Effective Date: May 24th, 2018
IMPORTANT RESORT doo, headquartered in Dubrovnik, Kardinala Stepinca 31, VAT: 41984487913, (hereinafter “the Company”), the email of the Data Protection Officer: email@example.com, extremely appreciates and understands the importance of protecting the confidentiality and privacy of personal information just collected or otherwise entrusted to us.
Personal data is considered to be any data relating to an individual whose identity has been identified or can be identified. Data on legal entities are not considered personal data and this Statement does not apply to them.
This way, we would like to inform you of how we process personal information that we collect directly from you or third parties, regardless of whether we collect them through our website or other channels. Certain parts of this Statement may be supplemented by notices provided on other parts of our website or in other ways, where appropriate.
This Declaration is subject to change, and the date of last change is indicated in the title of the statement. We will notify you of any changes to this Statement that will affect you through a suitable channel, depending on how we otherwise communicate with you. In any case, we invite you to follow our Statement changes on our website.
For better visibility, this Statement is divided into certain areas. If you have any questions, you can contact our privacy officer by sending an email to firstname.lastname@example.org or mail at the address stated at the beginning of the Statement.
1. Legal basis for processing your personal information – in general2. From which sources do we collect your personal information?3. Protect the security and integrity of your personal information4. Links to other websites5. How long do we keep your personal information?6. Sharing and transferring your personal information7. More detailed information for individual categories7.1. Guests and other users of our services7.1.1. Purposes and legal basis for processing7.1.2. What kind of personal information we collect7.1.3. Sharing data with Booking.com7.2. Business partners and employees of business partners7.3. Receivers of the newsletter7.4. Applications for work in IMPORTANT RESORT7.5. Video surveillance7.6. Collecting data through our web site8. Your rights and how to achieve them
- Legal basis for processing your data – in general
The law of the Republic of Croatia allows us to process personal data only if we have the purpose and legal basis for this, and we are required to inform you on which legal basis we rely. When we process your personal information, we rely on the following legal bases:
- the conclusion and execution of the contract: on this basis, it is based on the processing of the information we need to conclude the contract and make a contractual commitment to you, such as providing accommodation services, transportation and other services we have in our offer;
- legal obligation: this basis is applicable in cases where our law requires processing of certain data, such as a special law that prescribes which information we are obliged to collect about the guests we provide accommodation services, a law requiring us to keep the received and issued accounts, stipulates the obligation to use video surveillance at exchange offices;
- privola: In certain cases, we will ask for your explicit permission to process data for a particular purpose, and we will process your personal information only if you have agreed to it. You can withdraw one day’s privation at any time. For example, we will ask your privacy to send you our newsletter about special offers and events;
- protection of your key interests: Your personal information may be handled in emergencies when it is necessary for the protection of your life or health;
- legitimate interest: Your personal information will be processed in case of legitimate interest for the purposes of our lawful business, provided that your interests, rights and freedoms are not prevailed. Examples of our legitimate interest in our business are the following:
- providing information to individuals who visit our website and contact us through online contact forms,
- answering inquiries from potential guests, business partners, journalists and other persons,
- collecting data on users of our services with which we are not in direct contractual relationship to ensure the provision of appropriate services upon their arrival (eg, guests arriving via tourist agencies, congress organization etc)
- providing information on employment opportunities,
- Prevention of fraud and criminal acts and the protection of the security of our information system, confidential information, employee and property security,
- fulfilling our responsibilities towards society as a whole and corporate responsibility,
- monitoring the quality of services rendered and improving our business in accordance with the modern standards of the hotel industry,
- conducting marketing activities (eg photographing events in our area, prize games, promotional offers),
- conducting research and analysis activities with the aim of improving user experience, improving the functionality and quality of our online travel booking services,
- solving disputes or complaints, regulatory investigations and acting upon requests of competent authorities, obtaining legal claims or defending against other requests
Through collecting your information, we will notify you if the provision of personal data is a legal or contractual obligation or a condition necessary for the conclusion of a contract and you have the obligation to provide personal information and the consequences if you do not provide such information.
- From which sources do we collect your personal information?
Your personal information may be collected from the following sources:
- directly from you (via contact forms on the web, forms on paper, e-mail correspondence, telephone conversations, personally through conversation with you),
- other people (eg tourist agencies and event organizers who provide us with your information regarding your stay with us, the online platforms where you have booked the services, from people traveling with you, from people employed or otherwise engaged by Your employer with whom we have a service contract). In such cases, we trust that the persons who provide us with your personal information or give you instructions for their processing and are authorized and provided you with all the necessary information, that is, your approval if it is also necessary to provide you with us, from publicly available sources (eg court register, business entities’ websites and other publicly available information),
- through the video surveillance system installed in our premises.
In case you give us personal information of other persons, it is your responsibility to ensure that the person whose information you have provided has informed us and informed us of the way we use your personal information. In the event that we do not collect your information directly from you, but from any of the above mentioned persons, we may only be responsible for what we are undertaking with personal information from the moment we collect them. We are not responsible for and can not be held responsible for the activities that your personal information is being taken by the people we received your information, so please read the privacy policies of other people you provide personal information.
- Protect the security and integrity of your personal information
IMPORTANT RESORT applies reasonable policies and procedures for the protection of personal data against unauthorized access, misuse, alteration or destruction. Despite our best efforts, we can not guarantee the absolute protection of your data. In our best power, access to your information is limited to those who need to know them. Persons who have access to personal data are required to assume confidentiality.
When we engage third parties to process your personal data (processor) on our behalf and our instructions, we contract with such partners our partners undertake strict standards of data protection.
- Links to other websites
- How long do we keep your personal information?
We will make reasonable efforts to keep your personal information for as long as necessary to achieve the purpose for which your data was collected. The length of the storage period depends on the particular circumstances and reasons for which we have collected data.
For example, when our law implies a certain maximum data retention period, we apply the statutory deadline for retention. When the law prescribes a minimum deadline for data storage or does not prescribe any time limit, we will keep the data as much as necessary to ensure the efficient operation and protection of our interests. When there is a possibility that you will have a specific request to us or to you, we will keep this information at least until the expiration of legal obsolescence. If a court or similar procedure is in progress, we can keep the data as long as we need it for the purpose of conducting this process.
At the expiration of the deadlines for storing personal information printed on paper, we will destroy it in a safe manner, such as cutting or burning, while we will permanently delete or anonymize the data electronically. By anonymizing, the data lose the status of personal data and do not fall within the scope of this Statement.
If you request erasing of your data before the expiration of the deadlines, we will consider your request and satisfy you if we find that there are no data erasing barriers.
- Sharing and transferring your personal information
We will share your personal information with third parties in cases where we are legally obliged to do so; if there is a legitimate professional and business need for that; in order to comply with your request; to the extent necessary to realize the contractual rights and obligations and to protect our interests. This includes
Our service providers and business partners: We may share your personal information with our third-party service providers, such as those who maintain our IT applications, provide hosting services, provide newsletter service, business document archiving services; tourist agencies and congress organizers from which we get information about your arrival; carriers if you have requested a transport service; our legal, tax and other advisers, auditors, court interpreters and translators; providers of postal and delivery services; marketing agencies;
- other recipients who disclose personal information on your request: We may also share your personal information with other third parties that you need to disclose because you have so required to provide you with a particular service or to act upon your request (eg organization of transport and excursions , rental of cars and other equipment);
- courts and other state bodies: We may disclose your personal information on the request of the courts, the Personal Data Protection Agency, other state bodies upon which we are required to act, as well as when personal data is required or desirable to enable IMPORTANT RESORT to comply with the law , court order or protected his reputation and business;
- companies belonging to the same group of enterpreneurs: IMPORTANNE RESORT d.o.o. is part of the IMPORTANT Group and may share your personal information with other companies belonging to the group when it is necessary to perform common administrative functions;
- audits and internal investigations: disclosure of personal data may be necessary in the case of audits in the area of personal data protection and security and / or investigation or response to a complaint or threat of security;
- Insurers: We may disclose your information when contracting and administering insurance, as well as when it is necessary for our insurance companies, brokers, reinsurers and their professional advisors to fulfill their legal obligations and obligations to regulators;
- Reorganization of our business: We may disclose your personal information regarding the sale or transfer of part of our business to another person related to the part of the business that is the subject of sale or transfer.
We will take care that third parties do not disclose your information to a greater extent than is appropriate to circumstances. IMPORTANNE RESORT to none of the above mentioned recipients will make your personal information available to them for marketing purposes for their own purposes.
In the above cases, there may be a need to disclose your personal information to a recipient in a third country that does not provide an adequate level of protection. In order to ensure that in such cases your personal information is adequately protected, we will apply one of the safeguards prescribed in Chapter V. of the General Data Protection Act. If no derogation from special cases referred to in Article 49. of the General Data Protection Regulation can be applied, we will agree with the recipient of the data in the third country the standard contractual clauses in the text that has been adopted and approved by the European Commission
7. More detailed information for some categories7.1. Guests and other users of our services7.1.1. Purposes and legal basis for processing
We process personal information of guests and other users of our services when it is necessary to comply with our legal obligation, make or contract with you, act on your behalf or in accordance with our legitimate interest, for the following purposes:
– communication with you and customer support: When you contact us with a query, complaint to our service or praise, we will process your information so we can contact you back and act on your request. For example, if you do not complete your online reservation, we’ll send you a reminder to continue booking by email. We believe that this additional service is helpful as it allows you to proceed with your reservation without having to search for again or enter your reservation information,
- reservation of accommodation and other hotel facilities and conclusion of contracts: if you are interested in our accommodation or other services we offer, we will collect your information so that we can manage our capacity and arrange the services you have requested in a timely and orderly manner (eg accommodation, use of currency exchange services, congress organization, conferences, weddings, banquets and other services);
- respecting of contractual obligations and collection of services provided: to the extent necessary, personal data will be processed for the purpose of fulfilling its contractual obligation, providing the expected hospitality level and exercising its right to charge the provided service, irrespective of whether we are directly involved in the contract with you or with a tourist agency or organizer of events in our facility that is in a contractual relationship with you,
- check in and check out guest accommodation: if you are using accommodation services in our hotels, we are legally obliged to collect certain personal information for registration of your stay and registration in the central Croatian guest system,
- monitoring and improving the quality of services: we can ask you for feedback about your satisfaction with the services provided. We can use your contact information to send an invitation to post reviews to you via e-mail after your stay. This way you can help other travelers when choosing the right accommodation, but also for us to improve our services. If you submit a review, it may be published on our web site;
- To achive the legal requirements we have against you or the defense of your claim: We may use your personal information to exercise our rights to you, initiate procedures for, among other things, the payment of our fee, or to defend your claims arising out of or relating to By reserving or staying with us,
- protection of your security and property through video surveillance: part of our hotel and area around the hotel is under video surveillance, with visible notices visible. During your stay in our area, therefore, you may be affected by video surveillance. More about video surveillance can be found here.
7.1.2. What kind of personal information we collect
We collect only those personal information that are necessary for us to accomplish these purposes. Depending on the circumstances, this may include the following: first and last name, address, postal code and city, country, e-mail, telephone number or cell phone number; place, country and date of birth; citizenship; the number of visas if you are subject to the visa regime; the place of entry into the Republic of Croatia; credit card information (card type, card number, card name, expiration date and code), arrival and departure time (including unit preferences, content, or any other service used), people you travel with, special requirements information about the service you are using, identification information, airline information and the vehicle that you come to our hotel, impressions of our services, information on whether you come to a promotional action or a prize game, information about events that organize in our area and the names of participants in such events.
In addition to the above mentioned information about you, we may also request this information for people traveling with you.
Health data, religious or philosophical beliefs and other special categories of personal data will only be collected if you volunteer for us to better serve or meet your special requirements and needs (eg avoid serving food to which you are allergic, providing access to handicapped persons and the like). We will not actively seek out such a kind of information from you personally.
With regard to the credit card information we collect, we delete the same on the billing of our services. Regarding the deadlines for keeping other data, recipients, your rights and other details, please see the appropriate point of this Statement.
7.1.3. Sharing data with Booking.com
In addition to the information provided in section 6. Sharing and transferring your data, we would like to inform you of the way we share the information with Booking.com. We partner with Booking.com B.V. headquartered at Herengracht 597, 1017 CE Amsterdam, Netherlands (www.booking.com) (hereafter “Booking.com”) to provide you with online reservation service. While we are responsible for the content on this site and are directly booked through our site, the booking process is done through Booking.com. The information you enter on this page will also be available to Booking.com and its partners. This may include personal information such as your name, contact information, payment details, guest names traveling with you, and any other information you provided when booking.
Your personal information may be shared with the BookingSuite B.V. headquartered at Herengracht 597, 1017 CE Amsterdam, Netherlands, the company managing this website and the website of suite.booking.com
7.2. Business partners and employees of business partners
For the purpose of communicating with our business partners and suppliers, for which we have a legitimate interest, we collect contact details of business partners of physical persons, contact details of persons authorized to represent legal persons and contact details of their employees we are in contact with during business relationship. We do not collect any personal data from our business partners, but only official contact information (name, family name, work place, official telephone or mobile phone, email address) which business partners regularly make available to other entities as part of their regular business. When we are in a contractual relationship with a business partner who is a physical person, in addition to the above mentioned information we can collect other data necessary for the performance of contractual and legal obligations (eg billing, payment and reporting on public affairs related to work contracts and copyright contracts and for the realization and defense of legal requirements that may arise in connection with a contractual relationship.
7.3. Receivers of the newsletter
IMPORTANT RESORT may occasionally send you a newsletter to inform you about special offers and events. We will send you a newsletter only if you have given us the privilege. Attempting is voluntary, and you can withdraw your privy one day at any time. You can retrieve Privileges by clicking on the marked area in the newsletter.
To receive a newsletter, you can sign up for our website or by signing up at the hotel. In order to receive our newsletter, we need your name, last name and email address.
Sending a newsletter to our name is done by our processing agent, Rocket Science Group LLC, based in the United States via its Mailchimp service. The protection of your data is ensured by entering into the standard contract clauses in the text approved by the European Commission. Furthermore, Rocket Science Group LLC has obtained a certificate in accordance with EU-US Privacy Shieldu and is therefore deemed to provide an adequate level of protection of personal data.
More information on how the Rocket Science Group LLC handles your data can be found at the following link https://mailchimp.com/legal/privacy/#1._The_Basics
7.4. Applications for work in IMPORTANT RESORT
If you are interested in working in IMPORTANNE RESORT, you can sign up at email@example.com IMPORTANNE RESORT handles personal data of the candidate for the job, whether the candidates voluntarily report to the published job advertisement for the given job or to send an open application. The personal data of the candidate will be processed for the purposes of selecting the candidate for employment (review of received applications, contacting the candidate for the purpose of calling for a test and interview). The submitted data will also be processed for statistical purposes and for purposes of defense of your requests. In the event that we call you for testing and / or conversation, we will state this circumstance in your record as well as the result of the test and / or conversation. The legal basis for processing your personal data for employment purposes is your privation (Article 6 (1) (c) of the General Data Protection Regulation). You can give us your privilege to process your data only for the purposes of the specific selection process, but also for the purposes of future employment. If you are applying for a specific job placement, and you have not indicated that you want to process your information for future employment, then we will not contact you if there is a need to work in the future at a given place of work. For future employment purposes, we will contact you only if you have sent us an open application or you have been given an offer to respond to a particular contest.
The legal basis for processing data for statistical purposes, the defense of your requests, as well as the fact that we have tested and / or conversed with you is our legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation) . Our legitimate interest is to increase the efficiency of the selection process. Please provide only the information relevant to your application and selection of candidates (name and surname, date of birth, residence and contact information, completed education and work experience) in the documents you submit as attachments, and to protect your privacy by avoiding the delivery of surplus data. If you choose to provide any additional information, such as your photo or information about your interests and hobbies, we will consider that you provided us with such information for processing for employment purposes. Your personal information will not be provided outside Croatia. In case you submit the application on behalf of another person, it is your responsibility to ensure that the person in whose name you work is familiar with the provisions of this Statement of Privacy and that you have consented to processing your information. The personal information we collect based on your privacy will be retained until you withdraw the day’s privation or until the need for their retention otherwise ends, whichever comes first. The data we collected based on our legitimate interest (the circumstance you were invited to test and / or talk and about their results) will be kept for five years.
7.5. Video surveillance
IMPORTANNE RESORT in its facilities and on the areas it manages uses video surveillance for the following purposes:
- control of entries and exits from workrooms and premises and to reduce the exposure of workers to the risk of breakdown, burglary, violence, theft and similar events at work or in connection with work,
- to protect the safety of guests and other persons who, for any reason, find themselves in the area under our control and protect their property,
- protection of property IMPORTANNE RESORTS,
- preventing unauthorized entry into space IMPORTANNE RESORTS,
- Reducing the risk and increasing the protection of individuals with regard to performing currency exchange transactions.
The legal basis for the application of video surveillance for the purposes described above is our legitimate interest, while regarding the activities of performing currency exchange deals, we have a statutory obligation to use video surveillance for currency exchange supervision. We record videos for the last six months. We will keep them longer if necessary to run a court or other procedure. Samples obtained via the video surveillance system will not be delivered to third parties unless there is a request or order from the competent state body (eg police, state attorney, courts, labor inspectorate). Records may be used as evidence in court, administrative, arbitration or other equivalent proceedings, in accordance with the applicable procedural rules in such proceedings.
7.6. Collecting data through our web site
When using our site, some data (which may include personal data) is collected automatically. This information includes the language settings, IP address, location, device settings, device operating system, login information, usage time, required URL, status report, user agent (browser version information), operating system, visitor results (visit or reservation ), Search History, User Booking ID, and Data Type. We can also automatically collect data through cookies. For more information about cookies, please click here. The information contained herein does not disclose your email address or identify you in any other way. Identifiers such as IP addresses that we collect in our analytics reports are processed only for the purpose of identifying the number of unique visitors to our site and geographic area you are visiting from, and we will not go in to identify the identity of individual visitors. Collecting these data allows us to customize your user experience, improve the performance of our site, and measure the effectiveness of our marketing activities
- Your rights and how to achieve them
If you would like to apply for the right to process your data, you can contact our privacy officer by e-mail firstname.lastname@example.org or by mail to: IMPORTANNE RESORT doo, Kardinala Stepinca 31, 20 000 Dubrovnik (for Data Protection Officers). Your rights related to personal data processing are as follows:
- the right to access personal information ( the right to obtain information on what your data is processed and details of their processing). Before we give you this information, and to avoid potential misuse, we may ask you to prove your identity,
- the right to correct personal data,
- the right to delete personal data,
- the right to limit the processing of personal data,
- the right to object to processing of personal data based on our legitimate interest,
- the right to transfer of data,
- the right not to apply to you a decision based solely on automated processing, including the creation of a profile. In this connection, we want to point out that we do not apply such a way of making decisions.
- the right to withdraw the day’s privation.
The ability to exercise the above rights depends on the reason and basis on which we process your information. For example, in the event that we are legally obliged to keep personal information for a specified period, we can not delete them, even if you require it. Upon your request we will proceed within one month of receipt. In the case of a complex nature request or we have received a large number of requests, we will notify you that we will be required to act upon your request for more than one month, and we will certainly act upon your request within three months of your receipt. Your request can be accepted or rejected if we evaluate it as unfounded. In the case of placing claims that are manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to act upon the request, which we will notify you in advance. If you are not satisfied with our response, you have the right to file a complaint with the supervisory body, whether in Croatia or another EU Member State. In Croatia, the Supervisory Authority is the Personal Data Protection Agency, Martićeva ulica 14, 10 000 Zagreb, e-mail: email@example.com