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PRIVACY POLICY AND COOKIE POLICY

Privacy

 

This Privacy Policy describes how KPM Short Stay Management LTD (hereinafter the "Company" or "KPM"), through kpm-shortstaymanagement.com (hereinafter the "Site") collects, uses, and discloses your personal information when you visit, use our property management, co-hosting, and secure rental services, or otherwise communicate with us regarding the Site (collectively, the "Services"). For the purpose of this Privacy Policy, "you" and "your" refer to the user of the Services.

Please read this Privacy Policy carefully.

 

Regulatory References

 

The processing of your personal data is carried out in compliance with the applicable data protection regulations, including:

  • Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR).

  • For the United Kingdom (UK): UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

  • Directive 2002/58/EC – concerning the "processing of personal data and the protection of privacy in the electronic communications sector".

  • Italian Legislative Decree 30 June 2003, n. 196 – "Code regarding the protection of personal data" as amended by Legislative Decree 101/2018.

 

Changes to this Privacy Policy

 

KPM may update this Privacy Policy from time to time. KPM will publish the revised Privacy Policy on the Site, updating the "Last updated" date and adopting any other measures required by applicable law.

 

How We Collect and Use Your Personal Information

 

To provide the Services, KPM collects personal information about you from a variety of sources. The information collected and used varies depending on how you interact with the Site.

In addition to the specific uses indicated below, KPM may use the information collected about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and protect or defend the Services, our rights, and the rights of our users or others.

 

What Personal Information We Collect

 

The types of personal information obtained about you depend on how you interact with our Site and use our Services.

1. Information We Collect Directly from You (via Contact Form) This information is sent to us directly through the contact form and includes:

  • Contact/Identifiers: Name, email address, telephone number.

  • Request Information: The content of your message or the information you choose to include in the communication (e.g., property type, interest in co-hosting or secure rental, period of interest).

2. Information for Contract Execution (only after the relationship begins) This information is collected during the pre-contractual or contractual phase for the provision of the requested services and may include:

  • Billing and Contract Data: Billing address, tax code/NIN, bank details (for payments and transfers).

  • Data for Legal/Security Compliance (Secure Rental): (Where necessary and required by law) Details of identity document, date of birth.

3. Information We Collect about Your Usage ("Usage Data") KPM automatically collects certain information about your interaction with the Services. For this purpose, cookies, pixels, and similar technologies (“Technical Cookies”) may be used. Usage data may include information about your IP address and other information related to your interaction with the Site.

 

How We Use Your Personal Information and Legal Bases

 

KPM uses your personal information for the following purposes, based on the respective legal bases provided by the GDPR/UK GDPR:

  • Responding to Requests and Service Evaluation:

    • Legal Basis: Performance of Pre-contractual Measures (Art. 6(1)(b)).

    • Details: To respond to your inquiries sent via the contact form, provide quotes, and evaluate the feasibility of property management or co-hosting services.

  • Contract Fulfillment:

    • Legal Basis: Performance of a Contract (Art. 6(1)(b)).

    • Details: To stipulate and execute the service contract (e.g., rental management, payment handling, communication with guests and owners).

  • Marketing and Newsletter:

    • Legal Basis: Consent (Art. 6(1)(a)).

    • Details: To send you commercial communications, service updates, and special offers, only if you have provided your explicit consent via the dedicated checkbox in the contact form.

  • Security and Legal Compliance:

    • Legal Basis: Legal Obligation (Art. 6(1)(c)) and Legitimate Interest (Art. 6(1)(f)).

    • Details: To comply with legal and tax obligations (e.g., communication of guest data to competent authorities for secure rental in Italy and the UK) and to prevent fraud and maintain the security of the Site.

  • Service Improvement:

    • Legal Basis: Legitimate Interest (Art. 6(1)(f)).

    • Details: To analyze and improve the quality and functionality of the Services offered on the Site.

 

Cookies

 

Like many websites, KPM uses cookies on the Site. Currently, KPM only uses Technical Cookies (Necessary) to ensure the operation or provision of the Service, for which prior user consent is not required under current regulations.

Most browsers automatically accept cookies by default, but you can choose to set your browser to remove or reject cookies. Please note that removing or blocking technical cookies may negatively impact your user experience.

 

How We Disclose Your Personal Information

 

KPM may disclose your personal information to third parties for contractual performance purposes, legitimate purposes, and other reasons subject to this Privacy Policy. Such circumstances may include:

  • Vendors or other third parties who perform services on behalf of KPM (e.g., IT management, hosting providers, accounting consultants, property management platforms).

  • Public Authorities/Law Enforcement when required by law or to comply with secure rental obligations (e.g., communicating guest data to the State Police in Italy or equivalents in the UK).

  • With your consent or upon your direction.

  • Affiliates or otherwise within our corporate group.

 

Security and Retention of Your Information

 

  • KPM adopts technical and organizational security measures to protect your personal information.

  • KPM retains your personal information for as long as necessary to maintain your account, provide the Services, comply with legal obligations (e.g., tax or data retention obligations for rentals), resolve disputes, or enforce other applicable contracts and policies.

 

Your Rights

 

Depending on where you reside (Italy or the United Kingdom), you may have some or all of the following rights in relation to your personal information:

  • Right of Access/Knowledge: The right to request access to the personal information we hold about you.

  • Right of Erasure: The right to request the deletion of the personal information we hold about you (the "right to be forgotten").

  • Right of Rectification: The right to ask us to correct inaccurate personal information we hold about you.

  • Right to Data Portability: The right to receive a copy of the personal information we hold about you in a structured format and to request its transfer to third parties.

  • Right to Restriction of Processing: The right to ask us to stop or limit our processing of your personal data.

  • Right to Withdraw Consent: The right to withdraw consent previously given for marketing purposes (newsletter) at any time.

  • Right to Object to Processing: The right to object to processing based on legitimate interest.

You can exercise any of these rights by contacting KPM using the contact details provided below. KPM will respond to your request promptly as required by applicable law.

 

Complaints

 

If you have complaints about how KPM handles your personal data, we encourage you to contact us using the contact details provided below. If you are not satisfied with the response to your complaint, you have the right to lodge a complaint with the competent data protection Authority:

  • For Users in Italy: Garante per la Protezione dei Dati Personali (Italian Data Protection Authority).

  • For Users in the United Kingdom: Information Commissioner's Office (ICO).

 

International Users (Data Transfers)

 

Please note that KPM may transfer, store, and process your personal information outside the country where you live.

  • EU/EEA - UK Transfers: For the transfer of personal data between the European Union/EEA and the United Kingdom (and vice versa), KPM relies on the current Adequacy Decision (or Adequacy Regulations).

  • Transfers to other third countries: If KPM transfers your personal information outside Europe to a country without an adequacy decision, it will rely on recognized transfer mechanisms such as the European Commission's Standard Contractual Clauses (SCCs).

 

Data Controller and Contact Information

 

For the purposes of applicable data protection law, KPM is the Data Controller of personal data.

  • Company: KPM Short Stay Management LT

  • VAT/Registration Number: 16617165

  • Registered Office: 24 Parklands Road, SW166TE, London (UK

  • Data Controller Email Address: info@kpm-shortstaymanagement.com

Last updated: 02/12/2025

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