Privacy Statement — 101

Introduction

101 is committed to protecting your privacy and handling personal information with care, discretion, and respect.

This Privacy Statement explains how personal information is collected, used, and protected in connection with the personal and residential services provided by 101, in accordance with the EU General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 on Data Protection and Digital Rights (LOPDGDD).

By engaging with 101 or communicating with us, you acknowledge and agree to the practices described in this Privacy Statement.

Data controller

For the purposes of applicable data protection laws, 101 acts as the data controller in relation to personal data processed in the course of providing services.

Contact details for privacy-related matters are provided at the end of this statement.

Personal data collected

In the course of providing personal and residential services, the following categories of personal data may be collected:

Name, contact details, and preferred communication channels
Information relevant to personal assistance, arrangements, or residence oversight
Details relating to preferences, routines, or standards shared during the relationship
Information relating to third parties (such as family members, guests, staff, or advisors) where you choose to provide it

Where information about third parties is shared, it is assumed that you have the appropriate authority or consent to do so.

Purpose and legal basis for processing

Personal data is processed only where necessary and in accordance with applicable law.

Processing is carried out for the following purposes and legal bases:

Provision of services (Article 6(1)(b) GDPR – performance of a contract or pre-contractual measures)
Coordination of arrangements, bookings, and logistics (contractual necessity / legitimate interest)
Communication regarding ongoing matters (legitimate interest)
Residential oversight and continuity (contractual necessity)
Compliance with legal or regulatory obligations (Article 6(1)(c) GDPR)

Personal data is never used for advertising lists, mass marketing, or unrelated commercial purposes.

Sharing of data with third parties

Where necessary to carry out agreed arrangements, personal data may be shared with trusted third parties, such as:

Household staff or service providers
Contractors, venues, or suppliers
Advisors or representatives acting on your behalf

Third parties act as independent data controllers or processors, as applicable, and are responsible for their own compliance with data protection laws. 101 takes reasonable care in selecting contacts but is not responsible for the privacy practices of third parties.

International data transfers

Where arrangements require coordination outside Spain or the European Union, personal data may be transferred internationally.

In such cases, appropriate safeguards are applied in accordance with GDPR, including standard contractual clauses or equivalent legal mechanisms.

Data security

Appropriate technical and organisational measures are implemented to protect personal data against unauthorised access, loss, alteration, or misuse.

Access to personal information is limited to what is strictly necessary for the provision of services.

Data retention

Personal data is retained only for as long as necessary to:

Support the ongoing relationship
Comply with legal, fiscal, or regulatory obligations
Address administrative or operational requirements

Data is securely deleted or anonymised once it is no longer required.

Your rights

Under GDPR and Spanish data protection law, you may have the right to:

Access your personal data
Request rectification of inaccurate or incomplete data
Request erasure where appropriate
Request restriction of processing
Object to certain processing activities
Request data portability
Withdraw consent where processing is based on consent

You also have the right to lodge a complaint with the Agencia Española de Protección de Datos (AEPD).

Confidentiality

Confidentiality is fundamental to the work of 101.

Personal information, arrangements, and identities are not disclosed except where necessary to carry out agreed services or where legally required.

Changes to this Privacy Statement

This Privacy Statement may be updated to reflect legal or operational changes. Material updates will be communicated where appropriate.

Contact

For any questions regarding this Privacy Statement or the handling of personal data, please contact:

101
Privacy enquiries
ask@le-101.com
Ibiza, Spain