to the respective provider after the forwarding. For information on the handling of your personal data when using these websites, please refer to the respective data protection provisions of the providers you use

Data sharing and recipients

Your personal data will not be transferred to third parties, unless
  • we have explicitly referred to this in the description of the respective data processing,
  • you have given your express consent to this in accordance with Art. 6(1)(a) GDPR,
  • disclosure is necessary in accordance with Art. 6(1)(f) GDPR for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
  • in the event that a legal obligation exists for the disclosure pursuant to Art. 6(1)(c) GDPR and
  • insofar as this is necessary for the processing of contractual relationships with you in accordance with Art. 6(1)(b) GDPR.
In addition, we use external service providers for the processing of our services, which we have carefully selected, commissioned in writing and with whom we have concluded order processing agreements in accordance with Article 28 of the GDPR, if necessary. These service providers are bound by our instructions and are regularly monitored by us. These are, among others, service providers for hosting, sending e-mails as well as maintenance and care of our IT systems, etc. The service providers will not pass this data on to third parties.

Data security

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. This website uses SSL encryption for security reasons and to protect the transmission of confidential content.

Duration of the storage of personal data

The duration of the storage of personal data is determined by the relevant statutory retention periods (e.g. from commercial law and tax law). After expiry of the respective period, the corresponding data is routinely deleted. If data is required to fulfil or initiate a contract or if we have a legitimate interest in continuing to store it, the data will be deleted when it is no longer required for these purposes or you have exercised your right of revocation or objection.

Your rights

In the following, you will find information on which data subject rights the applicable data protection law grants you and the controller with regard to the processing of your personal data:
The right to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making, including profiling, and, if applicable, meaningful information about its details.
The right to request the correction of inaccurate or incomplete personal data stored by us without delay in accordance with Art. 16 GDPR.
The right to request the erasure of your personal data stored by us in accordance with Article 17 of the GDPR, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims.
The right to request the restriction of the processing of your personal data in accordance with Art. 18 GDPR, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defence of legal claims or you have objected to the processing in accordance with Art. 21 GDPR.
The right, in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transferred to another controller.
The right to complain to a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of the federal state where our registered office is located or, if applicable, that of your usual place of residence or workplace.
Supervisory authority: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
The right to revoke consent given in accordance with Art. 7 (3) GDPR: You have the right to revoke consent to the processing of data once given at any time with effect for the future. In the event of revocation, we will immediately delete the data concerned unless further processing can be based on a legal basis for processing without consent. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

Right of objection

Insofar as your personal data is processed by us on the basis of legitimate interests pursuant to Art. 6(1)(f) GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, insofar as this is done for reasons arising from your particular situation. Insofar as the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right of objection without the requirement to specify a particular situation.
If you would like to exercise your right of revocation or objection, simply send an e-mail to service@holidu.com.
The provision of personal data for the decision on the conclusion of a contract, the fulfilment of a contract or for the implementation of pre-contractual measures is voluntary. However, we can only make the decision in the context of contractual measures if you provide such personal data that is required for the conclusion of the contract, the performance of the contract or pre-contractual measures.

Automated decision making

No automated decision-making within the meaning of Art. 22 GDPR takes place, that is, no decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. Where you have consented to marketing cookies, your use of our websites is analysed in order to show you relevant advertising; this is described in the section "Cookies".

Additional information for customers, interested parties, hosts and business partners

We process your personal data in accordance with the provisions of the European Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG), insofar as this is necessary for the establishment, implementation or fulfilment of a contract or for the implementation of pre-contractual measures. Insofar as personal data is required for the initiation or implementation of a contractual relationship or in the context of the implementation of pre-contractual measures, processing is lawful pursuant to Art. 6(1)(b) GDPR.
If you give us express consent to process personal data for specific purposes (e.g. forwarding to third parties, evaluation for marketing purposes or advertising by e-mail), this processing is lawful on the basis of your consent pursuant to Art. 6 (1) a GDPR. Consent given can be revoked at any time with effect for the future (see section 9 of this data protection information).
If necessary and legally permissible, we process your data beyond the actual contractual purposes for the fulfilment of legal obligations pursuant to Art. 6(1)(c) GDPR. In addition, processing may be carried out to protect the legitimate interests of us or third parties and to defend and assert legal claims in accordance with Art. 6 (1) f GDPR. If necessary, we will inform you separately, stating the legitimate interest, insofar as this is required by law.

Categories of data processed

We only process data that is related to the establishment of the contract or the pre-contractual measures. This can be general data about you or persons in your company (name, address, contact details, etc.) as well as any other data that you provide to us in the context of establishing the contract.

Data sources

We process personal data that we receive from you in the course of contacting you or establishing a contractual relationship or in the course of pre-contractual measures or that you provide via our website or forms. In some cases, we also process data from publicly accessible sources.

Recipient of the data

We only pass on your personal data within our company to those areas and persons who need this data to fulfil contractual and legal obligations or to implement our legitimate interest.
We may transfer your personal data to our affiliates to the extent permitted by the purposes and legal bases set out in section 3 of this privacy notice.
Your personal data is processed on our behalf on the basis of order processing contracts in accordance with Art. 28 GDPR. In these cases, we ensure that the processing of personal data is carried out in accordance with the provisions of the GDPR. The categories of recipients in this case are CRM system providers, telephony providers, newsletter dispatch service providers, payment providers.
Otherwise, data is only forwarded to recipients outside the company if this is permitted or required by law, if the forwarding is necessary for the processing and thus the fulfilment of the contract or, at your request, for the implementation of pre-contractual measures, if we have your consent or if we are authorised to provide information. Under these conditions, recipients of personal data may be, for example:
  • External tax consultant
  • Public bodies and institutions (e.g. public prosecutor's office, police, supervisory authorities, tax office) if there is a legal or official obligation,
  • Recipients to whom the disclosure is directly necessary to establish or fulfil the contract, such as partners.

Transfer to a third country

A transfer to a third country is not intended. If one of our processors is located in a third country, we ensure that either an adequacy decision of the European Commission is in place or, in the case of transfers pursuant to Art. 46 et seq. appropriate safeguards such as standard contractual clauses are in place to ensure an essentially equivalent level of protection for your personal data.

Duration of data storage of customer, prospective customer and business partner data

As far as necessary, we process and store your personal data for the duration of our business relationship or for the fulfilment of contractual purposes. This also includes, among other things, the initiation and execution of a contract.
In addition, we are subject to various storage and documentation obligations, which result, among other things, from the German Commercial Code (HGB) and the German Fiscal Code (AO). The periods prescribed there for storage and documentation are two to ten years.
Finally, the storage period also depends on the statutory limitation periods, which, for example, according to §§ 195 et seq. of the German Civil Code (BGB), are usually three years, but in certain cases can be up to thirty years.

Your rights as a customer, interested party or business partner

You have a number of data protection rights that you can assert against us. You can find a detailed list in the section "Your rights" above in this data protection declaration.

Necessity of the provision of personal data

The provision of personal data for the decision on the conclusion of a contract, the fulfilment of a contract or for the implementation of pre-contractual measures is voluntary. However, we can only make a decision within the framework of contractual measures if you provide such personal data that is required for the conclusion of the contract, the fulfilment of the contract or pre-contractual measures.

Automated decision-making in connection with customer, prospect and business partner data

For the establishment, fulfilment or implementation of the business relationship as well as for pre-contractual measures, we generally do not use fully automated decision-making pursuant to Art. 22 GDPR. Should we use these procedures in individual cases, we will inform you about this separately or obtain your consent if this is required by law.

Property Management Platform

As a host, your user account gives you the opportunity to use our Property Management Platform.
When you make full use of our property management platform, the following data will be processed in addition to the data you provided during registration:
  • Holiday home data (e.g. address, equipment, object pictures)
  • Invoice address
  • Bank details
  • VAT number
The legal basis for data processing is Art. 6(1)(a) GDPR in the case of consent or Art. 6(1)(b) GDPR if processing is necessary to provide the requested services. Your data will be deleted as soon as the user account is deleted and insofar as no legal retention obligations exist.

Partner Portal

If you are a partner of Holidu or would like to enter into a partnership with us, we provide our partner portal for communication, registration, and the management of listings. In order to use the partner portal, we require the following information from you:
  • Data relating to your company, including your registration details, tax number, and bank account details
  • Data relating to the accommodations managed by you
  • Information regarding your website
  • Information regarding the configuration of your partnership with us, such as the preferred payment method and cancellation conditions
  • Email addresses and telephone numbers for contact purposes
  • Date of birth, if you are registered as an individual person
We process your personal data based on Art. 6(1)(b) GDPR, namely the necessity of the data for the performance of your contract or partnership with us, as well as based on Art. 6(1)(c) GDPR in order to comply with our statutory reporting and due diligence obligations under the Platform Tax Transparency Act (PStTG). Further information can be found in the section “Reporting under the Platform Tax Transparency Act (DAC7)” below.
Furthermore, we use cookies on the page of our Partner Portal. These are used for authentication, login, and assignment to the provider selected by you. We therefore process your data based on § 25 Abs. 2 Nr. 2 TDDDG in conjunction with Art. 6(1)(f) GDPR, our legitimate interest in providing you with an expressly requested service that enables the functionality of the Partner Portal.
We store your data for the duration of your partnership and beyond for as long as this is necessary to fulfill our retention and documentation obligations; see also “Duration of Data Storage” in this privacy policy.

Reporting under the Platform Tax Transparency Act (DAC7)

As the operator of a digital platform, we are legally obliged under Directive (EU) 2021/514 (DAC7) in conjunction with the German Platform Tax Transparency Act (Plattformen-Steuertransparenzgesetz – PStTG) to collect certain information about you as a partner, the accommodations offered by you via our Partner Portal and the transactions processed via our platform, and to report this information annually to the competent tax authority.
Data concerned (§ 14 PStTG):
  • your master data: first name and surname or registered company name, address of your residence or registered office;
  • for natural persons: your date of birth and any taxpayer identification number (TIN) issued to you, together with the Member State of the European Union that issued it or, where no TIN is available, your place of birth;
  • for entities: any TIN issued and the Member State that issued it, the business registration number and, where applicable, any permanent establishment in the European Union through which the rental activity is carried out, together with the Member State in which it is located;
  • where applicable, your VAT identification number;
  • the identifier of your financial account and, where you are not the account holder, the name of the account holder and any other information enabling the account holder to be identified;
  • the Member States of the European Union in which you are resident or in which your rented properties are located;
  • per quarter: the consideration paid or credited to you, the number of bookings in respect of which consideration was paid or credited, and any fees, commissions or taxes withheld or charged by us;
  • information on the rented properties: address, consideration per quarter and number of bookings per property and, where applicable, the type of property, the number of days on which it was rented and the land registration number or its equivalent under the law of the Member State in which the property is located;
  • where your identity and tax residence have been confirmed by means of a government identification service of a Member State or of the European Union: the identifier of that service and the Member State that issued it.
Purposes of processing: Compliance with our statutory reporting and due diligence obligations under the PStTG for the purposes of carrying out the taxation procedure.
Legal basis: Art. 6(1)(c) GDPR in conjunction with §§ 13 et seq. PStTG.
Recipients: Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt), for onward transmission to the competent tax authorities of the German federal states (Länder) and, where applicable, to the competent authorities of other Member States of the European Union.
Storage period: We retain the records created in the course of our reporting and due diligence obligations for a period of ten years in accordance with § 24(3) PStTG. Upon expiry of this period, the data will be deleted unless a further statutory retention obligation applies.
We will provide you with the reported information relating to you annually by 31 January of the year following the reporting period.

Existing customer advertising

We reserve the right to process the e-mail address provided by you in the context of the booking in accordance with the statutory provisions in order to send you the following content, among other things, by e-mail during or following the processing of the contract, provided you have not already objected to this processing of your e-mail address:
\- other interesting offers from our portfolio,
\- Overview of possible leisure activities.
The legal basis for the processing is Art. 6(1)(f) GDPR). We carry out the aforementioned processing for customer care and to increase our services. We delete your data when you terminate the newsletter subscription, but no later than two years after termination of the contract.
We would like to point out that you can object to receiving direct advertising at any time without incurring any costs other than the transmission costs according to the basic rates. You have a general right to object without giving reasons (Art. 21 (2) GDPR). To do so, click on the unsubscribe link in the newsletter or send us your objection to the contact details listed in the "Person responsible" section.

Subject to change

We reserve the right to adapt or update this data protection declaration if necessary in compliance with the applicable data protection regulations. In this way, we can adapt it to the current legal requirements and take into account changes to our services, e.g. when introducing new services. The current version applies to your visit.
Status of this privacy policy: August 2026