Privacy Policy

Last updated: 9 July 2026

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-matching service operated by Ayfinity Labs SARL-S, a company established in Luxembourg.

Company: Ayfinity Labs SARL-S
Registered office: 13A, Avenue Guillaume, L-1651 Luxembourg
Company registration: RCS Luxembourg (registration in progress; the number will be added here as soon as it is issued)
Privacy contact: privacy@ayla.lu, or message us on WhatsApp at +352 404 002
Website: ayla.lu
WhatsApp: +352 404 002

Ayfinity Labs SARL-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.

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 single-sex 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).
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.
An eligibility result for single-sex spaces. If you choose the women-only track, we verify your eligibility through our identity-verification partner, which reads the sex marker on your government ID. We store only the eligibility result plus the partner's name, a reference number, and the date. We do not store the image of your ID, and we keep this result out of the AI that reads your messages. This check happens only at the point it is needed, when you are about to be matched into a women-only home, not at signup. Edge cases are looked at by a person, in good faith, and we never ask for medical or transition proof. This is collected only from people looking for or offering a home in the women-only track, never from property managers, and never from people on the mixed track. (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.
The details of your home and listing: the address or area, the rent, room details, availability, and any photos you upload.
For a managed home, a short personality profile of the people already living there, which they share with us so we can find flatmates who fit. This is about how the household lives, not about who is allowed to live there.

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.

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 use any non-essential cookies (for example analytics), they will only run after you agree through a cookie banner, and we will list them in our cookie information.

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, and for the women-only track at the point you are about to be matched into a women-only home, the identity-verification result (and, for the women-only track, the eligibility result read from your ID's sex marker) comes from our verification partner after you complete the check with them.

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.

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 matching service you signed up for: building your profile, 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).
Single-sex-space eligibility verification (reading the sex marker on your government ID for the women-only track). Legal basis: your explicit consent (Article 9(2)(a)), because the sex 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 for the forming-flatshare track and the women-only track). 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.

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.

How matching works. When Ayla suggests people or homes, the suggestions are produced mostly by ordinary, fixed software 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 single-sex-space 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 is shown to you, or you are introduced into one, depends on your single-sex-space eligibility result. This is a deliberate, both-ways rule: people are not introduced into women-only homes unless their eligibility is verified. This is part of how the women-only track keeps its promise.

A person approves introductions, and you can always ask for one. At launch, no introduction or placement is made automatically. Every suggested match and introduction is reviewed and approved by a person at Ayla before anything is sent to you. 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 approves introductions, the strict rules on solely-automated decisions do not currently apply to them. 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-assisted assistant on WhatsApp, and AI helps shape your match suggestions, as described above. There is a fuller, friendlier explanation on our AI at Ayla page.

7. Sensitive data, handled with extra care

Two kinds of data we handle count as "special category" (sensitive) data under the GDPR, which means they get stronger protection:

The single-sex-space eligibility result. We treat this as sensitive because it relates to your sex and to a single-sex living choice. For the women-only track, our verification partner reads the sex marker on your government ID to confirm eligibility. We store only the eligibility result, not the ID image, and we keep it out of the AI that reads your messages. We check it only at the point it is needed, when you are about to be matched into a women-only home, and we use it only to make the women-only track work. Edge cases are reviewed by a person in good faith, and we never ask for medical or transition proof. We rely on your explicit consent for this.
The identity-verification result in the forming-flatshare track and the women-only track. 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 single-sex spaces safer. It is an identity check, not a background, criminal, or financial check, and it is not a vouch for anyone's behaviour.

You can withdraw your consent for either of these at any time (see section 11). Withdrawing the single-sex-space consent may mean we can no longer offer you the women-only track.

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. When you and another person are introduced, Ayla shares the relevant parts of your profile with each other so the introduction can happen, for example your first name and what you are looking for. We ask for your consent before sharing your phone number with a match.

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 the women-only check), hosting, databases, and off-platform 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.

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 account 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.
We keep records we are legally required to keep, such as accounting, tax and lease records, for 10 years, as Luxembourg commercial and tax law requires.
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 activity and event records for up to about 12 months, and we keep conversation transcripts while your account is active, removing them after a period of inactivity.
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, we keep the identity-verification result (and, for the women-only track, the eligibility result) until about 12 months after the relevant flatshare ends, then delete it. The photo and ID image are never kept by us.

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 data, and we will action it within one month. Some records we are legally required to keep (such as a property manager's contract and our accounting records) are retained, and we keep a record that a deletion happened without your personal details. When you ask us to delete your data, we also remove the photos you uploaded. 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, the single-sex-space eligibility verification, the identity check, the proactive messages we send about your search, 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.
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 single-sex-space 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.