Privacy Policy
Art. 13 EU Reg. 2016/679 – GDPR)
Last updated: April 25, 2026
1. DATA CONTROLLER
The Data Controller is:
Stayvolution is currently being tested in a limited private beta with selected hospitality partners. The service is operated by the project founder during the beta phase.
Email: [email protected]
2. PURPOSE OF THIS POLICY
This Privacy Policy explains how personal data is collected and processed when using the Stayvolution platform and related services.
Stayvolution is a SaaS platform for hospitality operators that enables the collection, management, and analysis of guest feedback and operational insights.
3. ROLE UNDER GDPR
Depending on the type of data processed, Stayvolution acts as:
3.1 Data Controller
for:
- customer account management
- billing and contractual relationships
- website and platform usage data (for service operation, security, and improvement)
- marketing and communication activities
3.2 Data Processor
for personal data relating to Guests processed through the platform by Customers.
In this case:
- the Customer acts as Independent Data Controller
- Stayvolution processes such data as Data Processor under Art. 28 GDPR
The terms governing this relationship are defined in a separate Data Processing Agreement (DPA).
4. PERSONAL DATA WE COLLECT
4.1 Data relating to Customers
We may collect:
- name and surname
- email address
- phone number
- business or residential address
- company name
- VAT number
- account credentials
- billing and payment data (via third-party payment providers)
- communication history with support
- technical data (IP address, device, browser information)
- platform usage data (logs, actions performed, timestamps)
4.2 Data relating to Guests (processed on behalf of Customers)
Guests’ personal data may be processed when Customers use the platform, including:
- name
- email address
- phone number
- reservation or stay details
- feedback, complaints, and messages
This data is provided and controlled by the Customer.
4.3 Data provided directly by Guests
Guests may submit:
- feedback
- complaints
- messages directed to accommodation providers
No account is required for Guests.
5. PURPOSES OF PROCESSING
5.1 Customer data (Controller role)
We process Customer data to:
- provide and operate the platform
- manage accounts and authentication
- provide customer support
- handle billing and payments
- comply with legal obligations
- ensure security and fraud prevention
- improve platform functionality and performance
5.2 Guest data (Processor role)
Guest data is processed exclusively to:
- enable Customers to collect and manage feedback
- support complaint handling workflows
- provide analytics and reporting tools
- display insights within the platform
5.3 Marketing and communications
Where permitted:
- send service updates and communications
- provide marketing content
- run advertising campaigns (Google, Meta, YouTube, Other)
- perform remarketing activities
5.4 Analytics
We use analytics tools (e.g. Google Analytics, Matomo or similar) to:
- analyse platform usage
- improve performance and user experience
- generate aggregated statistics
6. LEGAL BASIS
Processing is based on:
- performance of a contract (Art. 6(1)(b) GDPR)
- legal obligations (Art. 6(1)(c) GDPR)
- legitimate interests (Art. 6(1)(f) GDPR), including security and service improvement
- consent (Art. 6(1)(a) GDPR), where required (e.g. marketing cookies or emails)
7. CUSTOMER RESPONSIBILITY FOR GUEST DATA
Customers are responsible for ensuring that any Guest data processed through the platform is:
- collected in compliance with applicable data protection laws
- based on a valid legal basis under GDPR
- appropriately communicated to data subjects where required
Further obligations are governed by the Data Processing Agreement between the Customer and Stayvolution
8. DATA RETENTION
We retain personal data only for as long as necessary for the purposes described above:
- Customer account data: duration of contract + legal retention period (up to 10 years in Italy for accounting purposes)
- usage and technical logs: up to 24 months (unless required for security/legal reasons)
- Guest data: retained according to Customer instructions and platform configuration
9. DATA SHARING
Personal data may be shared with third parties acting as processors or service providers, including:
- hosting and cloud infrastructure providers (primarily EU-based)
- payment processors (e.g. Stripe)
- analytics providers (Google Analytics, Matomo, etc.)
- advertising platforms (Google, Meta, YouTube)
- CRM and marketing tools
- customer support and communication tools
- professional advisors (legal, accounting, tax, etc)
All providers are bound by appropriate contractual and GDPR-compliant safeguards.
10. INTERNATIONAL TRANSFERS
Some service providers may be located outside the European Economic Area (EEA).
In such cases, personal data may be transferred outside the EEA where necessary to provide the Service.
11. SECURITY MEASURES
We implement appropriate technical and organisational measures to protect data, including:
- encrypted communications (HTTPS/TLS)
- access control systems
- authentication and authorisation mechanisms
- logging and monitoring systems
- secure EU-based infrastructure where applicable
12. DATA SUBJECT RIGHTS
Data subjects have the right to:
- access their data
- rectify inaccurate data
- request deletion
- restrict processing
- object to processing
- withdraw consent where applicable
Requests can be sent to: [email protected]
Where applicable, requests relating to Guest data may be redirected to the relevant Customer.
13. COOKIES
The platform uses cookies and similar technologies for:
- essential functionality
- analytics
- marketing and advertising
Full details are provided in the Cookie Policy.
14. AUTOMATED PROCESSING
The platform may use automated systems to:
- categorise feedback
- analyse sentiment
- generate operational insights
These tools support decision-making but do not produce legal or similarly significant effects without human intervention.
15. CHILDREN
The service is intended for professional use and is not directed to individuals under 18 years of age.
16. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The last update date is at the top of this page.
17. APPLICABLE LAW AND JURISDICTION
This Privacy Policy is governed by Italian law and EU GDPR regulations.
Any dispute shall be subject to the exclusive jurisdiction of the Court of Florence, Italy.
