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Privacy

Privacy Policy

Sense Living · senseliving.app · Last updated 2026

1. Data Controller

The data controller is:

136 Rue Principale, L-5366 Munsbach, Luxembourg
Email: [email protected]

A. Data Submitted Through Website Forms

  • First name;
  • Last name;
  • Email address;
  • Professional role;
  • Company or building name;
  • Message content.

B. Website Usage Data

  • IP address;
  • Browser type;
  • Device information;
  • Cookies and analytics data;
  • Website interaction data.

C. Guest Onboarding & Stay Compliance Data

When Sense Living is deployed within residential or hospitality assets, the platform may temporarily facilitate the collection and transmission of guest onboarding and legally required stay information on behalf of the relevant building operator or accommodation provider.

This may include:

  • First and last name;
  • Passport or identity document information;
  • Number and identity of accompanying guests;
  • Stay and arrival information;
  • Digital signature;
  • Payment card authorization details processed through secure third-party providers.

Such information is processed exclusively for:

  • Guest onboarding and check-in procedures;
  • Compliance with accommodation and hospitality regulations;
  • Transmission to the relevant Property Management System (PMS);
  • Submission to competent governmental or regulatory authorities where legally required;
  • Verification and operational processing by the relevant building operator.

Sensitive identity and compliance-related information is processed temporarily and transferred to the relevant operator, PMS or authority as soon as operationally possible.

SENSE does not permanently store passport scans, identity verification documents or full payment card details unless legally required or strictly necessary for operational purposes.

D. Platform Usage & Behavioral Data

When users interact with Sense Living, SENSE may process operational and behavioral data related to:

  • Service bookings;
  • User preferences;
  • Feature interactions;
  • Engagement patterns;
  • Community participation;
  • Wellness and lifestyle interactions;
  • Booking history;
  • App navigation activity;
  • Amenity usage;
  • Operational support interactions.

This information is used exclusively to:

  • Improve platform functionality;
  • Personalize services and recommendations;
  • Optimize operational efficiency;
  • Enhance user experience;
  • Generate aggregated business insights and asset performance analytics.

Whenever required under applicable law, users will be asked for consent before advanced personalization or promotional profiling features are activated.

3. Purpose of Processing

Personal data may be processed for the following purposes:

  • Responding to demo requests;
  • Managing commercial communications;
  • Providing platform services and support;
  • Managing onboarding and access processes;
  • Facilitating service bookings and transactions;
  • Enabling operational integrations;
  • Improving user experience and platform performance;
  • Personalizing recommendations and services;
  • Supporting operational analytics and asset performance insights;
  • Complying with legal and regulatory obligations.

Processing activities are based on:

  • User consent;
  • Performance of contractual or pre-contractual measures;
  • Legitimate business interests;
  • Compliance with legal obligations;
  • Operational necessity within deployed building environments.

5. Data Minimization & Retention

SENSE applies strict data minimization and privacy-by-design principles.

High-Risk Sensitive Data

Sensitive onboarding and compliance-related information, including:

  • Passport or identity verification data;
  • Identity document scans;
  • Digital signatures;
  • Government reporting data;
  • Full payment card details;

is processed temporarily and retained only for the period strictly necessary to:

  • Complete onboarding and verification procedures;
  • Transfer information to the relevant PMS or building operator;
  • Fulfill legally required reporting obligations;
  • Support operational verification processes.

Once transfer and verification procedures are completed, such information is deleted, anonymized or no longer retained within Sense App systems unless legally required.

Payment card information is processed through secure third-party payment providers and is not directly stored by SENSE.

Operational & Experience Data

Operational and platform-related information necessary for the active use of the platform may be retained during the lifecycle of the user account, active stay or contractual relationship.

This may include:

  • Name and contact information;
  • Service bookings and operational history;
  • Active access permissions;
  • User preferences and engagement activity;
  • Community participation and amenity usage;
  • Support and operational interactions.

Such information is retained solely for operational continuity, service delivery, analytics, support and user experience optimization.

Aggregated & Analytics Data

SENSE may retain anonymized or aggregated operational analytics and platform usage insights for business intelligence, operational optimization and platform improvement purposes.

Such information does not directly identify individual users.

6. Role Allocation under GDPR

Depending on the context of use, SENSE may act as:

  • A Data Processor acting on behalf of the building operator or accommodation provider; or
  • An independent Data Controller for platform management, analytics, account administration and communications.

For guest onboarding and accommodation reporting obligations, the relevant building operator or accommodation provider generally acts as the primary Data Controller. Separate Data Processing Agreements (DPAs) may apply between SENSE and operators.

7. Data Sharing

Personal data may be shared with:

  • Hosting and cloud providers;
  • PMS and operational integrations;
  • Payment providers;
  • CRM and communication platforms;
  • Analytics providers;
  • Legal, regulatory or governmental authorities where legally required;
  • Professional advisors.

SENSE does not sell personal data to third parties.

8. International Data Transfers

Where data transfers occur outside the European Economic Area (EEA), SENSE implements appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs);
  • GDPR-compliant transfer mechanisms.

9. Promotional Communications

Users may receive operational communications related to:

  • Bookings;
  • Account activity;
  • Service confirmations;
  • Community events;
  • Building operations.

Where permitted by law or based on consent, SENSE may also send:

  • Promotional communications;
  • Curated offers;
  • Service recommendations;
  • Product updates;
  • Marketing campaigns.

Users may unsubscribe from promotional communications at any time through unsubscribe links or by contacting [email protected].

10. Data Subject Rights

Under GDPR, individuals have the right to:

  • Access their personal data;
  • Rectify inaccurate data;
  • Request deletion;
  • Restrict processing;
  • Object to processing;
  • Request portability;
  • Withdraw consent at any time.

Requests may be sent to: [email protected]

Users also have the right to lodge complaints with the competent supervisory authority.

11. Security Measures

SENSE implements appropriate technical and organizational measures, including:

  • Secure hosting environments;
  • Encryption in transit and at rest;
  • Restricted access permissions;
  • Internal security protocols;
  • Role-based access management;
  • Secure third-party payment infrastructure;
  • Monitoring and incident response procedures.

12. Cookies

The Website may use technical, analytics and marketing cookies.

Users may manage cookie preferences through the cookie banner or browser settings. A separate Cookie Policy applies.