Privacy Policy & data processing
Your privacy is important to us. It is Holiday Hero B.V.’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including via our app, Holiday Hero Platform, and its associated services.
Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use an app or online service.
In the event our app contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our app.
This policy is effective as of 13 February 2023.
Last updated: 28 October 2026
Information we collect
Information we collect falls into one of two categories: ‘voluntarily provided’ information and ‘automatically collected’ information.
‘Voluntarily provided’ information refers to any information you knhowingly and actively provide us when using our app and its associated services.
‘Automatically collected’ information refers to any information automatically sent by your device in the course of accessing our app and its associated services.
Log Data
When you access our servers via our app, we may automatically log the standard data provided by your device. It may include your device’s Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details about your usage.
Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.
Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Device Data
Our app may access and collect data via your device’s in-built tools, such as:
Your identity
Location data
Camera
Calendar
Contacts
Phone/SMS
Storage, photos and/or media
Notifications
Background data refresh
Mobile data
Device/app history
Bluetooth
When you install the app or use your device’s tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
Personal Information
We may ask for personal information — for example, when you submit content to us or when you contact us — which may include one or more of the following:
Name
Email
Date of birth
Phone/mobile number
Home/mailing address
User-Generated Content
We consider ‘user-generated content’ to be materials (text, image and/or video content) voluntarily supplied to us by our users for the purpose of publication on our platform, website or re-publishing on our social media channels. All user-generated content is associated with the account or email address used to submit the materials.
Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published it may be accessible to third parties not covered under this privacy policy.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance we only collect personal information that is reasonably necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website:
Register for an account
Sign up to receive updates from us via email or social media channels
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media
We may collect, hold, use and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:
to provide you with our app and platform’s core features and services
to enable you to customize or personalise your experience of our website
to deliver products and/or services to you
to contact and communicate with you
for analytics, market research, and business development, including to operate and improve our app, associated applications, and associated social media platforms
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you
to enable you to access and use our app, associated platforms, and associated social media channels
for internal record keeping and administrative purposes
to comply with our legal obligations and resolve any disputes that we may have
to attribute any content (e.g. posts and comments) you submit that we publish on our website
for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use
for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms
We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you consent to us accessing your social media profiles, we may combine information sourced from those profiles with information received from you directly to provide you with an enhanced experience of our app and services.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification.
Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.
You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.
However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
Disclosure of Personal Information to Third Parties
We may disclose personal information to:
a parent, subsidiary or affiliate of our company
third-party service providers for the purpose of enabling them to provide their services including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
our employees, contractors, and/or related entities
our existing or potential agents or business partners
credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
third parties, including agents or sub-contractors who assist us in providing information, products, services, or direct marketing to you
third parties to collect and process data
an entity that buys, or to which we transfer all or substantially all of our assets and business
Third parties we currently use include:
Google Analytics
MailerLite
Messagebird
Stripe
TinyMCE
BugSnag
DigitalOcean
Google service including Google Cloud hosting
Cloudflare
OpenAI
Meta Platforms (WhatsApp Business Platform)
Google User Data (Google Business Profile)
Operators can connect their Google Business Profile to Holiday Hero Platform. Holiday Hero then brings the reviews guests leave on Google into Reputation, next to the reviews from other channels, and lets the operator reply to them from Holiday Hero. This section explains what we access from Google, how we use, store and share it, and how you can remove it.
What we access
When you sign in with Google and allow Holiday Hero to manage your business profiles, we receive:
the email address and Google account ID of the Google login you sign in with
access and refresh tokens, which let us call the Google Business Profile APIs on your behalf
the business profiles (locations) that login manages: their name, address, map location and Google Maps link
for the locations you connect: the reviews (star rating, review text, dates, and the reviewer’s public Google name and profile photo, as Google shows them), the owner reply on each review, and the location’s average rating and number of reviews
How we use it
to show the locations your Google login manages, so you can choose which ones to connect and match them to your listings
to import the reviews and ratings of the connected locations into Reputation and keep them up to date
to post or update the owner reply on a Google review, only when you or your team send it from Holiday Hero, or when you have switched on automatic replies
We do not use Google user data for advertising, we do not sell it, and we do not use it to develop, improve or train generalised artificial intelligence or machine learning models. Our staff do not read it, except with your permission, to investigate a support request or a security issue, or where the law requires it.
Who we share it with
We share Google user data only as far as needed to provide these features:
OpenAI, which receives the content of reviews to translate them into your language and to draft suggested replies. OpenAI processes this on our behalf through its API and does not use it to train its models.
our hosting and infrastructure providers (DigitalOcean, Google Cloud and Cloudflare), which store and transport the data for us
Google, when we post a reply on your behalf; replies posted on Google are public
We do not transfer Google user data to anyone else, unless the law requires it.
How long we keep it and how to remove it
When you remove a Google login in the app’s settings, or uninstall the app, we delete that login’s tokens and revoke our access at Google straight away. If another Holiday Hero workspace of yours still uses the same Google login, we only delete the tokens of the workspace you removed it from, so the other workspace keeps working.
Reviews already imported stay in Reputation as part of your review history until you ask us to delete them or delete your account, as described under Deletion below. You can also remove Holiday Hero’s access at any time in your Google Account at myaccount.google.com/permissions.
Google API Services User Data Policy
Holiday Hero’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
WhatsApp Business Platform (Meta)
Operators can connect their own WhatsApp number to Holiday Hero Platform through Meta. Holiday Hero then sends the operator’s scheduled messages and inbox replies to guests on WhatsApp, and brings guests’ WhatsApp messages into the operator’s Holiday Hero inbox. Holiday Hero is a Meta Tech Provider: the WhatsApp number, the WhatsApp Business account and the business portfolio belong to the operator, and Meta bills the operator directly for messages. This section explains what we access, how we use, store and share it, and how you can remove it.
What we access
When you connect your WhatsApp number through Meta, we receive:
the IDs of your Meta business portfolio, WhatsApp Business account and phone number, your WhatsApp display number and business name, and their status at Meta (name approval, quality rating, messaging limit, payment method status)
an access token from Meta, which lets us call the WhatsApp Business Platform on your behalf, and the registration PIN we set for your number. Both are stored encrypted.
your message templates: their names, text, languages, category, approval status and quality rating
When guests message you, or you message them, we process:
the guest’s WhatsApp phone number or WhatsApp user ID, and the profile name they show on WhatsApp
the content of messages, and the photos, documents and other media guests send
when each message was sent, delivered and read, and how Meta categorised it for billing
If you connect a number that you also use in the WhatsApp Business app, and you agree to share them during the connection, we also receive your WhatsApp contacts, up to 180 days of chat history, and the messages you send from the app after connecting.
How we use it
to send your scheduled messages and your inbox replies to guests from your own WhatsApp number
to show guests’ WhatsApp messages in your Holiday Hero inbox, and to link a guest to their booking by matching the phone number
to submit your message templates to Meta for approval, follow their status, and make approved templates available in Holiday Hero
to show whether a message was delivered or read, and an estimate of what Meta bills you
We do not use WhatsApp data for advertising, we do not sell it, and we do not use it to develop, improve or train generalised artificial intelligence or machine learning models. Our staff do not read message content, except with your permission, to investigate a support request or a security issue, or where the law requires it.
Who we share it with
We share WhatsApp data only as far as needed to provide these features:
Meta, which delivers WhatsApp messages and reviews your message templates. Meta’s own terms and privacy policy apply to your WhatsApp Business account.
our hosting and infrastructure providers (DigitalOcean, Google Cloud and Cloudflare), which store and transport the data for us
OpenAI, only when you switch on translation or AI features in Holiday Hero, to translate messages or draft replies. OpenAI processes this on our behalf through its API and does not use it to train its models.
We do not transfer WhatsApp data to anyone else, unless the law requires it.
How long we keep it and how to remove it
When you disconnect WhatsApp or uninstall the app, we stop sending and receiving messages straight away and remove our access to your WhatsApp Business account. Thirty days later we delete the access token, the PIN, our copies of your message templates and our message records. If you reconnect within those 30 days, your setup is kept.
Conversations already in your Holiday Hero inbox stay there as part of your conversation history until you delete them or delete your account, as described under Deletion below. Your WhatsApp number, your WhatsApp Business account and your templates at Meta stay yours. You can also remove Holiday Hero’s access at any time in Meta Business Suite, under Business settings.
For guests
If you messaged an accommodation on WhatsApp, that accommodation decides how your messages are used, and Holiday Hero processes them on its behalf. Contact the accommodation to access or delete your data, or contact us using the details below.
International Transfers of Personal Information
The personal information we collect is stored and/or processed in Netherlands, or where we or our partners, affiliates, and third-party providers maintain facilities.
The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.
Your Rights and Controlling Your Personal Information
Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.
Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.
Downloading of Personal Information: We provide a means for you to download the personal information you have shared through our app. Please contact us for more information.
Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.
Use of Cookies
Our privacy policy covers the use of cookies between your device and our servers. A cookie is a small piece of data that an app may store on your device, typically containing a unique identifier that allows the app servers to recognise your device when you use the app; information about your account, session and/or device; additional data that serves the purpose of the cookie; and any self-maintenance information about the cookie itself.
We use cookies to give your device access to core features of our app, to track app usage and performance on your device, to tailor your experience of our app based on your preferences, and to serve advertising to your device. Any communication of cookie data between your device and our servers occurs within a secure environment.
Please refer to our Cookie Policy for more information.
Business Transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here and on our website.
If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.
If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)
Data Controller / Data Processor
The GDPR distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organizations that process personal information on behalf of other organizations (known as “data processors”). We, Holiday Hero B.V., located at the address provided in our Contact Us section, are a Data Controller and/or Processor with respect to the personal information you provide to us.
Legal Bases for Processing Your Personal Information
We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose.
Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:
Consent From You
Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. You may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
Performance of a Contract or Transaction
Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, we need technical information about your device in order to provide the essential features of our app.
Our Legitimate Interests
Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. For example, we collect technical information about your device in order to improve and personalise your experience of our app. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law
In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.
International Transfers Outside of the European Economic Area (EEA)
We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
Your Rights and Controlling Your Personal Information
Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.
Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.
Deletion: You may have a right to request that we delete the personal information we hold about you at any time, and we will take reasonable steps to delete your personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our app, website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information within 60 days of the deletion of your account. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.
Contact us
For any questions or concerns regarding your privacy, you may contact us using the following details:
Hjalte Niehorster