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PRIVACY POLICY

1. INTRODUCTION

Data protection and your privacy is of the highest importance to us. This privacy policy represents our data protection declaration through which we would like to transparently provide information on the nature, scope, purpose and conditions under which we collect, use and process personal data, as well as on the rights you are entitled to as a data subject. The processing of your personal data shall always be in line with the General Data Protection Regulation (GDPR), as well as specific Croatian data protection regulations. Your privacy matters to us, and

2. WHO IS DATA CONTROLLER?

As the data controller, D-Resort Šibenik has implemented numerous technical and organizational measures to ensure the comprehensive protection of personal data processed through our website and on our premises. In case of any questions regarding your personal data or our data protection practice, do not hesitate to contact us:

D-RESORT ŠIBENIK
Obala Jerka Šizgorića 1
22 000 Šibenik, Croatia
Tel : +385 22 331 452
Data protection officer (DPO): privacy@dresortsibenik.com

3. PERSONAL DATA WE COLLECT

D-Resort Šibenik collects your personal data and other information, such as your personal identification and contact details, business identification and contact details, other contractual details, mailing and billing address, financial and payment information, guest preferences, other information related to your reservation, stay or visit, information about vehicles you bring onto our property, publicly available information etc. This includes but is not limited to the following: name and surname, personal PIN, passport number, nationality, address, date of birth, gender, (mobile) phone number, e-mail address, profession, food and communication preferences, accommodation and spending details, transportation/travel details, membership number, details about insurance, credit card and invoice details and other types of information that you choose to provide to us or that we are obliged or allowed to obtain about you.

We may also collect information about you from third parties, such as travel agencies, online booking services or other external partners in your travel arrangements, from your social media services consistent with your settings on such services, as well as from other third-party sources that are lawfully entitled to share your data with us. We use this information (and may add it to the other information we have about you) for the purposes and under conditions described in this Privacy Policy.

4. HOW WE USE YOUR DATA

Processing of your personal data is based on a particular lawful basis. We fully respect the principle of purpose limitation, so your personal data are collected for specified, explicit and legitimate purposes and will not be further processed in a manner that is incompatible with those purposes.

Primarily, processing of your personal data is necessary for us to provide you with the service you have requested or it is necessary for the performance of a contract with you (e.g. making a reservation and processing payment).

In certain cases we are required to process your personal data to comply with the legal obligations (e.g. guest registration in e-Visitor system).

Additionally, following the consent obtained from you, we may process your personal data for some other specific purposes, such as sending promotional and advertising materials and providing you with personalized services.

We strive to provide you with the best possible service, so certain things we consider as our legitimate interests, in accordance with your reasonable expectations. Among others, such legitimate interest would be carrying out a voluntary satisfaction survey after your visit to D-Resort Šibenik, to understand our guests' needs and improve our everyday business.

If you have any concerns regarding purposes for which we process your personal data or wish to obtain more information, please contact us at privacy@dresortsibenik.com.

5. YOUR CONSENT AND CHOICES

As a part of the check-in process, we allow you to choose freely whether you e.g.:

  • wish to receive marketing information and promotional offers related to D-Resort Šibenik and our partners
  • want us to provide you with personalized services according to your expressed wishes and preferences
  • Agree that we share your personal data within Dogus Group (Doğuş Holding A.Ş.), to ensure the provision of tailor-made services in all Dogus facilities in and outside the EU
  • etc. (other possible legitimate and specified processing purposes, depending on the development and improvement of our services and the respective practice).

By marking the respective box on our consent form you will affirmatively express your consent to one or more of the above-stated purposes of processing (“opt-in“). Categories of personal data that are being processed for a certain purpose are strictly limited to those that are necessary (e.g. identification details and e-mail address for marketing) and/or those that were provided by you as an expression of your preferences or demands (e.g. food or room preferances).

You have the right to withdraw your consent at any time, which will not affect the lawfulness of processing based on your consent before its withdrawal. If you wish to exercise this right, please contact us at privacy@dresortsibenik.com.

 

6. YOUR RIGHTS

According to the GDPR, you are entitled to exercise the following rights:

Right of access
You have the right to ask us to confirm whether we are processing your personal data and to inform you on how they are being processed, in particular - for what purpose(s), which categories of personal data, are we sharing your data with anyone, how long will they be stored etc. You can also obtain a copy of your personal data being processed by D-Resort Šibenik.

Right to rectification (correction)
You have the right to request rectification of your personal data that are inaccurate, as well as the right to have your incomplete personal data completed. This can be done through submitting a request to us or providing a supplementary statement.

Right to erasure (“right to be forgotten“)
In certain circumstances, you are entitled to demand erasure of your personal data, in particular when your data is no longer necessary in relation to the purposes for which they were collected and processed, if your data have beeen unlawfully processed or if you withdraw your consent on which the processing was solely based and there is no other legal ground for processing of your personal data. However, in accordance with the GDPR, we shall not comply with your request for erasure of personal data, if processing of such is necessary for compliance with legal obligations, exercising the right of freedom of expression and information, for the establishment, exercise or defence of legal claims and other.

Right to restriction of processing
You have the right to request that D-Resort Šibenik limits the processing of your personal data in certain cases, such as:

  • during the process of responding to your request to update or correct personal data;
  •  if processing of your data was unlawful, but you do not want us to erase your data;
  •  in case we no longer require your personal data for the purposes of the processing, but you want us to retain them for the establishment, exercise or defence of legal claims;
  • when you have submitted an objection to processing based on our legitimate business interests, pending our response to such objection.

In case you have obtained restriction of processing of your personal data, D-Resort Šibenik shall inform you prior to lifting such restriction.

Right to data portability
You have the right to request that D-Resort Šibenik provides you (or a third party that you designate) with your personal data in a structured, commonly used and machine-readable format. Please note that the right to data portability applies only to personal data that you have provided to us, the processing was carried out by automated means and based on your consent or was necessary for the performance of a contract.

Right to object
You have the right to object to processing of your personal data:

  •  for direct marketing purposes and activities (including profiling related to such marketing);
  •  for statistical purposes, unless such processing is necessary for the performance of a task carried out for reasons of public interest;
  • if the processing is based on our legitimate business interests, unless we are able to demonstrate compelling grounds for such processing or we need to process your personal data in relation to legal claims.

In case you express an objection to our marketing acitivities, we shall immediately cease to process your data for that purpose.

Automated individual decision-making, including profiling
In conducting its business, D-Resort Šibenik does not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.
Human intervention/involvement is always a part of our decision-making process and you are welcome to express your point of view on issues concerning you.

For exercising any of the aforementioned rights, we would kindly ask you to contact us at privacy@dresortsibenik.com. After receiving your e-mail, we will provide you with the written request for exercising the rights regarding your personal data, as well as all the necessary instructions and additional information. We shall respond to your request without undue delay, usually within 30 days of our receipt of your request, unless there are extraordinary circumstances, which you will be duly notified about.

If you have any other questions about our data practices or the exercise of your rights, please do not hesitate to contact us at privacy@dresortsibenik.com.

In any case, you have the right to lodge a complaint with the supervisory authority.
In Croatia, the competent body is Croatian Personal Data Protection Agency, Martićeva 14, 10 000 Zagreb, www.azop.hr.

 

7. RECIPIENTS OF YOUR DATA

In conducting our business, providing you with the services you requested and to ensure compliance with our legal obligations, we may share your personal data with other subjects. This includes but is not limited to: public (regulatory or government) authorities, persons and departments within D-Resort Šibenik responsible for the processing of your personal data, IT administrators, external IT maintenance company, business partners that provide specific travel or leisure services upon your request or other similar service providers and suppliers that work on our behalf for the performance of any contract.

 

8. TRANSFER OF DATA OUTSIDE THE EU

We may transfer the personal information we collect about you, in line with the purposes described in this Privacy Policy, to third-countries outside the EU/EEA that are not considered by the European Commission as countries providing an adequate level of personal data protection. In particular, in certain cases we transfer your personal data to Turkey, where the registered seat of Doğuş Holding A.Ş. is.
In accordance with the GDPR, we use appropriate safeguards for such transfers - the EU standard contractual clauses. To obtain a copy of theses clauses or additional information on our third-country data transfers, you may send your request to privacy@dresortsibenik.com.


9. HOW LONG WILL YOUR DATA BE STORED?

We take seriously the GDPR principles of data minimisation and purpose and storage limitation. D-Resort Šibenik retains your personal data for the time necessary to accomplish the purpose for which they were collected, usually for the duration of any contractual relationship and a certain period thereafter. Our retention policy reflects our legitimate business needs, applicable statute of limitation periods and legal requirements. After the expiry of the applicable terms or when the purpose for processing is no more applicable or ceases to exist, your personal data will be securely deleted or anonymized. 


10. PERSONAL DATA PROTECTION

D-Resort has implemented various technical and organisational measures to protect your personal data from unauthorized access, loss, disclosure, modification or destruction, and to keep it accurate and up-to-date. Our employees, as well as service providers with whom we may share your personal data, are also obliged to exercise reasonable efforts and to ensure the confidentiality and security of your data. In the event that, despite all the security measures undertaken, the confidentiality or availability of your personal data is somehow compromised, we shall immediately notify the competent supervisory authority and/or data subjects, in accordance with the applicable laws or regulations.


11. CHANGES TO THIS POLICY

We may change this Privacy Policy, in accordance with the improvements in legislation, technology or our business practice. These changes shall become immediately applicable and valid when the amended version of Privacy policy is posted on our website, so please check it from time to time. If we decide to change our Privacy policy in a significant way, we will notify you in advance via e-mail you provided to us. 


Cookies are text files with tiny bits of information that are downloaded by your Internet browser upon your visit to http://www.dresortsibenik.com and that are stored on your computer, mobile phone or tablet.

12. USE OF COOKIES

The website http://www.dresortsibenik.com shall collect, process, disclose to third parties, and securely store your visit details in order to give better services to its visitors, to help its visitors and members to take advantage of their membership and to fulfil its statutory obligations, provided that such data shall not be used for any purpose or scope other than the one defined in this Privacy Policy.

"http://www.dresortsibenik.com monitors" details about your tour around the site and/or your membership usage history on the site in order to customize promotions for you, to offer promotions and marketing campaigns and to improve the contents of the web site according to you and/or to identify your preferences "http://www.dresortsibenik.com" uses session cookies and permanent cookies at its web site and mobile site. Session cookies will terminate when you close down your browser, whereas permanent cookies stay on your hard disc for a long time. You may delete permanent cookies and you may reject both session cookies and permanent cookies by following the instructions set out in the “help” file of your browsers or by visiting “www.allaboutcookies.org” or www.youronlinechoices.eu and you may continue to use the web site or mobile site but you may not have any access or may have restricted access to all functions offered by the web site or the mobile site.

How does "http://www.dresortsibenik.com" use third party cookies for advertisements and retargeting? This website may also use cookies to activate “Advertisement Technology” to offer you those advertorials that may be interesting to you in our opinion during your visit to search engines, “http://www.dresortsibenik.com” web site or mobile site and/or web site that “http://www.dresortsibenik.com” posts ads. Advertisement Technology uses such details collected from your previous visits to the web sites/mobile sites in which “http://www.dresortsibenik.com” posts ads to offer you customized or exclusive ads. While offering these ads, it may place third party cookies to your browser so that “http://www.dresortsibenik.com” will know you. Our site or mobile site of http://www.dresortsibenik.com also uses Google Analytics and Google Adwords, which is a web analysis service offered by Google, Inc (“Google”). Google Analytics and Google Adwords use cookies to analyze how visitors use the web site/mobile site. Details about your use of this web site/mobile site (including your IP address) shall be transferred to and safely stored by Google. Google will use such data to evaluate your use of the web site/mobile site; to collect “http://www.dresortsibenik.com” web site/mobile site operations and to provide other services in relation to the use of web site/mobile site and Internet use. But it will not match your IP address with other data stored by Google. For more information about the use by Analytics, please visit the following link:
http://www.google.com/intl/tr/policies/privacy/#infocollect.

In addition, in order to offer you such ads that may be interesting to you, and in order to create a specific target audience on Facebook, only your e-mail address out of your personal data that you have disclosed to “http://www.dresortsibenik.com” is disclosed to Facebook. Before we upload or disclose your e-mail address on Facebook, it shall be locally encrypted by Facebook on our system by means of the hash method. Your e-mail address which is encrypted by the hash method and disclosed to Facebook will be used for matching purposes only. It shall not be disclosed to third parties or other advertisers and it will be removed or deleted from Facebook systems as soon as possible after the said matching transaction is completed. Facebook will ensure confidentiality, privacy and security of the Data Encrypted via the hash method and Facebook User ID collection that constitute your special target audience, including technical and physical security measures developed (i) to protect the security and integrity of data as long as your personal data are kept at Facebook systems and (ii) to protect your personal data at Facebook systems in order to prevent unauthorized or erroneous access to them, or their unauthorized disclosure or use. Moreover, unless you give your consent or an applicable law requires so, Facebook does not provide access or information to third parties or other advertisers for your special target audience nor does it add your special target audience data to our user details or create profiles based on area of interest or use your special target audience for any purpose other than offering services to you. For more information about Facebook special target audience conditions, you may visit https://www.facebook.com/ads/manage/customaudiences/tos.php?_=, and for Facebook Privacy Principles, please visit https://www.facebook.com/privacy/explanation.