Ayla Operator Terms

Version: v1 · Last updated: 13 October 2026

These terms are the agreement between you and the company that runs Ayla when you use the Ayla portal at manage.ayla.lu to keep your rental records. Please read them before you accept. If anything is unclear, ask us first (section 15).

Three documents fit together:

These Operator Terms cover the portal: your account, your records, and the Ayla chat that helps you with them.
The Data Processing Terms (the annex at the end, also at ayla.lu/dpa) cover how Ayla handles your tenants' personal data for you. They are part of these terms.
Our Privacy Policy (ayla.lu/privacy) covers the data Ayla uses for its own purposes, such as your account. Our Terms of Service cover the separate flatmate-introduction service.

1. Who we are

Ayla is operated by Ayfinity Labs S.à r.l.-S, a société à responsabilité limitée simplifiée registered in Luxembourg.

Registered office: 13A, Avenue Guillaume, L-1651 Luxembourg
RCS Luxembourg: B309934
VAT number: LU37653060
Contact: hello@ayla.lu · Privacy: privacy@ayla.lu · WhatsApp: +352 404 002

"Ayla", "we" and "us" mean Ayfinity Labs S.à r.l.-S. "You" means the person or company that opens a portal account (the operator). An operator can be a company (an agency, a property manager, a property company) or a private person renting out a home they own (a private landlord).

2. The service

The portal lets you:

keep your properties, rooms, leases and lease documents, tenants, rent and deposits in one place;
send lease documents to Ayla by uploading them in the portal or, once Ayla offers it, by sending them to Ayla on WhatsApp at +352 404 002, so Ayla can file them in your account and fill in the lease details for you;
ask the Ayla chat questions about your leases and records; and
get reminders about your own records, such as a lease ending.

The Ayla chat and the lease reading are AI. An AI reads your lease documents and your questions and writes the answers. It can be wrong. Check anything important against the lease itself. Ayla does not give legal advice, and an answer from the chat is never advice about your situation.

Ayla is a tool for your records. Ayla is not your agent, does not act for you towards your tenants, does not collect rent and does not hold deposits.

3. How the contract is made

This section gives you the information Luxembourg law requires for contracts made online.

You sign in with Google or with a code sent to your WhatsApp number.
You tell us whether you are a company or a private landlord. A company gives its name, its RCS number (or equivalent) and your role.
Before you accept, we show you a summary of what you entered. You can go back and correct any mistake before you accept.
You tick the box to accept these terms, including the Data Processing Terms. The contract is made when you tick the box and continue.
We send you an email confirming your acceptance, with a copy of these terms (PDF) and the version you accepted.

These terms are in English. You can read and save them at any time on this page. We keep a record of your acceptance: the date and time, the version of the terms, your account, the identity you signed in with and the network address you used.

If you accept for a company, you confirm that you are authorised to bind that company to these terms.

4. Your account

You must be 18 or over.
The details you give us must be true and kept up to date.
Keep your sign-in secure and do not share it. If you let colleagues use the portal, you are responsible for what they do in it.
Tell us straight away at hello@ayla.lu if you think someone else has used your account.

5. Your tenants' data: your duties

When you keep tenants' details in the portal, you are the data controller for them and Ayla is your data processor. Ayla handles them only on your instructions, as set out in the Data Processing Terms. In particular, you agree that:

You have a lawful basis for every personal detail you put into the portal or send to Ayla on WhatsApp. For tenant records this is usually the lease itself and your legal duties as a landlord (GDPR Article 6(1)(b) and (c)).
You tell your tenants that you use Ayla to keep their details, for example with the tenant notice we provide (template at ayla.lu/tenant-notice). Ayla does not contact your tenants on your behalf to do this.
You add only what you need for managing the tenancy. Do not add health details, criminal records or similar sensitive data unless the tenancy truly needs it and you are allowed to keep it.
You handle your tenants' requests (to see, correct or delete their data). If a tenant contacts Ayla, we pass the request to you (Data Processing Terms, Part A).
You set how long records are kept. The choice is yours.
You keep your own register of processing activities and, where needed, your own impact assessment. We give you the information you need for both.

If you manage a property for its owner (for example as an agency), you confirm that your agreement with the owner allows you to use Ayla for it. Part A of the Data Processing Terms explains how this works.

6. What Ayla does not do with your records

Ayla uses your records and lease documents only to provide the portal to you. We do not use them:

to match people to rooms or to build profiles in our flatmate service;
to contact your tenants;
for our own analytics, product development, or to train any AI.

None of our AI providers may train on them either.

Listing a room on Ayla is a separate choice. If you choose to list a vacant room on Ayla's flatmate service, we use only the listing details you confirm for that room (such as rent, size, availability and photos), never your tenant records, payments, lease documents or chat history.

7. Acceptable use

You agree not to:

put in or send data you have no right to hold, or data about people unrelated to your rentals;
use the portal or the chat to break the law, including discrimination law and lease law;
upload malware, try to break into or overload the service, or read other operators' data;
copy, scrape, resell or reverse-engineer the service;
use the chat's answers to make a decision about a tenant or applicant on its own, without a person checking it.

8. Fees

The portal is free today. If we introduce a fee, we will:

tell you by email at least 30 days before it applies, with the price including all taxes and what it covers;
never charge you unless you accept the fee first, in a clear separate step.

If you do not accept, you can close your account and take your records with you (section 12) before the fee applies.

9. Private landlords: your consumer rights

If you rent out a home you own and use the portal as a private person, you are likely a consumer under Luxembourg law. In that case:

You can withdraw within 14 days of accepting these terms, without giving a reason and at no cost. Tell us clearly by email at hello@ayla.lu. When you withdraw, we return or delete your records as you choose (Data Processing Terms, Clause 10(d)).
While the portal is free, withdrawing simply means closing your account. Nothing is charged.
If a fee applies one day, the paid service will start during the 14 days only if you ask for it with a separate, unticked choice: "Start my paid plan now. I understand that if I withdraw within 14 days I pay for the days I used, and that I lose my right to withdraw once the service has been fully provided." If you then withdraw, you pay only for the days used and we refund the rest within 14 days.
Changes to these terms that affect you materially apply to you only once you accept them.
Nothing in these terms takes away any right you have as a consumer.

10. Changes to these terms

We may update these terms, for example when the service or the law changes. For a material change we tell you by email at least 30 days before it applies, and we show you what changed.

Companies: if you keep using the portal after that date, the new terms apply. If you do not agree, you can close your account before that date.
Private landlords: a material change applies to you only once you accept it.

Changes to our list of sub-processors follow the Data Processing Terms (30 days' direct notice and a right to object).

11. Liability

Nothing in these terms limits liability for death or personal injury caused by our fault, for fraud, for wilful misconduct or gross negligence, or for anything else that cannot lawfully be limited. Nothing limits a consumer's statutory rights, or the rights your tenants have against either of us under data-protection law.

Subject to that:

We provide the portal with reasonable care and skill (an obligation of means). We do not promise it will always be available or free of errors.
We are not responsible for decisions you take about your tenants or your properties, including decisions based on an answer from the Ayla chat.
You are responsible for the data you put in and for having the right to do so (section 5). If a claim arises because you did not, you cover our reasonable costs of it.
For companies only: each party's total liability to the other under these terms in any 12 months is limited to the greater of the fees you paid in those 12 months and EUR 1,000, and neither party is liable for loss of profit or other indirect loss.

12. Suspension and ending

You can close your account at any time by writing to hello@ayla.lu.
We can end the service for you with at least 60 days' notice by email, or straight away if you seriously breach these terms or the law requires it.
We can suspend your access straight away if your account is being misused, puts other people's data at risk, or breaks section 7. Where it is safe and lawful, we tell you why and how to fix it.
When the contract ends, you have 30 days to get a copy of your records. We then return them if you asked us to, delete them, and remove them from our backups when those roll over, within about 35 days. We confirm the deletion on request. We keep the records the law requires us to keep about you as our customer, such as invoices, and we keep the record of your acceptance for 10 years after your account closes, to prove the contract (see our Privacy Policy).

13. Confidentiality and security

We keep your records confidential, limit access to the people at Ayla who need it, and protect them as described in Annex III of the Data Processing Terms. If a security incident affects your records, we tell you without undue delay.

14. Governing law and disputes

These terms are governed by Luxembourg law. Please contact us first if something goes wrong.

Companies: the courts of Luxembourg-City have exclusive jurisdiction.
Private landlords: you can bring a claim before the courts of Luxembourg or of the country where you live where the law allows, and you keep the protection of the mandatory rules of that country. You can also use the Service national du Médiateur de la consommation, 6, rue du Palais de Justice, L-1841 Luxembourg, mediateurconsommation.lu.

15. Contact

Ayfinity Labs S.à r.l.-S, 13A, Avenue Guillaume, L-1651 Luxembourg. Email hello@ayla.lu, privacy questions privacy@ayla.lu, WhatsApp +352 404 002.

Annex: Data Processing Terms (below, and also at ayla.lu/dpa). They form part of these Operator Terms. If the two conflict on how Ayla handles your tenants' personal data, the Data Processing Terms win.

Ayla Data Processing Terms (annex to the Ayla Operator Terms)

Version: v1 · Last updated: 13 October 2026

These Data Processing Terms have two parts:

Part A sets out how the Clauses fit the Ayla portal. It sits outside the Clauses and never changes them.
Part B incorporates the Clauses themselves, unmodified, with Annexes I to IV filled in.

Part A. How these terms work

A1. Who is who. For the records you keep in the Ayla portal and the lease documents you send to Ayla, you (the operator) are the controller and Ayfinity Labs S.à r.l.-S ("Ayla") is your processor. Ayla's own purposes (your account, its flatmate service, its own WhatsApp conversations with seekers) are outside these terms and are covered by the Ayla Privacy Policy.

A2. When you act for an owner. You may manage a property on behalf of its owner. If, for a property, you process tenant data on the owner's instructions, then for that property:

the owner is the controller, you are its processor, and Ayla is your sub-processor;
you confirm that your agreement with the owner allows you to engage Ayla, and that you have passed on to the owner what it needs to know about Ayla and the sub-processors in Annex IV;
the Clauses apply between you and Ayla as written, with you in the controller's place towards Ayla, and you pass on to the owner any instruction, notice or information the Clauses give you, including the sub-processor notices under Clause 7.7(a);
Ayla accepts the same data-protection obligations towards you as the owner's contract places on you, as far as they concern Ayla's processing, in line with Article 28(4) GDPR; and
the owner may join these Clauses as a controller under the docking clause (Clause 5), by completing Annex I with you and Ayla.

A3. Requests from tenants. Under Clause 8(a), you authorise Ayla to acknowledge a request a tenant sends to Ayla and to tell the tenant that it has been passed to you. Ayla forwards the request to you within 3 working days. Ayla answers the substance of a request only on your written instruction.

A4. What Ayla never does with your data. Ayla does not use your records, lease documents, WhatsApp lease messages or chat history for matching, for profiles in its flatmate service, to contact your tenants, for its own analytics or product work, or to train AI. Doing so would make Ayla a controller (Article 28(10) GDPR) and breach Clause 7.2.

A5. Notices. Notices under the Clauses, including sub-processor changes (Clause 7.7(a)) and breach notices (Clause 9.2), go to the email address on your account. Publishing a change on the Ayla website alone is not notice.

A6. Order of documents. The Clauses prevail over Part A, the Operator Terms and any other agreement between us (Clause 4).

A7. Objecting to a new sub-processor. If you object to a change notified under Clause 7.7(a) and we cannot find a solution together, you can end the Operator Terms before the change applies, at no cost.

Part B. The Standard Contractual Clauses

B1. Incorporation. The parties agree to the standard contractual clauses between controllers and processors in the Annex to Commission Implementing Decision (EU) 2021/915 of 4 June 2021, official text: eur-lex.europa.eu/eli/dec_impl/2021/915/oj. They are incorporated here by reference, word for word, and the parties will not modify them (Clause 2(a)). Only the choices in B2 and the annexes below are added.

B2. Choices made in the Clauses. Decision (EU) 2021/915 has no "modules"; modules exist only in the separate clauses for international transfers, Decision (EU) 2021/914. The choices are:

Clause 1(a), and each clause offering "OPTION 1 / OPTION 2" (Clauses 8(c)(4), 9.1(b), 9.1(c), 9.2): OPTION 1, Regulation (EU) 2016/679 (GDPR). Option 2 is for EU institutions and is not used.
Clause 5, docking clause: included, so an owner (Part A2) or a group company of the operator can join.
Clause 7.7(a), sub-processors: OPTION 2, general written authorisation for the agreed list in Annex IV. Time period: at least 30 days in advance, notified directly to the controller (Part A5).
Clause 7.8(b), transfers by sub-processors: where a sub-processor transfers data outside the EEA, Ayla and that sub-processor use the transfer safeguards shown for it in Annex IV, such as the Decision (EU) 2021/914 clauses, Module 3 (processor to processor).
Signature (Annex I): electronic acceptance in the portal, recorded in Ayla's acceptance log.

Annex I. List of parties

Controller(s):

Name: [operator's legal or full name, filled from the account]. Address: [from the account]. Contact person's name, position and contact details: [the person who accepted, their role, email]. Signature and accession date: accepted electronically on [date and time], terms version [v1, version hash], acceptance log reference [id].
Where Part A2 applies and the owner joins under Clause 5: the owner's name, address and contact.

Processor(s):

Name: Ayfinity Labs S.à r.l.-S (trading as Ayla), RCS Luxembourg B309934. Address: 13A, Avenue Guillaume, L-1651 Luxembourg. Contact person's name, position and contact details: François de la Caffinière, gérant, privacy@ayla.lu. No data protection officer is designated (not required; Ayla's written assessment is on file). Signature and accession date: accepted electronically on the same date as the controller.

Annex II. Description of the processing

Scope. This annex covers three things only: (1) the portal records, (2) lease documents sent to Ayla by upload or on WhatsApp, and (3) the Ayla chat and lease reading over those records. It does not cover Ayla's flatmate matching, any tenant household profile, or messages Ayla sends on its own account. Messages to tenants on the operator's behalf are not part of the service today (see "Nature", point 6).

Categories of data subjects

Tenants and co-tenants
Guarantors
Household members named in a lease or inventory
Applicants, where the operator records them
Owners, where the operator manages for an owner
The operator's own staff or contacts named in documents
The private landlord, where the operator is a private person

Categories of personal data

Identity: name, date of birth where a lease states it, nationality or ID details where a lease states them
Contact: phone number, email, postal address
Tenancy: property, room, lease dates, rent, charges, notice dates, move-in and move-out dates
Payments: rent received, arrears, deposits (amount, how held, date received and returned)
Documents: leases, addenda, inventories, insurance certificates and other files the operator uploads or sends, including signatures and bank details they contain
WhatsApp lease messages: the operator's sending number, the time sent, the message text and the attached files
Chat: the operator's questions to the Ayla chat and the AI's answers

Sensitive data, and safeguards. Ayla does not ask for sensitive data. Lease documents can still contain it, for example a disability adaptation or a health reason for a lease ending. Safeguards: the data is used only for the purposes below; no AI provider may train on it; staff access is limited to support the operator asks for, and staff access as the operator is logged; it is never used in matching or profiling; it is deleted with the record.

Nature of the processing

Hosting, storing, organising and showing the operator's records in the portal.
Receiving lease documents uploaded in the portal or, once Ayla offers it, sent to Ayla's WhatsApp number +352 404 002, filing them in the operator's account, and keeping them.
Reading lease documents with AI to suggest lease details (names, dates, rent, deposit) for the operator to check and save.
Answering the operator's questions in the Ayla chat with AI, using the operator's records and lease documents.
Sending the operator reminders about their own records (in the portal, and on WhatsApp once Ayla offers it).
Not today: sending tenancy messages to tenants on the operator's behalf. This will be added only by a written instruction in this annex, limited to tenancy content, with the WhatsApp opt-in Meta requires.
Backup and restore; export to the operator; deletion; support at the operator's request.

Purposes. To provide the Ayla portal to the operator: keeping and organising the operator's rental records, reading lease documents for the operator, and answering the operator's questions about them. No other purpose (Part A4).

Duration. For as long as the Operator Terms run. Within that time, each record is kept for the period the operator sets. Chat history is kept while the operator's account exists, then deleted with it.

End of contract. At the operator's choice (Clause 10(d)), Ayla returns the records as an export and deletes them, or deletes them, within 30 days of the end. Copies in backups are gone within about 35 days after that. Ayla confirms the deletion in writing on request.

Processing by sub-processors (subject matter, nature and duration): see Annex IV.

Annex III. Technical and organisational measures

Encryption and pseudonymisation

All traffic uses TLS (HTTPS for the portal, TLS to the database, storage and AI providers).
Data at rest is encrypted by each provider (Neon, Cloudflare R2, AWS). The most sensitive fields, tenant names and phone numbers, are also encrypted by Ayla at application level.

Confidentiality, integrity, availability, resilience

Every record belongs to one operator account; every database query is scoped to that account, so one operator cannot see another's data.
The AI chat sees only the records of the account that asks; no context is shared across accounts.

Restoring access after an incident

Database backups with point-in-time restore; an encrypted copy of the database is kept for 26 days in AWS Frankfurt. Backups roll over within about 35 days.

Regular testing

Automated tests on each code change; regular security reviews of the code and the systems; an annual review of these measures.

User identification and authorisation

Operators sign in with Google or a one-time code sent on WhatsApp, with rate limits on code attempts.
Ayla staff reach operator data only through admin tools, only to support the operator or keep the service running. Every time a staff member acts as an operator, it is logged with who did it and why.

Protection during transmission and storage

Lease documents are stored in Cloudflare R2 buckets created in the EU jurisdiction. Data is held in the EU: Neon in Frankfurt (AWS eu-central-1), the portal on Vercel in Frankfurt (fra1).
AI runs in the EU only: Google Vertex AI in EU locations; AWS Bedrock, once used for lease reading, in eu-central-1 (Frankfurt).
WhatsApp: media retention at Meta set to "No Storage" (about 1 hour).

Physical security

Ayla has no servers of its own. Physical security is that of the sub-processors' data centres, covered by their certifications (ISO 27001 and SOC 2 reports, per each provider's DPA).

Events logging

Staff access as an operator, sign-ins and errors are logged. Error reports (Sentry) are scrubbed of personal details before they leave the portal.

System configuration

EU regions are pinned in configuration; Google Search grounding is off.

Governance and staff

Everyone at Ayla with access is bound to confidentiality in writing. Access is removed the day someone leaves.

Certification and assurance

Ayla holds no certification itself. It relies on its sub-processors' certifications and keeps each one's DPA on file.

Data minimisation and quality

Lease reading only suggests details; the operator checks and saves them. The portal asks only for the fields tenancy management needs.

Limited retention

Retention periods set by the operator; chat history deleted with the account (Annex II); WhatsApp media at Meta per the setting above; backups roll over within about 35 days.

Accountability

Acceptance log for these terms; register of processing kept per operator (Article 30(2) GDPR); sub-processor DPAs on file.

Portability and erasure

A copy of an operator's records, including the original files, on request; deletion on request or at the end of the contract, confirmed in writing.

Assistance to the controller (Clauses 8 and 9)

Tenant requests: forwarded to the operator within 3 working days (Part A3); the portal's editing tools, and a copy of the records on request, let the operator answer them.
Impact assessments: on request, Ayla gives the operator a short pack describing the system, data flows, AI settings and these measures.
Breaches: Ayla notifies the operator without undue delay, aiming for within 48 hours of becoming aware, with the content listed in Clause 9.2, by email, and keeps the operator updated as facts come in.

Annex IV. Sub-processors

This is the agreed list under Clause 7.7(a), Option 2. Annex IV is mandatory only under Option 1. Here it holds the agreed list that Option 2 refers to. Changes: at least 30 days' notice by email, with a right to object (Part A7).

1. Neon (Databricks, Inc., the parent company of Neon, LLC), 160 Spear Street, 15th Floor, San Francisco, CA 94105, USA

What it does for the portal: database for all portal records and chat history.
Where: AWS eu-central-1, Frankfurt.
Transfers outside the EEA: possible remote access from the US, under the standard contractual clauses in its DPA (Modules 2 and 3).

2. Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA

What it does for the portal: storage of lease documents and files (R2, EU jurisdiction); the admin worker that serves AI settings.
Where: EU.
Transfers outside the EEA: under the transfer terms of Cloudflare's DPA (standard contractual clauses).

3. Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA

What it does for the portal: runs the portal web app; data passes through it.
Where: Frankfurt (fra1).
Transfers outside the EEA: under the transfer terms of Vercel's DPA (standard contractual clauses).

4. Google Cloud EMEA Limited, Ireland

What it does for the portal: Vertex AI (Gemini), the Ayla chat and lease reading. No training on the data. Requests may be kept up to 90 days for abuse monitoring unless Google grants Ayla an exception.
Where: EU locations.
Transfers outside the EEA: Google LLC and other Google sub-processors, under Google's DPA.

5. Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg

What it does for the portal: the encrypted database copy (26 days). Bedrock (Anthropic Claude Haiku) for lease reading, from the date Ayla starts using it for that. No training on the data, not kept by AWS.
Where: eu-central-1, Frankfurt.
Transfers outside the EEA: none intended.

6. Meta Platforms Ireland Limited, Dublin, Ireland

What it does for the portal: WhatsApp Business Cloud API. Once Ayla offers it, it carries lease documents and messages the operator sends to Ayla, and reminders Ayla sends the operator. Media kept by Meta for about 1 hour ("No Storage"). Meta may act as an independent controller for the safety and integrity of its platform, as its own terms set out.
Where: messages pass through Meta's global systems.
Transfers outside the EEA: Meta Platforms, Inc. (US), under Meta's own transfer safeguards, including standard contractual clauses.

7. Functional Software, Inc. (Sentry), 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA

What it does for the portal: error monitoring for the portal; personal details are scrubbed before sending.
Where: EU (Frankfurt).
Transfers outside the EEA: under the transfer terms of Sentry's DPA (standard contractual clauses).