Privacy policy

In this statement we explain which personal data Via Boncompagni Holding S.à r.l. processes when you visit our website, make a request or book a stay, why we do so and what rights you have. The statement applies to the extent that we process personal data as controller.

1. Who is responsible

The controller is Via Boncompagni Holding S.à r.l., Rue de Luxembourg 295, 8077 Bertrange, Luxembourg, RCS Luxembourg B249086. You can send privacy questions to info@caribbeanluxuryapartments.com or ask them by telephone on +31 6 26003457. We have not appointed a data protection officer.

The website and the booking form are provided via Recreatie Online B.V. To the extent Recreatie Online processes personal data solely on our documented instructions, it acts as processor. Other parties may be independent controllers for their own services. The actual roles and arrangements are determined by the services and agreements that actually apply.

2. Which data we process and why

Request and booking. Name, contact details, address where necessary, dates of stay, accommodation, number of guests and correspondence. We process this data to handle your request and perform the agreement; the legal basis is performance of a contract or pre-contractual steps at your request.

Payment and administration. Invoice details, payment status, payment references and relevant booking data. We process this data to receive payments, keep our records and comply with legal obligations. The legal basis is performance of the contract and, where applicable, a legal obligation.

Stay and on-site management. Where necessary we may share name, arrival time, contact details and relevant stay information with a local manager, key holder or cleaning service for access, reception, safety and management. The legal basis is performance of the contract and our legitimate interest in safe and orderly management.

Questions, complaints and claims. We process the content of messages and the data needed to respond to them or handle a dispute. The legal basis is performance of the contract and our legitimate interest in customer service, legal claims and fraud prevention.

Website security and use. Technical data such as IP address, time, browser information and security logs may be processed to keep the website working, prevent abuse and investigate faults. The legal basis is our legitimate interest, after weighing your interests and rights. We only use non-essential analytics or advertising technology with your prior consent where legally required.

Marketing. We only send offers by email when consent is required and has been obtained or when another valid legal basis applies. You can unsubscribe at any time; this does not affect earlier processing.

We do not ask for special categories of personal data, such as health data. Please do not send these unless necessary. If you voluntarily provide health information to request an adjustment, we use it solely to handle your request, on an appropriate legal basis and no longer than necessary. Where no valid legal basis exists, we delete that data.

3. Who we share data with

We do not sell your personal data. We only share data needed for a specific purpose with:

• Recreatie Online B.V. for website and booking functionality, to the extent it acts as processor.
• Our accountant or bookkeeping office for invoicing, payment and statutory records.
• The local manager, key holder, cleaning service or other accommodation supplier, to the extent necessary for your stay.
• Payment, hosting, communication or IT service providers that we actually use; their names and roles can be provided on request and are stated in this statement where required.
• Public authorities when we are legally obliged to do so, for example for tax or registration obligations.

Where required we conclude a data processing agreement with processors and set out appropriate security and confidentiality obligations. The current list of relevant service providers is available on request via info@caribbeanluxuryapartments.com.

4. Transfers outside the European Economic Area

Our company is established in Luxembourg and the accommodation is located in Curaçao. To manage a booking it may therefore be necessary to make certain data available to a recipient in Curaçao. Curaçao is outside the European Economic Area. Before such a transfer takes place, we assess whether Chapter V of the GDPR applies and which valid transfer mechanism and safeguards are needed. This may be, for example, an applicable adequacy decision, appropriate safeguards such as standard contractual clauses, or a limited statutory exception. The specific recipients, data and safeguards depend on the actual arrangements and can be requested from us.

We also check where Recreatie Online B.V. and any sub-processors host data and from which locations they have access. The mere mention of a service provider does not mean that data is processed outside the EEA.

5. How long we keep data

We do not keep personal data longer than necessary for the purpose for which it was collected, unless a longer period is legally required or permitted. We keep booking and invoice data for the statutory retention period for accounting records. In Luxembourg this is in principle ten years.

We keep requests that do not lead to a booking no longer than necessary to handle the request and answer any questions about it. We keep correspondence as long as needed for handling and possible legal claims. We keep security logs no longer than necessary for the security of the website and for investigating faults. We keep marketing data until you unsubscribe or withdraw your consent, unless a shorter period is appropriate.

6. Security

We take appropriate technical and organisational measures to protect personal data against loss, unauthorised access, alteration or disclosure. Access is limited to people who need the data for their work. No website or data transmission can guarantee complete security. If you suspect that your data or our website is not secure, please contact us immediately via info@caribbeanluxuryapartments.com.

7. Your privacy rights

Depending on the circumstances and applicable law, you can request access, rectification, erasure or restriction of processing. You can also object to processing based on legitimate interest, request data portability and withdraw consent. Withdrawal does not affect the lawfulness of earlier processing. Some rights are not absolute; statutory retention obligations may, for example, mean that we do not delete certain data.

Send your request to info@caribbeanluxuryapartments.com. We will in principle respond within one month. For a complex or extensive request this period may be extended under the GDPR; we will inform you. To verify your identity we ask for appropriate additional information where necessary, but not as standard for a full copy of your identity document.

You can lodge a complaint with the Luxembourg Commission nationale pour la protection des données (CNPD) or, where applicable, with the supervisory authority of your habitual residence or place of work. Contact information for the CNPD is available on its official website.

8. Cookies and similar technologies

The website may use strictly necessary cookies for basic functionality, security and remembering steps in the booking process. For analytics, advertising or other non-essential cookies and similar technologies we ask for prior consent when the law requires it. You can adjust or withdraw your choices via the cookie settings on the website.

This statement does not mention specific analytics, advertising, map, video or security services unless it has been confirmed that the website actually uses them.

9. Changes and contact

We may change this statement when our processing or the law changes. The current version is on this website with the date of the last change. This version was updated on 9 October 2026. For questions you can contact us via info@caribbeanluxuryapartments.com or +31 6 26003457.