Scope of application
This Policy applies to any processing of personal data by The Pucić Palace hotel unless other The Pucić Palace hotel policy prescribes otherwise. Exceptionally, with regard to the processing of data of guests and users of The Pucić Palace hotel services, this Policy prevails over all other policies when such other policies prescribe rights and obligations regarding the processing of data in a different manner.
Data controller and legal framework
Sagrada Management company, as the Controller of your data, 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 the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Act on Implementation of the General Data Protection Regulation (Official Gazette, No. 42/2018) and other regulations governing this area that are applicable in Republic of Croatia.
Data protection officer
Sagrada Management company has appointed the personal data protection officer, who can be contacted, at any time, at the e-mail address email@example.com or by phone: ++ 385 20 326 222 or regular address to Ulica od Puča 1 - 20000 Dubrovnik 20 000 Dubrovnik, Croatia EU
Implementation of data-protection principles
Sagrada Management company within the framework of the implementation of this Policy, pays special attention to respecting the principles of data processing and processes data:
Transfer of data to third parties
The access to the personal data of guests, where necessary and to a limited extent, may also be granted to third party processors (for example, associates of Sagrada Management Company that provide IT or other services), who store such data in their databases until due processing of such data is completed. We will conclude a detailed contract with such parties regarding their powers and obligations during the processing of personal data, in accordance with the requirements of the Regulation.
Under certain circumstances, external parties and Sagrada Management company may jointly determine the purpose and manner of personal data processing. In that event, such external partners and Sagrada Management company will be considered joint data controllers. Joint data controllers, in their mutual relationship, determine their own responsibilities for acting in compliance with obligations prescribed by the Regulation in a transparent manner, especially with regard to the exercise of rights held by data subjects and their duty to process data in a transparent manner, unless their responsibilities are already established by law.
Should, within the data processing, data be transferred to third countries, Sagrada Management company will ensure the compliance with high standards of protection to in order to comply with the highest possible standard of personal data protection in accordance with the strict requirements of the Regulation.
Purpose of data collection
Sagrada Management company is required to collect certain personal data in order to execute due accommodation contract and comply with regulations governing hospitality. However, Sagrada Management company may collect other or the same data for other purposes, primarily maintaining contact. Such purposes include:
Sagrada Management company guarantees that collected data will be used only for the stated purposes.
Sagrada Management company may use depersonalised data for statistical purposes.
Legal basis for collection
The legal basis for the stated collection purposes may be:
Subject’s electronic consent
The subject may give its consent in an electronic form. Taking the fact that the consent must be unequivocal and voluntary into account, it is necessary to keep in mind that it is not allowed to “force” the consent, especially by checking the consent box in advance, or in some other way that significantly affects the use of a web page, or by adjusting the technical settings, but rather the choice in hand must be “neutral”.
Points of data collection
Sagrada Management company collects your data at:
Data storage period
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Data that was lawfully collected by is stored for a period of time prescribed by a particular law or other positive regulation.
Data that was contractually collected by the Sagrada Management company is stored only for a period of time necessary to fulfil the contract or provide a service.
Information about the name, surname and e-mail address collected by Sagrada Management company on the basis for direct marketing purposes is stored in its guest database for a period of 1 year.
Other information collected by Sagrada Management company on the basis of guest's explicit consent (mobile phone number, number of children, marital status, pets, interests, manner of travel, accommodation and destination preferences) is stored in its guest database for a period of 1 month.
Sagrada Management company may, based on your explicit consent, also collect your web browsing data (so-called cookies) and store them in its database for a period of 1 year. Sagrada Management company uses such data to inform you about special and personalised offers, news and events organised through online channels (e-mail, web, internet promotions).
Rights of the data subject
Regardless of the basis for data collection, you can, at any time, free of charge, request:
Please send your written request to the contact e-mail address of personal data protection officer Sagrada Management company e-mail firstname.lastname@example.org or by phone: ++ 385 20 326 222 or regular address to Ulica od Puča 1 - 20000 Dubrovnik 20 000 Dubrovnik, Croatia EU
Personal data collected from persons who booked accommodation and guests
Sagrada Management company, as the data controller, keeps personal data you are required to submit in order to be provided with accommodation services in its database solely for the purpose of concluding the accommodation contract and complying with legal requirements on provision and collection of personal data governing hospitality, and may use such data for other purposes allowed by positive regulations. In the event that you do not provide Sagrada Management company with minimum information required for the registration of guests in all relevant registers, Sagrada Management company will not be able to provide you with accommodation services in accordance with the contract and the law.
Personal data recorded by Sagrada Management company at the time of booking and filling in the registration card at arrival to the facility are collected on the basis of laws regulating hospitality and for the purpose of providing services to guests. These include the following data (subject to change with regard to positive regulations):
Sagrada Management company stores such data in its database of guests and shares them with competent authorities of the Republic of Croatia through the E-visitor system (electronic registration system) through the E-visitor system (electronic registration system) in which such data is required to be stored for 10 years. Sagrada Management company is also required to store all invoices issued to guests, including their personal information, for 11 years, in accordance with legal regulations.
Furthermore, in order to fulfil its contractual obligations, at the time of booking and filling in the registration card at arrival to the facility Sagrada Management company collects the following information:
Other information related to circumstances of your stay, such as the manner of travel, travel companions, marital status, number of children, pets and other interests, will also be collected when they are directly connected to the provision of accommodation services, but will be deleted after your departure from the accommodation facility.
Sagrada Management company as the data controller, based on a legitimate interest has the right to store your personal information (name and surname, e-mail address) in its database of guests and use such information for the purpose of direct marketing done solely for the purpose of informing you about Sagrada Management company offers and news by e- mail. Under these circumstances, you will have the right to request erasure (right to be forgotten) from the database for that purpose at any time and free of charge.
During and after your stay, Sagrada Management company will e-mail you, as our guest, a satisfaction questionnaire which, should you wish to fulfil it, namely, solely with your consent, The primary purpose of such satisfaction questionnaire is to collect data on services for the purpose of their improvement by, Sagrada Management company whereby Sagrada Management company depersonalises such data provided in questionnaires and processes them for statistical purposes.
In addition, a person who books accommodation, that is, a guest, can give Sagrada Management company a special permission, namely, consent, that all his or her information, such as:
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Video surveillance system
Sagrada Management company as the data controller, has the legitimate interest to implement video surveillance measures to protect property and persons in relation to certain workplace positions and statutory duty to install surveillance cameras that record employees and anyone moving within the surveillance camera field of view.
Sagrada Management company indicates all places where video surveillance system is installed in the prescribed manner.
Sagrada Management company is aware that the video recordings contain personal data of all the persons moving within the surveillance camera field of view, and therefore handles them with special care. Furthermore, we have implemented a security system and introduced availability and erasure policy regulated by internal the Sagrada Management company rules on safety.
Video recordings are regularly rewritten and thus automatically deleted after a maximum of 7 days after they are recorded. Exceptionally, video recordings are kept longer when they serve as evidence in proceedings before competent state authorities. Extracted video recordings are stored in a centralised messaging system with extremely limited access.
In the event of judicial and/or criminal proceedings, Sagrada Management company may use such video recordings. Access to personal data captured on video recordings may be granted to third parties, data processors and contractual partners of the Sagrada Management company who are registered and qualified to provide services of personal and property protection and who do not use any of these data independently but participate in activities related to the security of central supervisory and alarm systems. All other details regarding video surveillance are subject to special regulations that govern that area.
Protecting the personal information of children
Sagrada Management company advises parents and guardians to teach their children the importance of being responsible when dealing with personal information on the internet Sagrada Management company does not wish to collect and has no intention of collecting personal information of children. Personal information of children will be neither used nor divulged to third parties. A child may give his or her consent solely in relation to the provision of IT company services, whereby such child must be older than 16 years of age. Sagrada Management company may process all other information of children below the stated age limit and children under 18 years of age, except as expressly stated herein, only with the prior consent of the parent.
Rectification of data
You can contact us at any time to review your personal information, as well as for the purpose of updating, rectification or erasure of your data. Until such time, we will use your previously recorded data for the aforementioned purposes.
Technical and integrated data protection
Sagrada Management company, as the data controller, takes utmost care to meet the highest organisational and technical data protection standards. We, therefore, taking into account state of the art developments, the cost of implementation and the nature, scope, context and purpose of processing, as well as the risks arising from data processing of various levels of probability and severity that may affect the rights or freedoms of natural persons, at the time of choosing the processing resources and at the time of the processing itself, take appropriate technical and organisational measures to enable the effective application of data protection principles.
Furthermore, the Sagrada Management company takes the appropriate technical and organisational measures to ensure that only personal data necessary for each special purpose of processing are processed in an integrated way. Sagrada Management company imposes this measure to the amount of collected personal data, scope of their processing, storage period and their availability. Specifically, such measures ensure that personal data are not automatically, without personal intervention, made available to an unlimited number of persons.
Records of processing activities
Sagrada Management company as the data controller, keeps records on processing activities involving the following data:
Many of our External Third Parties are based outside the EU so their processing of your personal data will involve a transfer of data outside the Eu.
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Personal data breach
Sagrada Management company as the data controller, ensures that in the event of personal data breach, the competent supervisory authority is notified of personal data breach without further delays and, if possible, at least 72 hours after such breach has occurred, unless it is not likely that such personal data breach will pose a risk to rights and freedoms of natural persons.
The report submitted to the supervisory authority must contain all information prescribed by the Regulation.
In the event of personal data breach that is likely to pose high risk to rights and freedoms of natural persons, Sagrada Management company, as the data controller, will notify the data subject of such personal data breach without further delays. Data subjects will not be notified where the Regulation stipulates that such notification is not mandatory.
Data protection impact assessment
Where a type of processing in particular using new technologies, and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of data subjects, the Sagrada Management company will, as the data controller, prior to the processing, carry out an assessment of the impact of the envisaged processing operations on the protection of personal data.
A single assessment may address a set of similar processing operations that present similar high risks.
Sagrada Management company performs a data protection impact assessment in the event of:
Sagrada Management company ensures an adequate involvement of data protection officers in the perrmance of impact assessment.
In accordance with the provisions of the Regulation and, when necessary, after the performance impact assessment, we will consult the supervisory authority prior to processing.