TURISTHOTEL d.d., based in Zadar, Obala kneza Branimira 6, OIB: 74204012744 (hereinafter: TURISTHOTEL) as the controller of the personal data processing in business management, has to collect and use certain information about individuals.
Implementation of personal data and processing purposes, The Data Executives
Personal data is collected and processed solely on the legal basis:
- In cases determined by law and/or by regulation in order to enforce the legal obligations;
- For the purpose of concluding and executing a contract in which the respondent is a party, or in order to take action at the request of a respondent prior to the conclusion of the contract;
- In cases where processing is necessary for the legitimate interests of the processing manager or of a third party;
- Consent, in which case they are precisely assigned to the processing purpose;
- Legitimate interest;
- Other legal bases in accordance with the law of the Union and/or the law of the Republic of Croatia;
Turisthotel d.d. collects your data when booking an accommodation, when concluding and fulfilling the accommodation contract, at the reception desk upon the registration of guests, by the newsletter subscriptions, when joining the membership program, when participating in the prize games, by filling in the questionnaire form, at the places under the video surveillance system and other.
Employee data is collected when responding to job ads, sending an open applications and by an act of employment.
Obligation of collecting and processing the personal data is primarily due to the purpose of providing our services and fulfilling the accommodation agreement, the purposes of direct marketing, sending offers, holding prize competitions, the purpose of improving and personalizing the service to you as our guest, the purpose of measuring the satisfaction with the service provided, the purpose of protecting the property and safety of individuals by applying video surveillance measures, and the purpose of employment and fulfillment of the legal obligations.
Insights into the personal data that Turisthotel collects and processes have also been granted to the processing officers who, on behalf of Turisthotel d.d. (i.e. Turisthotel's associates providing information and other services and support). Such entities shall conclude a detailed contract regarding their rights and obligations in the processing of the personal data, in accordance with the requirements of the Regulation.
Rights of the Respondents, Personal Data Protection Officer
As a data collecting and processing subject you are entitled to:
- Access to data, rectification of data or completion of incomplete data in all databases of personal data, upon which Turisthotel will grant you the access or rectify your data, depending on your request, in all its databases; You can contact us at your own convenience to review your personal data, as well as for updating, correcting or deleting your data. Until that time, we use your previously recorded data;
- Erasure ("right to be forgotten") of personal data from all databases of personal data, upon which Turisthotel will erase such data from all its databases except those that Turisthotel is required to maintain and keep on the basis of positive regulations and when there are no overriding legitimate reasons for processing or when processing is not necessary for the establishment, exercise or defence of legal claims;
- Restriction of processing of your data or lodge a complaint regarding the processing of such data;
- Transfer of the data we have collected about you to yourself or to the third parties ("right to data portability"), in accordance with positive legal regulations;
- If the data is given on the basis of a consent, you can withdraw your consent at any time without any negative consequences, considering that withdrawal does not affect the legitimacy of data processing before the consent was withdrawn;
- Lodging a complaint with a supervisory authority – Personal Data Protection Agency (for more information, please visit www.azop.hr);
- Information on whether the provision of personal data is legal or contractual obligation, or a requirement necessary for the conclusion of the contract, and whether the data subject has the obligation to provide personal data and what the consequences may be if such personal information is not provided;
Turisthotel has appointed a Personal Data Protection Officer who can be contacted in case of any questions related to the protection of the personal data via e-mail: firstname.lastname@example.org or by mail to Turisthotel d.d., Obala kneza Branimira 6, 23000 Zadar, Republic of Croatia, or by personal delivery to the same address. All personal data protection issues should be addressed to the Personal Data Protection Officer.
Principles of Personal Data Protection
Within the framework of the implementation of this Policy, Turisthotel pays special attention to respecting the principles of data processing and processes data:
- Lawfully, fairly and in a transparent manner- data processing is made possible when it is permitted by law and only within the limits permitted by law.
- Determined by the Regulation/by applying all appropriate measures in order to protect personal data and privacy in general, informing the subjects about the processing of personal data and their rights;
- After data collection, the data subjects should be informed about all aspects of data processing until the process has been discontinued. Respondents are provided with a simple and quick access to their own data, including the ability to inspect and obtain copies in accordance with the Regulation. Certain information may be restricted only when required by law or when it is necessary for the protection of the third parties;
- Purpose limitation - Personal data is processed for purposes for which they are collected and may be processed for other purposes only when the requirements laid down in the Regulation are fulfilled. Depersonalized data can be used for statistical purposes.
- Reduction of the data amount - We collect and process only those personal information which are necessary and are in relation to the purposes for which they are being processed in the first place.
- Accounting on accuracy and timeliness of data, and deleting the inaccurate data;
- Within the given options;
- Storage Restrictions - Personal data is kept in a form which allows the identification of the respondent for as long as it is necessary in order to fulfill the purposes for which the personal data is being processed;
- Integrity and confidentiality - We take into account the application of the appropriate technical and organizational measures which ensure the proper security of personal information, including the protection from unauthorized or illegal processing, and from accidental loss, destruction or damage. Relevant measures shall be applied taking into account the risk of any type of data processing.
TURISTHOTEL activities related to data processing, Period of personal data retention:
Turisthotel d.d. as the data controller takes into account the highest organizational and technical data protection standards and implements the appropriate technical and organizational measures to enable the effective application of data protection principles. Turisthotel keeps the collected data in an appropriate manner and ensures their confidentiality.
Turisthotel d.d. as the data controller keeps records of processing activities that contain the information prescribed by the applicable legal regulation, which records the periods of retention of certain personal data.
Data collected on the basis of the law, Turisthotel d.d. is obliged to keep as long as it is determined by a particular law or other positive regulation. Data collected on the basis of the contractual relationship, Turisthotel d.d. will only keep as much as it is necessary for the purpose of fulfilling the contract or the provision of the service, i.e. the amount stipulated by the contract and / or minimum until the expiration of the statutory time limits. Personal information collected by Turisthotel d.d. based on legitimate interests and consents will be kept until recalled.
Turisthotel d.d. takes care of the protection of children's personal data in particular, and advises parents and custodians to teach children about safe and responsible dealing with the personal information on the Internet. Only childred aged 16 or more can give their consent in relation to any informational services regarding the privacy data. Any other process of personal data of children below the stated age limit, and other treatments, except as stated herein shall be permitted only if the parent has approved the consent, or if it was approved by the child custodian (person with the parental responsibility).
Personal data breach
Turisthotel d.d. 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 individuals. 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 individuals, Turisthotel, 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.
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Overview and verification:
TURISTHOTEL d.d. has the right to update this policy if necessary to reflect the best practice and to ensure that any changes or modifications are respected in terms of personal data protection. Turisthotel d.d. reserves the right to modify or terminate all or any part of this internet site and conditions of use at any time. Changes take effect by posting on our web site or when users are notified.