Villario  ·  a trading name of Cyridium Ltd  ·  Last updated: 22 October 2026  ·  ICO registration: ZC135949

This Privacy Policy explains how Villario, operated by Cyridium Ltd (registered in England and Wales; registered office 19 Brambles Crescent, Blythe Valley, Solihull, B90 8DJ), collects, uses, and protects personal data when you use Villario to search, book, list, or manage accommodation. We process data in accordance with UK GDPR and the Data Protection Act 2018.

1. Who we are

Cyridium Ltd, trading as Villario
Registered office: 19 Brambles Crescent, Blythe Valley, Solihull, B90 8DJ
Email: support@villario.co.uk
Privacy and data requests: privacy@villario.co.uk
ICO registration: ZC135949

2. Data we collect and why

3. Who we share data with

We do not sell personal data. We share it only as needed to run the Service:

We may also disclose data where required by law, to a relevant regulator or law-enforcement authority, or to protect the rights, safety, or property of Villario, our users, or others.

Guest violation records. There are two kinds — see our Acceptable Use Policy, Section 6, for how each is raised. Where a Host's dispute complaint about you results in a violation record, a Host reviewing your future Booking requests can see that a violation exists and the reason recorded for it — not the underlying dispute messages or evidence — so they can make an informed decision about accepting your Booking; on its own, it is never used to automatically block a Booking. Where a payment card chargeback on your Booking payment results in a violation record, that record does automatically block you from making new Bookings until it is cleared (see Section 9 for how this is handled under data protection law, and how to appeal a record).

4. International transfers

We transfer personal data outside the UK only where necessary to run the Service (for example, to a Sub-Processor providing a service described in Section 3). Where that transfer is to a third country (for example, the United States), we rely on an appropriate safeguard — typically the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. The sub-processors named in Section 3 that process data in the United States are Stripe, Anthropic and Google; those in the UK, the European Union or Switzerland (Zoho, OpenSanctions, OpenFreeMap, OpenStreetMap, the public business registers and our hosting in London) are covered by the UK's adequacy arrangements or are in the UK itself. You can ask us for a copy of the safeguard we rely on for a particular transfer at privacy@villario.co.uk.

Identity checks (Stripe). Your identity document image and selfie are collected and held by Stripe, not by us, and Stripe may hold them outside the UK and the European Economic Area, including in the United States. Villario keeps only the result of the check, in the UK or EU. For these transfers Stripe relies on its Data Processing Agreement and Data Transfers Addendum (which include the UK International Data Transfer Addendum and the EU Standard Contractual Clauses) and on Stripe, LLC's certification under the EU-U.S. Data Privacy Framework and its UK Extension. See Sections 6A and 7A.

5. How long we keep data

Backups. We keep encrypted backups so that we can recover your bookings and payments if something goes seriously wrong with our systems. When we erase your data it is removed from our live systems as described in Section 9, but copies may remain in our backups until those backups expire, which is no more than 30 days later. While they remain, those copies are put beyond use: they are kept only for disaster recovery, they are not used for any other purpose, and they are not consulted to answer questions about you. Only a small number of authorised people can access backups, and access through our systems is recorded. If we ever have to restore a backup, we erase again everyone who asked us to erase their data since that backup was taken, before the restored data is used for anything else. Backups are deleted automatically when they expire.

Inactive accounts. If you do not sign in or use your account for 24 months, we email you 30 days and 7 days before we pause it. A paused account cannot be used until you reactivate it with the link we send you, which stays valid for 30 days. We delete or anonymise paused accounts that never made a Booking or held a Listing, and keep the others only for the periods in this section.

6. Guest registration and identification required by a Host's country: we do not collect it

Some countries require accommodation providers to register their guests or keep a guest register. Villario does not collect, store, pass on or report your identity documents or registration details for this purpose, and it is not part of making a Booking. That duty is the Host's, not ours. If the law of a Property's country requires it, the Host will ask you directly, outside Villario, at or before check-in, and the Host is the Controller of what you give them.

• Information for Hosts. As a courtesy, we show a Host a short summary of what their country usually requires (who, what, where and by when to report). It is not legal advice, and it says that Villario collects, stores and reports nothing.

• What we do collect. We collect your country of residence (not your identity documents or registration details) so that we can meet reporting duties that fall on us as a platform, and for the other reasons in Section 6B. That is different from the guest registration this Section describes, which is the Host's duty.

• What we will never ask. We will never ask you to send an identity document to us, or to a Host, by ordinary message or email, or give you a link to do so for this reason. If you receive a message that appears to come from Villario asking for one, do not reply and tell us at support@villario.co.uk.

• This is not the check in Section 6A. Separately, we may ask you to verify your identity with Stripe before a Booking request is sent to the Host, to prevent fraud. That is a check we run, for our own purposes, and it is described in Section 6A.

6A. Verifying your identity before a booking request is sent (Guests)

This section is about a check we run, for our own purposes, on some booking requests, which is separate from anything a Host's country requires of the Host (Section 6). Villario decides why and how your data is used for it, so Villario is the Controller.

• When we ask. When you submit your booking request, we authorise your card (this holds the money without taking it; payment is captured only when the Host accepts), we sometimes ask a Guest to verify their identity before we send the request to the Host. We ask when a booking shows signs that need a closer look (for example a new account making a high-value booking at short notice, a payment that our payment provider rates as risky, or an earlier identity check that failed), or when the Host has asked to accept only verified Guests, and on some occasions we may ask every Guest who is not yet verified. We never use your nationality, ethnicity, the origin of your name, your age (beyond the legal minimum) or any other protected characteristic to decide whether to ask, and we review the rules for this. The Host is not told that you were asked, and does not see your request until you are verified.

• What you do and how long you have. You have 12 hours from when your card is authorised (2 hours if your stay starts within 48 hours), and we remind you halfway. You photograph a government-issued identity document (passport, driving licence or national ID card) with our payment provider, Stripe, using its Stripe Identity service, and then choose:

  • Fast verification (automatic). You also take a live selfie, which Stripe compares with the photo on the document using a facial scan. This uses biometric data, so we only do it if you tick a box to give your explicit consent first. You can try again up to three times if a photo is unclear.

  • Standard verification (manual review). No selfie and no facial scan. Stripe checks that the document is genuine, then a member of our team reviews it. This usually takes up to 24 hours but can take longer. The time limit stops while we review, and your request is not cancelled if we take longer: we tell you, and keep your request until we have decided.

  Choosing the standard track, or being unable to complete the fast track because of your document or country, never counts against you.

• What happens next. Once you are verified your request goes to the Host and the booking continues as normal. Nothing is charged until the Host accepts. If you do not verify in time, if the dates are confirmed to someone else while you verify, or if we cannot confirm your identity, we cancel the request, release the hold on your card (you are not charged; your bank decides when the released funds show again in your account), and tell you why. The Host is never told about a request that was cancelled for these reasons.

• Who collects it, and where it goes. Stripe collects your document image and selfie itself, directly from you, in its own window on our page: they do not pass through Villario's servers, and we never receive or store them. They, the details read from them and the facial comparison are held by Stripe, not by Villario. For the check you ask us to run, Stripe acts as our processor, on our instructions. Stripe is also an independent controller of some of this data for its own purposes (such as fraud prevention and security), so you and Stripe each have responsibilities towards you as separate controllers. Stripe may process and store the data outside the UK and the European Economic Area, including in the United States (Stripe's own privacy policy also names India). Those transfers rely on the safeguards in Stripe's Data Processing Agreement and Data Transfers Addendum (the UK International Data Transfer Addendum and the EU Standard Contractual Clauses), and on Stripe, LLC's certification under the EU-U.S. Data Privacy Framework, with its UK Extension. What Villario itself keeps (the result, the dates and reason codes) is stored with our hosting provider in the UK or EU (Section 3). Stripe's handling of the check is described in its Privacy Policy, its Privacy Center (Stripe Identity) and its Stripe Identity FAQ; how long it keeps biometric data is covered in Section 5.

• What we keep, and what Hosts see. We keep the outcome, not your documents (see the table in Section 2). A verification counts for 12 months, so you are not asked again on each booking; a later failed check on your account ends it early. Hosts do not see your identity document, selfie, or any result details. Where you have a current verification, the Host sees only a “Verified guest” label on your request and booking. No label means nothing: most Guests are never asked to verify. Hosts who have asked to accept only verified Guests never receive a request from an unverified Guest.

• If a check fails. A selfie that repeatedly does not match your document goes to manual review rather than being treated as a failure. A photo that is unclear, a document we cannot process automatically, or an attempt you do not finish is not treated as a failure and is not recorded against you: you can try again, or choose manual review. If Stripe's check finds that the selfie has been manipulated or that you are under the minimum age, or if a manual review cannot confirm your identity, the request is cancelled and a failed check is recorded on your account. While a recorded failure is kept (24 months, Section 5) we will always ask you to verify on later bookings, and two within 90 days mean new requests wait for a member of our team to review your account first. We do not close your account or ban you automatically because a check failed.

• Your country and your document. When you verify, Stripe tells us which country issued your document. We compare that with the country of residence you gave. Living in a different country from the one that issued your document is common and normal (expatriates, dual nationals, people who have recently moved), so a difference is never a failure on its own and never cancels a request. It is one signal among others. If it is the reason we want a closer look (we do this only where we have switched it on), a member of our team reviews your check and the request waits for that review rather than being cancelled; you are told, as for any manual review, that a person is looking at it, and you can contact support to explain. We keep only whether the two matched, not the document's country. Section 6B explains the purposes.

• Human review of the outcome. The decision to cancel after a failed check is made automatically from Stripe's result, with no person involved at that moment. It can have a significant effect on you (your booking request is cancelled), so we rely on Article 22(2)(a) (it is necessary for the contract between you and us: we cannot offer Bookings to Hosts without being able to guard against fraud and impersonation) and give you the safeguards in Article 22(3). You can ask for the outcome to be reviewed by a person at any time from your booking page (or by emailing support@villario.co.uk with your booking reference); you can explain your side and attach what you like; a member of our team decides, and an upheld appeal clears the recorded failure. A manual review decision is always made by a person.

• Lawful basis. The result and records are processed on the basis of our legitimate interests in preventing fraud and impersonation (Art. 6(1)(f)). The facial comparison, which exists only on the fast track, uses biometric data and is carried out only with your explicit consent (Art. 9(2)(a)), which you give on screen before the check starts and may withdraw (we can then no longer treat you as verified on that basis; you can verify on the standard track instead). You can withdraw it yourself in your account, under "Your identity check", or on the verification screen while you are verifying, or by emailing privacy@villario.co.uk. Withdrawing asks Stripe to delete what it holds for the check, and does not affect a booking request already sent to a Host. Because the standard track is a genuine alternative that involves no biometric processing, consent to the fast track is freely given.

• Retention, deletion and your rights. See Section 5. When we delete our record, we also ask Stripe to redact the check; Stripe may keep some data as its own controller, and you can ask Stripe directly, as described in Section 7A (“Your rights”), which applies to Guests in the same way. You have the rights in Section 9.

6B. Your country of residence

We ask every user for their country of residence when they register, and we ask you to confirm it, or give a different one, each time you make a Booking. For a Booking we also ask where each adult in your party lives (by default, the same country as you; children are recorded with yours). The Booking carries the countries you gave for that reservation, and you can correct them from your bookings until the stay ends.

• Why we ask. (1) Regulatory reporting: some laws require platforms like ours to report information about stays, including where guests live, to the authorities. The main one is the EU Short-Term Rental Regulation (Regulation (EU) 2024/1028): from 20 May 2026, for properties in areas where the authority has asked for the data, we send it the number of nights, the number of guests and their country of residence, with the property's address, registration number and listing link. Where a law applies to us we report only what it requires. (2) Your defaults: the country you choose sets a starting currency and date format on your profile, which you can change at any time. It never changes your language. (3) Fraud prevention: see below.

• Fraud prevention is a secondary use, and we tell you. Your country of residence, the country your payment card was issued in (which our payment provider shows us), and, if you verify your identity, the country that issued your document, may be used together to help detect and prevent fraud. A difference between any of them is not treated as fraud: there are many legitimate reasons for it (living abroad, dual nationality, a recent move, travelling, a card from another country). It is only ever one weighted signal, combined with others, and it can lead to a closer look by a member of our team, and only where we have switched that on, never to an automatic cancellation, ban or failed check on its own. You can always explain, and ask for a review (Section 6A).

• What we will not do. We do not use your country of residence for marketing, for advertising, or for any purpose unrelated to the ones above, and we do not sell it. We do not use it to decide who is asked to verify on the basis of nationality or ethnicity.

• Who sees it. Hosts never see your country of residence. It is kept on our side for reporting and fraud prevention. If the law where a Property is requires a Host to collect your residence or nationality, the Host asks you directly (Section 6), and does not receive our record. Our payment provider (Stripe) sees the country on the card and, if you verify, the issuing country of your document (Sections 6A and 3). Authorities receive it only where a law requires us to report it.

• Keeping it right. You can change your country of residence in your account at any time, and on each Booking. If you gave a country that is not true, a booking or report based on it may be wrong; please tell us. How long we keep it is in Section 5.

7. Host/trader verification data

To maintain a secure, high-integrity marketplace for all users, we voluntarily vet Hosts who act as "traders" (broadly, Hosts operating as a business or profession rather than as a private individual). Before a trader can offer a Property through Villario, we ask for essential identity, contact and business registration information, and we show some of it on the Host's public profile so Guests can see who they are booking with. This is separate from, and additional to, the payment-processing relationship Stripe already has with a Host.

As a micro-enterprise, Cyridium Ltd is currently exempt (under Article 29 of the EU Digital Services Act) from the trader verification requirements of Article 30 of that Act. We have nonetheless built our verification to follow those standards, which keeps the platform secure today and prepared for growth. We aim to review submitted trader information promptly, usually within 1 to 3 business days; this may take longer if we need clarification, document verification or follow-up from the Host. We may restrict access or pause Listings while verification is pending, to protect our community.

Whether a Host is a trader is worked out from the information they give when they register (their type of host and whether they let Properties as a business), together with a self-certification for traders. Where enabled, this may be supplemented by identity verification through a secure third-party partner. So that Guests know which consumer rights apply, Hosts who are businesses are labelled as such on their listing.

• What we collect it from: from you. When you register and set up payouts you give us your name or business name, address, phone, email and, for business Hosts, trade-register details, and tell us whether you act as a trader. We do not obtain card or bank account numbers, or copies of identity documents, for this purpose. Our payment provider, Stripe, separately collects its own onboarding information to provide payment services under its own terms and privacy policy; we do not use that information for our trader verification.

• Verification and correction. We make reasonable efforts to check the plausibility of the information described above (for example, cross-checking a stated trade-register number). If we identify data that appears missing, inaccurate, or outdated, we will ask the Host to correct it, and may restrict certain Host functionality until they do.

• Public disclosure. For each Host we have classified as a trader whose information is complete, the Host's public profile shows exactly these items and nothing more: the name (or business name) shown on the profile; the trade-register name and number, where the Host has one; and a statement that the Host has certified compliance with applicable EU product-safety and consumer-protection law, with the date of that certification. Address, phone and email are not made public.

• Sanctions and business-register checks. We screen the names we hold for a Host (the name on their profile, their legal and trading name, and the name on their payment account) and any business registration number against official sanctions lists: the UK Sanctions List, the United Nations Security Council consolidated list, the United States sanctions lists and the European Union consolidated list. We download these lists and match them on our own systems, so the Host's details are not sent to a screening provider. We screen when our team reviews a Host, and again when a list or the Host's details change. A possible match is always reviewed by a person with a compliance role before any decision is made. While we complete a compliance check we may pause payouts or listings, and we may not be able to tell the Host why. We keep a record of each screening: what was checked, when, by whom, which list it was checked against and the result. We keep these records for 6 years (for a possible match, 6 years from the date it was identified, and in any case until the matter is closed), even if the Host's account is closed or erased, so that we can show that we checked and defend any claim or inquiry. We also check a business registration or VAT number against the public register (Companies House, the Dutch Chamber of Commerce or the EU VAT register). We do this to prevent fraud and financial crime and to protect the Service and our users from the serious consequences of dealing with a sanctioned person (our legitimate interests, Art. 6(1)(f)).

• Retention. We retain this data for a maximum of six months after the Host's account is closed (or permanently deactivated), after which it is deleted or irreversibly anonymised unless a longer period is required by law or for legal claims (sanctions screening records are kept for 6 years, as described above), even if the Host's Stripe account is separately closed or disconnected in that time.

• Identity verification. Everyone who registers to host or manage Properties on Villario is also required to complete an identity check carried out by Stripe, which involves an identity document and a selfie. How that works, and what we keep, is explained in Section 7A.

7A. Identity verification of Hosts, Property Managers and team members

Before you can use the Host portal, Villario requires you to verify your identity. This applies to everyone who registers on a Host portal — Hosts, Property Managers, and team members invited to an organisation — whether or not you receive payouts. It exists to protect Guests and the platform from fraud and impersonation, and to help us meet our obligations as an online marketplace.

• You choose how to verify. The check is carried out by our payment provider, Stripe, using its Stripe Identity service. You photograph a government-issued identity document (passport, driving licence or national ID card) and then choose:

  • Fast verification (automatic). You also take a live selfie, which Stripe compares with the photo on the document using a facial scan. This uses biometric data, so we only do it if you tick a box to give your explicit consent first. The result is usually immediate.

  • Standard verification (manual review). No selfie and no facial scan. Stripe checks that the document is genuine, then a member of our team reviews the result against the details you gave when you registered. This usually takes 1–2 days. You can set up your account and create listings while you wait, but you cannot publish a listing until the review is complete.

  Choosing the standard track has no other consequence for you, and you can switch between the two tracks if a check does not succeed.

• Who collects it, and where it goes. Stripe collects your document image and selfie itself, directly from you, in its own window on our page: they do not pass through Villario's servers, and we never receive or store them. They, the details read from them and the facial comparison are held by Stripe, not by Villario. For the check you ask us to run, Stripe acts as our processor, on our instructions. Stripe is also an independent controller of some of this data for its own purposes (such as fraud prevention and security), so you and Stripe each have responsibilities towards you as separate controllers. Stripe may process and store the data outside the UK and the European Economic Area, including in the United States (Stripe's own privacy policy also names India). Those transfers rely on the safeguards in Stripe's Data Processing Agreement and Data Transfers Addendum (the UK International Data Transfer Addendum and the EU Standard Contractual Clauses), and on Stripe, LLC's certification under the EU-U.S. Data Privacy Framework, with its UK Extension. What Villario itself keeps (the result, the dates and reason codes) is stored with our hosting provider in the UK or EU (Section 3). Stripe's handling of the check is described in its Privacy Policy, its Privacy Center (Stripe Identity) and its Stripe Identity FAQ; how long it keeps biometric data is covered in Section 5.

• What we keep. Only the outcome: whether you are verified, the date, the status of each attempt, and, if a check fails, Stripe's reason code and a reference to the check. We do not receive or store your identity document, your selfie, your date of birth or your document number in our own systems. They remain with Stripe. On the standard track, the reviewer sees only the name that Stripe read from your document, next to the details you registered with, and records approve or reject with a reason; they do not see your document image or selfie in our systems. Access to individual Stripe checks through the Stripe dashboard is restricted to authorised personnel and is permitted only where necessary for a specific, lawful purpose, for example to respond to a valid data-subject request, a lawful request from a competent authority, or to investigate and resolve a payment- or fraud-related issue. All such access is logged and subject to periodic review.

• If a check does not succeed. You are shown the reason Stripe gives and can try again, or switch to the other track (for example, verify without a selfie). You can also contact Stripe support about the check, or contact us. Until you are verified you cannot publish a Listing, but you keep access to your account. If you believe the result is wrong, contact us and we will review the case; we may ask you for more information, and our decision after that review is final. We do not close your account or block your email address because a check failed. We record failed attempts so that we can monitor how the check performs and spot misuse.

• Lawful basis. The result and records are processed on the basis of our legitimate interests in preventing fraud and impersonation (Art. 6(1)(f)). The facial comparison, which exists only on the fast track, uses biometric data and is carried out only with your explicit consent (Art. 9(2)(a)), which you give on screen before the check starts and may withdraw (withdrawing means we can no longer treat you as verified on that basis; you can verify on the standard track instead). You can withdraw it yourself in your account, under "Your identity check", or on the verification screen while you are verifying, or by emailing privacy@villario.co.uk. Withdrawing asks Stripe to delete what it holds for the check, and does not affect a booking request already sent to a Host. Because the standard track is a genuine alternative that involves no biometric processing, consent to the fast track is freely given. Identity-document processing on both tracks does not rely on consent.

• Retention and deletion. We keep the result and attempt history while your account is active and for a maximum of six months after your account is closed or permanently deactivated, after which they are deleted or irreversibly anonymised unless a longer period is required by law or for the establishment, exercise or defence of legal claims (see Section 5). When we delete it, we also ask Stripe to redact the verification so that Stripe removes the document and selfie data it holds for that check, subject to any period Stripe must keep it for by law. Stripe is also an independent controller of some of that data: for data Stripe holds in that capacity you should contact Stripe directly, and we will tell you this when we confirm your erasure.

• Requests from authorities. If a competent authority lawfully requires proof of a Host's identity, we will follow a documented procedure: we respond only to valid, lawful requests, provide the minimum necessary (normally the outcome of the check, not images), keep a log of every request and response, and refer anything unusual to legal before releasing images. We may need to ask Stripe for the relevant information.

• Your rights. You have the rights in Section 9, including to ask what we hold. Requests about the document and selfie held by Stripe can also be made to Stripe, which holds that data as an independent controller as well as acting for us. You can read how Stripe handles personal data in its Privacy Policy and Privacy Center. To ask Stripe to delete data it holds about you, email privacy@stripe.com. Say that the data relates to a Stripe Identity check carried out for Villario, and give the name and email address you registered with so that Stripe can find it. Stripe will tell you what else it needs and will respond under its own policy; we cannot make Stripe's decision for it. Asking us to delete our records, and asking Stripe to delete its own, are separate requests: when we erase your account we also ask Stripe to redact the check we ran for you (see "Retention and deletion" above), but you may still contact Stripe about anything it keeps for its own purposes.

8. Cookies

Villario uses cookies for authentication, security, and (where you consent) analytics. See our Cookie Policy for full details and how to manage your preferences.

9. Your rights

Under UK GDPR, you have the right to:

• Access a copy of the personal data we hold about you;

• Rectification of inaccurate data;

• Erasure of your data in certain circumstances; what we delete and what we must keep is set out in the table below;

• Restriction of how we use your data;

• Portability of data you provided under a contract or consent, in a machine-readable format;

• Object to processing based on legitimate interests;

• Withdraw consent at any time where we rely on it, without affecting processing already carried out.

You can make a request in any way you like, including by email to privacy@villario.co.uk, by phone, in writing or in person; email is only the quickest. You can also delete your account yourself from your account settings. We respond without undue delay and in any case within one calendar month of receiving your request. We do not extend that deadline. We may need to confirm who you are first, so that we never delete or hand over the wrong person's data. Information a Host collects from you directly, for example a guest register that local law requires them to keep, is held by the Host and not by us (Section 6): ask the Host about it.

What happens when you ask us to erase your data

Before anything is deleted we show you this list and ask you to confirm. We delete what we can; we keep only what the law lets or requires us to keep, and for no longer than stated.

When we cannot erase straight away

The right to erasure is not absolute. While you have an upcoming or current Booking, or a payment dispute is open, we need a minimum of your data to carry out the contract with you and the Host and to answer the dispute (UK GDPR Article 17(3)). We do not ignore your request: we log it on the day it arrives and tell you in writing, within one calendar month, what is stopping us and what we are keeping. You then choose between:

• Cancelling the Booking. The Cancellation and Refund Policy applies. Once the cancellation is processed and any refund or payout has settled, we erase your data as set out above.

• Deleting after your stay. We keep the Booking and queue your erasure. We delete automatically once the stay is over and every payment, refund and dispute has cleared.

Until then we keep only what is needed to run the stay and settle the money, and we use it for nothing else: no marketing and no newsletters.

We tell you in writing what we deleted and what we kept, and why. Where we passed your data to a Host, we tell the Host that you asked us to erase it.

Guest violation records. A violation record (Section 3) raised from a Host's dispute complaint is always a decision made by a human reviewer — we do not use automated decision-making or profiling to create one, and Article 22 UK GDPR's protections against solely-automated decisions with legal or similarly significant effects are not engaged by this process for that reason.

A violation record raised from a payment card chargeback is different: it is created automatically, with no human review, and — because it blocks you from making new Bookings until cleared — it is a solely-automated decision with a legal or similarly significant effect on you within the meaning of Article 22(1). We rely on Article 22(2)(a): it is necessary for entering into or performing our contract with you (protecting the Service, and other users, from payment fraud is necessary to be able to offer Bookings on the terms in our Terms of Service at all). As required by Article 22(3), you have the right to obtain human intervention, to express your point of view, and to contest the decision — exercised the same way as any other appeal: email support@villario.co.uk with the Booking or dispute reference. A human reviewer will consider your appeal; an upheld appeal clears the record and removes the booking block.

Cross-account payment-risk matching. Separately from the violation records above, we automatically block a new Booking attempt — with no human review at the time — where the payment card, email, or phone number used matches an existing active violation record on a different account. The matching is deliberately narrow: it compares only against active records created by a payment card chargeback (never records raised from a Host's complaint, and never records that have been cleared or expired), and it looks only for an exact match of the card fingerprint, email address or phone number, not similar-looking details. If this match is only identified after your card has already been charged, the charge is refunded to you in full automatically as part of the same block. This is also a solely-automated decision with a legal or similarly significant effect within the meaning of Article 22(1), and we rely on the same basis described above (Article 22(2)(a) — necessary for our contract with you, to protect the Service and other users from payment fraud). The same right to human intervention and appeal applies: email support@villario.co.uk with your Booking reference. Every appeal against a payment-risk matching decision is reviewed by a person. We will provide our decision within one calendar month of receiving the appeal, and we aim to respond more quickly whenever possible. An upheld appeal clears the match and removes the block.

Identity check before a booking request is sent. If a Guest's identity check fails in a way that is not fixable (Section 6A), the request is cancelled automatically. This is a solely-automated decision with a legal or similarly significant effect within the meaning of Article 22(1); we rely on Article 22(2)(a), and the right to human intervention, to express your point of view and to contest the decision is described in Section 6A: every appeal is reviewed by a person. We will provide our decision within one calendar month of receiving the appeal, and we aim to respond more quickly whenever possible.

10. Children

Villario accounts are for people aged 18 and over. We do not knowingly collect personal data from children. Children may of course appear as guests on a Booking (e.g. as part of the guest count) — that limited data (age category, not identity) is handled as part of the Booking record described in Section 2.

11. Complaints

If you're unhappy with how we've handled your personal data, contact us first at privacy@villario.co.uk. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: ico.org.uk

• Helpline: 0303 123 1113

12. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or an in-product notice. The date at the top of this page reflects the last revision.

13. Contact

Cyridium Ltd, trading as Villario
19 Brambles Crescent, Blythe Valley, Solihull, B90 8DJ
Email: support@villario.co.uk
Privacy and data requests: privacy@villario.co.uk
ICO registration: ZC135949