Politika privatnosti
PRIVACY POLICY
ADRIAINVEST-INŽENJERING d.o.o., with headquarters in Zagreb, Bednjanska 8a, OIB: 55697816159 (hereinafter: ADRIAINVEST-INŽENJERING), respects the privacy of every person whose personal data it collects. We would like to inform you about what personal data ADRIAINVEST-INŽENJERING collects, how we protect it and what your rights are.
ADRIAINVEST-INŽENJERING reserves all copyrights for the use of photos, texts and other published materials, in terms of positive legal regulations in the Republic of Croatia. Photos, texts and other material may not be published, sold, publicly or privately published or used in any other way without the consent of ADRIAINVEST-INŽENJERING. Any non-compliance with the previous conditions entails responsibility and the obligation to compensate ADRIAINVEST-INŽENJERING for non-material damage per violation for a particular material.
Scope of application
This Policy applies to any processing of ADRIAINVEST-INŽENJERING’s personal data, unless otherwise prescribed by another ADRIINVEST-INŽENJERING policy. Exceptionally, in relation to the processing of data of guests and users of ADRIAINVEST-INŽENJERING’s services, this Policy has priority over other policies if rights and obligations regarding data processing are otherwise prescribed by these policies.
Controller and legal framework
ADRIAINVEST-INŽENJERING, as the Data Controller, respects your privacy and undertakes to protect your personal data. The collection and storage of data is carried out in accordance with the provisions of Regulation EU 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals in connection with the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Law on Implementation General Regulation on Data Protection (Official Gazette 42/2018) and other regulations governing the subject area, which are applicable in the Republic of Croatia.
Data Protection Officer
ADRIAINVEST-INŽENJERING has appointed a personal data protection officer who can be contacted at any time via the following address: info@aii.hr or by mail to Adriainvest-inženjering d.o.o., Bednjanska 8a, 10000 Zagreb, Republic of Croatia.
Application of data protection principles
ADRIAINVEST-INŽENJERING, within the framework of the application of this Policy, takes particular care to respect the principles of data processing and processes data:
Legal – processing will be possible if it is permitted by law and within the limits permitted by law.
Fair – respecting the specifics of each relationship, applying all adequate measures to protect personal data and privacy in general, and not preventing the respondent from exercising their rights.
Transparent – informing respondents about the processing of personal data. From the very collection of data, when respondents are informed about all aspects of data processing until the end of data processing, respondents are provided with simple and quick access to their own data, which includes the possibility of viewing and obtaining a copy in accordance with the provisions of the Regulation. Certain information may be restricted only when required by law or when it is necessary to protect third parties.
With purpose limitation – processing personal data for the purposes for which they were collected and for other purposes if the conditions from the Regulation are met. Data may be processed for compatible purposes only taking into account (a) any connection between the purposes of collecting personal data and the purposes of the intended continuation of processing; (b) the context in which the personal data was collected, especially with regard to the relationship between the data subject and Adriainvest-inženjering; (c) the nature of personal data, in particular whether special categories of personal data are processed in accordance with Article 9 of the Regulation or personal data related to criminal convictions and criminal offenses in accordance with Article 10 of the Regulation; (d) possible consequences of the intended continuation of processing for the data subjects; and (e) the existence of appropriate protective measures.
With storage limitation – storing data in a form that enables the identification of the data subject only for as long as is necessary for the purposes for which the personal data is processed, and longer only if permitted by the Regulation.
While reducing the amount of data – processing data if it is appropriate, relevant and limited to what is necessary. Special care is taken not to collect data for which there is no justified need for processing.
Taking care of accuracy – taking care of the accuracy and up-to-dateness of data and deleting inaccurate data as far as possible.
Taking into account the integrity and confidentiality – providing adequate security of personal data with technical and organizational measures, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage by applying appropriate technical or organizational measures. Relevant measures are applied taking into account the riskiness of each type of data processing.
Delivery of data to third parties
If necessary and to a limited extent, third parties, processors (for example ADRIAINVEST-INŽENJERING’s associates who provide IT services or other services), who store them in their databases until the end of the processing, can also have insight into the guests’ personal data. A detailed contract is concluded with such subjects regarding their powers and obligations in the processing of personal data, in accordance with the requirements of the Regulation.
In certain situations, it is possible for external entities together with ADRIAINVEST-INŽENJERING to jointly determine the purposes and methods of personal data processing, then these external partners and ADRIAINVEST-INŽENJERING are joint processing managers. In these relationships, the joint processing managers transparently determine their responsibilities for compliance with the obligations from the Regulation, especially with regard to the exercise of the data subject’s rights and their duties to respect the transparency of the processing, unless the responsibilities are determined by law.
If data is transferred to third countries as part of data processing, ADRIAINVEST-INŽENJERING ensures compliance with high protection standards in order to comply with the highest possible standard of personal data protection, in accordance with the strict requirements of the Regulation. In this sense, when international transfers of personal data are applied, ADRIAINVEST-INŽENJERING will inform the respondent about the intention to transfer personal data to a third country or international organization and about the existence or non-existence of the European Commission’s decision on adequacy. At the same time, the respondent will be directed to suitable or appropriate protective measures and ways of obtaining their copy or the place where they are made available if the transfer is subject to appropriate protective measures according to Article 46 of the Regulation, the application of binding corporate rules according to Article 47 of the Regulation or if it is applicable Article 49, paragraph 1, subparagraph 2 of the Regulation. Any transfer of personal data to third countries will be carried out in accordance with Chapter V of the Regulation.
Purpose of collection
ADRIAINVEST-INŽENJERING is obliged to collect some of your personal data due to the fulfillment of the accommodation contract and due to the regulations governing the hospitality industry, but ADRIAINVEST-INŽENJERING may collect some other or the same data for other purposes, primarily for contact purposes, namely:
fulfillment of accommodation contracts
fulfilling the requirements of the law and other valid positive regulations governing the hospitality industry
for direct marketing purposes
sending offers
for the purpose of holding prize games
for the purpose of improving and personalizing the service to you as a guest
for the purpose of protecting property and the safety of individuals by applying video surveillance measures
ADRIAINVEST-INŽENJERING guarantees that the collected data will be used only for the stated purposes.
ADRIAINVEST-INŽENJERING may use depersonalized data for statistical purposes.
Legal basis of collection
The legal basis for the stated collection purposes are:
legal,
contractual,
key interests of the respondents,
a legitimate interest that is stronger than that of the respondent or
consent or express consent of the respondent depending on the purpose of processing and the type of personal data
Data collection sites
ADRIAINVEST-INŽENJERING collects your data during:
accommodation reservations (web reservations or telephone reservations)
when completing the accommodation contract – registration at the reception of the facility, by filling out the registration card
subscriptions to the newsletter on ADRIAINVEST-INŽENJERING’s website, including subscription to free Wi-Fi.
joining the loyalty program
participation in the prize game by filling out the survey form
in places under the video surveillance system.
Data retention time
The data collected by ADRIAINVEST-INŽENJERING on the basis of the law is required to be kept as long as determined by a specific law or other positive regulation.
The data that ADRIAINVEST-INŽENJERING collects on the basis of the contractual relationship will be kept only as long as necessary for the purpose of fulfilling the contract or providing the service.
Name, surname and e-mail address data collected by ADRIAINVEST-INŽENJERING based on legitimate interest for direct marketing purposes will be kept in its guest database for 10 years.
Other data that ADRIAINVEST-INŽENJERING collects based on the express consent of the guest (mobile phone number, number of children, marital status, pets, interests, method of travel, accommodation preference and destination preference) will be stored in its guest database for 5 years.
ADRIAINVEST-INŽENJERING can also, based on your express consent, collect and store data about the content you view on the web pages (so-called cookies), and in that case it will keep them in its database for a period of 2 years. ADRIAINVEST-INŽENJERING will use the above information for the purpose of informing about special and personalized offers, news and events that it organizes through online channels (e-mail, web, internet promotion).
Rights of respondents
Regardless of the basis of data collection, you can request free of charge at any time:
access, modification or addition of data in all personal data bases, on the basis of which ADRIAINVEST-INŽENJERING will provide access to or change your data in all its databases depending on your request,
deletion (“right to be forgotten”) of personal data in all personal data databases, based on which ADRIAINVEST-INŽENJERING will delete you from all its databases, except for databases that ADRIAINVEST-INŽENJERING is obliged to have and keep on the basis of positive regulations, and if they do not exist stronger legitimate reasons for the processing or if the processing is not necessary for establishing, exercising or defending legal claims,
limiting the processing of your data or objecting to the processing of such data
that the data we have collected about you be transferred to you or to third parties (“the right to data portability”), in accordance with positive legal regulations,
if the data was given on the basis of consent, you can always withdraw that consent without negative consequences,
the right to submit a complaint to the supervisory body – the Agency for the Protection of Personal Data (more on this at www.azop.hr)
Send your written request to the contact address of the personal data protection officer: info@aii.hr or by mail to Adriainvest-inženjering d.o.o., Bednjanska 8a, 10000 Zagreb, Republic of Croatia.
Personal data collected from persons who have booked accommodation and guests
ADRIAINVEST-INŽENJERING, as the processing manager, stores your personal data that you must submit in order to provide you with the accommodation service in its database exclusively for the purpose of fulfilling the accommodation contract and fulfilling legal delivery obligations, as well as collecting personal data related to the catering business, and can also be used for other purposes provided by positive regulations. In the event that you do not provide ADRIAINVEST-INŽENJERING with the minimum data required for guest registration in all relevant registers, ADRIINVEST-INŽENJERING will not be able to provide you with accommodation services in accordance with the contract and the law.
Personal data recorded by ADRIAINVEST-INŽENJERING already at the time of reservation and on the registration card when arriving at the facility, were collected based on the laws governing the hospitality industry, and for the purpose of providing services to guests. These are the following data (which can be changed due to positive regulations):
name and surname
address of residence (Croatian citizens)
date of birth
number, type of identification document and place of issue
citizenship
object name
accommodation unit number
date of arrival and departure of the guest
sex.
ADRIAINVEST-INŽENJERING keeps the above data in its guest database and sends it to the E-visitor system (electronic system for guest registration) to the competent authorities of the Republic of Croatia, and the above data must be kept in the system for 10 years. Also, ADRIAINVEST-INŽENJERING is obliged to keep all invoices issued to guests with the guest’s personal data for 11 years, in accordance with legal regulations.
Furthermore, in order to fulfill the contractual obligation, ADRIAINVEST-INŽENJERING collects the following data during the reservation, as well as on the registration card when arriving at the facility:
language
phone.
Other data related to the circumstances of your stay, such as: method of travel, with whom you travel, marital status, number of children, pets, other interests, will also be collected if they have a direct connection with the provision of accommodation services, and will be deleted after of your departure from the accommodation facility.
Your personal data (name and surname, e-mail address), ADRIAINVEST-INŽENJERING, as a data controller, has the right to collect it in its guest database based on legitimate interest and use it for the purpose of direct marketing, and exclusively for the purpose of informing you about ADRIINVEST-INŽENJERING’s offers and news via e-mail. In this case, you have the right to request deletion (right to be forgotten) from the database for this purpose at any time and free of charge.
During and after your stay, ADRIAINVEST-INŽENJERING sends you, as a guest, a satisfaction questionnaire via e-mail that we received from you, which, if you wish to fill it in, is processed by ADRIAINVEST-INŽENJERING only with your consent. The primary purpose of the satisfaction questionnaire is to collect data about the service in order to improve the service by ADRIANVEST-INŽENJERING and ADRIANVEST-INŽENJERING depersonalizes and processes the data from the questionnaire for statistical purposes.
In addition, the person booking the accommodation or the guest can give special permission, consent, to ADRIAINVEST-INŽENJERING, that all his data, such as:
Name
last name
date of birth
state
other personal data collected during the stay (e.g. mobile phone number, phone number, gender, number of children, marital status, language, pets, interests and activities during the stay, method of travel, accommodation preference, destination preference, etc.)
other personal data collected when browsing the web (so-called cookie), including IP address.
collects and uses for further profiling of respondents and for the purpose of contacting and informing about special and personalized offers, news and events organized by ADRIAINVEST INŽENJERING via online channels (e-mail, web, internet promotion). In this case, the subject has the right to withdraw the given consent at any time, which includes processing for the purposes of profiling to the extent that it is related to such direct marketing, either in relation to initial or further processing, at any time and free of charge, as well as the right at any the era of data change and the right to be forgotten.
Data is stored in the guest database of ADRIAINVEST-INŽENJERINGA for 5 years.
ADRIAINVEST-INŽENJERING also collects personal data through the video surveillance system.
Personal data collected by signing up for the newsletter, including signing up for free Wi-Fi.
When signing up for the newsletter, the respondent will have the option to provide the following additional data with consent (not including first and last name and e-mail address, which ADRIAINVEST-INŽENJERING collects based on legitimate interest):
sex
date of birth
state
language.
When updating the subscription to the newsletter, the respondent will be able to provide the following additional information with consent:
street, house number, postal code, city
telephone number
mobile number
interests
mode of travel
pets
accommodation preference
destination preference.
The collected data is collected on the basis of express consent for the purpose of informing about special and personalized offers, news and events organized by ADRIAINVEST-INŽENJERING via online channels (e-mail, web, internet promotion).
Data is stored in the guest database of ADRIAINVEST-INŽENJERINGA for 5 years.
The respondent has the right to change data and the right to be forgotten.
Personal Data collected when participating in the prize game / filling out the survey form
ADRIAINVEST-INŽENJERING may occasionally organize prize games, in which case it will collect your personal data only if you decide to participate in the prize game. The data that will be collected in this way and which are necessary for participation in the prize game, will be determined by the Rules of the prize game, for each separate prize game, and may be different. Data collected in this way, based on a kind of contractual obligation, will be used for the purpose of conducting the prize draw, in accordance with the rules of the prize draw. and deleted within 5 years after the end of the prize draw.
In case you fill out the survey form for the prize draw with data that is not necessary for participation in the prize draw, (the data may be different in different prize draws) ADRIAINVEST-INŽENJERING can use all that depersonalized data for statistical purposes.
Based on legitimate interest, ADRIAINVEST-INŽENJERING has the right to collect and use data on name, surname and e-mail address, which you fill out in the survey form for the prize draw, for the purpose of direct marketing and exclusively for the purpose of informing about offers and news of ADRIAINVEST-INŽENJERING via e-mail. – mail. In this case, the data subject has the right to object to such processing, including profiling to the extent related to such direct marketing, whether in relation to initial or further processing, at any time and free of charge.
The above data is kept in the guest database of ADRIAINVEST-INŽENJERING for 10 years.
The respondent has the right to change data and the right to be forgotten.
In addition, the person participating in the prize draw can give special permission, consent, to ADRIAINVEST-INŽENJERING that all his data provided by filling out the survey form for the prize draw (the data may be different in different prize draws) will be collected and used by ADRIAINVEST-INŽENJERING for further profiling of respondents. and for the purpose of contacting and informing about special and personalized offers, news and events organized by ADRIAINVEST-INŽENJERING via online channels (e-mail, web, internet promotion). In this case, the subject has the right to withdraw the given consent at any time, which includes processing for the purposes of profiling to the extent that it is related to such direct marketing, either in relation to initial or further processing, at any time and free of charge, as well as the right at any the era of data change and the right to be forgotten.
Data is stored in the guest database of ADRIAINVEST-INŽENJERINGA for 5 years.
Cookies and Internet technologies
As is the case with many other portals, ours can be used with “cookies” (small files that we save on your computer when you access our websites in order to enable the basic or additional functionality of those pages) and other technologies that make it easier for us to deliver content depending about your areas of interest, processing reservations or requests, and/or analyzing the characteristics of your visits. Cookies cannot be used to reveal your personal identity. When you access our web pages, this information identifies your browser to our servers, but not you.
We use different types of cookies:
Necessary cookies – they are necessary for the functioning of the website, which cannot function without them. This means that the website cannot be opened or displayed without these cookies. These cookies are used for the purpose of transmission of communication or are necessary for providing an information society service that is expressly required from the user of such service. Also, these cookies will enable us to perform a basic analysis of websites with the aim of improving the website’s performance through data that is completely anonymized, i.e. not based on your personal data or data that can be linked to you in any way. For these cookies, your consent is not required and we do not ask for it.
Functional cookies – we use them to perform a more advanced analysis of website performance. These cookies are used to analyze user behavior, and based on the obtained anonymous data, we can determine what website visitors want and view most, so we are then able to adjust the website and make its content and functionality as easy to use as possible. We ask for your consent for these cookies.
Advertising cookies – we use them to analyze your interests and wishes, and they serve us to market information that is interesting to you and create offers adapted to your use of ADRIAINVEST-INŽENJERING’s internet pages. We ask for your consent for these cookies.
ADRIAINVEST-INŽENJERING stores cookies in the database and keeps them for a maximum of 2 years for the purpose of informing about special and personalized offers, news and events organized through online channels (e-mail, internet, online promotions).
If you have changed your mind about the cookie settings on the ADRIAINVEST-INŽENJERING web pages, you can change them at any time at the link: (link to the cookie consent box). You can always delete the cookies that are saved on your computer, thus preventing the further processing of your personal data through such technology. Each internet browser has its own procedure for deleting cookies, and here are the procedures for the most popular internet browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=hr
Mozilla Firefox: https://support.mozilla.org/hr/kb/Brisanje%20kola%C4%8Di%C4%87a
Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
Video surveillance system
ADRIAINVEST-INŽENJERING, as a processing manager, has a legitimate interest in implementing video surveillance measures for the protection of property and persons, and in relation to certain work positions and the legal duty to install surveillance cameras that record employees and all persons who move in the surveillance camera’s field of view.
ADRIAINVEST-INŽENJERING is aware that the videos contain personal data of all persons moving in the camera’s field of view, and therefore preserves them with special care, has a regulated system of security, availability and their deletion policy, which is governed by ADRIAINVEST-INŽENJERING’s internal security rules.
Videos are regularly overwritten so that they are automatically deleted after a maximum of 15 days from the day of recording. Exceptionally, videos are kept longer if they are evidence in proceedings before competent state authorities. Exempted videos will be stored in a central reporting system with extremely limited access.
In case of judicial and/or criminal proceedings, ADRIAINVEST-INŽENJERING may use the mentioned videos. Third parties, processors, contractual partners of ADRIANVEST-INŽENJERING registered and expert in providing services for the protection of persons and property may also have access to personal data on the videos, who in no way use the specified data independently, but take care of the security of the central supervisory and notification systems. Special regulations governing that area apply to all other details related to video surveillance.
Protection of children’s personal data
ADRIAINVEST-INŽENJERING advises parents and guardians to teach children about safe and responsible handling of personal data on the Internet. ADRIAINVEST-INŽENJERING does not want and has no intention of collecting personal data of children, will not use it in any way, nor will it give it to third parties. A child can give his consent exclusively in relation to possible services of the information society, and that child is over 16 years old. Any other processing of the data of children below the specified age limit and other processing than expressly stated here, for children up to 18 years of age, is permitted by ADRIAINVEST-INŽENJERING only with the prior consent of the parents.
Data change
You can contact us at any time to review your personal data, as well as to update, correct or delete it. Until that moment, we use your previously recorded data for the stated purposes.
Your consent
When providing information to ADRIAINVEST-INŽENJERING, in any way (reservation, registration card…) you guarantee us that the information you have attached is correct, that you are commercially competent and authorized to dispose of the information provided, and that you fully agree to ADRIAINVEST-INŽENJERING using your data and collects in accordance with the law and the terms of this privacy policy.
Technical and integrated data protection
ADRIAINVEST-INŽENJERING, as a processing manager, takes care of the highest organizational and technical data protection standards. Therefore, taking into account the latest achievements, the cost of implementation and the nature, scope, context and purposes of processing, as well as risks of different levels of probability and severity for the rights and freedoms of individuals arising from data processing, at the time of determining the means of processing and at the time of the processing itself, appropriate technical and organizational measures to enable effective application of data protection principles.
Also, ADRIAINVEST-INŽENJERING implements appropriate technical and organizational measures to ensure that only personal data that is necessary for each specific processing purpose is processed in an integrated manner. ADRIAINVEST-INŽENJERING applies this measure to the amount of personal data collected, the scope of their processing, the period of storage and their availability. More precisely, such measures ensure that personal data are not automatically, without individual intervention, available to an unlimited number of individuals.
Records of processing activities
ADRIAINVEST-INŽENJERING, as a processing manager, keeps records of processing activities with the following data:
the name and contact details of the controller, if applicable, the joint controller, and the data protection officer;
processing purposes;
description of categories of respondents and categories of personal data;
categories of recipients to whom personal data has been or will be disclosed, including recipients in third countries or international organizations;
if applicable, transfers of personal data to a third country or international organization, including identification of that third country or international organization and, in the case of transfers from Article 49, paragraph 1, second subparagraph, documentation on appropriate protective measures;
if possible, the deadlines for the deletion of different categories of data;
if possible, a general description of technical and organizational security measures
Handling of personal data breaches
ADRIAINVEST-INŽENJERING, as a data controller, ensures that in the event of a personal data breach, without undue delay and, if feasible, no later than 72 hours after becoming aware of the breach, the competent supervisory authority is notified of the personal data breach, unless it is likely that the breach of personal data will cause a risk for the rights and freedoms of individuals.
The report submitted to the supervisory authority contains all the information in accordance with the Regulation.
In the event of a personal data breach that is likely to cause a high risk for the rights and freedoms of individuals, ADRIAINVEST-INŽENJERING, as the processing manager, notifies the respondent of the personal data breach without undue delay. Respondents will not be notified in cases where the Regulation stipulates that the same is not mandatory.
Data Protection Impact Assessment
If it is likely that some type of processing, especially through new technologies and taking into account the nature, scope, context and purposes of the processing, will cause a high risk to the rights and freedoms of the data subject, ADRIAINVEST-INŽENJERING, as the processing manager, performs an assessment of the impact of the intended processing procedures before the processing to the protection of personal data.
A single assessment may refer to a number of similar processing operations that pose similar high risks.
ADRIAINVEST-INŽENJERING carries out an assessment of the impact on data protection in the case of:
systematic and comprehensive assessments of personal aspects relating to individuals based on automated processing, including profiling, and on the basis of which decisions are made that produce legal effects relating to the individual or similarly significantly affect the individual;
extensive processing of special categories of personal data from Article 9, paragraph 1 or data related to criminal convictions and punishable acts from Article 10 of the Regulation;
systematic monitoring of the publicly accessible area to a large extent,
in other situations determined by the competent supervisory authority.
ADRIAINVEST-INŽENJERING ensures adequate involvement of the data protection officer in the performance assessment process.
In accordance with the provisions of the Regulation, if necessary, after the impact assessment procedure, a preliminary consultation procedure with the supervisory authority will be carried out.
Transparency
This Privacy Policy is available on the website www.hoteladria.hr and also at the reception of our facility.
If we decide to change our privacy policy, we will post and publish the changes on the website www.hoteladria.hr and at the reception of our facility.
