The short answer
You recognise repeat guests who book through portals by surname with postcode, phone number and earlier stays, not by email address, which is often only forwarded. You merge two profiles only on a clear match. As a rule, you may send a recognised guest marketing by email only with prior consent.
Key takeaways
- Portal guests often arrive with a forwarded email address. On their next visit via another channel, a second profile is created.
- You recognise a repeat guest by surname with postcode, phone number and earlier stays. Merge automatically only on a clear match.
- Recognition needs only a few fields that are already collected to handle the stay.
- Recognising a guest does not mean you may write to them: marketing email in Austria and Germany generally requires prior consent, with a narrow exception for your own customers.
- Guests who book directly leave a real address and can be reliably matched next time.
You recognise repeat guests who book through portals not by their email address, but by surname with postcode, phone number and earlier stays. You merge two profiles only on a clear match, so you may not yet send marketing to a recognised guest.
The booking data usually comes from the connected channel manager or PMS. Which fields a booking carries with it is described, for example, in the Smoobu documentation [Q1]. This article covers the matching and what is permitted afterwards.
Why portal guests end up twice in the system
Guests who book through portals often appear with a forwarded email address that no longer delivers after the stay. If the same guest then books directly or through another portal, the system creates a second profile. After a few seasons, a loyal guest has three entries, and none of them shows that they are coming for the third time.
How to recognise a repeat guest
| Feature | Strength of signal | Handling |
|---|---|---|
| Surname and postcode | high, if both match | merge after a brief check |
| Phone number | high | merge |
| Surname alone | low | put on the review list |
| Forwarded email address | none, applies to one booking only | do not use for matching |
| Earlier stays and rooms | supports the other features | use as confirmation |
Merge automatically only on a clear match. Everything else goes on a review list that someone works through once a week. At reception, it helps to ask whether the guest has been there before, and to note the answer where it will be looked up next time.
A reliable route is the direct one. Guests who book via your own website with direct booking leave a real address and a phone number.
Which fields are enough for recognition
Name, email, phone, postcode, language, stays with date and room category, a notes field for requests, and the consent status for marketing with a date. These details are collected anyway to handle the stay. The GDPR allows processing to the extent it is necessary for the performance of a contract, Article 6(1)(b), and requires that data be kept to what is necessary, Article 5(1)(c) [Q2].
Notes are data like any other: under Article 15 GDPR, guests can request information about what is stored about them [Q2]. Therefore write only what you would read out to the guest. Registration data and tourist tax follow their own rules. What the EU regulation on short-term rentals changes here is explained in the article on the short-term rental regulation.
What this looks like for a 24-room hotel
| Example calculation (per assumptions) | Value |
|---|---|
| Occupied nights, 24 rooms at 60 percent occupancy | 5,256 |
| Stays at 2.5 nights per stay | around 2,100 |
| Repeat guests, assumed 15 percent | around 315 per year |
| Profiles after five years without merging | over 10,000 |
The roughly 315 repeat guests a year are the group that matters. You will find them in this volume only if matching happens at check-in, and not in a clean-up once a year.
What this looks like for four holiday flats
Four flats with 180 occupied nights each give 720 nights. At an assumed five nights per stay, that makes 144 bookings a year. If an assumed 20 percent of guests return, that is around 29 repeat guests. The number is manageable, and the channel manager's guest list is enough for it. The difficulty lies with portal addresses: without a phone number or a direct booking, the returning guest remains unrecognised.
What you may do with a recognised repeat guest
In Austria, sending electronic mail for direct marketing without the recipient's prior consent is not permitted under Section 174 para. 3 of the Telecommunications Act 2021 (TKG 2021) [Q3]. Para. 4 names an exception for your own customers, whose conditions must all be met, including the option to refuse use of the address at the time it is collected [Q3]. In Germany, advertising by email without prior express consent counts as an unreasonable nuisance under Section 7 para. 2 no. 2 of the Act Against Unfair Competition (UWG); Section 7 para. 3 UWG contains a comparable exception [Q4]. Check the exact requirements in the statutory text (as of October 2026).
If outreach rests on consent, you must be able to prove it, under Article 7(1) GDPR [Q2]: when consent was given, through which form, with which wording. The guest can object to direct marketing at any time, under Article 21(2) GDPR [Q2]. An unsubscribe link belongs in every mailing.
Whether an address forwarded by a portal falls under the exception for own customers depends on the individual case. This section is general information and does not replace legal review. Have the form wording and the process reviewed by a specialist once.
How the implementation works with HOHEIT
HOHEIT sets up guest data as part of the direct-booking website: for hosts in four to six weeks, for hotels in eight to fourteen weeks from approval of the concept. In the first consultation, HOHEIT checks against the interface documentation whether your channel manager or PMS can be connected, for example Smoobu, Lodgify, Beds24, Hostaway, Apaleo or Mews. The application runs on servers in Frankfurt. Domain, content and guest data remain your property. If the AI concierge also replies, it identifies itself as an AI before every conversation, as Article 50 of the EU AI Act requires from 2 August 2026 [Q5].
When a separate repeat-guest process is not worth it
With few units and few repeat guests, the channel manager's guest list is enough, supplemented by a notes field. If you rent almost exclusively through one portal and receive no phone numbers, you can hardly match repeat guests. Only your own direct booking helps there. A second system alongside the booking system is worthwhile only once you want to link stays over years and manage consents. Before that, it is one more place where data goes stale.
Next, take your last twenty bookings and check how many of them you can assign to a known person. Then read how HOHEIT sets up guest data and repeat guests. For a conversation about your property, you can book a call.
Sources and further reading
- [Q1] Smoobu API documentation
- [Q2] Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR), EUR-Lex
- [Q3] RIS: Telekommunikationsgesetz 2021 (Austrian Telecommunications Act 2021), § 174 (version valid from 1 November 2021)
- [Q4] Gesetze im Internet: § 7 UWG (Act Against Unfair Competition)
- [Q5] Regulation (EU) 2024/1689 (EU AI Act, KI-Verordnung), Publications Office of the EU
Häufige Fragen
What do we do if two different guests have the same surname and the same postcode?
This happens in families and small villages. In that case, do not merge. Put both profiles on the review list and decide based on first name, phone number or year of birth from the registration form. A wrongly merged profile is harder to separate than two entries that later turn out to belong together.
What happens to the data if we change system?
Before the switch, clarify in which format a complete export is possible and whether it includes stays, notes and consents. An export that delivers only names and addresses wipes out years of upkeep. Also agree when the previous provider deletes the data after the contract ends.
Can we send guests a review request after the stay?
It depends on the route. If the booking came through a portal, that portal's rules on communication apply. For direct bookings, it depends on the legal basis for the message. A factual request without advertising is assessed differently from an offer in the same text. Have the process checked once.
Talk to us
Direct booking, without the commission
We build the booking site, connect it to your channel manager and keep it running.
Book a first call