Privacy & Data Protection Policy

1. Introduction

Mavoe Properties Ltd is committed to protecting the privacy, confidentiality and security of personal information collected through our serviced accommodation and property management activities.

We provide serviced accommodation for leisure and business travellers, contractors, families and guests requiring short- or long-term stays. We also work with landlords through agreed-rent property arrangements.

This policy explains how we collect, use, store, share and protect personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

It applies to our website, guest bookings, landlord enquiries, website chat, email, telephone, WhatsApp and other business communications.

Mavoe Properties Ltd acts as the data controller for personal information collected and processed directly in connection with its services.

2. Information We Collect

Depending on your interaction with our business, we may collect:

Guest information

• Full name and contact details.
• Booking dates, guest numbers and accommodation preferences.
• Payment and reservation information.
• Guest communications and special requests.
• Photographic identification for guest verification.
• Information relating to complaints, incidents or maintenance requests.

Landlord and business enquiries

• Names and contact details.
• Property addresses and relevant property information.
• Details required to assess and manage property agreements.
• Business correspondence and contractual information.

Website and communication information

• Information submitted through website forms.
• Email, telephone and WhatsApp communications.
• Website chat messages.
• Technical information, including IP addresses, browser information and service logs, where collected by our service providers.

We only collect personal information that is reasonably necessary for legitimate business purposes.

3. How We Use Personal Information

We process personal information to:

• Respond to enquiries and provide customer support.
• Manage accommodation bookings and reservations.
• Verify guest identities before providing property access.
• Communicate check-in instructions and accommodation information.
• Manage landlord relationships and property agreements.
• Coordinate cleaning, maintenance and operational services.
• Respond to complaints, emergencies and incidents.
• Maintain the security of our properties and services.
• Meet applicable legal, regulatory and contractual obligations.

We do not sell personal information to third parties.

4. Lawful Basis for Processing

Under UK GDPR, we process personal information using the following lawful bases, as applicable:

Contractual necessity: To manage accommodation reservations, property agreements and services requested by customers.

Legitimate interests: To respond to general enquiries, provide customer support, maintain property security and operate our business effectively, where these interests are not overridden by individuals’ rights.

Legal obligations: To comply with applicable accounting, tax, regulatory and legal requirements.

Consent: Where consent is required for a particular activity, we will request it. Individuals may withdraw consent at any time.

5. Guest Identification and Verification

To protect our properties and guests, we may require photographic identification before releasing accommodation access instructions.

Identification information is collected solely for legitimate verification, security and applicable legal purposes.

Access to identification documents is restricted to authorised individuals and service providers who require the information.

Identification documents must be retained only for as long as necessary for their intended purpose or an applicable legal requirement, after which they should be securely deleted.

Guests should not submit identification documents through unsecured communication channels or the website chatbot.

6. Data Security and Confidentiality

Mavoe Properties Ltd is committed to maintaining appropriate technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Our data protection procedures include:

• Restricting access to personal information to authorised individuals.
• Using password-protected business accounts and systems.
• Limiting the sharing of guest information to what is operationally necessary.
• Using established third-party platforms for bookings and payments.
• Reviewing access to sensitive information when responsibilities change.
• Securely deleting personal information when no longer required.
• Investigating suspected data security incidents.

Employees, contractors and service providers who handle personal information are expected to maintain confidentiality and follow applicable data protection requirements.

7. Direct Bookings and Payments

Our direct booking service is provided through Smoobu.

Information submitted through the booking system is processed to manage reservations, communicate with guests and provide accommodation services.

Card payments are processed through Stripe Connect within the booking process.

Mavoe Properties Ltd does not request payment card details through website enquiry forms, WhatsApp or the website chatbot.

Smoobu and Stripe operate under their respective privacy and data protection arrangements.

8. Website Chat and WhatsApp

Our website assistant uses an AI service to respond to general enquiries.

Information entered into the chatbot may be processed by the service provider to generate responses.

Guests should avoid submitting sensitive personal information, identification documents or payment details through the chatbot.

Where guests choose to continue conversations through WhatsApp, a pre-filled message may contain their latest enquiry. Guests can review or edit this message before sending it.

WhatsApp processes information in accordance with its own privacy policy.

9. Sharing Personal Information

We may share relevant personal information with trusted service providers where necessary to operate our business.

These may include:

• Accommodation booking and property management platforms.
• Payment processing providers.
• Website hosting and communication providers.
• Guest verification services.
• Cleaning and maintenance contractors.
• Professional advisers, insurers and legal representatives.
• Regulatory authorities where legally required.

We limit information sharing to what is necessary for the relevant service or purpose.

Where third parties process personal information on our behalf, appropriate data protection arrangements must be maintained.

10. Data Retention

We retain personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected, including contractual, operational and legal requirements.

Retention periods depend on the type of information and the reason for processing.

Our approach includes:

• General enquiries: Retained for as long as necessary to respond and manage relevant follow-up communications.
• Booking records: Retained for operational, accounting and applicable legal purposes.
• Guest identification: Retained only for the period necessary for verification, security or applicable legal requirements.
• Property agreements: Retained for the duration of the business relationship and any applicable legal retention period.
• Financial records: Retained in accordance with applicable UK accounting and tax requirements.

Once information is no longer required, it will be securely deleted, destroyed or anonymised.

11. Data Breaches and Incident Management

Mavoe Properties Ltd takes suspected personal data breaches seriously.

Where a breach is identified, we will:

1. Investigate the incident promptly.
2. Take reasonable steps to contain the breach and protect affected information.
3. Assess the potential impact on affected individuals.
4. Document the incident and any corrective action taken.
5. Notify the Information Commissioner’s Office (ICO) where legally required.
6. Inform affected individuals where the breach is likely to result in a high risk to their rights and freedoms.

Where notification to the ICO is required, we will report the breach without undue delay and, where feasible, within 72 hours of becoming aware of it.

We will review incidents to identify improvements to our data protection practices.

12. International Data Transfers

Some third-party service providers may process or store personal information outside the United Kingdom.

Where personal information is transferred internationally, we will ensure that applicable UK data protection requirements are met, including the use of appropriate safeguards where required.

13. Cookies and External Services

Our website and integrated third-party services may use cookies or similar technologies to support website functionality, booking services and security.

Users can manage cookies through their browser settings.

Where consent is legally required for non-essential cookies or similar technologies, we will obtain it before they are used.

Third-party services may have their own privacy and cookie notices.

14. Your Data Protection Rights

Under UK data protection law, individuals may have the right to:

• Request access to their personal information.
• Request correction of inaccurate information.
• Request deletion of personal information in certain circumstances.
• Restrict or object to certain processing activities.
• Request the transfer of their personal information where applicable.
• Withdraw consent where processing relies on consent.

Requests can be submitted using the contact details below.

We aim to respond to valid requests within one calendar month, subject to applicable legal exceptions or extensions.

Individuals also have the right to raise concerns with the Information Commissioner’s Office (ICO).

15. Policy Review and Responsibilities

Mavoe Properties Ltd is responsible for maintaining appropriate data protection practices across its business operations.

This policy will be reviewed annually or sooner where significant changes occur to our services, systems, legal obligations or data processing activities.

Any individuals handling personal information on behalf of Mavoe Properties Ltd are expected to comply with relevant data protection requirements.

16. Contact Information

For questions about this policy or requests relating to personal information, please contact:

Individuals may also contact the Information Commissioner’s Office (ICO) to raise concerns about the handling of personal information.