1. Data controller

The controller responsible for processing personal data through this website and in connection with accommodation bookings is Riccardo Gabriele Grossi, a self-employed operator trading as Prime Living.

Business name: Prime Living
Data controller: Riccardo Gabriele Grossi
NIF/NIE: Z0884636S
Address: Calle Los Pinos 9, 35100 San Bartolomé de Tirajana, Las Palmas, Spain
Email: info@primeliving.life

For privacy enquiries and the exercise of data-protection rights, please contact: info@primeliving.life.

2. Personal data we process

Depending on how you use the website and the services requested, we may process the following categories of personal data:

• Identification data, including name, surname, date of birth, nationality and identity-document information.
• Contact data, including postal address, email address and telephone number.
• Booking data, including stay dates, number and identity of guests, selected services, requests and communications.
• Payment and transaction data, including payment method, payment status and transaction references.
• Guest-registration data required by Spanish accommodation and public-security legislation.
• Information relating to incidents, damage, complaints and customer-service requests.
• Technical and browsing data, including IP address, device information, browser data and cookies, where applicable.

Payment-card details are generally processed directly by the selected payment-service provider. Prime Living does not normally receive or store the complete card number or security code.

3. Sources of the data

Personal data may be obtained directly from you, from the person making a booking on your behalf, from booking platforms or channel managers through which the reservation was made, and from service providers used to manage guest registration, payments and the stay.

The person making the booking must ensure that they are authorised to provide the personal data of the other guests and that those guests have been informed of this policy.

4. Purposes and legal bases

We process personal data for the following purposes and on the following legal bases:

• Managing enquiries and booking requests: taking steps at your request before entering into a contract.
• Managing and performing the accommodation contract: processing the booking, payments, communications, check-in, access, stay and check-out. The legal basis is the performance of the contract.
• Complying with guest-registration, public-security, tax, accounting and tourism obligations: the legal basis is compliance with applicable legal obligations.
• Preventing misuse, managing incidents, protecting the property and pursuing or defending claims: the legal basis is Prime Living’s legitimate interest in protecting the accommodation, its services and its legal rights.
• Sending commercial communications: only where permitted by law or where you have provided consent. Consent may be withdrawn at any time.
• Using non-essential cookies or analytics technologies: based on the consent provided through the website’s cookie settings.

5. Mandatory information

Data marked as mandatory is necessary to manage the booking, comply with legal obligations or provide access to the accommodation. If the required data or valid identification is not supplied, Prime Living may be unable to confirm the booking or permit check-in.

6. Guest registration and communication to authorities

Spanish legislation requires accommodation providers to collect, record, retain and communicate specific information concerning reservations, transactions and guests to the competent authorities.

Where legally required, these data will be communicated to the Spanish Ministry of the Interior, the State Security Forces, judicial authorities or other competent public authorities. This processing does not require the guest’s consent because it is necessary to comply with a legal obligation.

7. Service providers and recipients

Personal data may be processed or accessed, only where necessary, by providers that assist Prime Living in operating the website and managing bookings, including:

• Smoobu and other property-management, channel-management or booking-engine providers.
• Chekin or other legally compliant guest-registration and online check-in providers.
• Payment-service providers and financial institutions.
• Website-hosting, email-communication and IT-support providers.
• Accounting, tax, legal and administrative advisers.
• Cleaning, maintenance and operational providers, limited to the information strictly necessary to perform their services.

These providers must process personal data according to Prime Living’s instructions or under their own legal obligations, as applicable.

Personal data will not be sold to third parties.

8. International data transfers

Some technology providers may process data outside the European Economic Area. Where this occurs, the transfer will be based on an adequacy decision, the European Commission’s Standard Contractual Clauses or another safeguard permitted by the General Data Protection Regulation.

Further information about the safeguards used by a particular provider may be requested using the privacy contact email shown above.

9. Data retention

Personal data will be retained only for as long as necessary for the purpose for which it was collected and for the periods required by applicable legislation.

• Booking, contractual, payment, invoicing and accounting information will be retained for the applicable legal limitation and tax or accounting periods.
• Guest-registration records subject to Spanish accommodation legislation will be retained for three years from the end of the contracted service.
• Information required for complaints or legal claims may be retained until the applicable limitation periods have expired.
• Data used for commercial communications will be retained until consent is withdrawn or the recipient objects.

After the relevant period, data will be securely deleted or blocked where required by law.

10. Data-protection rights

Where applicable, you may exercise the following rights:

• Access your personal data.
• Request the correction of inaccurate or incomplete data.
• Request the deletion of your data.
• Request restriction of processing.
• Object to processing based on legitimate interests or to direct marketing.
• Request data portability.
• Withdraw consent at any time, without affecting processing carried out before its withdrawal.
• Not be subject to a decision based solely on automated processing where it produces legal or similarly significant effects.

To exercise these rights, send a request to info@primeliving.life, identifying the right you wish to exercise. Additional information may be requested only where reasonably necessary to verify your identity.

You also have the right to lodge a complaint with the Spanish Data Protection Agency at www.aepd.es.

11. Automated processing and dynamic pricing

Accommodation prices and availability may be calculated or updated automatically according to factors such as dates, demand, occupancy and availability. Prime Living does not make decisions based solely on automated processing that produce legal or similarly significant effects concerning guests.

12. Cookies

This website may use technical cookies that are necessary for its operation and do not require consent. Analytics, advertising or other non-essential cookies, where used, will only be activated after the user has provided consent through the cookie banner or configuration tool.

The cookie-configuration tool available on the website provides information about the categories and purposes of the cookies used and allows users to accept, reject or manage non-essential cookies.

Consent may be withdrawn or changed at any time through the available cookie settings. Withdrawing consent does not affect the lawfulness of processing carried out before its withdrawal.

Disabling strictly necessary cookies may affect the operation of certain website or booking functions.

13. Security

Prime Living applies appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, loss, disclosure or destruction. Nevertheless, no internet-based system can guarantee absolute security.

14. Minors

Bookings may only be made by persons aged 18 or over. Data relating to minors staying at the accommodation will be processed only when provided by their parent, legal guardian or accompanying responsible adult and where required for the booking or legal guest registration.

15. Changes to this policy

This policy may be updated to reflect legal, technical or operational changes. The current version and its latest update date will always be published on this website.

Last updated: 31 August 2026