Privacy policy
1. General Overview and Controller
Holiday Innovation SA (registered office: Via Arch. Rino Tami 18, 6924 Sorengo, Switzerland; hereinafter "WowHomes", "we", or "us"), as the operator of this website and provider/intermediary of vacation rentals, is the data controller responsible for the processing of your personal data.
We place great importance on protecting your privacy and process your personal data ("Personal Data") in compliance with the Swiss Federal Act on Data Protection (revFADP) and—where applicable—the EU General Data Protection Regulation (GDPR).
If you have any questions regarding the processing of your Personal Data or wish to exercise your rights, you can contact us as follows:
-
Postal Address: Holiday Innovation SA, Via Arch. Rino Tami 18, 6924 Sorengo, Switzerland
-
E-mail for Privacy Inquiries: dpo .at. wowhom.es
2. Collection and Processing of Personal Data
2.1 Information Provided by You
We collect Personal Data that you voluntarily provide to us when using our website, making bookings, or communicating with us:
-
Booking Data (Mandatory Information): First name, last name, residential address, e-mail address, mobile phone number. Without this data, we cannot execute the requested booking.
-
Forms & Special Requests: Data submitted via online forms (e.g., via Jotform).
-
Statutorily Mandated Identification Data: Identification numbers and copies of passports, national identity cards, or other ID documents where legally required to fulfill statutory registration requirements for guest reporting to authorities.
-
Payment & Financial Data: Information for processing payments, security deposits, and refunds (e.g., credit card details, bank account information).
-
Communication Data: Correspondence and records of inquiries via e-mail, telephone, contact forms, or messaging services (e.g., WhatsApp).
-
Feedback and Surveys: Voluntary responses to customer surveys or reviews.
2.2 Data Collected Automatically
Whenever you visit our website, we automatically collect technical data regarding your device and your usage of our platform:
-
IP address, server log files, date and time of access
-
Browser type and version, operating system
-
Referrer URL (the previously visited page) and clickstream activity
-
Location data (provided you have consented to its collection in your browser/device settings)
3. Purposes of Data Processing
We process your Personal Data exclusively for the following purposes:
-
Contract Performance & Booking Management: To process reservations, provide accommodations, handle payments, and deliver customer support.
-
Compliance with Legal Obligations: To satisfy statutory and police registration/reporting obligations for vacation guests, as well as tax and accounting record-keeping requirements.
-
Communication: To send booking confirmations, arrival details, and support responses.
-
Marketing & Information: To send newsletters or promotional offers (where you have consented or where we have a legitimate interest; you may object to this processing at any time).
-
Security & Optimization: To ensure the IT security of our website, troubleshoot issues, and measure reach/analytics.
4. No Automated Individual Decision-Making / No Profiling
We do not carry out fully automated individual decision-making that produces legal effects concerning you or significantly affects you (Art. 21 revFADP). Likewise, we do not conduct high-risk profiling.
5. Disclosure of Data to Third Parties
To fulfill our contractual obligations and deliver our services, we engage selected partners and service providers. Your data is only disclosed to the following recipients or categories of recipients:
-
Property Owners & Landlords: When you book an accommodation through our platform, we pass your relevant booking details (e.g., name, arrival date, contact details) to the respective owner or landlord of the booked property so that they can manage accommodation provision and check-in on site.
-
Appointed Service Providers: If you book additional services through us or if required for accommodation provision (e.g., external cleaning companies for final cleaning, transport, or maintenance services), we share necessary data (e.g., name, contact details, cleaning time slots, or billing address) with the respective service providers.
-
Fiduciary, Tax Advisors & Accounting Software: To comply with statutory accounting and tax duties, we transfer relevant financial and billing data to our external tax advisor/fiduciary and store them in accounting software solutions (e.g., Banana Accounting).
-
IT & Software Service Providers (PMS / CRM / Forms): Avantio (Spain) for property and booking management, and Jotform (USA) for online form collection.
-
Payment Service Providers & Banks: Stripe (USA/EU) and Payrexx (Switzerland) for secure online payment processing, as well as banking institutions (PostFinance, Wise) for executing financial transactions, refunds, or security deposits.
-
Automation & Document Management: Make.com (Czech Republic), Google Drive / Google Workspace (Google LLC), and esignatures.com for electronic contract execution.
-
Customer Service & Communication: WATI (WhatsApp Business Solution) for customer communications.
-
Web Analytics: Google Analytics for anonymized website usage measurement.
-
Authorities & Police: Where legally required, e.g., under statutory guest reporting duties.
6. International Data Transfers
Our service providers and servers are primarily located in Switzerland and countries within the European Union (EU / EEA) (e.g., Spain, Czech Republic, Germany).
Where local service providers (e.g., cleaning services) or Swiss accounting tools (Banana) are used, such data remains within Switzerland or the EU.
Because we also utilize international service providers and cloud services, your Personal Data may be transferred to the following third countries outside Switzerland and the EU:
-
USA (e.g., Google, Stripe, Jotform, esignatures.com)
-
Australia (esignatures.com)
-
Hong Kong / India (WATI)
-
United Kingdom / International (Wise)
If a recipient country does not guarantee an adequate level of data protection by law, we ensure the protection of your data by concluding Standard Contractual Clauses (SCCs) issued by the European Commission (including Swiss adaptions) or through other legally recognized safeguards.
7. Retention Period
We process and store your Personal Data only for as long as necessary to fulfill our contractual and legal obligations or the purposes for which it was collected:
-
Booking & Financial Data: Pursuant to Swiss commercial and tax law obligations (Art. 958f Swiss Code of Obligations), accounting documents, payment records, and business correspondence are retained for 10 years.
-
Statutory Identification Documents: ID scans uploaded through our booking system are no longer accessible to us after guest check-out. ID numbers are retained in our booking files in accordance with statutory retention periods.
-
Inactive User Accounts / Marketing: Data from inactive user profiles is deleted 5 years after last activity, or 1 year after an account deactivation request.
-
Blocked Accounts: In case of breaches of our Terms and Conditions, we retain data for 2 to 10 years after blocking to prevent circumvention.
8. Cookies and Web Analytics
8.1 Use of Cookies
Our website uses cookies and similar technologies. Cookies are small text files stored on your device. We use technically necessary cookies required for website operation and booking execution, as well as functional and analytical cookies to optimize our services.
You can decline the storage of cookies or delete existing cookies via your browser settings. Deactivating technically necessary cookies may, however, limit the functionality of our website. For further details, please consult our separate Cookie Policy.
8.2 Web Analytics with Google Analytics
We use Google Analytics on our website, a web analytics service provided by Google Ireland Limited (for users in Europe/Switzerland) or Google LLC (USA).
Google Analytics uses cookies that enable an analysis of your use of the website. We use Google Analytics with IP anonymization enabled. Your IP address is shortened by Google within Switzerland and the EU prior to transmission. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
You can prevent the collection and processing of data generated by the cookie by Google by installing the browser plugin available at: https://tools.google.com/dlpage/gaoptout or by adjusting your preferences in our Cookie Banner.
9. Your Rights
Under the Swiss Federal Act on Data Protection (revFADP), you have the following rights regarding your Personal Data:
-
Right of Access: You have the right to request information free of charge as to whether and what Personal Data we process about you.
-
Right to Rectification: You can request the correction of inaccurate or incomplete Personal Data.
-
Right to Erasure (Right to be Forgotten): You may request the deletion of your data, provided no statutory retention duties (e.g., 10-year accounting retention requirement) or overriding legitimate interests apply.
-
Right to Restriction & Objection: You may object to data processing (in particular for direct marketing purposes) or request the restriction of processing.
-
Right to Withdraw Consent: Where processing is based on your consent, you may withdraw your consent at any time with future effect.
-
Right to Data Portability: You have the right to receive Personal Data you provided to us in a structured, commonly used, and machine-readable format.
Please send requests or inquiries by e-mail to dpo .at. wowhom.es or by post to our address. We process requests within the statutory deadline of 30 days.
You also have the right to lodge a complaint with the competent supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner (FDPIC) (www.edoeb.admin.ch).
10. Data Security
We implement appropriate technical and organizational security measures (TOMs) in accordance with Art. 8 revFADP to protect your Personal Data against unauthorized access, loss, misuse, or alteration. In the event of a high-risk security breach affecting your personality rights or fundamental rights, we will notify the FDPIC and, where required, you without delay.
11. Amendments to this Privacy Policy
We reserve the right to amend this Privacy Policy at any time to adapt it to changing legal requirements or changes in our services. The version currently published on our website shall apply.
