Privacy Policy

1.0 Overview
This information is provided in accordance with Article 13/14 of EU Regulation 679/2016 (hereinafter "GDPR") and the UK Data Protection Act 2018, which incorporates GDPR.
Smart Villas Limited is the data controller and will be referred to as "we", "our", and "us." The term "customer" or "guest" refers to the person who made the booking.

2.0 Data Controller
Smart Villas Limited acts as an intermediary between the customer and the owner of the property. The owner expressly authorises Smart Villas Limited to rent their property.

This Privacy Policy applies to data received and processed by:
Smart Villas Limited
Registered in Leeds, United Kingdom
(+44)7503 925 581
info@smart-villas.co.uk
Company number: 13865142

3.0 Type of data processed
Below is a list of the types of personal data that we collect during the booking and check-in process.

• Name and Surname
• Date of birth
• Nationality
• Place of birth
• Address
• Telephone number
• Email address
• Identity document details

Unless otherwise indicated, all requested data is considered mandatory to fulfill the processing purposes described in paragraph 5.0. Customers who have questions about which data is mandatory are encouraged to contact Smart Villas Limited. To do so, simply send an email, make a phone call, or contact us via WhatsApp

4.0 Data communicated voluntarily by the user
The information provided when booking one of the villas is processed by Smart Villas Limited, which includes the personal information necessary to complete the reservation. Depending on the booking, we may also request residential address, phone number, payment details, date of birth, and the names of any other individuals traveling with you in relation to the stay. Additionally, we may gather information through reviews you leave us, including the displayed name and photo (if available).

Following the reservation, we process personal data to enable and optimize the service. All information we hold is stored and can be updated whenever necessary. Furthermore, personal, fiscal, and contact data, including email addresses, are processed for various purposes.

We may also collect personal data, such as name, surname, email address, and phone number, from vacation rental portals where the villas are advertised (e.g., Vrbo, Airbnb, and Booking.com) at the time of booking request.

5.0 Purpose of use
The personal information provided will be used exclusively for:

• Finalising bookings.
• Communicating guest information to the Local Authority, as required by Public Security Communications obligations, as established by Law no. 214 of 22 December 2011.
• Fulfilment of legal obligations.
• Sending communications and providing assistance through one or more contact methods, such as email, phone, SMS, or WhatsApp. We use the data to manage communications sent to Smart Villas Limited, including:
• Responding to and managing inquiries.
• Sending administrative messages or security notices.
• Inviting you to leave a review.
• Improving our services. We may use personal data for analytical purposes (e.g., improving customer experience, understanding trends). We commit to using pseudonymized data for such analytical purposes only.

6.0 Sharing of Information
Guests' personal information will not be shared with third parties, except where necessary to fulfil contractual or legal obligations, such as compliance with local authorities' requirements.

The client's personal data may be transferred to a country other than the one in which the client is located. For more information on where and how your data is processed, you may request further details from Smart Villas Limited.

7.0 Use of Security Cameras
For the security of our properties when unoccupied, the villas are equipped with external security cameras. These cameras are installed exclusively at the entrance areas and in the backyard. They do not record footage and remain always turned off. The system uses infrared sensors solely to detect movement in case of unauthorised access and is activated only when the villa is unoccupied.

Since no recording is made, no footage is stored or saved.

The cameras do not monitor any internal parts of the villa, such as bedrooms, bathrooms, hallways, nor any external areas where guests can reasonably expect privacy, such as outdoor showers.

The presence and location of any security devices are always indicated in the property listing description to ensure maximum transparency.

8.0 WhatsApp 
Smart Villas Limited can also be reached via WhatsApp.
Please note that Smart Villas Limited cannot guarantee the security of data transferred via WhatsApp, as it is outside of our control.

By using WhatsApp to contact us, you agree to its terms of use and privacy policy. For more information, please refer to WhatsApp's legal page.

9.0 Data retention
We retain guests' personal information only for as long as necessary to fulfil the purposes stated in this policy, unless a longer retention period is required for legal obligations. For data provided in paragraph 5.0, as indicated in point (e), it will be retained for the time necessary to achieve the purpose for which it was collected, such as improving services or correcting errors.
For more information on retention periods, you can contact us via email at info@smart-villas.co.uk.

10.0 Your data protection rights 
Under data protection law, the customer has rights including:

• right of access – to receive confirmation of the existence of personal data and access its content.
• Right to rectification – to update, modify, and/or correct your personal data.
• Right to erasure and restriction – to request the erasure or restriction of processing of processed data that do not require storage in relation to the purposes for which the data were collected or processed.
• Right to object – the right to object to the processing of your personal information in certain circumstances.
• Right to withdrawal – the right to withdraw consent.
• Right to data portability – to request the transfer of personal information, in certain circumstances.
• Right to object: You have the right to object to the processing of your personal data in certain circumstances, such as for direct marketing purposes.

Requests must be addressed to Smart Villas Limited, by sending an e-mail to info@smart-villas.co.uk.

11.0 Transfer of data to non-EU countries
Smart Villas Limited is based in the United Kingdom, which, despite not being part of the European Union, offers an adequate level of data protection as outlined in the UK Public General Act - Data Protection Act 2018.

12.0 Changes to our Privacy Policy
Smart Villas Limited reserves the right to make changes to this privacy policy at any time by notifying customers via email, if possible, or on the website. If technically and legally feasible, customers may also receive a notification through one of the contact details we have on file.

Therefore, we encourage you to visit our website frequently and check the date of the last modification indicated below.

Last modified: 4 June 2025.

13.0 Complaints
If there are concerns about our use of your personal information, please file a complaint using the details in paragraph 2.0 (Data Controller) of this policy.

Your safety and privacy are our top priorities.