Privacy Policy
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1.- Who is the controller?
This Privacy Policy explains how we process your personal data when you use myholidayupgrade.com, make a reservation, contract a rental, contact Holiday Upgrade or use our online channels, including digital tools used to manage deliveries and returns.
The controller is:
| Item | Information |
| Controller | Dinou Potes S.L.U. |
| Trade name | Holiday Upgrade |
| Tax ID | B88742564 |
| Registered office | Lugar PolÃgono 31, Parcela 933, 07670 Felanitx, Illes Balears |
| Website | myholidayupgrade.com |
| Contact email | dataprivacy@myholidayupgrade.com |
| Official telephone / WhatsApp | +34 675 493 884 |
In this policy, Holiday Upgrade refers to Dinou Potes S.L.U.
2.- What data do we process?
Depending on how you use the website or our services, we may process the following categories of data:
| Category | Examples |
| Identification | Name, surname, signature or digital acceptance and indication of verified identity. Where necessary, we may check an official identity document without retaining a copy, photograph or number of the document, unless a legal obligation or justified reason requires otherwise. |
| Contact | Email, telephone, WhatsApp, delivery or pickup address, holiday accommodation address. |
| Reservation and contract | Rented product, dates, reservation number, accepted terms, incidents and communications. |
| Payment and security deposit | Payment method, amounts paid, security deposit, pre-authorisation, refunds, charges and payment incidents. We may also process the identifier or token of the saved payment method, partial payment method data shown by the provider, mandatory pre-authorisation of a security deposit charge to cover possible damage or breaches, authorisation for subsequent charges, one-off non-recurring charges, deposits, associated supporting documentation, non-payments and economic claims linked to the reservation or contract. |
| Delivery and return | Person receiving or returning the item, date, time, address, digital delivery or return protocol, checklist and comments. |
| Condition of the item | Photographs, videos, checklists, damage, accessories, dirtiness, incidents and visible condition of the product. |
| Verified identity | Indication that identity has been checked, type of document shown, date of verification and, where applicable, authorised person. We do not retain a copy, photograph or number of the identity document, unless a legal obligation or justified reason requires otherwise. |
| Browsing and device | IP, browser, device, operating system, cookies, identifiers and website usage data. |
| Communications | Emails, WhatsApp, forms, requests, claims and messages related to the reservation. |
| Marketing and analytics | Preferences, interaction with campaigns, cookies, pixels or measurement tools, only where applicable and where there is a sufficient legal basis. |
Holiday Upgrade does not request or need special categories of personal data. You should not send us health data, ideology, religion, sexual orientation, biometric data or other specially protected data through the website or contact channels.
3.- What do we use your data for?
We process your data for the following purposes:
| Purpose | Explanation |
| Managing reservations and contracts | Processing requests, reservations, changes, cancellations, contracts and confirmations. |
| Providing the rental service | Preparing, delivering, collecting and managing the rented goods or equipment. |
| Verifying identity | Checking the identity of the Customer or authorised person at delivery or return, without retaining a copy, photograph or number of the identity document, unless a legal obligation or justified reason requires otherwise. |
| Managing payments and security deposits | Processing payments, pre-authorisations, refunds, charges, security deposits and outstanding amounts. |
| Documenting delivery, return and condition of the item | Preparing digital protocols, checklists, photographs or videos to evidence delivery, return, damage, accessories or incidents. |
| Handling queries and incidents | Responding to requests, claims, doubts, communications and customer service matters. |
| Preventing fraud and breaches | Detecting fraudulent reservations, non-payments, misuse, damage, loss, theft or breaches. |
| Complying with legal obligations | Meeting tax, accounting, commercial, administrative, consumer and data protection obligations. |
| Defending rights | Managing evidence, claims, liabilities and judicial or extrajudicial proceedings. |
| Sending commercial communications | Sending promotions or news where consent or another sufficient legal basis exists. |
| Improving the website and services | Analysing website use, security, user experience and reservation operation where there is a sufficient legal basis. |
| Advertising and measurement | Using measurement, advertising or remarketing tools only if configured on the website, listed in the Cookie Policy or configuration panel, and where the user has given prior consent when required. |
4.- What is the legal basis?
We use your data on the following legal bases:
| Legal basis | When it applies |
| Performance of a contract or pre-contractual measures | Reservations, rentals, deliveries, pickups, payments, deposits, modifications, cancellations, service-related support and sending the digital protocol where necessary for contracting or performing the rental. |
| Compliance with legal obligations | Invoicing, accounting, taxes, commercial obligations, consumer law and data protection. |
| Legitimate interest | Fraud prevention, security, defence of claims, documentation of the condition of goods, retention of contractual evidence and internal service improvement, provided that the data subject’s rights and freedoms do not prevail. |
| Consent | Non-technical cookies, marketing, certain analytics or advertising tools, forms and voluntary processing. |
You may withdraw your consent at any time. Withdrawal does not affect processing carried out before withdrawal.
5.- With whom do we share your data?
We may share data or allow access to personal data where necessary to provide the service, comply with legal obligations or defend our rights.
| Recipient or provider | Purpose |
| Reservation or online contracting management tools | Managing reservations, availability, contracts, communications and rental-related processes. |
| Payment providers enabled by Holiday Upgrade | Payments, security deposits, pre-authorisations, refunds and fraud prevention. |
| Technology providers | Hosting, maintenance, technical support, security, website operation and, where applicable, operation of the app or digital protocol system. |
| Email and messaging providers | Confirmations, notices, sending protocols, customer service and operational or commercial communications. |
| WhatsApp or other messaging channels, if used | Communications with the Customer when such channels are used. |
| Analytics and marketing tools, where applicable | Measurement, analytics, advertising or campaigns, in accordance with the Cookie Policy and required consent. |
| Legal, tax, accounting or administrative advisers | Compliance with obligations and defence of rights. |
| Insurers, where applicable | Management of claims, damage, incidents or liabilities covered by policies. |
| Public authorities, courts and regulators | Compliance with legal obligations or response to requests. |
Some providers will act as processors on behalf of Holiday Upgrade. Others may act as independent controllers for certain processing, in accordance with their own terms and privacy policies.
Main provider table
| Provider | Role | Purpose | Country / location | Applicable safeguards |
| Shopify / Booqable | Processor or independent controller, depending on processing and configuration | Reservation and contract management | According to provider terms | Processing agreement, provider terms and applicable safeguards |
| Stripe | Processor or independent controller, depending on processing and configuration | Payments, deposits, pre-authorisations, tokenisation, subsequent authorised charges, refunds, non-payments and payment incidents | According to provider terms | Provider terms and applicable safeguards, including international transfer safeguards where applicable |
| Hetzner / Shopify Messaging / Mailchimp / WhatsApp Business | Processor or independent controller, depending on processing and configuration | Communications and protocol delivery | According to provider terms | Provider terms and applicable safeguards |
| Hetzner / own delivery protocol app | Processor | Delivery and return | European Union / Germany | Data processing agreement and technical and organisational measures |
| Google Analytics 4 / Plausible / Meta / Mailchimp / Pandectes GDPR Cookie Tool | Processor or independent controller, depending on processing and configuration | Measurement, analytics or advertising | According to provider terms | Prior consent where required, Cookie Policy and applicable safeguards |
6.- Digital delivery and return protocols
We use a digital tool to document the delivery and return of rented goods. With this tool, we can create a digital delivery or return protocol recording the delivery or collection process, the condition of the item, the accessories delivered or returned, any damage, dirt, incidents, observations, and confirmation by signature of the Customer or authorized person.
What data may be included in the digital protocols
As part of a digital delivery or return protocol, we may process, among others, the following data:
- Customer’s name;
- booking, order or contract number;
- Customer’s email address for sending the protocol;
- date and time of delivery or return;
- type of action, i.e. delivery or return;
- protocol language;
- person receiving or returning the item;
- Holiday Upgrade staff member carrying out the delivery, collection or inspection;
- data relating to the rented equipment or item, including model, internal number, accessories, visible condition, damage or incidents;
- photographs of the item, accessories or visible damage, where necessary to document the condition of the item;
- signature of the Customer or authorised person and signature or identification of Holiday Upgrade;
- indication that identity has been verified and, where applicable, the type of document shown.
The digital protocols are generated as a photograph or evidence of the condition of the delivery or return at the time it takes place. Once the protocol has been completed, its content may be retained as contractual evidence.
Identification of the Customer or authorized person
Holiday Upgrade may verify the identity of the Customer or authorized person by means of an official document before delivering or collecting the goods. We do not retain a copy, photograph or number of the identity document, unless a legal obligation or justified reason requires otherwise.
As a general rule, we only document that the identity has been verified, the type of document shown, the verification date and the person who carried it out.
Photographs of goods, accessories or damage
We may take photographs of the goods, accessories or visible damage where necessary to document the condition of the item upon delivery or return, evidence incidents, handle claims, manage the deposit or exercise or defend rights arising from the contract.
Photographs or videos shall be limited, insofar as reasonably possible, to the rented item, its accessories, visible condition and incidents, avoiding the capture of persons, minors, identity documents, payment methods, private areas or elements of the surroundings that are not necessary to document the delivery, return or incident.
If a photograph or video accidentally captures persons or unnecessary private elements, Holiday Upgrade will assess whether it should be replaced, cropped, anonymized or deleted.
Providers and tool infrastructure
The digital protocol tool will be provided through technology providers acting as processors on behalf of Holiday Upgrade, on the basis of a data processing agreement where required.
Where the tool is provided through a solution located within the European Union or the European Economic Area, this will be indicated in the provider table. If the infrastructure, providers or countries from which the data is processed change substantially in the future, Holiday Upgrade will update this policy where necessary.
Retention of digital protocols
Digital delivery and return protocols shall be retained for as long as necessary to manage the booking, delivery, return, deposit, damage, incidents, claims and contractual liabilities.
As a general criterion:
- closed protocols with no open claim or incident may be retained in active use for an approximate maximum period of 6 months in order to handle queries, re-sending, internal checks or initial claims;
- thereafter, they may be retained in blocked form or with restricted access for a general maximum period of 5 years, where necessary for the evidence, exercise or defence of rights arising from the contract;
- once those periods have elapsed, they shall be securely deleted, unless there is a claim, proceeding, debt, incident, legal obligation or justified reason requiring them to be retained for longer;
- photographs with no damage, claim or incident shall be retained for the reasonable period required to review and close the booking and, as a general rule, for a shorter period than the full protocol;
- photographs or evidence linked to damage, incidents, non-payment, deposits or claims may be retained for as long as necessary to manage or defend the relevant liability;
- identification data shall be limited to the minimum necessary and, in particular, no copy, photograph or number of the identity document shall be retained, unless there is a legal obligation or justified reason.
7.- How long do we keep data?
We keep data for the time necessary to fulfil the relevant purpose and, afterwards, for the periods necessary to address legal, contractual, tax, accounting or administrative liabilities.
| Data | Retention period |
| Non-contractual enquiries | For the time necessary to respond and, as a general rule, up to 12 months from the last communication, unless an incident or claim remains pending. |
| Reservations, contracts and related communications | During the contractual relationship and thereafter during the applicable limitation period for legal actions. |
| Digital delivery and return protocols | Up to 6 months in active use where there is no open incident and then blocked or with restricted access up to a general maximum of 5 years for evidence, exercise or defence of rights, unless longer retention is justified. |
| Invoices, payments and tax/accounting data | During the periods required by applicable tax, accounting and commercial rules; as a reference, up to 6 years for accounting and commercial documentation, without prejudice to other applicable legal periods. |
| Security deposits, pre-authorisations, damage, non-payments and incidents | For the time necessary to manage the reservation, deposit, incident or claim and thereafter during the applicable limitation period. |
| Photos, videos, checklists and delivery/return documentation | For the time necessary to manage delivery, return, deposit, damage and possible claims; if there is no incident, only for the reasonable review and closing period of the reservation, unless later retention is necessary. |
| Data processed on consent | Until you withdraw consent or until they are no longer necessary for the consented purpose. |
| Cookies | According to the duration indicated in the Cookie Policy or configuration panel. |
8.- International transfers
Some technology, payment, analytics, marketing, messaging or reservation management providers may be located outside the European Economic Area or process data from third countries.
Where international transfers occur, Holiday Upgrade or the relevant provider shall apply the safeguards required by applicable law, such as adequacy decisions, standard contractual clauses or other legal mechanisms.
9.- Your rights
You may exercise the following rights: access, rectification, erasure, objection, restriction, portability and withdrawal of consent.
You may exercise your rights by writing to dataprivacy@myholidayupgrade.com, indicating which right you wish to exercise. We may request additional information to verify your identity.
10.- Complaints to the supervisory authority
If you consider that the processing of your data does not comply with the rules, you may lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.
11.- Security
Holiday Upgrade shall apply reasonable technical and organisational measures to protect your data against loss, misuse, unauthorised access, disclosure, alteration or destruction.
12.- Cookies, analytics and similar technologies
The website may use own or third-party cookies and similar technologies for technical, preference, analytical, advertising or behavioural advertising purposes.
The use of cookies is regulated in the Cookie Policy. Where cookies involve the processing of personal data, this Privacy Policy shall also apply.
Holiday Upgrade shall not install non-technical or non-necessary cookies without first obtaining your consent where required.
13.- Commercial communications and marketing
Holiday Upgrade may send you commercial communications, promotions or news if you have given your consent or if another legal basis allows it.
You may object or unsubscribe at any time through the mechanism indicated in each communication or by writing to dataprivacy@myholidayupgrade.com.
14.- WhatsApp and other electronic channels
Holiday Upgrade may communicate with you by email, telephone, official WhatsApp, reservation or online contracting management tools, web forms or other electronic channels provided by you or enabled by Holiday Upgrade.
15.- Minors
Holiday Upgrade services are not addressed to minors. The user declares that they are of legal age and have sufficient capacity to use the website and contract the services.
16.- Updates to this policy
Holiday Upgrade may update this Privacy Policy to adapt it to regulatory, technical, operational, commercial or organisational changes.
The current version shall be the one published on the website at any given time.
17.- Related legal texts
This Privacy Policy must be read together with the other applicable legal texts, including:
Legal Notice.
Cookie Policy.
Online Rental General Terms and Conditions of Holiday Upgrade.
Online Rental Agreement of Holiday Upgrade, where applicable.
Any legal or contractual information shown during the reservation process on the website or in the reservation or online contracting management tools used by Holiday Upgrade.
Prevalence of the Spanish version
In the event of any discrepancy between the Spanish version and any translation, the Spanish version shall prevail, unless expressly stated otherwise in the reservation or applicable contractual document.
18.- Date of update
Last updated: 1 July 2026.