Concierglio · Legal
Privacy Policy
Last updated 18 October 2026
Note: this is a working template. It must be reviewed by a lawyer and completed with the company details before publication. Replace the bracketed placeholders.
1. Who is responsible
[COMPANY NAME], [ADDRESS], company ID: [VAT/OIB], email: [CONTACT EMAIL] (“Concierglio”, “we”) is the controller of personal data described in this policy. Write to us at that address with any question about your data.
2. What we collect
Property owners (our customers): name, email, property details and whatever content you enter, plus subscription and billing records.
Guests: name, email, mobile number and stay dates. Where local law requires guest registration — for example Croatia's eVisitor system — also identity-document details (document type and number, date of birth, nationality, residence).
Automatically: basic technical logs and usage counts, to operate and secure the service.
3. Why we process it, and on what basis
- Providing the digital concierge service (performance of a contract).
- Guest registration with the authorities where the owner is legally required to file it (legal obligation of the property owner).
- Taking subscription payments and keeping accounts (contract, legal obligation).
- Communicating with guests during a stay (the host's legitimate interest).
4. Concierglio as a processor
For guest data the property owner is the controller and Concierglio acts as a processor, handling it only on the owner's instructions and to provide the service. A data processing agreement is concluded with each owner.
5. Identity documents
Document details are collected only where guest registration is legally required. They are kept for the shortest possible time and deleted automatically after the stay ends (see retention below).
6. Who else processes data (sub-processors)
We rely on a small number of providers, who may process data on our behalf:
- Cloudflare — hosting and database (EU/global).
- Google — nearby place data (Places API).
- OpenAI — concierge replies, where enabled.
- Stripe — subscription payments.
- Resend — transactional email.
We do not sell personal information. Transfers outside the EEA are covered by appropriate safeguards, including the European Commission's standard contractual clauses.
7. How long we keep it
Guest data — including contact and document details — is deleted or anonymised shortly after the stay ends, unless the law requires us to keep it longer. Owner data is kept while the account exists, and for the statutory accounting retention period after that.
8. Your rights (EEA/UK)
You have the right to access, correct, delete, restrict and port your data, and to object to processing. Write to [CONTACT EMAIL]. You may also complain to your national supervisory authority — in Croatia, AZOP.
9. Your rights (California and other US states)
If you are a California resident, the CCPA/CPRA gives you the right to know what personal information we collect and why, to request its deletion or correction, and to receive a copy. We do not sell or share personal information for cross-context behavioural advertising, and we do not use it for profiling that produces legal effects. Exercising these rights will never result in worse service or a different price.
Residents of other US states with comparable laws have equivalent rights. Send any request to [CONTACT EMAIL]; we respond within the period the applicable law requires.
10. Children
The service is not directed at children and we do not knowingly collect data from anyone under 16. A guest's details are entered by the person who made the booking.
11. Cookies
We use strictly necessary cookies for signing in and running the service. We do not use advertising cookies.
12. Changes
We may update this policy from time to time; the date of the last change is shown at the top of this page.