Privacy Policy

Who is the controller of your personal data?

The company TRIO LJUBIĆ d.o.o., Splitska 9, 21300 Makarska, Croatia, OIB: 14175482190, e-mail: [email protected] (hereinafter referred to as the “Controller“) respects your privacy and undertakes to protect it during and after your visit to this website (hereinafter referred to as  the “Site”), visits to our business sites and when you use any of our products or services.

In order to protect the personal data processed, we have implemented appropriate physical, electronic and managerial safeguards. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on this Site or on our servers will be completely secure from unauthorized access by third parties. Therefore, we have adopted this Privacy Policy to explain how your personal data is processed and protected.

By accessing the site, visiting our business locations, and booking and/or purchasing any of our products or services, you agree to this Privacy Policy. This Privacy Policy is subject to change, and the date of the last modification is indicated in the title.

As the Controller, we process your personal data in accordance with the applicable rules on the protection of personal data, in particular in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter: the General Regulation) and the Act on the Implementation of the General Data Protection Regulation (OG 42/2018).

Types of personal data to be processed, purpose and legal basis for the processing of personal data

As the Controller, we process your personal data, e.g. information that can be used to directly or indirectly identify you, in particular by means of identifiers such as name, surname, address, e-mail address, phone number, photo and recording, IP address, billing data and other personal data if you provide them in communication with us, during the performance of a contractual relationship,  Attending events, accessing this site, or accessing our business locations (“Personal Data”) for the following purposes:

  • Communication with you: when you contact us with an inquiry about our services, a request for a quote or with a comment about our services, we will process the data you have provided to us in order to contact you back and act on your request.
  • reservations of accommodation and other hotel facilities: when you are interested in accommodation or other services we offer, we collect your data in order to be able to monitor the occupancy of hotel capacities and to arrange, organize and perform the services you have requested in a timely and orderly manner (e.g. accommodation, organization of events, etc.),
  • check-in and check-out of the guest’s accommodation: if you use the accommodation services in our hotel, we are legally obliged to collect certain personal data in order to record your arrival,
  • Provision and payment of hotel services: During your stay at the hotel, we collect information about special requests you may have in order to provide you with the expected level of hospitality. We also collect information about the services we have provided to you in order to monitor your consumption and their collection, such as the use of bars, minibars, etc., and in order to ensure the payment of the services provided, we collect the credit card number,
  • Event organisation: in order to fulfil our contractual obligation, we collect your personal data when you are the organiser of the event. In the event that you are a participant or visitor to an event in our premises, we may collect information that allows us to provide instructions and information about events;
  • Monitoring and improving the quality of services: Your satisfaction is extremely important to us, and for this purpose we use questionnaires in which you can evaluate our services and make comments. In doing so, you decide for yourself whether to complete such questionnaires and whether and to what extent you will provide personal data in them;
  • protection of your safety and property through video surveillance: part of the premises of our hotels and the area around the hotel is under video surveillance, about which visible notices are highlighted. During your stay at the hotel, you can therefore be caught up in video surveillance. More information about video surveillance can be found in a separate section
  • Connecting with us via social networks for the purpose of responding to your inquiries
  • processing of your application or application for a job in our business units
  • Your Access to Our Site
  • photographing the events and activities we organize,
  • sending newsletters
  • Invoicing for products/services
  • cooperation with you as our suppliers and business partners

We collect only the data that is necessary for us to achieve the above purposes. Depending on the circumstances, this may include the following: your contact details, information regarding your reservation, stay or visit to the hotel, your preferences, name and surname, date of birth, gender, ID number, credit card number, country of birth, citizenship, visa number if you are subject to the visa regime, place of entry into the Republic of Croatia, date of arrival at the facility and date of departure, personal consumption,  information about the airline and the vehicle you use to get to our hotel, impressions of our services (if you decide to provide personal information in the questionnaires), information about events you organize in our area and the names of participants in such events, but also other information that you provide to us or that we receive for the above purposes. In addition to the above information about you, we may also ask for the above information about the people traveling with you.

We will collect information about health, religious or philosophical beliefs and other sensitive data only if you voluntarily provide it to us in order to better serve you or meet your special requirements and needs (e.g. providing access for disabled people, avoiding serving food to which you are allergic, etc.).

The need to collect the above data may arise from our legal obligation, for the purpose of concluding and performing the services from the contract, on the basis of a legitimate interest, but also on the basis of your consent. When consent is the basis for data collection, we will clearly indicate this. The processing of Personal Data is limited only to the purpose for which it was collected in accordance with the terms of this Privacy Policy.

When we process data on the basis of your consent, we process only those personal data that you have voluntarily provided to us when communicating with us, to answer your questions or to process your job application, accommodation reservation and when you have subscribed to receive newsletters. The purpose of the processing is to take steps according to your request, e.g. answering questions and comments, receiving offers, making reservations, communicating about your activities on the site, processing open applications and applications for announced tenders.

On the basis of legitimate interest, we process personal data when you access our Site (IP address), when we take photos of events and activities that we organize, as well as when we record you with surveillance cameras when visiting our business locations. If we organize an event and other activities during which we will take photos and videos of guests, we will do so either on the basis of legitimate interest, of which you will be informed in advance and before entering the filming/photographing area, or you will be asked for your consent beforehand. The purpose of this processing also includes the process of investigating suspected fraud, harassment, physical threats or other violations of the rules of the Site, or any suspicious behavior that we consider to be indecent. We process recordings/images of participants at our events for the purpose of promoting the event. It is also our legitimate interest to deliver a newsletter to existing users of our services and customers of our products.

For the performance of a contractual obligation and on the basis of laws and regulations, we are obliged to process your personal data when you purchase our products or use our services. In particular, we process the data of business partners and suppliers (e.g. agreements on the performance of services), in addition, we process the contact data of business partners who are natural persons and their employees (e.g. name and surname, company phone / mobile phone number, e-mail address), as well as customers for the purpose of issuing invoices.

Open job applications and vacancies

We process open applications of candidates who want to work for us and applications of candidates for vacancies that we announce in such a way that only authorized persons have access to this personal data, and the data is kept for 2 years from the date of receipt of the open application.

Video surveillance

We use video surveillance in our premises for the following purposes:

  • protect the safety of guests and other persons who find themselves in our business premises for any reason and protect their property,
  • control of entry and exit from work premises and premises and to reduce the exposure of workers to the risk of robbery, burglary, violence, theft and similar events at work or in connection with work, to protect our property and to prevent unauthorized entry into our business premises

The processing of personal data obtained by video surveillance is carried out on the basis of a legitimate interest in the protection of persons and property. Recordings are automatically deleted after a maximum of 6 months by copying newer content. Access to the video surveillance system is granted only to persons who need it for the performance of their tasks, and recordings are reviewed only when we learn that there is a justified reason to achieve one of the above purposes (with the approval of an authorized person), whereby only recordings relevant to such reasons can be excluded and kept for a longer period,  while there is a need and a legal basis for it. We do not provide video surveillance recordings to third parties, except when there is a request or order from a competent state authority (e.g. police, state attorney’s office, courts,
Inspectorate of the Council). The recordings may be used as evidence in judicial, administrative, arbitration or other equivalent proceedings, in accordance with the applicable procedural rules applicable in such proceedings. The video surveillance system is not connected to other systems, nor do we use video surveillance for profiling or automated decision-making.

Storage of personal data

We process personal data only for the time necessary to achieve the purpose of their processing.
We process personal data that we process on the basis of consent only until you withdraw your consent, while you can object to the processing of personal data based on legitimate interest. We keep open applications and applications for announced vacancies for 2 years from the date of receipt of them. Other Personal Data that we process on the basis of your inquiries, reservations, orders, etc., we keep for a maximum of 6 months from the receipt of the same, and we keep the data of business partners and suppliers until the termination of business cooperation and do not deliver them to third parties or take them to third countries. In doing so, we do not collect any data of a private nature, but data related to the fulfillment of work tasks.
All other personal data that we process on the basis of the performance of a contractual relationship and on the basis of a legal obligation, we store in accordance with the positive regulations in which the storage period is determined (e.g. the Accounting Act). Exceptionally, we will keep your personal data longer than the stated periods when it is necessary to exercise mutual legal claims.
Upon the expiration of the deadlines, the stored personal data printed on paper will be destroyed in a secure manner, for example by cutting or burning, while the data in electronic form will be irreversibly deleted.

Your Personal Information may be disclosed in the following cases:

  • entities necessary for the execution of the event – photographing the event,
  • authorized PR and marketing agencies and entities that are directly involved in the implementation and realization of certain events
  • entities that maintain our IT systems,
  • entities that we have authorized to process Personal Data, which are subject to an appropriate legal obligation of confidentiality (e.g. bookkeeping service, media agency for sending newsletters, digital agency for administering social networks, etc.),
  • law enforcement and public authorities when required to do so by applicable law or in good faith (to protect and defend our rights and/or property, or to act in urgent circumstances to protect the personal safety of our guests, employees, the Site or the public, in accordance with a legal obligation we have as a hotel accommodation provider);
  • to our legal advisors in the event of the need to forward data for legal procedures
  • the company through which the payment of hotel accommodation is made in the case of using the web form on this website, which is the company: Monri Payments d.o.o., Radnička cesta 54, 10000 Zagreb, Croatia. The protection of personal data of this company can be found at the link: https://ipg.webteh.hr/hr/privacy-policy?inline=true
  • business partners for their needs only in accordance with the relevant legal basics
  • media houses and digital marketing agencies for the purpose of publishing photos in print media, on websites and social networks
  • in the event that you are the organizer of an event that takes place in our premises and you are looking for services related to such an event, at your request we may share information about the event with third parties who can send you offers for the services you request (which is usually limited to your name and contact information) or we may provide you with the contact details of our partner to contact them yourself

Transfer of Personal Data to Third Countries

The data we collect is stored within the European Union (EU) and the European Economic Area (EEA) other than Switzerland, but may also be transferred to and processed in a country outside the EU and EEA, in particular the USA. Any such transfer of personal data will be carried out in accordance with applicable legal regulations. For transfers outside the EEA, we use Standard Contractual Clauses, adequacy decisions, appropriate safeguards, while any transfer to the USA is covered by the Privacy Shield Agreement between the European Union and the USA, which guarantees adequate protection of personal data.

Cookies

Our website uses cookies to enhance your user experience. Cookies are small files that are stored on your device and allow us to track your interactions with the site, help analyze visits, and provide personalized content.

By using our website, you agree to the use of cookies in accordance with our privacy policy. If you do not wish to use cookies, you can disable them in your browser settings.

Data protection provisions on the use and use of: Facebook and Twitter

On its websites, the controller can integrate or has integrated components of the company

Facebook in Twitter

Facebook is a social network operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If the person lives outside the United States of America or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Port, Dublin 2, Ireland. The data protection policy published by Facebook is available at: https://facebook.com/about/privacy/                                                                                                    and https://help.instagram.com/519522125107875?helpref=page_content and provide information about the collection, processing and use of personal data on that social network.

Twitter is a social network, the operating company of which is Twitter, Inc. 1355 Market Street, Suite 900, San Francisco, CA 94103. If the person lives outside the United States, the controller is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 IRELAND. The data protection policy published by Twitter is available at: https://twitter.com/en/privacy and provides information on the collection, processing and use of personal data on this social network.

Manage consents

You can always revoke the consents granted to us.
If you revoke your consent, we will no longer process your data for the stated purposes, but this does not affect the lawfulness of the processing before the withdrawal of consent.

Your rights

  1. Right to rectification:

If we process your personal data that is incomplete or inaccurate, you can ask us to rectify or complete it at any time.

  1. Right of access:

You have the right to obtain confirmation as to whether or not we are processing your personal data, and where this is the case, you have the right to obtain confirmation under the conditions set out in Art. 15 of the General Regulation.

  1. Right to erasure:

You can ask us to delete your personal data if we have processed it unlawfully or if this processing constitutes a disproportionate interference with your protected interests. Please note that there are reasons that prevent immediate deletion, for example to comply with a legal obligation requesting processing.

  1. Right to restriction of processing:

You can ask us to restrict the processing of your data:

  • if you contest the accuracy of the data during the period that allows us to verify the accuracy of the that data;
  • if the processing of the data was unlawful, but you object to the deletion and instead request the restriction of the use of the data;
  • if we no longer need the data for the intended purposes, but you still need it for the purposes of the fulfilment of legal claims, or;
  • if you have objected to the distribution of this data.
  1. Right to data portability:

You can ask us to provide you with the data you have entrusted to us for archiving purposes in a structured format, in a commonly used machine-readable format:

  • if we process this data on the basis of consent that you have given us and which you can revoke or for the performance of a contract, and
  • if the processing is carried out by means of automated processes.
    1. Right to object:
  • If we distribute your data for the performance of tasks in the public interest or the tasks of public authorities, or if we rely on our legitimate interests when processing them, you can object to such data processing if there is an interest in protecting our data.
  • If you believe that we have violated Croatian or European data protection regulations when processing your data, please contact us to clarify any questions. You certainly have the right to file a complaint with the competent supervisory authority, which is the Personal Data Protection Agency, Martićeva 14, Zagreb.

Exercising rights

If you wish to exercise any of the above rights, please contact us using our contact details from this privacy policy or send us an e-mail at [email protected].

When you make a request to exercise your rights, we are required to first establish your identity and for this purpose we will ask for additional information to verify it. This serves to protect your rights and private sphere.
If you use any of these rights too often and with obvious intent to abuse them, we may charge an administrative fee or refuse to process your request.

Changes and updates to our privacy policy

We reserve the right to change or update this Privacy Policy at any time and without prior notice. Please check back from time to time for any changes or updates to our Privacy Policy.