PRIVACY POLICY

1. INTRODUCTION

ASMA Adriatic International d.o.o. is a company with its registered seat in Croatia, Zagreb, Prilaz Gjure Deželića 16, identification number (OIB): 08031624549, (further in text: ASMA) engaged in renting and managing of real estate, i.e. villas. ASMA is considered as a controller within the meaning of the applicable General Data Protection Regulation (EU) 2016/679 (further in text: GDPR) and the Act on implementation of General Data Protection Act (further in text: the Act).

Herewith we want to clarify in transparent manner which personal data is collected, how and for what purposes is data being processed, what are your rights and other details significant for processing and protection of personal data.

2. HOW WE COLLECT PERSONAL DATA

ASMA can collect your personal data in the following ways:

  1. if you contract i.e. use our services;
  2. if you contact us – for example by completing a reservation form on our website; if you request an offer for rental or accommodation in a villa, or you contact us for any other reason, by e-mail or in any other way; or if you subscribe for receiving newsletter on our website;
  3. if you visit or follow our pages on social media (for example Facebook, Instagram, and other) or you perform certain activity or interaction on our social media (for example “like”, “comment“, “share“); if you gave your consent to use your photos on social media or similar (for example Facebook, Instagram, and other)

3. TYPES OF PERSONAL DATA WE PROCESS

Within the scope of its business activities, ASMA collects i.e. processes personal and other data of its clients and/or contractual parties and partners and other individuals, depending on the case, such as:

  1. name and surname, address of primary/secondary residence (street and street number, city and postal number, state), telephone and/or mobile phone and/or e-mail address;
  2. number of passport, ID card or other identification document issued by the competent authority;
  3. Croatian personal identification number (OIB) or any other identification number;
  4. place, state and date of birth, citizenship, gender;
  5. number and control number of credit or other card;
  6. other data regarding the payment (payment conditions, account numbers, possible discounts and similar);
  7. data on location, if applicable and if you enabled collection of such data on your device(s);
  8. IP address;
  9. history of services;
  10. technical data (number of visits to our website and other).

Our policy is to collect only personal data necessary for achievement of a specific legitimate purpose of data processing.

Consequences of non-disclosure of personal data and management of consent

In case of non-disclosure of your personal data requested by ASMA for the purpose of concluding and exercising rights under the contract, contract on rental i.e. accommodation in villa and providing of potential other services cannot be concluded, as ASMA as the controller will not be able to perform the contract.

In case you do not give your consent or subsequently withdraw the consent to receive our marketing notices, you will no longer receive our marketing messages (newsletter, e-mail notices of services) or surveys sent by ASMA to improve services.

You may withdraw the consent you have given to ASMA for a particular processing purpose at any time, in which case we will no longer use your personal data collected on the basis of consent for the stated purpose.

You can withdraw your consent at any time by clicking on the unsubscribe link at the end of each newsletter or by sending an e-mail to: privacy@villafedora.com.

4. PURPOSE OF PERSONAL DATA PROCESSING

We collect and process your personal data in order to:

  1. fulfill our contractual obligations and provide you with services you ordered/contracted;
  2. fulfill obligations prescribed by applicable laws and regulations;
  3. provide you with information and/or offers and/or other requested from us;
  4. provide you with a newsletter;
  5. manage, analyze and administrate our websites;
  6. manage, analyze and administrate our pages i.e. profiles on social media;
  7. inform you on important news such as, for example, changes and/or amendments of our terms of contract and/or other changes or information important for our business or your stay in villa or other.

Performance of the contract

If you contract or use our services, we will collect and process personal data above stated in order to take actions that precede or aim at concluding a contract, for the purpose of rental i.e. providing services of accommodation in villa or entering into and performing other contracts and/or services we provide, and executing business processes that includes resolving customer requests as service users. If you have contracted or used our services, collection of certain personal data related to you is necessary in order to fulfill our contractual obligations and provide you with services you ordered or contracted.

Compliance with legal obligations

Laws and regulations applicable on the territory of the Republic of Croatia prescribe certain obligations which demand that we collect and process certain personal data for purposes determined by the law and also, in certain cases, that we provide such data to the competent authorities.

For example, data on your name and surname, gender, etc. is required to register and deregister your stay with the competent tourist office, within prescribed deadlines, which is one of our legal obligations.

Legitimate interest

We collect and process your IP address because we consider it is our legitimate interest to protect ourselves from frauds and to protect and ensure security, but also to use such data in order to analyze visits and usage of our website, among other for statistical purposes.

If you are our client or you already use our services, your name and surname, telephone and/or mobile phone and/or e-mail address can be used for sending information on services and/or benefits related to the services you used, and all because we consider we have the legitimate interest therefor. It is important to emphasize that you can unsubscribe or deregister from this list of receivers at any time, as stated above.

Consent

In certain cases, we can collect and process your personal data only if you gave consent therefor. It is important to emphasize that you have a right to withdraw your consent at any time in a way that you contact us in any abovementioned way.

Your name and surname, telephone number and/or mobile phone number and/or e-mail address are used for sending newsletters, marketing messages, notification on services and/or benefits, if you subscribed for receiving such content i.e. if you gave consent.

6. RECIPIENTS OF YOUR PERSONAL DATA

Certain personal data collected we can transfer i.e. disclose to those persons who undertake certain actions in our name or provide us with certain services, such as accountants, lawyers and other, which are considered as processors within the meaning of GDPR.

Processor can only be a person providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of the GDPR and ensure the protection of rights of the data subject. Therefore, in stated cases such processors are bound and limited by a contract on data processing, which they concluded with us and which determines which personal data certain processor can process and for which purposes.

We can transfer or disclose your personal data to our reliable business partners without whose services we would not be able to provide our services or part of our services, for example real time authorization of your credit and debit cards or other.

When such obligation is foreseen by applicable laws and regulations or if necessary for protecting our rights, property or safety, we are obliged to transfer or disclose certain personal data we collect to the competent authorities.

Only authorized persons of ASMA and of processors who act in the name and on behalf of ASMA have the right to access personal data collected by means of video surveillance. In cases foreseen by applicable laws and regulations, competent authorities of the Republic of Croatia may also have access to video recordings.

7. LINKS

On our websites you can find links to the websites of third parties, which we place because we find them necessary or useful to our clients.

Please note that such third parties’ websites are out of the scope of this Privacy policy and we cannot bear any kind of responsibility for them because those websites are of third parties and therefore rules and terms of personal data protection of such third parties apply accordingly.

8. COOKIES AND IP ADDRESSES

Our website uses cookies in order to function properly and be able to make further upgrades for purpose of improving your browsing experience, which means that our website must save a small file (so-called cookies) on your computer, mobile phone or other device.

Before saving cookies, we are obliged to ask for your consent, therefore notification about cookies and request for consent appear when you open our website. If you refuse or disable the use of cookies, there is a possibility you will not be able to use some of the functions of our website or its part.

Functionality cookies are used in order to recognize you on our website and remember your previously selected preferences. These may include your preferred language and your location.

Marketing cookies are used in order to collect information about your visits to our website, the content you have viewed, the links you have followed, and information about your browser, device and your IP address. The website sometimes shares some limited aspects of this information with third parties for marketing purposes. We may also share online data collected by use of cookies with our marketing partners. That means that when you visit another website, you may see a marketing message based on your search patterns on our website.

Preferences and cookie settings can vary, depending on the device, operating system and Internet browser you use. For more information please visit www.allaboutcookies.org.

Data on your IP address we primarily collect due to safety and technical reasons, but also for statistical and analytical purposes, as well as for improvements of quality of services we provide.

9. KEEPING OF PERSONAL DATA

We will not keep your personal data longer than it is necessary for fulfilling or achieving the purpose for which such data is collected. Generally, we will keep personal data of our contracting parties for as long as it is prescribed by law as mandatory, personal data of persons who applied for receiving a newsletter – until they withdraw their consent or unsubscribe from the list of recipients, personal data of persons who contacted us for some reason – during the communication, etc.

When your personal data is no longer necessary or basis for processing no longer exists, we will erase such data from our system or destroy all documentation in which your data is contained, depending on the case.

10. SAFETY

With regard to safety and protection of your personal data, we strive to apply appropriate technical and organizational measures in order to protect them. Nevertheless, unfortunately, no one can guarantee that transfer or keeping or any other system or measure related to personal data is 100% safe.

There is no automated decision making in the ASMA, i.e. ASMA does not perform automated profiling and decision-making through its systems.

11. NEWSLETTER AND MARKETING MESSAGES

Newsletters and marketing messages will be sent to you if you gave consent for such purpose or if that is in accordance with our legitimate interest, all in order to inform you on our products and services. You can withdraw your consent at any time in a way that you contact us by any foreseen way or by simply unsubscribing from our list of recipients with “unsubscribe” option on our website.

12. YOUR RIGHTS RELATED TO PERSONAL DATA

According to GDPR you have certain rights related to your personal data as stated below. You can exercise your rights at any time by contacting us in any of the foreseen ways.

Right of access - you have a right to request a confirmation as to whether or not your personal data is being processed, and access to the same data.

Right to correction - you have a right to request a correction of your personal data, which is incorrect or incomplete.

Right to erasure (Right to be forgotten) - you have a right to request an erasure of your personal data and we will erase such data without undue delay, provided that the conditions from Article 17 paragraph 1 of GDPR are fulfilled.

Right to restriction of processing - you have a right to request a restriction of processing of your personal data where one of the following applies:

  1. you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data; or
  2. the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; or
  3. we as controller no longer need the personal data for the processing purposes, but you request them for the establishment, exercise or defense of legal claims; or
  4. you have objected to processing expecting the verification whether the legitimate reasons of us as controller supersede your reasons.

Right to data portability - you have a right to request your personal data, which you provided to us in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller, if conditions from Article 20 Paragraph 1 of GDPR are fulfilled.

Right to object - you have the right to object at any time on your personal data processing, which is based on legitimate interest because of your specific situation, unless the reasons for such processing supersede the right of protection of personal data.

Right of complaint to the supervisory authority - if you find that we process your data in an unlawful way and do not consider you can find a solution of your situation together with us, you have a right to file a complaint to the supervisory authority i.e. Croatian Personal Data Protection Agency with its registered seat in Zagreb, Selska cesta 136. For more information, please visit the official website www.azop.hr.

13. INSTRUCTIONS AND CONTACT DETAILS

For all your questions, comments and requests for exercising your rights, and especially rights from Article 12 of this Privacy policy, you can contact us by:

  1. e-mail on address: privacy@villafedora.com
  2. letter on address: Zagreb, Prilaz Gjure Deželića 16
  3. through contact form available on our website.

When submitting a request for exercising any of your rights from Article 12 of this Privacy policy, state clearly what is the subject of your request and which personal data does it refer to. Note that we will have to verify your identity before acting upon your request, due to ours and your safety reasons.

We will consider your request and strive to act on it within a reasonable time period. Please have in mind that certain circumstances can cause a certain delay in action, such as large number of requests received within the same time period.

14. CHANGES AND AMENDMENTS OF PRIVACY POLICY

As controller, we will monitor the status of personal data protection and improve our protection measures and other important issues, if needed, therefore we reserve the right to change and/or amend this Privacy policy from time to time.

Information on changes and/or amendments of this Privacy policy will be published on our website.

Version dated 18.05.2022