Privacy Policy
As of: 18.10.2026
1. Data controller
Rebekka & Thomas Billen Immobilien GbR
represented by the shareholders Thomas Billen and Rebekka Billen
Zum Kehrnagel 8
54317 Kasel
Email: rtb@billen.me
We have not appointed a data protection officer, as we are not legally required to do so. If you have any questions about data protection, please contact us directly.
2. Your Rights
You have the right at any time to
- request information about the data we hold about you (Art. 15 GDPR),
- correction of inaccurate data (Art. 16 GDPR),
- deletion of your data, unless statutory retention requirements apply (Art. 17 GDPR),
- request restriction of processing (Art. 18 GDPR),
- Data portability (Art. 20 GDPR),
- Right to object to processing (Art. 21 GDPR, see Section 10).
You may withdraw your consent at any time, with effect for the future.
You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:
The State Commissioner for Data Protection and Freedom of Information of Rhineland-Palatinate
Hintere Bleiche 34
55116 Mainz
3. Visiting our website
Our website is hosted using the website builder provided by Smoobu GmbH, Pappelallee 78/79, 10437 Berlin. The domain is registered with IONOS SE, Elgendorfer Straße 57, 56410 Montabaur.
When you visit the website, technical information is collected automatically (server log files), such as your IP address, the date and time of access, browser type and operating system. This data is technically necessary to deliver the website and ensure its security and stability. We do not use it to draw conclusions about you.
The legal basis is our legitimate interest in maintaining a secure, fully functioning website (Art. 6(1)(f) GDPR). The data will be deleted once it is no longer needed for these purposes. Smoobu acts as our data processor.
Data is transmitted securely using HTTPS (SSL/TLS).
4. Contact Form and Inquiries
If you contact us via the contact form, email, telephone or WhatsApp, we process the information you provide (e.g. your name, contact details, travel dates and message) to respond to your enquiry. The contact form is provided by Smoobu, where your enquiry is stored.
The legal basis is taking steps prior to entering into a contract (Art. 6(1)(b) GDPR) and/or our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR). If no booking is made, we delete the data once the enquiry has been fully dealt with and there is no obligation to retain it.
WhatsApp: At your request, we use WhatsApp Business (WhatsApp Ireland Ltd., Dublin, Ireland) to communicate with guests. This may also involve transferring data to Meta Platforms Inc. in the USA. Transfers are protected by the EU-US Data Privacy Framework. If you do not wish this, please contact us by email or phone.
5. Booking and Stay
To book and provide your stay, we process in particular your name, address, contact details, travel dates, number of guests and payment information.
The legal basis for processing is the performance of the rental agreement (Art. 6(1)(b) GDPR). We retain booking and invoice data for the statutory retention periods under commercial and tax law (generally 6 to 10 years, Art. 6(1)(c) GDPR), after which we delete it.
We use software from Smoobu GmbH (Berlin) to manage bookings, with Smoobu acting as our data processor. Data is stored in the EU.
Bookings through platforms: If you book through Booking.com, Airbnb or other platforms, we receive the information needed to process your booking from the platform. The platform operator is responsible for processing your data on its platform; please refer to their privacy policy.
6. Online Check-in and Registration Form
Before arrival, please complete the online check-in. We collect the information required under the Federal Registration Act (in particular, name, date of birth, address, nationality, arrival and departure dates, and details of accompanying guests).
The legal basis is our statutory reporting obligation (Art. 6(1)(c) GDPR in conjunction with Sections 29 and 30 of the German Federal Registration Act). The information is required by law; accommodation cannot be provided without it. We retain registration data for one year from the date of departure and delete it within three months thereafter. Data is disclosed only to the competent authorities, where they request it as permitted by law.
Online check-in is provided by Smoobu, which acts as our data processor.
7. Access codes (smart lock)
Access to the apartments and sauna is provided by electronic locks from Nuki Home Solutions GmbH (Graz, Austria). To automatically generate time-limited access codes, Smoobu sends the necessary booking details (name, travel dates) to Nuki or its service provider, Seam. The locks record when each code is used.
The legal basis is performance of the rental contract (Art. 6(1)(b) GDPR) and our legitimate interest in keeping the accommodation secure (Art. 6(1)(f) GDPR). Access codes expire at the end of your stay.
8. Sauna reservations
We use the appointment scheduling feature in Google Calendar (Google Ireland Ltd., Dublin, Ireland) for sauna reservations. This involves processing your name, email address, apartment and chosen time. Your data may be transferred to Google LLC in the USA; the transfer is protected by the EU-US Data Privacy Framework.
The legal basis is performance of the rental agreement (Art. 6(1)(b) GDPR). After your stay, we retain booking records so that sauna use can be traced in the event of damage or queries (Art. 6(1)(f) GDPR), and delete them no later than twelve months after your stay ends.
9. Payment
For direct bookings, you can pay by bank transfer or PayPal. For bank transfers, we process the payment details provided to us by our bank. For PayPal payments, your payment details are transmitted to PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg; PayPal’s privacy policy also applies.
The legal basis is the performance of the rental agreement (Art. 6(1)(b) GDPR).
10. Right to Object under Article 21 GDPR
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your data based on Art. 6(1)(f) GDPR (legitimate interests).
If you object, we will no longer process your data unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary to establish, exercise or defend legal claims.
Please send your objection to:
Rebekka & Thomas Billen Immobilien GbR, Zum Kehrnagel 8, 54317 Kasel, rtb@billen.me
11. Amendments