Privacy policy


www.comfystylishstaymalaga.com Privacy Policy


Iryna Akopian
Calle Feria de San Isidro Labrador, 2
29640 Fuengirola
Malaga, Spain
VUT/MA/82214


Effective Date: (01/01/2025)


This Privacy Policy explains how we, Iryna Akopian, as the data controller, collect, use, store, and protect the personal information of our website visitors and guests in compliance with the General Data Protection Regulation (GDPR) and Spanish data protection laws.

1. Who We Are

We manage and rent a vacation property in Malaga, Spain, under the registration number VUT/MA/82214. We use a combination of online platforms and software to manage our bookings, payments, and operations.

2. Personal Data We Collect

We collect and process personal data that is necessary for the purposes outlined in this policy. This data may include:

  • From our website and direct inquiries:
    • Name, email address, and phone number when you contact us via a contact form or email.
    • Information collected automatically via cookies, such as IP address, browser type, and usage data, to improve our website and services.
  • From booking platforms (Airbnb, Booking.com, Agoda, VRBO, and HomeToGo):
    • When you book our property through any of these platforms, they provide us with certain personal data to facilitate your stay. This typically includes:
      • Your full name and the names of all guests in your party.
      • Contact information (email and phone number).
      • Reservation details (check-in/out dates, number of guests).
      • Other information required for communication and managing the booking.
    • Please note that each of these platforms has its own separate privacy policy that governs the data they collect directly from you. We only receive the data necessary to fulfill the reservation.
  • From our Property Management Software (Smoobu):
    • We use Smoobu as our property management system. All booking data from Airbnb, Booking.com, Agoda, VRBO, HomeToGo, and direct bookings from our Smoobu-powered website are automatically synchronized with Smoobu. This means that the data we receive from these platforms is stored and processed within Smoobu to manage your reservation, calendar, communication, and other operational tasks.
  • From our Payment Processor (Stripe):
    • For payments made directly through our website (which is run on Smoobu), we use Stripe to process payments. Stripe is a leading payment service provider that collects and processes payment information on our behalf. When you make a payment, you will provide your name, billing address, and credit/debit card details directly to Stripe via a secure payment gateway. We do not have direct access to your full credit card information.
  • For legal registration purposes (Chekin):
    • Under Spanish law (specifically,Organic Law 4/2015 for Citizen Security and Royal Decree 933/2021), all hosts are legally required to register guests aged 16 and over with the Spanish authorities (National Police or Guardia Civil). To fulfill this legal obligation, we use a service called Chekin.
    • Chekin facilitates the collection and submission of the following mandatory data:
      • Full name (including first and second surnames, if applicable)
      • Date of birth
      • Nationality
      • Gender
      • Type of identity document (e.g., Passport, DNI)
      • Identity document number
      • Place of issue of the document
      • Date of entry to the property
      • Signature
    • The Chekin platform is used for digital check-in, identity verification, and secure transmission of this data to the authorities.

3. Purpose and Legal Basis for Processing Your Data

We process your personal data for the following purposes, based on the corresponding legal grounds:

  • To fulfill our contractual obligations with you: We process data to manage your reservation, confirm your booking, process your payment (via Stripe), communicate with you about your stay, and provide access to the property. (Legal basis: Performance of a contract - GDPR Art. 6.1(b)).
  • To comply with a legal obligation: We are legally required to collect and submit guest identification data to the Spanish authorities. The data processed by Chekin is strictly for this purpose. (Legal basis: Compliance with a legal obligation - GDPR Art. 6.1(c)).
  • For our legitimate interests: We use contact information from our website to respond to your inquiries. We may also use some data for administrative purposes, such as internal record-keeping and business analysis, to improve our services. (Legal basis: Legitimate interest - GDPR Art. 6.1(f)).

4. Data Sharing and Recipients

Your personal data may be shared with the following recipients for the purposes described above:

  • Booking platforms: The data you provide to Airbnb, Booking.com, Agoda, VRBO, or HomeToGo is shared with us to manage your reservation.
  • Property Management Software (Smoobu): Your reservation data is shared with Smoobu for operational management.
  • Payment Processor (Stripe): Your payment information is securely shared with Stripe to process your payment.
  • Legal Compliance Service (Chekin): Your mandatory identification data is shared with Chekin to facilitate the legal reporting obligation. Chekin, in turn, transmits this data securely to the authorities.
  • Spanish Authorities (National Police / Guardia Civil): We are legally obligated to report your identification details to these authorities within 24 hours of your arrival.

We will not sell, rent, or otherwise disclose your personal data to any other third parties for marketing purposes.

5. Data Residency

We rely on third-party service providers who may process data outside of the European Economic Area (EEA). We ensure that all our data processors comply with the GDPR and have implemented appropriate safeguards, such as Standard Contractual Clauses (SCCs), to protect your data.

  • Airbnb: As a global company, Airbnb may process data in various locations, including the United States. They have implemented measures to ensure compliance with international data transfer regulations.
  • Booking.com: Booking.com is headquartered in the Netherlands and primarily processes data within the EU. However, as a global company, some data may be processed in other locations with appropriate safeguards in place.
  • Agoda: As a company with a strong presence in Asia, Agoda may process data in various locations outside the EEA, including Singapore. They have implemented measures to ensure compliance with international data transfer regulations.
  • VRBO: VRBO is part of the Expedia Group, a global company that may process data in various locations, including the United States. They rely on appropriate data transfer mechanisms for cross-border transfers.
  • HomeToGo: HomeToGo is headquartered in Germany and primarily processes data within the EU, but may use services that process data in other locations, such as the United States (e.g., via AWS).
  • Smoobu: Smoobu is a German company that processes data primarily on servers within the European Union.
  • Stripe: Stripe, Inc. is a U.S. company, but Stripe Payments Europe, Limited is an Irish entity that acts as a data controller for European users. Stripe stores and processes data globally, with strong security measures and data transfer agreements, including participation in the EU-U.S. Data Privacy Framework, to ensure GDPR compliance.
  • Chekin: Chekin is a Spanish company that operates in compliance with European data protection laws.

6. Data Retention

We will retain your personal data for the period necessary to fulfill the purposes for which it was collected, as well as to comply with legal obligations.

  • Guest registration data: The data collected for legal registration purposes (via Chekin) is retained for a minimum of three years, as required by Spanish law.
  • Booking and communication data: We will retain this data for as long as necessary to manage our relationship with you and for a reasonable period thereafter to address any potential legal claims or disputes.
  • Website inquiry data: This data will be kept only for the time required to respond to your inquiry and resolve any follow-up questions.

7. Your Data Protection Rights

Under the GDPR, you have the following rights regarding your personal data. To exercise any of these rights, please contact us at the email address provided at the top of this policy.

  • Right of access: You have the right to request a copy of the personal data we hold about you. Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
  • Right to erasure ("right to be forgotten"): You have the right to request the deletion of your personal data, subject to legal limitations (e.g., we cannot delete the data we are legally required to keep for police registration).
  • Right to restriction of processing: You have the right to request that we limit the processing of your data in certain circumstances.
  • Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
  • Right to object: You have the right to object to the processing of your personal data in certain situations, such as for direct marketing.
  • Right to lodge a complaint: You have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) if you believe we have violated your data protection rights.

8. Data Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, use, alteration, or destruction. We rely on the security protocols of our service providers (Airbnb, Booking.com, Agoda, VRBO, HomeToGo, Smoobu, Chekin, and Stripe) and ensure that they are also GDPR-compliant.

9. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. We will post the revised policy on this page with an updated "Effective Date."

10. Contact Information

For any questions or concerns about this Privacy Policy or our data processing practices, please contact us at:

Iryna Akopian - casa.daddio.coREMOVEME@gmail.com - +34661431153