PRIVACY AND DATA PROTECTION POLICY

Direct reservations and guest registration at www.manlia.es

1. Data Controller

In compliance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), and Organic Law 3/2018 (“LOPDGDD”), users and guests are informed that their personal data will be processed by:

• Data Controller: JAYJOR LIVING 2024 SL (hereinafter, “MANLIA”)
• Tax ID (CIF): B70849062
• Address: PASEO RONDA 88 BJ, 03600 ELDA, Spain
• Email: info@manlia.es
• Phone: +34 919 93 20 28

MANLIA acts as data controller for reservations, stays, guest registration, and check-in processes.

2. Scope of this policy

This policy applies to:
• People who browse www.manlia.es
• People who fill out contact or inquiry forms on the website
• People who make direct reservations through our website (without intermediaries)
• Guests staying after making a direct reservation
• People completing online or in-person check-in

If you book through external platforms (e.g., Booking.com, Airbnb, etc.), their privacy policy will apply. MANLIA will process your data as co-controller or independent controller to manage your stay.

3. Personal data we process

3.1. Browsing and website usage data

• IP address and online identifiers
• Browser type, device, operating system
• Pages visited, time spent, clicks, navigation paths
• Cookies and similar technologies (as detailed in our Cookies Policy)

3.2. Contact form data

• Name and surname (if provided)
• Email and/or phone number
• Message, subject, and any information you freely provide

3.3. Direct reservation and guest data

• Name and surname
• Phone number and email
• Reservation data: check-in/check-out dates, number of guests, apartment reserved, reservation channel
• Payment and billing data: data necessary for payment processing via secure gateway; billing data (name, tax ID, address)
• MANLIA does not directly store full card numbers, except what is strictly necessary and always via secure providers
• Data required by tourist/police regulations: document type and number, date of birth, nationality, and other mandatory fields
• Stay-related data: incidents, preferences, special requests, communications

3.4. Guest registration and check-in data (online or in person)

For identity verification and guest registration, we may process:
• Full name, date of birth, nationality
• ID/passport number and issuing country
• Reservation details (dates, apartment, number of guests)
• For online check-in: a photo of your ID/passport and, if required, a selfie — solely to verify authenticity and match

Photos are automatically deleted once verification is completed.

4. Purposes and legal bases

4.1. Website browsing and improvement

Purposes: technical functioning, usage analysis, error detection, user experience improvement
Legal bases:
• Essential cookies → legitimate interest (Art. 6.1.f GDPR)
• Non-essential cookies → consent

4.2. Handling inquiries and information requests

Purposes: respond to inquiries about availability, prices, apartments, etc.
Legal bases:
• Pre-contractual measures (Art. 6.1.b)
• Legitimate interest (Art. 6.1.f)

4.3. Managing direct reservations and stays

Purposes: process reservations, confirmations, payment management, legal obligations, incident management
Legal bases:
• Contract performance (Art. 6.1.b)
• Legal obligation (Art. 6.1.c)

4.4. Communications related to your reservation

Purposes: confirmations, pre-arrival information, check-in instructions, check-out reminders, post-stay surveys
Legal bases:
• Contract performance and legitimate interest (Art. 6.1.b, 6.1.f)

4.5. Commercial communications (marketing)

Purposes: sending offers, promotions, and updates for future stays
Legal bases:
• Explicit consent (Art. 6.1.a)
• Legitimate interest, with right to object (Art. 6.1.f)

You may withdraw consent or object at any time by emailing info@manlia.es.

4.6. Security, fraud prevention, and legal defense

Purposes: prevent misuse, manage conflicts or claims, damages, serious incidents
Legal basis:
• Legitimate interest (Art. 6.1.f)

4.7. Purposes related to guest registration and check-in

Purposes:
• Execute the accommodation contract
• Fulfill legal obligation to register guests with Spanish authorities
• Ensure safety of the apartment and building
Legal bases: contract (Art. 6.1.b), legal obligation (Art. 6.1.c), legitimate interest (Art. 6.1.f)

MANLIA does not use these data for marketing unless you provide separate explicit consent.

5. How we process, store and share your data

• Registration is carried out through our management system (Avantio), under a processor contract with appropriate security measures
• Photos from online check-in are deleted automatically after verification
• Only the legally required guest registration document is kept
• Mandatory guest information is sent via SES Hospedaje to the Spanish Ministry of Interior
• Technical service providers (hosting, PMS, email, analytics) act as processors under GDPR-compliant agreements
• Property owners may receive minimal data strictly when necessary to manage incidents or access
• Data is not sold to third parties
• Public authorities and financial entities may receive data when legally required or necessary for payments

6. International data transfers

Some providers may be located outside the EEA. MANLIA ensures adequate protection through:
• Adequacy decisions, or
• Standard contractual clauses or other safeguards

More information is available by emailing info@manlia.es.

7. Data retention periods

• Reservation and billing data: duration of contract plus legal retention periods (generally 5–6 years)
• Guest registration data: 3 years from check-out, in accordance with Royal Decree 933/2021
• Inquiry data: for the duration of the inquiry and a reasonable follow-up time, then anonymized or deleted
• Marketing data: until consent is withdrawn, objection is exercised, or after prolonged inactivity
• Legal defense data: while liability may exist

After retention periods, data are deleted or anonymized.

8. Cookies and similar technologies

This website uses essential cookies and, with consent, analytics and personalization cookies.
See the Cookies Policy for full details.

9. Your data protection rights

You may exercise the following rights free of charge:
• Access
• Rectification
• Erasure
• Restriction
• Objection
• Portability

Contact:
JAYJOR LIVING 2024 SL
Paseo Ronda 88 BJ, 03600 Elda
Email: info@manlia.es
Phone: +34 919 93 20 28

Include: full name, right you wish to exercise, data concerned, and copy of ID.

If you are not satisfied with the response, you may file a complaint with the Spanish Data Protection Agency (AEPD) — www.aepd.es.

10. Information security

MANLIA applies technical and organizational measures: HTTPS, access controls, staff confidentiality policies, secure systems, and more.
Although no system is 100% invulnerable, MANLIA commits to acting quickly and diligently in case of an incident.

11. Check-in options

You may choose how to complete your registration:

11.1. Fully online check-in

• Provide your details and upload a photo of your ID/passport (and selfie if required)
• Online verification before arrival
• Images are automatically deleted after validation

11.2. In-person check-in at our office

• Present your original ID/passport
• Identity is verified in person
• Only legally required data are recorded
• No need to upload photos or documents online