Privacy policy
Last updated: 13 August 2026
This is a courtesy translation. The binding version is the Spanish one. If the two differ, the Spanish text prevails.
1. Data controller
- Controller
- Lazar Kocic
- Tax number (NIE)
- Z4523536Q
- Address
- Calle Oriente 21, Pta 3 — 46006 Valencia, Spain
- Contact
- [email protected]
2. What data is processed, and why
This website has no forms. We only process personal data if you write to us by email or call us, and in that case the data is whatever you provide yourself: usually name, email, phone number and the content of your message.
The purpose is to answer your enquiry, prepare a proposal where appropriate, and — if we reach an agreement — manage the contractual relationship and its invoicing.
3. Legal basis
- Consent (art. 6(1)(a) GDPR) when you contact us on your own initiative.
- Performance of a contract (art. 6(1)(b)) for delivering the service you have engaged.
- Legal obligation (art. 6(1)(c)) for retaining invoices and tax records.
- Legitimate interest (art. 6(1)(f)) where we contact holiday rental professionals to offer our services, using data from public professional sources and limited to what that contact requires.
4. How long it is kept
Enquiries that do not lead to an engagement are kept for the duration of the contact and up to a year afterwards, unless you ask for deletion sooner. Client data is kept for the duration of the relationship and thereafter for as long as tax and commercial obligations require — in Spain, six years for accounting records.
If you appear in our register of professional contacts and ask to be removed, the entire record is deleted immediately and permanently.
5. Who else has access
We do not sell or share personal data with third parties. Only the providers needed to deliver the service have access, each under a data processing agreement:
- Cloudflare — hosting and infrastructure for this site and the websites we maintain.
- Cloudflare Email Service — sending automated emails (confirmations and sign-in links) and receiving the domain’s mail.
- Stripe — payment provider for our clients' websites. Payment details are handled by Stripe directly; we neither see nor store them.
- Our accountant, and public authorities where the law requires it.
Some of these providers may process data outside the European Economic Area. Where that happens, transfers rely on the standard contractual clauses approved by the European Commission or on an adequacy decision.
6. Data belonging to our clients' guests
This distinction matters. On the websites we build and maintain, the controller of guest data is the property owner, not us. We act as the data processor: we process that data solely on their instructions and in order to run the website and its bookings.
Booking data is stored on infrastructure within the European Union, limited to what managing the stay requires, and the property owner can export it or request its deletion at any time. A data processing agreement is signed with every client.
7. Cookies
This website uses no analytics, profiling or advertising cookies and includes no third-party measurement tools. That is why you will not see a cookie banner: there is nothing to consent to.
The infrastructure provider may set strictly technical security cookies, needed to protect the service against abusive traffic. These are exempt from the consent requirement because they are necessary.
8. Your rights
You may at any time exercise your rights of access, rectification, erasure, objection, restriction of processing and portability, and withdraw any consent given. Simply write to [email protected] saying which right you wish to exercise. We reply within one month at the latest.
If you believe we have not handled your request properly, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
9. Security
We apply reasonable technical and organisational measures to protect data: encryption in transit, restricted access, passwords never stored in plain text, and strict separation of each client's data so that no client can reach another's information.
10. Changes to this policy
If the way we handle data changes, we will update this page and its date. It's worth checking back occasionally.