Draft — pending legal review. This document is a structural scaffold. Every value in square brackets must be completed by Klimpy and the whole text reviewed by a qualified adviser before it is relied on.
Privacy Policy
How Klimpy collects, uses and stores personal data, including the traveller data processed on behalf of accommodation providers.
Last updated: [date]
1. Who is responsible for your data
The controller is [legal entity name], [company form], registered at [registered address], with tax identification number [NIF/CIF] and entered in the [registry] under [registry entry].
Questions about this policy, or about how your data is handled, go to support@klimpy.com. Where a data protection officer has been appointed, their contact details are [DPO contact].
2. Controller and processor: which one applies
Klimpy acts as a controller for the data of its own customers — the accounts, billing details and support correspondence of the hosts and property managers who use the service.
For traveller data submitted through the platform under Real Decreto 933/2021, Klimpy acts as a processor on the accommodation provider's instructions. The provider remains the controller and the party registered with the authority.
3. What data is processed and why
Account data — name, email address, telephone number, billing details — is processed to provide and bill the service, on the basis of the contract between you and Klimpy.
Traveller identity and payment-method data is processed to meet the documentary-registration duty the accommodation provider is subject to, on the basis of that legal obligation. The categories of data are those enumerated in the annex to the decree in force.
Support correspondence and product usage data is processed to operate and improve the service, on the basis of legitimate interests. Optional analytics is processed only where consent has been given, and can be withdrawn at any time through Cookie Preferences in the footer.
4. Who the data is shared with
Traveller submissions are transmitted to the Spanish Ministry of the Interior through the SES Hospedajes platform, and to equivalent authorities in other jurisdictions where the provider operates.
Klimpy uses sub-processors for hosting, database, email delivery and payment processing. The current list, together with the location of each, is [sub-processor list]. Sub-processors are bound by written terms no less protective than those in this policy.
5. Where the data is stored and for how long
Data is stored in [region]. Where a transfer outside the EEA occurs, it is covered by [transfer mechanism].
Traveller records are retained for the period the applicable decree requires, which is set by law and not by Klimpy. Account data is retained for the life of the account and for [retention period] afterwards. Support correspondence is retained for [retention period].
6. Your rights
You may request access to your data, correction of inaccurate data, erasure, restriction of processing, portability, and you may object to processing based on legitimate interests. To exercise any of these, write to support@klimpy.com.
Where Klimpy acts as a processor, requests about traveller data are forwarded to the accommodation provider, who is the controller and answers them.
If you consider your data has been handled unlawfully you may complain to the Agencia Española de Protección de Datos, or to the supervisory authority of your country of residence.
7. Cookies
Essential cookies keep the site working — the chosen language, the chosen theme, and the record of your cookie decision itself. They cannot be switched off because the site cannot function without them.
Analytics cookies are optional, set only after consent, and measure which guides are read. You can change your decision at any time through Cookie Preferences in the footer.
8. Changes to this policy
Material changes are announced on this page and take effect on the date shown at the top. The date changes whenever the text changes.