Legal
Privacy policy
Last updated: 03/11/2026
At Sereno Tech S.L. we take the protection of your personal data seriously. This Privacy policy explains what data we process, what we use it for, on what legal basis, how long we keep it, who we may share it with and how you can exercise your rights.
This policy applies to your use of tusereno.es, to contact forms, requests for information, marketing communications, the booking process, customer service, the management of stays and, where applicable, the private area or the guest and owner portal.
1. Data controller
| Item | Details |
|---|---|
| Controller | Sereno Tech S.L. |
| CIF/NIF | B44916658 |
| Registered address | Calle Tulipán, 1 — 11160 Barbate, Cádiz, España |
| Contact email | gestion@tusereno.es |
| Telephone | +34 623 008 140 |
| Website | tusereno.es |
| Data Protection Officer | Not appointed, unless legally required or unless we state otherwise |
For any matter relating to privacy or data protection you may write to gestion@tusereno.es, putting Data protection in the subject line.
2. Personal data we may process
We process different data depending on your relationship with Sereno and on how you use the website.
2.1. Contact and form data
- First name and surname.
- Email address.
- Telephone number.
- The message or query you send.
- Any data you choose to include in the form.
- Technical data about the submission (IP address and browser), to stop automated or abusive submissions.
2.2. Booking and stay data
- First name and surname of the person making the booking.
- Contact details.
- The accommodation selected.
- Arrival and departure dates.
- Number of guests.
- Preferences, special requests or comments attached to the booking.
- Information needed to handle changes, cancellations, incidents or assistance during the stay.
2.3. Data required for the traveller register
In order to comply with the applicable rules on accommodation and public safety, we may request the legally required details of the people staying, including, as appropriate:
- Identifying details.
- Identity document or passport, type and number.
- Nationality.
- Date of birth.
- Sex, where this is compulsory.
- Address or contact details, where these are required.
- Relationship to, or details of, accompanying minors, where the rules require it.
- Arrival and departure dates.
- Signature on the entry form, where this is required.
Sereno will neither request nor keep full copies of identity documents or passports unless there is a specific legal obligation or a duly documented lawful basis for doing so.
2.4. Payment and billing data
- The booking amount.
- Payment status.
- Transaction reference.
- Billing details where these are needed.
- Partial or tokenised payment method information provided by the payment provider.
Card payments are processed through Stripe. Sereno does not store full bank card details.
If you choose to pay for your booking in instalments, Stripe stores your card so that the remaining instalments can be charged automatically on the dates shown to you when you book.
If you have an account on the website, you can also ask Stripe to remember your card so that you can pay for future bookings without typing it again, by ticking the box when you pay or by adding it from your account. You can see and remove your saved cards at any time from your account, except while an instalment is still due on that card.
Sereno never sees the full card number: only the brand, the last digits and the expiry date, so that you can recognise it. A saved card is only used for payments you make or for the instalments you agreed to when booking.
2.5. Data of owners and partners
When you contact Sereno as an owner, a prospective owner, a supplier, a partner or an investor, we may process:
- First name and surname.
- Email address and telephone number.
- Details of the home or property.
- Financial, contractual or operational information needed to assess or manage the relationship.
- Communications exchanged with Sereno.
If you write to us using the owner request form, we also process: the town and address of the home, how many homes you have, whether they have a holiday rental licence, your financial expectations, any photos you choose to upload, how you heard about us and the language in which you filled in the form. Photos are kept in private storage that only the Sereno team can access.
2.6. Data of job applicants
When you send us your application through the ‘Work with us’ form, or send us your CV by any other means, we may process:
- First name and surname.
- Email address and telephone number.
- Town or city of residence.
- Your CV and all the information you decide to include in it.
- The roles and areas you are interested in working in, and whether you have a vehicle.
- Any message or covering note you write to us.
- The date of your consent and technical details of the submission, such as the IP address, so that we can evidence it.
We do not ask for your identity document, date of birth or a photograph in order to join the talent pool. Those details are only requested if we go on to hire you.
So that we do not have to copy your CV by hand, an artificial intelligence system (Microsoft Azure OpenAI) reads it and suggests some details for your record, such as where you live, your driving licence, languages or years of experience. It is only a suggestion that a member of our team reviews: decisions about your application are always made by a person, never by the system on its own.
2.7. Browsing data and cookies
When you visit the website we may process:
- IP address.
- Online identifiers.
- Browser and device type.
- Pages visited.
- Date and time of access.
- Traffic source.
- Interactions with the website.
- Technical errors that occur in your browser (the page, the error message and whether the browser was translating the page), so that we can fix them.
Some parts of the website are loaded from other providers, which therefore receive your IP address and technical data about your browser:
- Cloudflare Turnstile, on the owner, job application and season alert forms: it checks that the form is being sent by a person and not by an automated program. It does not set tracking cookies.
- CARTO, which serves the map images on each house page. It only receives the area of the map being viewed, not who you are.
- Vimeo, which serves the background video on the owners page. It is loaded in Vimeo's no-tracking mode ("Do Not Track"), which sets no cookies and stores no data about your session.
Details of cookies and similar technologies are available in the Cookie policy.
2.8. Newsletter subscription data
When you sign up on the website or on the guest portal to be told when next season’s dates open or to receive our news, or tick the marketing communications box when you create your account on the website, we may process:
- First name and email address.
- Telephone number, only if you tick the box to receive the alerts by WhatsApp as well.
- The language you are browsing in and where you signed up (the website, account sign-up, the guest portal or the traveller register).
- The date of your consent, the version of the text accepted, your IP address and browser, so that we can evidence it.
The subscription is activated when you confirm the link we send you by email (double opt-in); until then we send you nothing. If you sign up from your account on the website or when creating it, we do not ask for that confirmation: the account email has already been verified, with a code when the account was created or by Google if you sign in with Google, and we record it that way as proof. You can unsubscribe from any message.
2.9. Data from conversations with Serena, the booking assistant
Serena is an automated assistant that answers questions about our houses, availability and prices in the website chat. It does not ask for personal details and we recommend you don’t type any. When you use it, we process:
- The text of the messages you write and of the assistant’s replies.
- The page you write from, the language, and the date and time of each message.
We do not store your IP address with the conversation. To prevent abuse we count how many messages are sent from the same connection using an encrypted fingerprint of the IP, which is deleted automatically within 24 hours at most.
2.10. Measuring advertising on Google
If you accept marketing cookies and reach the website from a Google ad, when you send the request form for owners we tell Google Ads that the ad brought in a contact (a “conversion”). To measure it more accurately (enhanced conversions) your email and phone number are also sent, encrypted by your own browser (SHA-256) before they leave it: Google only receives that encrypted fingerprint and uses it to match existing Google accounts and count the conversion.
The same happens when you complete a booking on the website: with marketing cookies accepted, the booking is reported to Google Analytics and Google Ads together with your email, encrypted in the same way in your browser, so that we know which ad brought it in. If you have not accepted marketing cookies, the booking is measured without your email.
With the same consent, Google Ads may add your browser to lists of people who have visited the website, together with which houses you have viewed or started to book (their identifier, destination and price, never your contact details), to show you Sereno ads, including for those same houses, on other sites (remarketing). If you do not accept marketing cookies, or withdraw them from “Cookie settings”, none of this data is sent.
2.11. Your account data on the website
You can book without an account. If you choose to create one, with your email and a password or with your Google account, we process:
- Your email address, which identifies your account.
- First name, surname and telephone number.
- Billing address, if you add it.
- Whether you sign in with a password, with Google or both, the language of the website, the date you signed up and the date of your last sign-in.
- The reference of your customer record in Stripe, so that we can show you your saved cards and receipts.
- If you sign up for the season notice from your account, which season and when, so that we do not offer it to you again (the subscription itself is handled as explained in section 2.8).
- The identifier of your user in Microsoft Entra External ID, so that we can delete it when you delete your account.
- Proof that you accepted the terms and conditions and this policy: which version of each, the date, how you did it (by ticking the box on the form or by continuing with Google, with the notice below the button), your IP address and your browser.
- A random identifier for Google Analytics, which is not derived from your email or any other data about you. Only if you are signed in and have accepted analytics cookies do we send it to Google Analytics, so that your visits from your phone and your computer count as coming from the same person. Your email and name are not sent with it.
Sign-in is handled by Microsoft Entra External ID: it checks your password and sends you the verification codes by email. Sereno never stores your password. If you sign in with Google, Google knows that you have signed in to Sereno and gives us your email address.
With your account we show you your direct bookings (those made on the website, by phone or by WhatsApp with the same email as the account), what you have paid and what is still due, your receipts, and we give you direct access to the portal for your stay. We also fill in the booking form with your details. Bookings made on Airbnb, Booking.com or other platforms do not appear in the account.
You can change your details and delete the account from the account itself, with the «Delete my account» button, or ask us to delete it by writing to gestion@tusereno.es. If you have an outstanding payment on a booking, deletion waits until it is paid, because that charge is made to the card you used. When the account is deleted, we remove your user in Microsoft Entra External ID and your profile, and detach your saved cards from Stripe. Bookings and invoices are kept for the legal periods set out in section 7. Whatever Google Analytics has received with the account’s random identifier stays there until it expires under its own retention period but, once the account is deleted, we can no longer link it to you.
3. Purposes and legal bases
| Processing | Purpose | Legal basis |
|---|---|---|
| Contact and requests for information | Answering queries, sending the information requested and maintaining related communications | Consent or steps taken prior to entering into a contract |
| Booking management | Handling requests, confirming bookings, managing payments, changes, cancellations, check-in, the stay and customer service | Performance of a contract or pre-contractual steps |
| Traveller register | Collecting, keeping and reporting the data required by accommodation legislation | Legal obligation |
| Payments | Processing charges, refunds, confirmations and fraud prevention, charging the remaining instalments when you choose to pay in instalments, and saving your card when you ask us to | Performance of a contract and legitimate interest in preventing fraud |
| Website account | Giving you access with your email or with Google, keeping your profile, showing you your bookings, payments and receipts, filling in the booking form and opening the portal for your stay | Performance of the account contract you accept when you create it (Art. 6(1)(b) GDPR) |
| Proof of acceptance of the terms | Being able to show which version of the terms and of this policy you accepted, when and how | Legitimate interest in being able to evidence the conditions accepted (Art. 6(1)(f) GDPR) |
| Analytics while signed in | Counting your visits from different devices as coming from the same person, using a random account identifier | Consent (analytics cookies) |
| Invoicing and accounting | Issuing invoices and receipts, keeping accounting records and meeting tax obligations | Legal obligation |
| Marketing communications | Sending news, offers or commercial information about Sereno where there is consent or a prior relationship that allows it | Consent or legitimate interest in the cases permitted by the LSSI (the Spanish e-commerce act) |
| Season alerts and news | Letting you know when we open dates for the next season and sending you news from Sereno, by email and, if you tick the box, by WhatsApp | Consent (Art. 6(1)(a) GDPR), which you may withdraw at any time |
| Website security | Preventing abuse, fraud, unauthorised access, attacks and improper use, including the anti-bot check on forms (Cloudflare Turnstile) and the limit on submissions per connection | Legitimate interest in protecting the website and the people who use it |
| Error diagnosis | Detecting and fixing technical faults on the website | Legitimate interest in the website working properly |
| Internal alerts to the team | Instantly alerting the team member who has to handle an owner request, a job application or a sign-up that could not be saved | The same legal basis as the request being notified (pre-contractual measures or consent) |
| Management of owners and partners | Assessing properties, preparing proposals and managing contractual, operational and commercial relationships | Pre-contractual steps, performance of a contract, legal obligation and legitimate interest |
| Management of job applications | Assessing your CV, contacting you and considering you in current and future selection processes | Consent (Article 6(1)(a) GDPR) |
| Measurement and remarketing on Google Ads | Knowing which ads bring requests and bookings, including sending the encrypted email and phone number from the owners form and the email from bookings (enhanced conversions), and showing ads to people who have visited the website | Consent (marketing cookies) |
| Booking assistant (Serena) | Answering your questions about houses, availability and prices, and reviewing conversations to improve the service | Legitimate interest in answering your queries and improving the service, and pre-contractual steps when you ask about a booking |
4. Marketing communications
We will only send marketing communications by email, SMS, WhatsApp or other electronic means where there is a legal basis for doing so.
You may unsubscribe at any time by following the link included in each communication, by replying to the message you received, or by writing to gestion@tusereno.es.
5. Recipients and processors
We do not sell your personal data.
We may disclose data to third parties where this is necessary to provide the service, to comply with legal obligations or to manage our relationship with you. In particular:
- Public authorities, State law-enforcement agencies, courts and competent administrative bodies where there is a legal obligation.
- Accommodation owners or operators where this is necessary to manage a booking or a stay.
- Payment providers.
- Providers of web hosting, infrastructure, security, maintenance and technical support.
- Providers of booking management software, channel managers, PMS platforms and operational tools.
- Providers of email, messaging and communications services.
- Tax, accounting, employment, legal and administrative advisers.
- Banks and other providers needed for charges, payments and refunds.
Where these third parties process data on behalf of Sereno, they act as processors and must offer appropriate guarantees of confidentiality, security and regulatory compliance.
| Provider | Use | Description |
|---|---|---|
| Stripe | Online payments | Processing of charges, refunds and fraud prevention, and the cards you choose to save |
| Microsoft Entra External ID | Account sign-in | Checks your password or your Google sign-in and sends the verification codes by email. Data is stored in Europe |
| Sign in with Google | Only if you choose to sign in with your Google account: it confirms who you are and gives us your email address | |
| Hostify | PMS and accommodation management | System for managing bookings, availability and operational property data |
| Microsoft Azure | Infrastructure, web hosting and CRM | The website servers, the database where accounts, requests, job applications and subscriptions are kept, private storage for photos and CVs, and the error log. All in data centres in the European Union (the Netherlands, Spain and Sweden) |
| Resend | Transactional email | Sending booking confirmations, notifications and system emails |
| Cloudflare | Form security | Anti-bot check (Turnstile) on the owner, job application and season alert forms |
| CARTO | Maps | Map images on each house page |
| Vimeo | Video | Background video on the owners page, in no-tracking mode |
| Google Analytics | Website measurement | Statistics on visits and completed bookings and, while you are signed in, the random account identifier. Only if you accept analytics cookies; the encrypted booking email, only if you accept marketing cookies |
| Microsoft Clarity | Website measurement | Heatmaps and anonymous recordings of browsing to find errors. Only if you accept analytics cookies |
| Google Ads | Advertising | Knowing which ads bring visits, requests and bookings (with the encrypted email and phone number from the owners form and the encrypted email from bookings) and showing ads to people who have visited the website. Only if you accept marketing cookies |
| Microsoft Azure OpenAI | Booking assistant | Generates Serena's replies. Conversations are processed within the European Union and Microsoft does not use them to train its models |
| Microsoft Azure OpenAI | Management of job applications | Reads CVs to suggest the details of the applicant's record. Microsoft does not use that data to train its models |
6. International transfers
The website, the CRM, the database and the booking assistant run in Microsoft Azure data centres located in the European Union. Some of the providers listed in section 5 are companies based outside the European Economic Area, mainly in the United States, or may access the data from there:
- Stripe (payments).
- Google (Google Analytics and Google Ads), only if you accept the corresponding cookies, and when you choose to sign in with your Google account.
- Microsoft (Clarity), only if you accept analytics cookies.
- Resend (emails).
- Cloudflare (anti-bot check on forms).
- Vimeo (owners page video).
In those cases, transfers rely on the safeguards provided for in the GDPR: the European Commission's adequacy decision for companies certified under the EU-U.S. Data Privacy Framework and, failing that, the standard contractual clauses approved by the European Commission or other safeguards provided for by law.
If you would like more information about the specific providers and the safeguards applied, you may write to us at gestion@tusereno.es.
7. Retention periods
We will keep your data for as long as is necessary to fulfil the purpose for which it was collected and, thereafter, for the periods required by law or needed to deal with any liability that may arise.
| Type of data | Indicative period |
|---|---|
| Contact enquiries | Up to 12 months from the last communication, unless a contractual or legal relationship arises |
| Website account | For as long as you keep the account, including the proof of acceptance of the terms. If you delete it or ask us to delete it, your access, profile and saved cards are removed; bookings and invoices follow their own periods |
| Bookings and contractual documentation | For the duration of the contractual relationship and thereafter for the applicable liability periods |
| Tax, accounting and invoicing data | For the applicable statutory tax and commercial periods |
| Traveller register | The period required by the applicable accommodation legislation |
| Marketing communications | Until you withdraw your consent or ask to be unsubscribed |
| Cookies | The period indicated for each cookie in the Cookie policy |
| Data of owners and partners | For the duration of the relationship and for as long as legal or contractual liability may arise |
| Applications and CVs | 12 months from receipt, or from the last time you ask us to keep you in the talent pool, unless you ask us to delete them sooner or the application leads to a job offer |
| Conversations with the booking assistant | 30 days from the last message; they are then deleted automatically |
| Owner requests (details and photos) | Up to 12 months from the last communication if no contract is signed; if one is signed, as for owner data |
| Season alerts and news | Until you unsubscribe; if you do not confirm your email, the subscription is never activated |
| Internal alerts to the team | The same period as the request or application they relate to |
| Technical error log | Up to 90 days |
| Submission limits per connection (IP address or its encrypted fingerprint) | Between 1 and 24 hours; then deleted automatically |
Once the data is no longer needed, it will be securely deleted or blocked for the applicable limitation periods.
8. Rights of data subjects
You may exercise the following rights:
- Access: to know what data we process about you.
- Rectification: to correct inaccurate or incomplete data.
- Erasure: to ask for your data to be deleted where appropriate, including the deletion of your account.
- Objection: to object to certain processing.
- Restriction: to ask us to restrict the processing of your data.
- Portability: to receive your data in a structured format where appropriate.
- Withdrawal of consent: to withdraw your consent at any time, without affecting the lawfulness of processing carried out beforehand.
To exercise your rights, write to:
Please state which right you wish to exercise and provide the information needed to identify you. If we have reasonable doubts about your identity, we may ask for additional information that is proportionate and necessary to verify it. We will reply within one month, which may be extended by two further months if the request is complex; if so, we will let you know.
Where we process your data on the basis of legitimate interest, you may object at any time on grounds relating to your particular situation, and you may always object to marketing communications without giving any reason. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
You may also lodge a complaint with the Agencia Española de Protección de Datos (the Spanish data protection authority) if you consider that the processing of your data does not comply with the rules: www.aepd.es.
9. Security
Sereno applies reasonable technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction.
These measures may include access controls, encryption in transit, backups, permission management, security requirements for providers, access reviews and internal confidentiality procedures.
10. Minors
The website and the booking services are aimed at adults with the legal capacity to enter into a contract. We do not knowingly collect data about minors except where this is necessary to manage a booking or a stay, or to comply with legal obligations regarding the traveller register, in which case the data must be provided by the responsible adult.
11. Accuracy of the data
The user warrants that the data provided is truthful, accurate, complete and up to date. Where the data belongs to third parties, the user declares that they have sufficient authority to provide it and undertakes to inform those third parties of this Privacy policy where appropriate.
12. Changes to this policy
Sereno may update this Privacy policy to reflect legal, technical, operational or service changes. The version in force at any given time is the one published on this page.
Where the changes are significant, we will endeavour to inform users by reasonable means.