Last updated: July 2026
1. Controller
The controller responsible for the processing of personal data on this website is:
Bernd Bötzel
Jan Sofat North 29
Willemstad
Curaçao / Netherlands Antilles
Email: info@curacao-frangipani-apartments.de
2. General information
We take the protection of personal data seriously. Personal data means any information that can directly or indirectly identify a person, such as a name, email address, telephone number, IP address, travel dates or booking information.
This Privacy Policy explains which personal data is processed when you visit this website, contact us, leave an entry in the guestbook or make a booking request.
3. Hosting and technical operation of the website
This website is operated using WordPress. The website is hosted on a server located in Germany. The server is rented from a hosting provider in Germany. The technical maintenance of the website is carried out by commissioned technical service providers.
When you access this website, technically necessary data is processed in order to display the website and operate it securely. This may include in particular:
- IP address
- date and time of access
- page or file accessed
- referrer URL
- browser used
- operating system used
- amount of data transferred
- server status codes
This data is processed in order to provide the website, detect technical errors, prevent attacks and ensure the stability and security of the website.
The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure and reliable operation of the website.
Server log data is stored only for as long as necessary for the purposes stated above. Unless security-related analysis is required, log data should be deleted or anonymised regularly.
4. Cookies and consent banner
Our website uses cookies and similar technologies. Some cookies are technically necessary for the website to function. Other cookies or services are only used if consent has been given.
When visiting the website for the first time, a consent banner is displayed. Visitors can use it to choose which categories of cookies and services they wish to allow. The selection can be saved so that the website can take the cookie settings into account during later visits.
Technically necessary cookies are used on the basis of Section 25(2) TDDDG and Art. 6(1)(f) GDPR. Our legitimate interest lies in the technically error-free and user-friendly operation of the website.
Non-essential cookies and services, in particular statistics, marketing or external services, are used only on the basis of consent pursuant to Section 25(1) TDDDG and Art. 6(1)(a) GDPR. Consent that has been given can be withdrawn or changed at any time via the cookie settings.
According to the current status, we do not use Google Analytics.
5. Contact by email, telephone or contact form
If you contact us by email, telephone or via the contact form, we process the data you provide. This may include in particular:
- name
- email address
- telephone number
- content of the message
- desired travel period
- number of guests
- any other information you provide voluntarily
The data is processed in order to respond to your enquiry, clarify follow-up questions, check availability and, where applicable, prepare or carry out a stay.
The legal basis is Art. 6(1)(b) GDPR if the enquiry serves to prepare or perform a stay. In all other cases, the legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in processing and responding to enquiries.
Contact enquiries are transmitted by email and stored in the email mailbox. Automatic deletion does not necessarily take place. The data will be deleted once it is no longer required for processing, unless statutory, contractual or legitimate retention interests prevent deletion.
6. Google reCAPTCHA
We use Google reCAPTCHA to protect our forms against spam, misuse and automated access.
The provider is Google. When reCAPTCHA is used, technical data may be transmitted to Google, in particular IP address, browser and device information, user behaviour on the relevant form page, referrer URL as well as date and time of access. Cookies or similar technologies may also be used.
reCAPTCHA is used to check whether an input is made by a natural person or automatically by a program.
Where reCAPTCHA is not technically strictly necessary, it is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and Section 25(1) TDDDG. Consent can be withdrawn at any time via the cookie settings.
It cannot be ruled out that data may be transferred to Google servers outside the European Union. Google may use appropriate data protection safeguards for this purpose.
7. Guestbook
Our website includes a guestbook. If you leave an entry in the guestbook, we process the data you provide. This includes in particular:
- name
- email address
- content of the guestbook entry
- time of the entry
- where applicable, technical data such as IP address or anti-spam verification data
The name you provide and the guestbook entry may be published on the website after review. The email address will not be published.
The data is processed in order to receive, review, publish and protect guestbook entries against spam or misuse.
The legal basis for publishing the name and guestbook entry is your consent pursuant to Art. 6(1)(a) GDPR. The legal basis for technical review, moderation and prevention of misuse is Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure operation of the guestbook and protection against spam, unlawful or abusive entries.
Guestbook entries may remain visible on the website permanently until they are deleted. You may request deletion or correction of your entry at any time using the email address stated above.
8. Booking enquiries and bookings via Smartness / Smartpms
An external booking system from Smartness / Smartpms may be used or linked on our website for bookings or availability checks. If you start or complete a booking through this system, you will be redirected to the external provider’s booking page or the provider’s booking function will be technically integrated.
The provider is Smartness Srl, Italy.
As part of a booking, the following data in particular may be processed:
- name
- contact details
- email address
- telephone number
- travel period
- booked apartment
- number of guests
- booking requests and messages
- payment and billing information, where payments are offered through the system
The processing serves to check availability, receive and manage bookings, communicate with guests, process payments and carry out the stay.
The legal basis is Art. 6(1)(b) GDPR if the processing is necessary to prepare or perform a stay. Where data is processed on the basis of statutory retention obligations, the legal basis is Art. 6(1)(c) GDPR.
For data processing that takes place directly on the pages or systems of Smartness, the privacy notices of Smartness also apply.
9. Performance of the stay on site
To carry out a booked stay, personal data may also be processed on site in Curaçao. This concerns in particular data required for communication with guests, handover of the apartment, organisation of the stay, billing and, where applicable, access organisation within the residential complex.
Depending on the individual case, data may be passed on to local contact persons, service providers or offices where this is necessary for carrying out the stay. This may include in particular name, travel period, booked apartment, contact details and information on the number of guests.
The legal basis is Art. 6(1)(b) GDPR. Where disclosure is necessary to protect legitimate interests, for example for security, organisation or claims handling, the legal basis is Art. 6(1)(f) GDPR.
Curaçao is located outside the European Union and the European Economic Area. Therefore, when personal data is processed or transferred to Curaçao, a different level of data protection may apply than within the European Union. Processing takes place insofar as it is necessary for carrying out the stay.
10. External links and embedded content
Our website contains links to external websites and services, for example tourist information, travel information, maps, 3D tours, booking services or review platforms.
If you click on an external link, you leave our website. The respective provider is responsible for the processing of personal data on external websites. Please refer to the privacy notices of the respective provider.
If external content is embedded directly on our website, personal data may be transferred to the respective provider when this content is accessed. This may include in particular the IP address, browser data and information about the access to the respective page. Non-essential external content is loaded only after consent, where required.
11. Recipients of personal data
Personal data may be transferred, where necessary, to the following categories of recipients:
- hosting providers
- technical service providers for operation and maintenance of the website
- email and communication service providers
- providers of the booking system
- payment service providers, where online payments are offered
- local contact persons or service providers on site in Curaçao
- offices or parties required for access, security or organisation of the stay
- tax advisors, legal advisors or authorities, where legally required
Data is transferred only where a legal basis exists.
12. Storage period
We store personal data only for as long as necessary for the respective purposes.
Contact and enquiry data is stored for as long as necessary to process the enquiry, carry out a stay or protect legitimate interests. Booking and contract data is stored in accordance with statutory or contractual retention obligations. Guestbook entries may remain visible until deletion or until consent to publication is withdrawn.
Where statutory retention obligations exist, data will only be deleted after the expiry of these periods. Where data is no longer required and no retention obligations prevent deletion, it will be deleted.
13. SSL/TLS encryption
For security reasons, this website uses SSL/TLS encryption. You can recognise an encrypted connection by the fact that the browser address bar begins with “https”. This means that data you transmit to us cannot easily be read by third parties.
14. Your rights
Subject to the statutory requirements, you have the following rights:
- right of access to the personal data processed
- right to rectification of inaccurate data
- right to erasure
- right to restriction of processing
- right to data portability
- right to object to certain processing operations
- right to withdraw consent with effect for the future
- right to lodge a complaint with a data protection supervisory authority
If you wish to exercise any of these rights, you may contact us at any time using the email address stated above.
15. Objection to direct advertising
We do not use your data for newsletters or automated direct advertising. Should we use newsletters or promotional emails in the future, this will only take place on the basis of separate consent or another legal basis.
16. Changes to this Privacy Policy
We reserve the right to amend this Privacy Policy if technical, legal or organisational changes occur, in particular if new services, booking systems, analytics functions or external content are used.
