Privacy Policy

Your privacy matters to us

At Codebay Solutions Limited (“We”, “Us”, or “Our”), Our primary aim is to ensure that all Personal Data is processed lawfully, fairly, and transparently, in full accordance with applicable data protection laws.

This Privacy Policy describes how We collect, use, and otherwise process Personal Data when individuals interact with Us—for example, by visiting www.lodgify.com, creating a Customer Account, using Lodgify Platform and/or any other Service provided by Us (“You”, “Your”). It also outlines the rights granted under applicable data protection law and how they may be exercised.

Before navigating or interacting with this Website, accessing its content or contacting Us through any of its channels, You should carefully read and understand this Privacy Policy. Likewise, if You intend to create and maintain a Customer Account, access the Lodgify Platform or use Our Services, You must first accept this Privacy Policy along with Our Terms of Service, which jointly establish the terms and conditions governing such use.

Depending on the specific features, functionalities or Services You choose to activate or use, please note that additional privacy notices may apply to the processing of Your Personal Data. In such cases, we encourage You to consult this Privacy Policy, along with any other applicable service-specific privacy notice, in order to fully understand how We—and, where relevant, Our Partners or any other third-parties involved—process Your Personal Data. If You are unsure which privacy notice applies to Your situation, please contact Us before proceeding.

If You have any questions or concerns about this Privacy Policy or about how Your Personal Data is handled, You may contact Us at any time via our online request form or through any of the contact channels provided herein.

Contents

1. Definitions
2. To whom this Privacy Policy applies?
3. Who is the Data Controller of Your Personal Data?
4. What category of Personal Data do We collect and process?
   4.1. Personal Data provided by You
   4.2. Personal data You give Us about other individuals
   4.3. Personal data We collect automatically
   4.4. Personal Data received from Our Partners and/or other third parties
5. Why do We collect and process Your Personal Data, on what legal basis, and for how long?
6. To whom do We disclose Your Personal Data, and under what circumstances?
7. What are Your rights under Data Protection Law?
8. Cookies
9. Validity and Modifications

1. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below.

Undefined terms shall have the same definition as in Our Terms of Service.

Terms such as “Consent”, “Data Controller”, “Data Processor”, “Personal Data”, “Process/Processing” and “Personal Data Breach” shall have the meaning given to them under the UK GDPR.

Affiliate means an individual who promotes Lodgify Platform, and, in return, earns a commission for each new customer referred.

Customer(s) means either (i) the individual who signs up for a Customer Account; or (ii) the legal entity or company on whose behalf an individual creates and manages a Customer Account in order to access and use the Lodgify Platform and/or the Services.

Customer Account refers to the account which the Customer creates in order to access the Lodgify Platform and/or use the Services.

Customer’s Services refers to the services, products, or offerings made available by Customers through Lodgify Platform and or the Services, including, but not limited to, property rentals, booking management, and any other related activities or services independently operated by the Customer.

Guest(s) refers to the natural person who uses Customer’s Services (e.g., the individual who makes a booking).

Lodgify Platform refers to the proprietary software environment operated by Us, which includes the web-based interface, and any associated applications, systems, tools, or features.

Our Partner(s) refers to any third-party entity with which We have established commercial or technical collaborations. Partners may provide complementary services, technologies, or integrations that enhance or support the functionalities of the Lodgify Platform and/or the Services.

Service(s) refers to all services provided by Us to Customers, which may include, among others, the creation, maintenance, and hosting of websites, the provision of booking and payment systems, the management of bookings and communications with Guests, as well as the integration and synchronization of content with third-party channels via channel managers and functionalities such as Smart Pricing.

User(s) is an individual or entity designated by Our Customer and entrusted with the administration and oversight of one or multiple short-term rental properties.

User Account refers to the account created by a Customer and assigned to a User in order to access the Lodgify Platform and/or use the Services. This account is configured with specific permissions defined by Our Customer, granting User access to certain features and data within the Lodgify Platform.

Visitor(s) refers to any natural person who visits, accesses and/or interacts with the Website and/or any related service provided by Us through it, without having registered as a Customer, an Affiliate or a User.

Visitor Account refers to the account which the Visitor creates in order to access the Lodgify Academy, the Independent Host Academy, and/or the Services provided within the Website .

Website means the website operated by Us, accessible at www.lodgify.com.

2. To whom this Privacy Policy applies

This Privacy Policy applies to Visitors, Customers, Users and Affiliates. It does not apply to Guests and/or to individuals who visit, browse, or interact with websites operated by Our Customers. In such cases, the relevant Customer acts as the sole Data Controller. Any processing of Personal Data conducted by Customers as an independent Data Controller shall be governed by Customer’s own privacy policy.

If You access third-party websites, products, services, applications, or platforms — including those of Our Partners — via links, integrations, or functionalities available on Our Website or Lodgify Platform, please note that the data processing practices of such third parties may fall, in whole or in part, outside the scope of this Privacy Policy and/or beyond Our control. We strongly recommend that You carefully review the applicable privacy policies before sharing or submitting any Personal Data.

3. Who is the Data Controller of Your Personal Data?

The Data Controller is:

CODEBAY SOLUTIONS LIMITED

Registered at the Registrar of Companies for England and Wales under number 5903966

Address: Magma House, 16 Davy Court Way, Castle Mound Way, Rugby, Warwickshire, CV23 0UZ, United Kingdom.

Phone: (+44) 20-3871-3305.

ICO Registration Number: ZA188069.

4. What category of Personal Data do We collect and process?

The Data Controller is:

CODEBAY SOLUTIONS LIMITED

Registered at the Registrar of Companies for England and Wales under number 5903966

Address: Magma House, 16 Davy Court Way, Castle Mound Way, Rugby, Warwickshire, CV23 0UZ, United Kingdom.

Phone: (+44) 20-3871-3305.

ICO Registration Number: ZA188069.The categories of Personal Data We collect and process vary according to the specific features You use, the purpose of the interaction, and the channels through which You engage with Us.

Personal Data may be obtained directly from You, automatically generated when You interact with the Website or Lodgify Platform or received from third parties with whom We collaborate.

4.1. What category of Personal Data do We collect and process?

The Data Controller is:

CODEBAY SOLUTIONS LIMITED

Registered at the Registrar of Companies for England and Wales under number 5903966

Address: Magma House, 16 Davy Court Way, Castle Mound Way, Rugby, Warwickshire, CV23 0UZ, United Kingdom.

Phone: (+44) 20-3871-3305.

ICO Registration Number: ZA188069.The categories of Personal Data We collect and process vary according to the specific features You use, the purpose of the interaction, and the channels through which You engage with Us.

Personal Data may be obtained directly from You, automatically generated when You interact with the Website or Lodgify Platform or received from third parties with whom We collaborate.

We process the Personal Data that You voluntarily provide to Us —for instance, when You create or manage a Customer or Visitor Account, set up property listings, complete forms, subscribe to a newsletter, register for a webinar, or post a comment on Our blog.

In such cases, the categories of Personal Data collected and processed by Us may include, among others, identification and contact details (e.g., name, email address, and telephone number); billing and business data; property-related information (e.g., property address); account settings; and any kind of content voluntarily shared by You that includes Personal Data.

When You communicate with Us—whether via support tickets, email, telephone, chat, webinar participation, or social media— We may process both the content of Your Communication and the associated metadata, including timestamps, communication channels, and technical identifiers.

Where applicable, such as during recorded demos or webinars, audiovisual recordings may be collected and stored. This means We may process Your image and voice when You participate in those sessions. Where the processing involves the recording of audio or video content, You will be expressly informed in advance.

Where communications take place through AI-supported sales or onboarding calls, We may process audio recordings, AI-generated transcripts, and related call metadata in accordance with the purposes described in this Privacy Policy. Where audio recording occurs, You will be expressly informed in advance.

We may further process data reflecting Your preferences and expressed interests — such as submitted reviews, ratings, saved materials, or interactions with Our content — in order to personalize Your experience and enhance the relevance of the information or services We provide.

4.2. Personal data You give Us about other individuals

You may occasionally submit Personal Data relating to other individuals or entities —for instance, when setting up or administering a Customer Account on behalf of a legal entity, or when inviting Users to create a User Account.

If You disclose to Us Personal Data about others, You are responsible for ensuring that the relevant individuals have been properly informed of the disclosure of their Personal Data to Us. Where required, You must ensure that valid consent has been obtained, or that another appropriate legal basis under applicable data protection laws supports the processing of such Personal Data.

4.3. Personal data We collect automatically

When You access or use the Website and/or the Lodgify Platform, We may automatically collect certain categories of Personal Data, such as the full Uniform Resource Locators (URL) clickstream to, through and from Our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call Our customer service team.

Part of this data is collected through cookies or similar tracking technologies. Where such technologies are not strictly necessary for the operation of the Website or the provision of the Services, We rely on Your prior consent to process such data, and the processing is carried out in accordance with Our Cookie Policy.

4.4. Personal Data received from Our Partners and/or other third parties

We may obtain Personal Data through Our Partners and/or other third parties with whom We maintain contractual relationships, such as payment service providers, analytics and advertising providers, communication infrastructure partners etc.

The Personal Data We receive from Our Partners and/or third-parties may be processed together with the information You provide Us.

Please note that Lodgify does not directly collect or store payment card details. All payments made through the Platform are processed by external providers, who act as independent Data Controllers with respect to payment data.

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6. To whom do We Disclose Your Personal Data, and under what circumstances

We may disclose Your Personal Data to third-party entities that provide services to Us and act as Data Processors. These service providers are engaged solely to carry out functions that are essential for the proper functioning, ongoing maintenance, and continuous improvement of the Lodgify Platform and the Services We offer. The categories of such recipients may include, among others:

– Codebay Solutions S.L.U., a wholly owned subsidiary of Codebay Solutions Ltd, which supports the development and management of the Lodgify software infrastructure by providing operational and technical assistance;

– Technical and operational service providers, including channel managers, payment processors, video conferencing and recording platforms, domain registration services, and software vendors whose technologies integrate with Our Services (including, but not limited to, Airbnb Ireland UC, Booking.com B.V., Homeaway.com Inc., Expedia Lodging Partner Services Sarl, Google LLC, Newfold Digital Inc., and Rental Ninja SL);

– Marketing and advertising partners, for the delivery of targeted promotional content and the measurement of campaign performance;

– Analytics providers, who assist Us in understanding interactions and in improving the usability, functionality, and overall performance of Lodgify Platform and the Website;

– Communications infrastructure providers, who facilitate the operation of security features such as multi-factor authentication (e.g., Twilio Spain S.L.).

– AI-enabled service providers, who support the delivery of certain functionalities of the Lodgify Platform and the Website, including the conduct of demonstration sessions, onboarding assistance, AI-supported sales calls, the processing of customer support enquiries, the recording or transcription of AI-supported calls for quality assurance purposes, and the analysis of interactions in order to improve the usability, functionality, and overall performance of the Lodgify Platform and the Website;

In certain cases, Your Personal Data may be transferred to or stored in jurisdictions outside the European Economic Area (EEA), including countries that may not provide the same level of data protection as under EEA regulations. When such transfers occur, We ensure that adequate safeguards are in place, in accordance with UK GDPR or EU GDPR, as applicable. These may include, among others:

– Adequacy decisions issued by the Information Commissioner’s Office (ICO), confirming that the destination country ensures an adequate level of protection; or

– Standard Contractual Clauses (SCCs) approved by the European Commission under Article 46(2) GDPR, the Data Transfer Agreement (IDTA) and International Data Transfer Addendum (Addendum).

Additionally, We may disclose Your Personal Data when such disclosure is required to comply with applicable legal obligations, including those arising under administrative, judicial, or regulatory procedures. This may occur, for example, in response to lawful requests by public authorities, court orders, or legal proceedings.

We may also disclose Your Personal Data when such disclosure is reasonably necessary to protect and defend Our rights or property, enforce Our Terms of Service or other contractual obligations, prevent or investigate suspected fraud, abuse, or security incidents, or to ensure the safety and legitimate interests of Customers, Affiliates, Visitors, Users, or third parties.

7. What are Your rights under Data Protection Law?

Regardless of the specific purpose or legal basis under which We process Your Personal Data, You may exercise the following rights in accordance with applicable data protection legislation:

Right of Access. You have the right to obtain confirmation as to whether We are processing Your Personal Data and, if so, to access such data. You may also consult part of this information directly through Your Account settings.

Right to Rectification. You may request the rectification of inaccurate or incomplete Personal Data concerning You, without undue delay. You may also update Your details directly within the relevant section of Your Account. Please ensure that all data provided to Us is accurate and up to date and inform Us promptly of any changes. You are solely responsible for any loss or damage caused as a result of providing inaccurate, incomplete, or outdated Personal Data.

Right to Erasure You may request the erasure of Your Personal Data when it is no longer necessary for the purposes for which it was collected, when You withdraw Your consent (where applicable), or when We are no longer legally permitted to retain it.

Right to Restriction of Processing. In certain circumstances, You may request the restriction of the processing of Your Personal Data — for example, while We verify the accuracy of the Personal Data or assess an objection to processing.

Right to Data Portability. Where processing is based on consent or a contract and carried out by automated means, You may request to receive the Personal Data You provided in a structured, commonly used, and machine-readable format, and to have it transmitted directly to another Data Controller, where technically feasible.

Right to Object. Where We rely on Our legitimate interest as a legal basis, You have the right to object to the processing of Your Personal Data. We will evaluate such objection and cease processing unless We can demonstrate compelling legitimate grounds that override Your interests, rights, and freedoms.

Right to Withdraw Consent. Where We rely on Your consent to process Your Personal Data, You have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights. You may exercise any of the above rights by contacting Us at the following addresses:

– Postal address: Avenida de Josep Tarradellas, 20-30, P.5., 08029 Barcelona, Spain

– Email: privacy@lodgify.com

Right to Lodge a Complaint. You also have the right to lodge a complaint with the competent Data Protection Authority if You believe that the processing of Your Personal Data infringes applicable data protection law:

– In Spain: Agencia Española de Protección de Datos (AEPD)

– In the United Kingdom (if applicable): Information Commissioner’s Office (ICO)

8. Cookies

We use cookies and similar tracking technologies to ensure the proper operation of Our Website, improve Your experience, analyze browsing behavior, and, where applicable, deliver personalized content or advertising.

You can configure Your browser settings to block or alert You about the use of cookies. Please note that disabling certain types of cookies may affect the functionality or availability of specific features on the Website.

For detailed information about the categories of cookies We use, their specific purposes, and how You can manage or withdraw Your consent, please refer to Our Cookies Policy.

9. Validity and modifications

This Privacy Policy may be amended, supplemented, or updated at any time in order to reflect changes in Our data processing activities, legal obligations, or technological developments.

Any material changes will be communicated through the same channels by which this Privacy Policy is made available (e.g., via publication on the Website), or, where appropriate, via direct notification.

The version of the Privacy Policy published at the time of access or interaction with the Website, the Platform, or the Services shall apply, until it is replaced by a new version duly published. We encourage You to check this page periodically to stay informed of how We protect Your Personal Data.