Effective date: 10 August 2026
This Privacy Policy explains how SAGNA PROPERTIES LIMITED, operating the Roomsing Service, processes and protects Personal Data.
The Service is operated by:
SAGNA PROPERTIES LIMITED
Private Limited Company incorporated in the Republic of Cyprus
Company Registration No.: HE 478223
Email: hi@roomsing.com
For the purposes of this Privacy Policy, “Roomsing”, “we”, “us” and “our” refer to SAGNA PROPERTIES LIMITED.
This Privacy Policy applies to Personal Data processed in connection with:
This Policy does not govern independent processing carried out by third parties acting as separate Data Controllers.
Personal Data means information relating to an identified or identifiable natural person.
Data Subject means the individual to whom Personal Data relate.
User means an individual accessing or using Roomsing.
Guest means an individual using or intending to use accommodation services provided by an Accommodation Provider.
Accommodation Provider means a hotel, apartment operator, property-management company or other organisation using Roomsing.
Controller means the person or organisation determining the purposes and means of processing Personal Data.
Processor means an organisation processing Personal Data on behalf of a Controller.
GDPR means Regulation (EU) 2016/679.
Roomsing may act either as a Data Controller or Data Processor depending on the processing activity.
SAGNA PROPERTIES LIMITED normally acts as Controller where it independently determines the purposes and means of processing.
This may include Personal Data relating to:
Where an Accommodation Provider uses Roomsing to process Guest Personal Data, the Accommodation Provider normally acts as Controller and SAGNA PROPERTIES LIMITED normally acts as Processor.
In such circumstances Roomsing may process Personal Data for:
Roomsing processes such data in accordance with documented instructions from the relevant Accommodation Provider and the applicable contractual arrangements.
The exact categories depend on the Roomsing functionality used.
Roomsing applies the principle that Personal Data should be adequate, relevant and limited to what is necessary for the relevant purpose.
We may process:
Where Roomsing is used for online check-in or Guest registration, we may process:
Roomsing may technically extract or structure textual information contained in an identity document where necessary to facilitate Guest registration.
Roomsing does not process biometric data for the purpose of uniquely identifying an individual.
Roomsing does not:
Where an identification document contains a photograph, that photograph is treated as part of the identification document.
Roomsing does not create a biometric template from such photograph and does not use it for automated biometric identification.
Roomsing may process:
Depending on the functionality used, Roomsing may process:
Where Roomsing provides digital-access functionality, we may process:
Such information may be exchanged with the relevant smart-lock or access-control provider where necessary to provide the functionality.
Roomsing does not accept, collect, initiate, route, settle or otherwise process payments made by individual Users or Guests.
Roomsing does not collect or store Guest payment-card credentials for accommodation payments and does not act as a payment intermediary between a Guest and an Accommodation Provider.
Any payment for accommodation or related services is carried out outside Roomsing directly with the relevant Accommodation Provider or through an external service independently selected by that Accommodation Provider.
Accordingly, Guest payment transactions do not form part of the categories of Personal Data processed by Roomsing under this Privacy Policy.
Where electronic-document functionality is used, Roomsing may process:
Where Roomsing communication functionality is used, Personal Data may be processed through:
This may include:
When a User accesses Roomsing, certain technical information may be processed automatically, including:
Personal Data may be obtained:
For example when the User:
For example where a hotel or apartment operator provides reservation information to Roomsing.
These may include:
Personal Data may be processed for:
Where SAGNA PROPERTIES LIMITED acts as Controller, processing may be based on one or more of the following legal bases.
Processing may be necessary to perform a contract or take steps requested before entering into one.
Article 6(1)(b) GDPR.
Processing may be necessary to comply with applicable legal obligations.
Article 6(1)(c) GDPR.
Processing may be necessary for legitimate interests including:
Such interests will be balanced against the interests, rights and freedoms of the Data Subject.
Article 6(1)(f) GDPR.
Where consent is the appropriate basis for optional processing, consent will be requested separately.
Article 6(1)(a) GDPR.
Consent may be withdrawn at any time.
Acceptance of this Privacy Policy, use of Roomsing or completion of online check-in does not automatically constitute consent to optional marketing.
Where marketing requires consent, such consent will be obtained separately.
A User may withdraw marketing consent at any time.
Withdrawal from marketing does not affect operational communications necessary for a reservation, check-in, digital access, security or requested Service.
Roomsing may provide AI-assisted technology for Guest communications and operational purposes.
Such functionality may process:
Roomsing does not use AI functionality for biometric identification of Guests.
Unless otherwise specifically disclosed, Roomsing does not make decisions based solely on automated processing that produce legal effects concerning an individual or similarly significantly affect that individual.
Roomsing does not sell Personal Data.
Personal Data may be disclosed where necessary to provide Roomsing functionality, comply with documented Controller instructions or fulfil applicable legal obligations.
Recipients may include:
Where Roomsing acts as Processor, it may use sub-processors where necessary to provide elements of the Service.
Relevant sub-processors are required to be subject to appropriate obligations concerning:
Where Personal Data are transferred outside the European Economic Area, Roomsing will use an appropriate transfer mechanism where required by applicable law.
This may include:
Supplementary safeguards may be implemented where appropriate.
Roomsing does not retain Personal Data indefinitely merely because a User has used the Service.
Personal Data are retained only for as long as reasonably necessary for the applicable purpose.
Retention periods may depend on:
Where Roomsing acts as Processor, Personal Data will be deleted or returned in accordance with the relevant agreement and documented instructions of the Controller unless continued storage is required by law.
Where an image or copy of an identification document is processed through Roomsing, it should not be retained longer than necessary for the purpose for which it was collected.
Where Roomsing acts as Processor, retention may depend on:
Roomsing does not use stored identification documents to create biometric or facial-recognition databases.
Roomsing implements appropriate technical and organisational measures designed to protect Personal Data against:
Measures may include:
Where SAGNA PROPERTIES LIMITED acts as Controller, Personal Data breaches will be assessed and managed in accordance with applicable law.
Where Roomsing acts as Processor, it will notify the relevant Controller without undue delay after becoming aware of a Personal Data breach affecting data processed on behalf of that Controller.
Subject to applicable law, Data Subjects may have the right to:
These rights may be subject to conditions and exceptions under applicable law.
Where SAGNA PROPERTIES LIMITED acts as Controller, requests may be submitted to:
hi@roomsing.com
Roomsing may request reasonable information to verify the identity of the person making the request.
Where Roomsing acts solely as Processor, Roomsing may refer the request to the relevant Accommodation Provider and assist that Provider as required.
If a User provides Personal Data relating to another person, including an accompanying Guest, the User should only provide such information where authorised or otherwise legally permitted.
Users should not submit another person’s identity documents or Personal Data without appropriate authority or legal basis.
Where Personal Data relating to a minor are processed in connection with accommodation, the relevant Accommodation Provider is responsible for determining the appropriate lawful basis and complying with applicable requirements relating to minors.
Roomsing does not use Personal Data relating to minors for targeted advertising.
Roomsing may use strictly necessary technologies required for:
Where consent is required for optional analytics or marketing technologies, such technologies will not be activated until the required consent has been provided.
Users should be able to reject optional cookies and modify or withdraw their preferences where applicable.
Roomsing may contain links to or integrations with third-party services.
Where a third party independently determines the purposes and means of its processing, that third party acts as a separate Controller and its own privacy terms apply.
Roomsing may update this Privacy Policy where reasonably necessary because of:
The current version will be published on the Roomsing website together with its effective date.
Where required by applicable law, material changes will be communicated through appropriate means.
Personal Data are processed in accordance with applicable data-protection legislation, including:
A Data Subject has the right to lodge a complaint with a competent data-protection supervisory authority.
Where SAGNA PROPERTIES LIMITED acts as the relevant Controller and Cyprus is the competent jurisdiction, the competent supervisory authority is:
Office of the Commissioner for Personal Data Protection
Republic of Cyprus
A Data Subject may also have the right to lodge a complaint with another competent EU or EEA supervisory authority in accordance with applicable law.
SAGNA PROPERTIES LIMITED
Company Registration No.: HE 478223
Email: hi@roomsing.com
© 2026 SAGNA PROPERTIES LIMITED / Roomsing.
