Last updated: November 21st 2025
1. Who We Are
This website (“we”, “us”, “our”) is operated by:
Data Controller (EU):
Germain Delagardelle
Luxembourg
Email: germain@delagardelle.lu
Property Owner (USA):
Roude Leiw Investments LLC
A Florida limited liability company
Registered in the State of Florida, USA
The property (Villa Melusina) is owned by Roude Leiw Investments LLC, but the website and guest data are managed by Germain Delagardelle (Luxembourg).
2. Information We Collect
2.1 Information you provide
- Full name
- Email address
- Phone number
- Address & country
- Booking details (dates, number of guests)
- Payment details (processed via third-party)
- Messages and special requests
- ID/passport details (if required)
2.2 Automatically collected
- IP address
- Browser and device information
- Pages visited
- Cookies and tracking data
- Referral sources
2.3 Payment information
Processed securely by:
- Stripe
- PayPal
- WooCommerce payment gateways
We do not store your credit card details.
3. How We Use Your Data
- To process bookings and payments
- To communicate with you
- To manage your stay
- For legal and tax reporting
- For security and fraud prevention
- To improve our website and services
We never sell personal data.
4. Legal Bases (GDPR & U.S. Law)
We process your data based on:
- Contract (to fulfil your booking)
- Legal obligation (tax, accounting, local laws)
- Legitimate interests (security, customer service)
- Consent (cookies, optional marketing)
5. Data Sharing
We share data only with:
- Payment processors
- Hosting providers
- Booking and communication tools
- IT security providers
- Tax or government authorities if legally required
No commercial sharing or selling of data.
6. International Transfers
Data may be transferred to:
- United States (Florida)
By using this site, you consent to this transfer and understand that data will be processed under U.S. law with GDPR-level safeguards applied where possible.
7. Cookies
We use:
- Essential cookies
- Analytics cookies
- Security cookies
- Payment-related cookies
Non-essential cookies are only activated after consent.
See our full Cookie Policy below.
8. Data Retention
- Booking & invoices: up to 7 years
- Emails & messages: up to 24 months
- Security logs: 30–180 days
- Cookie preferences: until deleted
9. Your Rights (GDPR)
You may request:
- Access
- Correction
- Deletion
- Restriction
- Withdrawal of consent
- Data portability
Contact: germain@delagardelle.lu
10. Children
Bookings must be made by adults.
We do not knowingly collect data from minors under 18.
11. Security Measures
- SSL encryption
- Secured payment gateways
- Firewalls and monitoring
- Restricted access to personal data
12. Governing Law
This Privacy Policy is governed by:
State of Florida, USA
Venue: Lee County, Florida
Without prejudice to GDPR protections for EU residents.
13. Contact
For privacy questions:
Germain Delagardelle
Luxembourg