1. Who is the controller
The data controller is HIBCN APARTMENTS SL, tax ID (NIF) B56824360, with registered address at calle Bailén 50, entresuelo 1.ª, 08009 Barcelona.
Contact email for everything related to privacy: hola@livyo.ai.
We do not have a data protection officer: given our size and activity we are not required to appoint one. Write to us at the address above.
2. Who this applies to
This policy covers:
- anyone who visits livyo.ai or writes to us from the website;
- the members of our clients' teams who have an account on the portal (portal.livyo.ai).
It does not cover the data of our clients' guests. We process that data on behalf of the client, who decides about it. We explain this in section 4.
3. What data we process and why
3.1 If you request access or contact us from the website
- Data: what you give us in the request form or in your email: name, email address, phone number if you provide it, company, number of properties, the management software (PMS) you use and whatever you write in the message.
- Purpose: to reply to your request, prepare a demonstration, set up your free trial and create your account if you decide to sign up. We will not send you newsletters or advertising because you filled in the form.
- Legal basis: the application of pre-contractual measures at your request (Article 6.1.b of the GDPR). To submit the form you tick the box confirming that you have read this policy; you can ask us at any time to delete your request.
- Where it is stored: the request is recorded in our database, hosted in the European Union, and we receive an email notification so that we can reply to you. That notification goes to the mailboxes of the Livyo team: the corporate email and the personal mailbox of one of the founders (the providers for each are listed in section 7).
- Protection against abuse: of the IP address from which the form is submitted we keep only its cryptographic fingerprint (hash), never the IP address in clear, and we delete it after 48 hours. It serves only to stop mass or automated submissions.
3.2 If you have an account on the portal
- Data: name, work email, the company you belong to, your role within the account and your password. The password is stored by our authentication provider only as an irreversible fingerprint (bcrypt hash), never in readable form: nobody at Livyo can see it.
- Purpose: to give you access to the portal, identify you and provide the service your company has contracted.
- Legal basis: performance of the contract between Livyo and your company (Article 6.1.b) and our legitimate interest in managing access (Article 6.1.f).
3.3 Access and activity logs
- Data: date and time of sign-in and sign-out, relevant actions within the portal (invitations, password changes, billing changes, exports, knowledge base corrections), session identifier and failed access attempts. The IP address is not stored in clear: we store its cryptographic fingerprint (SHA-256), which lets us limit abusive access attempts without keeping the IP address.
- Purpose: security, detection of improper access, traceability and incident resolution.
- Legal basis: our legitimate interest in protecting the service and that of our clients (Article 6.1.f) and compliance with our security obligations (Article 32 of the GDPR).
3.4 Technical logs
- Data: the logs that our infrastructure providers generate on their own when serving the website, the portal and the database: requests, response codes, errors and connection data.
- Purpose: to keep the service running, diagnose errors and protect it against attacks.
- Legal basis: legitimate interest (Article 6.1.f).
3.5 Billing
- Data: tax details of the client company and the contact person, and billing history.
- Purpose: to invoice and comply with accounting and tax obligations.
- Legal basis: performance of the contract (Article 6.1.b) and legal obligation (Article 6.1.c).
4. Guests' data
To provide the service we process messages and data of our clients' guests. Regarding that data we decide nothing: we act as data processors and follow the instructions of the client, who is the controller.
We store it in our own database, hosted in the European Union. We are not a mere conduit between the PMS and the model: we keep the conversation history so that the client can supervise the service, correct what the assistant knows and follow up on escalated cases. Specifically, we store the guest's name, the text of their message, the reply the assistant gave them, their booking dates, the property, the channel and the conversation identifier.
We keep it for a maximum of 24 months from when it is generated, and we delete it or return it to the client when their contract ends (section 9).
Exactly what data it is, what it is used for, what security measures apply, who the sub-processors are and what happens when the contract ends is detailed in the data processing annex that each client receives when signing up.
If you are a guest at a property managed with Livyo and want to exercise your rights, contact the company that manages your property. If you write to us, we will forward your request to that company and let you know.
5. Cookies
No analytics, no advertising, no trackers
This website does not install any cookies. We do not use any analytics tool, we do not use advertising cookies and we do not embed third-party trackers. That is why you will not see a cookie banner.
The portal uses a single, strictly necessary cookie:
__Host-livyo_sessio: keeps you signed in. It isHttpOnly(the page's JavaScript cannot read it),Secure(it only travels over HTTPS) andSameSite=Strict(it is not sent from other sites). It expires 7 days after you sign in (and also if you spend 7 days without activity); for sessions of the Livyo administration team, after 8 hours. It is deleted when you sign out.
Because it is strictly necessary for a service you have requested, this cookie does not require prior consent.
The portal also stores, in your browser's local storage (these are not cookies and are not sent to any server), your preferred language, the property view you have chosen and, during sign-up, the identifier of the form you are filling in. You can delete them from your browser.
This website does not load any third-party resources. The fonts, images, styles and the little JavaScript there is are served from our own domain; there are no requests to external font services, to a third-party CDN, to social networks or to any other external server. By visiting this page, your browser does not send your IP address to anyone other than us and our infrastructure providers. Only if you submit the request form does the data travel directly to our server, in the European Union. The same applies on the portal.
6. Where the data comes from
The data reaches us from you directly (website forms, sign-up on the portal) or from the client company that registers you as a portal user. We do not buy lists or obtain data from public sources for prospecting.
7. Who we share it with
We do not sell data or hand it over to third parties for their own purposes. We share it only with the providers we need in order to operate, who process it on our behalf. With each of them their standard data processing agreement (DPA) applies, which forms part of their terms of service:
| Type of provider | Purpose | Where it processes the data |
|---|---|---|
| Cloud infrastructure provider (database and servers) | Stores the accounts, sessions, activity logs, requests received from the website, each client's configuration and the history of conversations with guests (messages, replies, escalated cases and the context of each property). | European Union |
| Web hosting and content delivery network provider, and sending of notification emails | Serves the website and the portal, forwards email addressed to livyo.ai and sends the notification emails. | Global network; traffic originating in the EU is served in Europe |
| Corporate email provider | Livyo's email (for example, hola@livyo.ai), where we receive the notifications of requests from the website. | European Union |
| Email provider for the personal mailbox of a founder | Receives the email notification of requests submitted through the website form. Only for this purpose: it never receives guest data. | May involve processing outside the EU |
| Artificial intelligence provider | Drafts the replies to guests. It receives only what is necessary to generate each reply. | United States |
If you want to know the identity of a specific provider, write to us at hola@livyo.ai and we will tell you.
We may also disclose data to authorities, courts or administrations when a rule requires us to.
8. Transfers outside the EU
The database is in the European Union. The main exception is the artificial intelligence model.
The replies are generated by our artificial intelligence provider, which processes the data in the United States, so there is an international transfer, covered by its data processing agreement and by the European Commission's standard contractual clauses.
On what our artificial intelligence provider does with what we send it, according to its commercial terms and its privacy documentation:
- It does not train its models on the content we send it. Its commercial terms say so expressly and its privacy documentation confirms it.
- Inputs and outputs are automatically deleted within 30 days of being received or generated.
- Exception: if content is flagged for breaching its usage policy, our artificial intelligence provider may retain inputs and outputs for up to 2 years, and safety classification scores for up to 7 years. In that case, the provider's staff may review that content to verify the breach.
- The rights over what is sent remain with the client, and the client owns what the model generates from it.
Put plainly: the model does not keep the data or learn from it, but it does leave the European Union while the reply is being generated.
Some of our infrastructure providers are companies headquartered in the United States. Although the data is hosted or served in Europe, any access from outside the EU is covered by the safeguards of their data processing agreements (standard contractual clauses and, where applicable, the EU-US Data Privacy Framework).
9. How long we keep it
| Data | Period |
|---|---|
| Guest messages, assistant replies and conversation data, stored in our database on behalf of the client | A maximum of 24 months from when they are generated. When the contract with the client ends they are deleted or returned to the client, within the periods of the data processing annex that the client receives |
| Portal account (name, email, role, membership of a client) | While the account is active; it is deleted when the account is closed or the contract with your company ends |
| Portal access and activity logs | While the account is active and, afterwards, for the time needed to handle claims or comply with legal obligations |
| Access keys to the client's PMS | For the duration of the contract; they are deleted when it ends |
| Access requests and enquiries received from the website | Up to 12 months from the date of the request, if they do not become a contract; if you sign up, they become part of your account data |
| Fingerprint (hash) of the IP address from which the website form is submitted | 48 hours |
| Billing and accounting documentation | The periods required by tax and commercial regulations |
Once these periods have passed, the data is deleted. In the backups of our database provider it disappears when those backups expire through their normal rotation.
10. How we protect it
- All traffic is encrypted with TLS (HTTPS), both the website and the portal and the calls to our providers.
- The access keys to clients' PMSs are stored encrypted with 256-bit AES-GCM. The encryption key lives outside the database and the system refuses to run if it is not properly configured. Once stored, they are never shown in full again.
- Session identifiers and invitation tokens are never stored in clear: only their SHA-256 fingerprint is stored in the database.
- Passwords are never stored in readable form. They are handled by our authentication provider, which only stores an irreversible fingerprint (bcrypt hash). Nobody at Livyo can see them and they are not recorded in any log.
- Isolation per client: each client's data is kept separate and the tables have row-level access control enabled; access is only possible from the portal's backend, which checks which client each user belongs to.
- Restricted access: only Livyo's founding partners access the production environment, each with a named, individual administration account. There are no shared accounts and no external staff with access.
- Data in the European Union: the database where the conversations with guests are stored is in the European Union. The only exit of guests' data from the EU is the AI model (section 8).
- Traceability: sensitive actions on the portal are recorded in an audit log.
No system is infallible. If a security breach affecting your data were to occur, we will act as the GDPR requires: we will notify the Spanish Data Protection Agency within a maximum of 72 hours where there is a risk to individuals, and we will notify you directly if the risk is high. If it affects guests' data, we will notify the responsible client within the periods of the data processing annex that they receive when signing up.
11. Your rights
You can exercise at any time your rights of:
- Access: to know what data of yours we process.
- Rectification: to correct data that is inaccurate.
- Erasure: to ask us to delete it.
- Objection: to object to processing based on our legitimate interest.
- Restriction: to ask us to keep it but not use it.
- Portability: to receive in a commonly used format the data you gave us.
- Withdraw consent where the processing is based on it, without affecting what was done before.
Write to us at hola@livyo.ai stating which right you want to exercise. We will reply within one month. We may ask you to prove your identity if we cannot confirm it in any other way.
If you believe we have not handled your request properly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es, C/ Jorge Juan 6, 28001 Madrid).
12. Changes to this policy
If we change this policy, we will publish the new version on this page with a new update date. If the change is significant, we will notify portal users by email.
Last updated: 11 November 2026