Privacy Policy

Last updated: 29 October 2026

What changed on 15 October 2026. New section 19 covers tenants who choose to answer a few questions about their home after an invitation from their landlord or agency. Section 6 now describes how a person takes part in matching today: a person at Ayla reviews every round of suggestions before a home sees it, and the home chooses who to meet. We also removed the statement that a person reviews every introduction on the women-only track.

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What changed on 13 October 2026. New sections 17 and 18 cover the Ayla portal for property managers: what we keep about managers, and how we handle tenants' details for a manager who keeps them in the portal. Section 1 now explains that for those tenant details we act for the manager, not for ourselves.

This policy explains what personal data Ayla collects about you, why we collect it, who we share it with, how long we keep it, and the rights you have over it. We have tried to write it plainly. If anything is unclear, you can reach us using the contact details below and we will explain.

1. Who we are

Ayla is a flatmate-introduction service operated by Ayfinity Labs S.à r.l.-S, a company established in Luxembourg.

  • Company: Ayfinity Labs S.à r.l.-S
  • Registered office: 13A, Avenue Guillaume, L-1651 Luxembourg
  • Company registration: RCS Luxembourg B309934
  • VAT number: LU37653060
  • Privacy contact: privacy@ayla.lu, or message us on WhatsApp at +352 404 002
  • Website: ayla.lu
  • WhatsApp: +352 404 002

Ayfinity Labs S.à r.l.-S is the data controller for the personal data described in this policy. That means we decide why and how your data is used, and we are responsible for it.

One exception. When a landlord or an agency keeps their tenants' details in the Ayla portal, the landlord or agency is the controller of those details and we only handle them on their instructions (we are their processor). Section 18 explains what that means if you are one of those tenants.

We have assessed whether we are legally required to appoint a Data Protection Officer and concluded that we are not, given our size and activity. You can still contact us about any data-protection matter using the privacy contact above.

2. What Ayla does, in one line

Ayla helps people in Luxembourg find flatmates and rooms. You talk to Ayla through WhatsApp, we build a profile from what you tell us, and we suggest people and homes that fit. Ayla is open to everyone and also offers a dedicated women-only track for people who want a women-only living space.

3. The personal data we collect

We collect only the data we need to match you well. Depending on how you use Ayla, this can include the following.

If you are looking for a place, the information you give us through WhatsApp and onboarding:

  • Your phone number (this is how we identify you and message you). If you first message us from a WhatsApp username instead of a phone number, we will ask you to share your number so we can set you up and follow up about rooms and flatmates.
  • Your WhatsApp username, if you use one. This is the public handle you have chosen on WhatsApp. We may store it so we can recognise you.
  • Your first name (and any name you choose to share).
  • Your date of birth. We ask for this to confirm you are at least 18, because Ayla is for adults only, and so that we can match you with homes whose flatmates have stated an age range they are looking for. We do not show your exact date of birth to other users.
  • Your move-in date or move-in window.
  • Your budget for rent.
  • The neighbourhoods you are interested in.
  • How long you plan to stay.
  • Notes about your lifestyle, habits and what you are looking for in a flatmate (we call these your "vibe"), including whether you smoke or have a pet, which we record as housing preferences, and any dealbreakers you mention.
  • A photo of you, if you choose to add one. It is optional. A photo can show things about you, such as your ethnic origin or your religion, which is one more reason it is always your choice. When you upload it, we remove the hidden details stored in the file, such as where it was taken. Section 8 says who sees it.
  • What you write about yourself for your profile, such as a short answer in your own words and, if you like, a note to future flatmates.
  • Your stated gender answer, and your track choice. At the start, Ayla asks whether you are a woman or a man (or rather not say), because the women-only track only works if we know who it is for. We store that answer as you gave it: Woman, Man, or Rather not say. If you answer that you are a woman, we also record the kind of homes you want: women-only, mixed, or both. If you answer that you are a man, or rather not say, your search covers mixed homes. We use the stated answer to route your search and to keep an honest record of what you chose; it is not a verified fact about your gender, and it is not what unlocks verified women-only eligibility (see below). The AI can never change your gender answer on its own. If it needs correcting, contact us (section 11). (See section 7.)
  • An eligibility result for women-only spaces, where an identity check is used. Identity verification through our partner, which can read the gender marker on a government ID, is used today for the forming-flatshare track. On the regular women-only track we currently rely on your own declaration. If we switch identity checks on for the women-only track as we grow, the same rules apply: we store only the eligibility result plus the partner's name, a reference number and the date, never the image of your ID, and we keep the result out of the AI that reads your messages. The check happens only at the point it is needed, edge cases are looked at by a person in good faith, and we never ask for medical or transition proof. Never collected from property managers. (See section 7.)

If you offer a room or a home (property managers, and people listing a home of their own):

  • An email address used to sign in to our management portal (for example through Google) and to contact you about your listings.
  • If you use the Ayla portal (manage.ayla.lu), your account details as described in section 17.
  • The details of your home and listing: the address or area, the rent, room details, availability, and any photos you upload.
  • If you live in the home you offer, the same kind of profile people looking for a room have: your first name, your date of birth, what you do, the languages you speak, how you live, what you write about yourself, and a photo of you if you choose to add one.
  • If you are a landlord or an agency and do not live there: whether you are a private landlord or an agency, the agency's name, your first name and the languages you speak. We ask you to confirm you are 18 or over, but we do not keep your date of birth. If we check a landlord or an agency for the "Verified" mark, we may ask for documents that show who you are and that you can rent out the room, such as a company register entry, a utility bill or your lease. We use them only for that check, record the date we did it, and delete them once the check is done, apart from what stays in our message history for up to 90 days if you send them in the chat.
  • For a managed home, the people living there can choose to answer a few questions about how the household lives, after an invitation from their landlord or agency. Ayla asks for their consent first (see section 19).

The content of your conversation with Ayla:

  • The messages you exchange with Ayla on WhatsApp. Ayla is an AI-assisted service, so the conversation is read by AI to understand what you are looking for and to build your profile. (See section 6.)
  • If you send a voice message, we convert it to text so Ayla can read it.

Information about how you use the service:

  • Basic technical and activity records needed to run the service reliably and securely, such as message delivery status, error logs, and a record of the decisions made about your matches. We also record when your match or review link is opened, so we can see whether introductions actually reach people and improve how Ayla works.

For the forming-flatshare track only (people forming a new shared flat with strangers):

  • An identity-verification result. Before strangers are introduced to share a lease, we ask each member to verify their identity through our verification partner (a photo of a government ID plus a selfie). We store only the result, the partner's name, a reference number, and the date. We do not store the photo of your ID or the selfie. Those are handled and then deleted by our verification partner inside the EU. (See section 7.)

From the website (ayla.lu):

  • The website may set strictly necessary cookies needed for it to work. If we ever use cookies beyond that, they will only run after you agree through a cookie banner, and we will list them in our cookie information.
  • The website uses cookieless analytics (Vercel Web Analytics) to count page visits and clicks in aggregate. It sets no cookies, stores nothing on your device, and does not follow you across websites. We see counts and trends, never an individual visitor's browsing.

Safety-incident records:

When a person reports harassment or a safety concern, or Ayla's safety guard flags one, we keep a record of the report: what was said, who reported, who it concerns, and what we did.

We do not ask for or want more than this. In particular, we do not collect data about property managers' gender, and we do not run criminal background checks, criminal-record checks, or financial checks on anyone. The identity verification we use confirms that a person is who they say they are. It is not a vetting of their history.

4. Where we get your data

Most of your data comes directly from you, through your WhatsApp conversation with Ayla and through the onboarding questions. If you offer a room or a home, some of your data also comes from signing in to our management portal (for example through Google) and from what you enter there.

For the forming-flatshare track, the identity-verification result comes from our verification partner after you complete the check with them. The same would apply to the women-only eligibility result if an identity check is used there.

If you used Ayla before our relaunch, your existing profile was carried forward into the new service, and we asked you to confirm your consent before continuing.

If you used Ayla before we added the new profile, we may use AI inside the EU to fill in the new profile lines, such as your work and the languages you speak, from what you already told Ayla. Nobody else sees those lines until you have checked your profile and confirmed it.

If you are a tenant and your landlord or agency uses the Ayla portal, your details come from them, not from you. They decide what is kept. See section 18.

5. Why we use your data, and our legal basis for each use

Under the GDPR, we must have a valid legal reason ("lawful basis") for each way we use your data. Here is exactly what we do and why we are allowed to do it.

  • Running the introduction service you signed up for: building your profile, showing it to the people deciding on you (section 8), finding and suggesting flatmates and homes, making introductions, and sending you service messages on WhatsApp about your search. Legal basis: performance of a contract with you (Article 6(1)(b)). This is the core service you asked for when you started using Ayla.
  • Using AI to read your messages and to help rank and suggest matches (the AI-assisted part of the service). Legal basis: your consent (Article 6(1)(a)), asked for clearly when you start, and recorded. You can withdraw it (see section 11).
  • Your profile photo, if you add one. Legal basis: your explicit consent (Article 6(1)(a) and, because a photo can reveal sensitive things about you, Article 9(2)(a)), asked for when you add it and recorded with the wording you saw. You can ask us to remove your photo at any time, in your WhatsApp chat or at the privacy contact in section 1, and that withdraws your consent.
  • Checking new profile photos and profile text before others see them, and keeping a copy as evidence when we remove something that breaks our rules. Legal basis: our legitimate interest in keeping people on Ayla safe (Article 6(1)(f)).
  • Your stated gender answer and your track choice (Woman, Man, or Rather not say, asked at the start, and the kind of homes you want). Legal basis: performance of a contract (Article 6(1)(b)), because your answer determines which homes the service can show you, supported by our legitimate interest (Article 6(1)(f)) in keeping the women-only track what it promises to be. We store Man and Rather not say as those answers so they are not mixed up with each other or with older records from before we kept this field.
  • Women-only eligibility verification (reading the gender marker on your government ID), where an identity check is used. Legal basis: your explicit consent (Article 9(2)(a)), because the gender marker counts as sensitive data. We ask for it specifically and separately, at the point the check is needed.
  • Identity verification (the ID and selfie check, used today for the forming-flatshare track, and for the women-only track if identity checks are switched on there). Legal basis: your explicit consent (Article 9(2)(a)) for the sensitive (biometric) part of the check, with the rest of the check resting on performance of the contract (Article 6(1)(b)).
  • Keeping records we are legally required to keep, such as accounting and tax records, and the record of decisions about introductions. Legal basis: legal obligation (Article 6(1)(c)) for tax and accounting records, and our legitimate interest (Article 6(1)(f)) in being able to show our matching decisions were made properly.
  • Keeping the service secure and reliable, such as error monitoring and preventing abuse. Legal basis: legitimate interest (Article 6(1)(f)) in operating a safe, working service, balanced against your rights.
  • Keeping a safety-incident record when a person reports harassment or a safety concern, or Ayla's safety guard flags one: what was said, who reported, who it concerns, and what we did. We do this to keep people safe and to handle complaints under the Digital Services Act. Legal basis: our legitimate interest in keeping people safe (Article 6(1)(f)) and a legal obligation (Article 6(1)(c)). Where the report includes sensitive data, we rely on the defence-of-legal-claims and substantial-public-interest conditions (Article 9(2)(f) and (g) GDPR).
  • Reviewing conversations to improve Ayla. Our team reads a sample of conversations, and sometimes uses AI to help analyse them, to understand where Ayla helps, where she confuses people, and what to build next. Any AI used for this runs under the same rules as the rest of our AI: inside the EU, and barred from training on your data. Legal basis: legitimate interest (Article 6(1)(f)) in understanding and improving the service, balanced against your rights. You can object at any time (see section 11).
  • Understanding how the website is used, through cookieless, aggregate analytics (page visits and clicks, never individual tracking). Legal basis: legitimate interest (Article 6(1)(f)) in understanding and improving our website, using a method deliberately chosen to avoid cookies and individual tracking.

The service is free to use at launch. If we ever introduce a fee, we will update this policy and tell you before you pay anything. If we ever want to use your data for a genuinely new purpose, we will tell you first and, where the law requires it, ask for your consent.

6. Automated decision-making and AI

Ayla is an AI-assisted service, and we want to be clear about it.

AI reads your messages. To build your profile and understand what you are looking for, AI models read the content of your WhatsApp conversation with Ayla. We ask for your consent for this when you start. The AI providers we use act on our instructions only and are bound by contracts that prohibit them from using your data to train their own models. The AI also reads what you write about yourself for your profile, in the same way, to help find people you would get along with. It never sees your photo, and your photo is never used to rank or suggest matches.

How matching works. When Ayla suggests people or homes, the suggestions are produced mostly by fixed rules working from the details you gave us, such as your dates, your budget and the areas you want. AI adds one narrow input: a simple rating of how well two people might get along. It does not write free-text opinions about you, it does not see your women-only eligibility result, and it does not use protected details such as your age, your job, or your identity to rank you. A person always reviews the result before anything reaches you.

Some hard filters use the facts you gave us. A few of the suggestions are filtered on simple, factual criteria you provided, such as your move-in dates, your budget, and, where a household has set an age range for who lives in the home, your age. Where a home's flatmates have set an age range, someone outside that range is not shown that home. This reflects the household's own preference about who they live with.

The women-only filter. Whether a women-only home can be shown to you depends on your own answers: the women-only track is open to people who told us they are women, and a strictly women-only search keeps mixed homes out. This is a deliberate, both-ways rule, and it is part of how the women-only track keeps its promise.

A person reviews every round, and you can always ask for one. A person at Ayla reviews every round of suggestions before a home sees it, and the home then chooses who it wants to meet. So decisions that affect you are not made solely by a machine. Separately, you can ask to speak to a person at any point in your conversation, and we will route you to one.

Your rights around these decisions (GDPR Article 22). Because a person at Ayla reviews every round and the home makes the choice, the strict rules on solely-automated decisions do not currently apply to matching. Even so, you always have the right to:

  • ask for a human to review a decision about your matches,
  • tell us your point of view, and
  • contest a decision you disagree with.

You can do this simply by replying in your WhatsApp conversation and asking to speak to a person, or by using the contact details in section 1.

If automation increases later, it will be consent-based. Over time we may let parts of the matching process run more automatically. If we do, we will rely on your consent for it, we will update this policy first, and we will keep these safeguards fully in place before we switch anything on: clear information about the logic involved, your right to a person reviewing the outcome, your right to express your view, and your right to contest the decision.

For the forming-flatshare and women-only tracks: if your identity or eligibility check does not pass, you will not be silently stuck. A person looks at edge cases in good faith, and you can reach a person to sort it out.

Under the EU AI Act: we tell you plainly when you are interacting with an AI system. You are talking to an AI on WhatsApp, and AI helps shape your match suggestions, as described above. There is a fuller, friendlier explanation on our AI at Ayla page.

AI in the Ayla portal. In the portal for property managers, an AI chat answers the manager's questions about their records and leases, and an AI reads the lease documents a manager uploads (or, once Ayla offers it, sends to Ayla on WhatsApp), to suggest details such as names, dates and rent. The manager checks and saves those details. The chat is labelled as an AI, its answers can be wrong, and it never decides anything about a tenant. These AI services run in the EU (Google Vertex AI, and, once we start using it for this, Anthropic Claude through Amazon Web Services in Frankfurt), act only on instructions, and may not train on the data.

7. Sensitive data, handled with extra care

Two kinds of data get stronger protection from us because of what they reveal:

  • Your stated gender answer and any women-only eligibility result. We treat these with extra care because they relate to your gender and to a women-only living choice, even where the law classes a simple self-declared answer as ordinary personal data. We store the answer as you gave it (Woman, Man, or Rather not say), we keep it out of the AI that reads your messages, and we use it to route which homes we can show you and to keep that choice honest on your profile. It is not a verified gender check. Where an identity check is used (today, the forming-flatshare track), our verification partner reads the gender marker on your government ID and we store only the eligibility result, never the ID image. Edge cases are reviewed by a person in good faith, and we never ask for medical or transition proof. For an identity check we rely on your explicit consent.
  • The identity-verification result in the forming-flatshare track (and the women-only track, if identity checks are switched on there). The check itself involves a selfie, which is biometric data. We rely on your explicit consent for it, we store only the result and a reference, and we never keep the photo or the ID image. Our verification partner handles and deletes those inside the EU. We use this only to make stranger-formed flatshares and women-only spaces safer. It is an identity check, not a background, criminal, or financial check, and it is not a vouch for anyone's behaviour.

Where an identity check is used, you can withdraw that consent at any time (see section 11). Withdrawing it may mean we cannot run the check it covers, and so cannot offer you the part of the service that depends on it.

8. Who we share your data with

We do not sell your data. We share it only with the following.

Other Ayla users, when you ask to be matched. Ayla shows your profile to the people who decide whether you could live together, before they decide.

  • If you are looking for a room, your profile goes to the people who choose who joins a home: the people who live there, people starting a new flatshare together, and landlords and agencies. It shows your first name, your age (never your date of birth), what you do, the languages you speak, how you live, what you are looking for (such as your budget, your dates and how long you want to stay), what you wrote about yourself (or, until you have written something, a short summary Ayla writes from what you told her) and, if you added one, your photo. A note you write to future flatmates is shown to the people who live in the home or are starting a flatshare, not to landlords and agencies.
  • If you offer a room in a home you live in, people looking for a room see your profile in the same way: your first name, your age, what you do, the languages you speak, how you live and what you wrote about yourself (or a short summary Ayla writes from what you told her). They see your photo, if you added one, only after they have said yes to the room.
  • If you are a landlord or an agency, people looking at your rooms see who is renting: whether you are a private landlord or an agency, the agency's name, your first name and the languages you speak, and a "Verified" mark if we have checked who you are and that you can rent out the room.

Before a landlord or an agency sees anyone's photo, they agree to use what they see only to decide about that room, not to keep copies of it, and never to turn someone down for a reason the law forbids, such as their ethnic origin, religion, disability or sexual orientation. A person at Ayla checks each new profile photo, and each new answer or note you write for your profile, before anyone else sees it. Profile photos never appear on a public page, and the links that show them stop working within minutes.

We ask for your consent before sharing your phone number with a match.

We never mix portal records into the flatmate service. The records a landlord or an agency keeps in the Ayla portal, their tenants' details, payments, lease documents and chat history, are never used to match people, to build profiles, to contact tenants, or to improve Ayla or train AI.

Service providers (sub-processors) who help us run Ayla. These are carefully chosen companies that process data on our behalf, under contracts that require them to protect it and use it only on our instructions. They include providers for messaging (WhatsApp and Meta are how the service is delivered, so Meta necessarily processes your phone number and message content), AI processing, voice-to-text, identity verification (for the forming track, and for the women-only track if identity checks are switched on there), hosting, databases, and off-site backups, error monitoring, and our web portals.

The full, current list of these providers, what each one does, and where it is located, is published on our sub-processors page at ayla.lu/sub-processors, which we keep up to date. Please refer to that list for the current detail rather than relying on a snapshot here.

Authorities or advisers, where the law requires it, for example a regulator, a court, or our professional advisers, but only to the extent we are obliged or genuinely need to.

9. Where your data is processed (international transfers)

We have built Ayla to process personal data inside the European Union (or EEA). Our AI processing, voice-to-text, identity verification, hosting, databases, and backups are all configured to run in EU regions. The photos you upload, of you or of a home, are stored in the EU.

Some of our service providers are companies with parent groups based outside the EU, for example in the United States, even though they process your data in EU data centres. Where that is the case, we put appropriate legal safeguards in place, such as the European Commission's Standard Contractual Clauses (a standard, EU-approved contract that keeps your data protected to EU standards even when a provider is based outside the EU), so that your data keeps EU-level protection. You can ask us for a copy of these safeguards using the contact details in section 1.

You reach Ayla through WhatsApp, which is run by Meta. We process your data in the EU wherever we control it. WhatsApp messages travel through Meta's own global systems, which may be outside the EU, and Meta protects them with its own legal safeguards, such as Standard Contractual Clauses.

We keep your data in the EU wherever we can, and where a provider has a parent outside the EU we rely on these safeguards to protect it.

10. How long we keep your data

We keep your data only as long as we need it for the purposes in this policy, and then we delete or anonymise it.

In short:

  • We keep your profile and matching data while your profile is active. After you stop using Ayla or ask us to delete your data, we keep it for a short grace period of about 30 days and then delete it.
  • Your profile photo stays while your profile is active and is deleted with it. If you change it, or we remove it at your request, the old photo is deleted straight away (within a day if you change it again within an hour), and a photo you start to upload but never add to your profile is deleted within a day. If we remove a photo or profile text because it breaks our rules, we keep a copy with the safety record, as evidence, for as long as that record is kept.
  • We keep records we are legally required to keep, such as our accounting and tax records and our invoices, for 10 years, as Luxembourg commercial and tax law requires. Lease records a landlord or an agency keeps in the Ayla portal are kept for as long as that landlord or agency decides (section 18), not by us for our own purposes.
  • We keep the record of introduction decisions in a secure, tamper-evident log for 7 years, as part of being able to show our decisions were made properly.
  • We keep about the last 90 days of your WhatsApp conversation with Ayla, and older messages are deleted automatically on a rolling basis. We keep activity and event records for up to about 12 months, but the text of your messages is removed from them after 90 days.
  • We keep safety-incident records for 12 months from when we record the report, and longer only while a legal hold or an open case requires it (the 12 months then restart when the hold is lifted).
  • Some of your data may also stay in our secure backups for a limited period (currently up to about 35 days) after it is removed from the live service, until those backups roll over. We do not use backups to bring back data you have asked us to delete.
  • For the forming track (and the women-only track, if an identity check was used there), we keep the identity-verification result (and any eligibility result) until about 12 months after the relevant flatshare ends, then delete it. The photo and ID image are never kept by us. Your gender answer and track choice live with the rest of your profile and follow the profile's retention: kept while your profile is active, deleted with it.

We maintain a detailed, category-by-category retention schedule internally as part of our records. The summary above is the public version.

11. Your rights

Under the GDPR, you have the following rights over your personal data. We will respond within one month, and the first request is free.

  • Access: ask for a copy of the data we hold about you. We provide this on request within one month.
  • Rectification: ask us to correct anything that is wrong or out of date. You can usually do this just by telling Ayla in the conversation.
  • Erasure ("right to be forgotten"): ask us to delete your account, and we will action it within one month. We delete your profile, messages and matching data, and the photos you uploaded. Some records can stay. A safety report is kept if it is still being handled, is under legal hold, or also has an account reference to someone else. In those cases, we remove the report’s links to your account, but keep the report itself as written. It may still contain your name, number or other personal details included in the report. A closed report with no legal hold is deleted with your account if it has no account references to anyone else. Reports we keep follow the retention periods in section 10. If we blocked you for safety reasons, a hashed marker of your number stays so you cannot be reintroduced. Records we are legally required to keep, such as a property manager’s contract and our accounting records, are also retained. We keep a record that a deletion happened without your personal details. We never hold the image of your ID or your selfie in the first place.
  • Restriction: ask us to pause how we use your data in certain cases.
  • Portability: ask for the data you gave us in a portable, machine-readable format. We provide this on request within one month.
  • Objection: object to processing based on our legitimate interests.
  • Withdraw consent: where we rely on your consent (the AI layer, your profile photo, the women-only eligibility verification, the identity check, any future more-automated matching, and phone-number sharing), you can withdraw it at any time, as easily as you gave it. We record each consent with the version of the wording you agreed to and the date, so a grant or a withdrawal is always provable. Withdrawing consent does not affect anything we lawfully did before you withdrew it, and it may mean we can no longer offer part of the service. For the messages we send you about your search, replying STOP or simply telling Ayla you want no more messages is enough: we stop straight away, and you can ask Ayla to start again whenever you like.
  • Human review of decisions about your matches: as described in section 6.
  • Stop being messaged: you can pause or stop Ayla's proactive messages at any time, for example by asking Ayla to pause your search.

To exercise any of these rights, message Ayla on WhatsApp and ask, or contact us using the details in section 1.

12. How we protect your data

We take security seriously. Among other measures, we encrypt the most sensitive personal data, such as your name and phone number, at rest. We protect the women-only eligibility marker with strict access controls and keep it out of the AI, and we are working to add a further layer of encryption to it as we grow. We route processing through EU regions, we remove personal details from our logs and monitoring where we can, and we run regular security reviews of our code and systems. We keep the most sensitive records, such as the introduction-decision log and the identity-verification results, under stricter controls.

No system is perfectly secure, but we work to protect your data and to keep improving.

13. Data breaches

If a data breach happens that is likely to put your rights at risk, we will notify the Luxembourg supervisory authority (the CNPD) within 72 hours of becoming aware of it, as the law requires, and we will tell you directly if the breach is likely to result in a high risk to you. We keep an internal breach-response procedure so we can act quickly.

14. Children

Ayla is a service for adults. It is for people aged 18 and over. We ask for your date of birth at signup and do not let anyone under 18 use the service. If we learn that a user is under 18, we remove their data.

15. Changes to this policy

This is a living document. If we change how we handle your data, we will update this policy and, where the change is significant, we will tell you. The "last updated" date at the top always shows the current version.

16. Complaints

We hope you will come to us first if you have a concern, so we can put it right. You always have the right to lodge a complaint with the Luxembourg data-protection authority:

Commission nationale pour la protection des données (CNPD), Service des réclamations, 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg. Website: cnpd.public.lu

You can also complain to the data-protection authority in the EU country where you live or work, if that is not Luxembourg.

17. If you are a property manager using the Ayla portal

This section is for landlords, agencies and property managers who use the Ayla portal at manage.ayla.lu. For your account, we are the controller. For your tenants' details, you are the controller and we act for you under the Ayla Operator Terms and Data Processing Terms.

What we keep about you: your name; the email or Google account and the WhatsApp number you sign in with; the one-time sign-in codes we send; if you act for a company, its name, its register number and your role; whether you use the portal as a company or as a private landlord; your acceptance of our terms (date, time, version, the identity you signed in with and the network address you used); your choices for portal messages (on or off, and when); your messages to our support and to Ayla on WhatsApp; security records such as sign-ins; and, if we ever charge a fee, your billing details.

Why, and on what basis:

  • to run your account and the portal you signed up for: performance of a contract (Article 6(1)(b));
  • to keep invoices and accounting records once a fee exists: legal obligation (Article 6(1)(c));
  • to be able to prove what you accepted and that you could accept it for your company, and to keep the portal secure: our legitimate interest (Article 6(1)(f));
  • to send you service messages about your account and records: performance of a contract (Article 6(1)(b));
  • to send you one WhatsApp message 90 days before a fixed-term lease ends, asking if you want to list the room on Ayla, only if you turned this on in the portal: your consent (Article 6(1)(a)). You can turn it off at any time in the portal, and we keep the record of when you turned it on or off;
  • to tell you about new portal features: as you are our customer, we may email you about similar Ayla services, with a way to stop in every message.

Who sees it: the sub-processors listed at ayla.lu/sub-processors, and, once a fee exists, our accountant and our payment provider.

How long: your account details for as long as your account is open, then for the time needed to settle any claim; your acceptance record for 10 years after your account closes; the record of your choices for portal messages while your account exists; invoices and accounting records for 10 years; security records for up to 12 months.

Your rights are those in section 11, and you exercise them in the same way.

18. If your landlord or agency keeps your details in the Ayla portal

Some landlords and agencies use the Ayla portal to keep their rental records. If yours does, this section is for you.

Who is responsible. Your landlord or agency decides what is kept about you and why. They are the controller. Ayla stores and handles those details only on their instructions, under a data-processing contract. We are their processor. Their own privacy notice tells you what they keep and why.

What may be kept: your name and contact details, the details of your lease (dates, rent, charges, deposit), payments, and documents such as the lease, addenda and inventories. Your landlord or agency may send us these documents through the portal or, once Ayla offers it, on WhatsApp.

How AI is used. An AI may read the lease documents to suggest details for your landlord or agency to check, and an AI chat may help them find information in their own records. It runs in the EU, it never decides anything about you, and it may not train on your data.

What we never do with it. We do not use your details for our flatmate service, to build a profile of you, to contact you, or to improve Ayla or train AI. We do not sell them.

Who else handles it. Our sub-processors, listed at ayla.lu/sub-processors, all bound by the same rules. Lease documents sent on WhatsApp pass through Meta.

How long. As long as your landlord or agency decides, often several years after your lease ends because the law makes them keep some records. When they stop using Ayla, we return or delete their records.

Your rights. Ask your landlord or agency first: they are responsible for answering. If you write to us at privacy@ayla.lu, we pass your request to them and tell you we have done so. You can complain to the CNPD (section 16).

The household profile. We no longer use your landlord's records to contact you or to ask about your home, and have not since 13 October 2026. Your landlord or agency may instead give you an invitation to write to Ayla yourself: section 19 explains how it works.

19. If your landlord or agency invites you to tell us about your home

Some landlords and agencies who use the Ayla portal give the people living in their homes an invitation link or QR code. If you use one, this section is for you.

Who is responsible. For your answers, we are: we are the controller. This is separate from your landlord's records in section 18, and your answers are never added to them.

How it works. The link opens WhatsApp with a short message to Ayla that holds a code. Nothing happens unless you send it. Ayla then tells you who we are, that Ayla is an AI assistant, and what we do with your answers, and asks if you agree. If you say no, we ask nothing more and save no answers about your home.

What we keep: your phone number and WhatsApp name (as for anyone who writes to us, section 3), which home the invitation is for, your yes or no and when you gave it, and your answers to 4 questions with set choices: how lively your home is in the evening, how often you share meals or time, how common overnight guests are, and how tidy shared spaces are. We never ask about age, gender, origin, religion or health.

Why, and our legal basis. To suggest people who would fit in when a room in your home is listed on Ayla. We use your answers only for rooms in your home that your landlord or agency lists on Ayla. Our legal basis is your consent.

What your landlord or agency sees. Only how many people answered, and only once at least 3 have. Never who answered, who said no, or what anyone said.

Who else handles it. Our sub-processors, listed at ayla.lu/sub-processors. Your messages pass through Meta, because you write to us on WhatsApp.

How long. Until you ask us to delete your answers, your Ayla account is deleted, or your landlord or agency removes your home from the portal. We delete your answers 12 months after you finish answering, or 12 months after you started if you never finish. Changing an answer later does not change this date.

Your rights. You can change your mind at any time: tell Ayla on WhatsApp that you want your answers deleted, or write to privacy@ayla.lu. Withdrawing your consent does not affect what we did before. You also have the rights in section 11, and you can complain to the CNPD (section 16).

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