Privacy Policy

I. Data Controller

The controller of your personal data, i.e., the entity that decides on the purposes and means of processing your personal data, is Comfy Cloud. For questions about data processing, please contact us at hello@comfy-cloud.co.uk.

II. Purposes of Data Processing

Comfy Cloud provides professional vacation rental and property management services for property owners and guests. In fulfilling our business objectives, we process your personal data for the following purposes:

• for the purpose of entering into and executing property management and rental contracts (Article 6(1)(b) GDPR);
• for the purpose of sending marketing content based on your consent (Article 6(1)(a) GDPR);
• for the purpose of processing bookings and managing properties through platforms we work with, including Airbnb, Booking.com, and other rental platforms;
• for billing, accounting, and financial reporting purposes (Article 6(1)(c) GDPR);
• for the purpose of sending the requested newsletter (Article 6(1)(b) GDPR);
• for the purpose of managing the contact form (Article 6(1)(f) GDPR);
• for customer satisfaction surveys, for example through the use of questionnaires;
• for improving the quality of services offered by Comfy Cloud;
• for social media purposes, for example Facebook, Instagram, LinkedIn;
• for the purpose of managing complaints, requests, and claims;
• for establishing, investigating, and defending claims;
• for the purpose of processing cookies. Comfy Cloud uses cookies necessary to enable the basic functions of the website. In addition, in the case of statistical research, marketing, or recording your preferences using cookies, Comfy Cloud will obtain your consent for storing cookies on your device.

III. Processing of Data for Human Resources

Comfy Cloud, in the process of recruiting and hiring staff, processes personal data for the following purposes:

• for human resources management – employees and contractors (Article 6(a, b, c and f) GDPR; Article 9(2)(a, b, h) GDPR);
• for the purpose of recruitment (Article 6(1)(a), (c) GDPR – for candidates for employee positions); Article 6(1)(a) and (b) GDPR – for candidates for contractor positions.

IV. Data Retention Period

Comfy Cloud is required to process your data for a legally defined period of time:

• contracts with clients for the time period specified in the contract, necessary for Comfy Cloud to fulfill its obligations that require data processing;
• financial documents for a period of time until the expiration of data retention obligations under the law, in particular the retention of accounting documents (usually 5-7 years after the year in which the legal event that required the issuance of the accounting document occurred);
• for conducting marketing activities until you have raised an objection, i.e., until we have been informed in the manner chosen by you that Comfy Cloud has ceased sending you marketing information, or until the expiration of the limitation period for claims;
• recruitment for up to 6 months after the completion of the recruitment process and, in the case of consent given for subsequent recruitment processes, for no more than one year;
• employment of employees in accordance with applicable legislation that requires archiving of employment law documents, i.e., we retain personnel files for a period of 50 or 10 years. The 10-year retention period for employee records applies to employees hired after 1.01.2019. For other employees, records will be retained for a period of 50 years;
• consent given for marketing activities until it is withdrawn;
• cookies for the periods indicated in section VIII or until you object to processing.

V. Disclosure of Data to Third Parties

In connection with its activities, Comfy Cloud will disclose your personal data to the following entities:

• business persons, including lawyers and legal advisors, who cooperate with Comfy Cloud in providing consulting services for Comfy Cloud clients;
• to state authorities or other entities authorized by law;
• entities that support us in our activities on our behalf, in particular: external ICT system providers to support our activities, entities that audit our activities, an entity that provides accounting services, or entities that cooperate with Comfy Cloud in marketing campaigns, where such entities will process data on the basis of a contract with Comfy Cloud and only in accordance with our instructions;
• payment service providers, as well as banks, in the case of a settlement requirement;
• in the case of candidates for job positions, also online recruitment portals.

VI. Mandatory or Voluntary Nature of Data Provision

The provision of data is necessary to enter into contracts and to account for activities carried out and for Comfy Cloud to comply with legal requirements. This means that if you wish to use the services we offer, you must provide your personal data.

For the rest (in particular the processing of data by Comfy Cloud for marketing purposes), the provision of data is voluntary.

VII. Your Rights

In connection with the processing of your personal data by Comfy Cloud, you have the right to:

• access your data and receive a copy of your data;
• rectification (modification) of your data;
• deletion of your data;
• restriction of processing of your data;
• portability of your data – where the legal basis for processing is consent (Article 6(1)(a) or Article 9(2)(a) GDPR) or contract (Article 6(1)(b) GDPR);
• object to the processing of your personal data – where the legal basis for processing is a legitimate interest (Article 6(1)(f) GDPR);
• withdraw your consent at any time, without affecting the lawfulness of processing based on consent before withdrawal;

In addition, you have the right to lodge a complaint with the supervisory authority, i.e., the Information Commissioner's Office (ICO) in the UK.

VIII. Cookies

Cookies are small text files that can be used by websites to allow you to use the website as smoothly as possible. The law provides that we can store cookies on your device if this is necessary for the operation of our website. For all other types of cookies, we need your consent.

Since some of the cookies we use constitute personal data, we want you to be aware of your rights under GDPR:

• Comfy Cloud stores https requests directed to the server;
• Your personal data will be processed to provide basic functions of our website, such as navigating our website and accessing secure areas of our website. If you have given appropriate consent (voluntarily), your data will also be processed to provide you with services, offers, and communications tailored to your preferences and to analyze website traffic and provide social functions (depending on the preferences you have indicated).

If you have questions about this Privacy Policy, please contact us at hello@comfy-cloud.co.uk.