PRIVACY POLICY
1. Introduction
Jadran d.d., Bana Jelačića 16, 51260 Crikvenica, OIB: 56994999963, as the data controller, respects privacy and protects personal data in accordance with the General Data Protection Regulation (GDPR), the Act on the Implementation of the General Data Protection Regulation, and other applicable regulations of the Republic of Croatia.
This Privacy Policy applies to the processing of personal data of guests of hotels, resorts, and campsites managed by Jadran d.d.:
- Boutique Hotel Esplanade
- Boutique Hotel Noemia
- Elements Camping Selce
- Grand Hotel View
- Heritage Hotel Stypia
- Holiday Resort Ad Turres
- Holiday Resort Kačjak
- Hotel Delfin
- Hotel Kaštel
- Hotel Katarina
- Hotel Omorika
- Pavilion Omorika
- Hotel Slaven
- Pavilion Slaven
The Policy also applies to website visitors, business partners, shareholders, and other persons whose personal data is processed within the business operations of Jadran d.d.
Contact details of the Data Protection Officer:
- sluzbenik@jadran-crikvenica.hr
- Bana Jelačića 16, 51260 Crikvenica, attn. Data Protection Officer
- Adria Coast Turizam d.o.o. has appointed a Data Protection Officer whom you may contact by e-mail at sluzbenik@a-c-t.hr or by post at: Adria Coast Turizam d.o.o., Bana Jelačića 16, 51260 Crikvenica, Croatia, marked DPO (Data Protection Officer), for any questions relating to the protection of personal data and the exercise of your rights guaranteed under the General Data Protection Regulation (GDPR).
2. Purpose of Personal Data Processing
2.1. Reservation and Provision of Accommodation Services
Accommodation reservations may be made via the website, by e-mail, by telephone, or through partner booking platforms.
When making a reservation or inquiry, personal data necessary for processing the request and organizing the stay is processed, including name and surname, e-mail address, telephone number, arrival and departure dates, number of guests, and any additional notes or requests related to the reservation.
For the purpose of providing accommodation services during the stay, data related to the use of additional facilities and services, as well as data necessary for calculating and charging for services, is processed.
During their stay, guests may have access to various services and facilities, such as wellness facilities, restaurants and bars, room service, animation and recreational activities, and other related services. For the purpose of organizing, providing, and charging for these services, personal data such as the guest’s name and surname, type and time of the service used, related costs, and any special requests or notes may be processed.
For certain wellness or health treatments, it may be necessary to collect information about the guest’s health condition in order to assess whether individual treatments are safe and appropriate. Such data is processed exclusively for the purpose of protecting the guest’s health and ensuring the safe provision of the service. If relevant information is not provided, certain treatments may not be provided or carried out safely.
Legal basis for processing: Taking pre-contractual steps at the request of the data subject, performance of obligations arising from a contractual relationship, consent of the data subject.
2.2. Guest Registration in the eVisitor System
In accordance with the applicable regulations of the Republic of Croatia, all guests must be registered and deregistered through the eVisitor information system.
For these purposes, personal data prescribed by applicable regulations is processed, including name and surname, date of birth, nationality, place and country of birth, gender, type and number of identification document, and information on the duration of the stay.
Legal basis: Legal obligation of the data controller.
2.3. Payment for Services
When making online reservations for certain accommodation units, promotional offers, or reservations that include special benefits and discounts, payment may be made in advance using a payment card. For these purposes, data necessary for processing online payments, confirming reservations, and recording transactions is processed, including data required for carrying out card transactions.
During check-in or while using certain services, a pre-authorization of the payment card may be performed, i.e. a temporary hold of a certain amount of funds, for the purpose of securing payment for reserved and used services, as well as any additional costs incurred during the stay.
Payment card data is processed through secure and certified systems for processing card transactions that apply appropriate security standards for the protection of payment data. Card data is encrypted and processed through authorized payment service providers, with appropriate technical and organizational protection measures applied to prevent unauthorized access, use, or misuse of data.
For the purpose of processing payments, issuing invoices, fiscalization, and maintaining accounting records, data necessary for charging for services is processed, including name and surname, address, OIB where applicable, data on services used, amounts, payment method, and transaction data.
Legal basis for processing: Taking pre-contractual steps at the request of the data subject, performance of obligations arising from a contractual relationship, legal obligation of the data controller.
2.4. Marketing Activities
The e-mail address collected when making a reservation or registering a stay may be used to send notifications about services, benefits, special offers, discounts, events, and other information related to the business operations and offer of Jadran d.d., when such services and content may be relevant to guests.
For these purposes, personal data is processed on the basis of the legitimate interest of Jadran d.d. in promoting its own services and maintaining relationships with guests.
Recipients of marketing messages may object to such processing or unsubscribe from the mailing list at any time by using the unsubscribe link included in each message sent.
Data subjects may also independently subscribe to the newsletter recipient list via the form on the website. In this case, the processing of personal data is based on the consent of the data subject.
Legal basis: Legitimate interest of the data controller or consent of the data subject.
2.5. Inquiries and Communication with Guests and Other Data Subjects
Personal data submitted by e-mail, through contact forms on the website, by telephone, via social media, or in person is processed for the purpose of receiving and processing inquiries, providing requested information, responding to requests, and further communication related to the services and business operations of Jadran d.d.
For these purposes, personal data such as name and surname, contact details, reservation or stay details, and data related to a business or other relationship with Jadran d.d. may be processed.
Legal basis: Depending on the content of the inquiry and the nature of the relationship with the data subject (guest, potential guest, etc.), processing is based on consent or on taking pre-contractual steps at the request of the data subject and exercising rights and obligations arising from a contractual relationship.
2.6. Handling Complaints and Objections
In the event of an objection, complaint, or other grievance regarding the service provided, Jadran d.d. processes personal data necessary for receiving, recording, processing, and resolving the complaint.
For these purposes, personal data such as name and surname, contact details, details of the stay or service used, content of the complaint, attached documentation, and information on the manner of resolving the complaint and further communication is processed.
Legal basis: Legal obligation of the data controller, performance of obligations arising from a contractual relationship.
2.7. Video Surveillance
Certain areas of hotels, campsites, and other facilities of Jadran d.d., such as entrances and exits, reception areas, parking lots, garages, and other shared areas, are covered by a video surveillance system for the purpose of protecting the safety of guests, employees, visitors, and the Company’s property.
The video surveillance system is used for the purpose of preventing and detecting unlawful acts and protecting persons and property of Jadran d.d.
Appropriate notices with basic information on the processing of personal data through the video surveillance system are displayed in all areas covered by video surveillance.
Legal basis: Legitimate interest of the data controller.
2.8. Recording Calls in the Reservation Center
For the purpose of improving service quality, verifying the accuracy of received reservations and agreed information, and protecting the rights and interests of Jadran d.d. and guests, incoming and outgoing telephone calls to customer support are recorded.
Call recordings are used exclusively for the purposes of ensuring service quality, resolving complaints and disputes, and proving the content of communication.
Before the start of the conversation, data subjects are provided with appropriate information about the recording of the telephone call.
Legal basis: Legitimate interest of the data controller.
3. Processing of Special Categories of Data and Children’s Data
Jadran d.d. processes children’s personal data exclusively to the extent necessary for providing accommodation services, organizing the stay, and fulfilling legal obligations, for example when registering the stay in the eVisitor system. Children’s data is generally collected from parents, legal representatives, or other persons authorized to organize the stay.
For booking and using accommodation and most additional services, it is not necessary to provide special categories of personal data. However, before or during the stay, a guest may voluntarily provide certain data relating to health condition, allergies, dietary needs, reduced mobility, or other circumstances relevant for a safe stay and the provision of customized services.
Such data is processed exclusively for the purpose of providing appropriate and safe service, protecting the health and safety of the guest, and adapting facilities and services to the guest’s individual needs.
Legal basis: Legal obligation of the data controller, guest’s consent.
4. Establishment and Performance of Business and Contractual Relationships
Jadran d.d. processes personal data of business associates, suppliers, persons authorized to represent legal entities, and other contractual partners for the purpose of concluding and performing contracts, establishing business cooperation, and conducting business communication.
For these purposes, personal data such as name and surname, function or job position, contact details, data on deliveries, calculations and payments, and other data necessary for the implementation of the contractual relationship and business cooperation is processed.
Legal basis for processing: Taking pre-contractual steps at the request of the data subject, performance of obligations arising from a contractual relationship.
5. Keeping Business and Accounting Records
Personal data contained in invoices, accounting documents, and other business documentation is processed for the purpose of keeping business and accounting records, issuing invoices, fiscalization, processing payments, and fulfilling obligations prescribed by accounting, tax, and other applicable regulations.
Legal basis for processing: Legal obligation of the data controller.
6. Processing of Shareholders’ Personal Data
For the purpose of convening and holding the General Assembly of Jadran d.d., personal data of shareholders, participants in the assembly, their proxies, and legal representatives is processed.
Jadran d.d. also processes shareholders’ personal data necessary for maintaining the share register, exercising shareholders’ rights, and fulfilling regulatory obligations. Such data is received from the Central Depository & Clearing Company Inc., which performs tasks related to the deposit and transfer of shares and maintains shareholder records.
Legal basis for processing: Legal obligation of the data controller.
7. Selection Process and Employment
Jadran d.d., as a potential employer, processes candidates’ personal data within the selection process.
Detailed information on the processing of candidates’ personal data, including purposes of processing, legal bases, data retention periods, and candidates’ rights, is available at the link https://karijere-jadran-hotels-and-camps.talentlyft.com/privacy.
8. Cookies
The website of Jadran d.d. https://www.jadran-crikvenica.hr/hr uses cookies and similar technologies for the purpose of ensuring the proper functioning of the website, improving user experience, analyzing visits, and improving content and services.
Detailed information on the types of cookies used, their purpose, retention periods, and options for managing cookie settings is available in the separate document “Cookie Policy”.
9. Recipients of Personal Data
9.1. Data Processors
Personal data of guests and other data subjects is available exclusively to authorized persons and contractual partners to whom the data is necessary for performing tasks and providing services related to the business operations of Jadran d.d.
Data processors also participate in the processing of personal data, providing services on behalf of and according to the instructions of Jadran d.d. that are necessary for regular business operations, such as reservation system management services, payment transaction processing, website maintenance, newsletter distribution, IT support, hosting, and other related services.
Relations with data processors are regulated by data processing agreements, which ensure data confidentiality, the application of appropriate protection measures, and the processing of personal data exclusively according to the instructions of Jadran d.d. as the data controller.
9.2. Other Recipients of Personal Data
In accordance with the applicable regulations of the Republic of Croatia, Jadran d.d. is obliged to provide certain personal data of guests and other data subjects to competent authorities and institutions.
For the purpose of fulfilling the legal obligation to register stays, guest data is entered into the eVisitor information system managed by the Croatian National Tourist Board.
Personal data may also be submitted to other competent authorities, such as the police, courts, tax authorities, inspection bodies, and other public authorities, when there is a legal obligation or another valid legal basis for such disclosure.
Personal data is provided exclusively to the extent necessary to achieve the specific purpose and with the application of appropriate personal data protection measures.
9.3. Recipients of Data Outside the EU
Personal data of guests and other data subjects is generally processed and stored within the European Union or the European Economic Area.
Such transfers are carried out exclusively with the application of appropriate safeguards prescribed by the General Data Protection Regulation, including the European Commission’s standard contractual clauses and other protection mechanisms provided for in Chapter V of the General Data Protection Regulation.
The text of the European Commission’s standard contractual clauses is available at the link https://eur-lex.europa.eu/legal-content/HR/TXT/HTML/?uri=CELEX%3A32021D0914&utm_source=chatgpt.com
10. Retention Period of Personal Data
Personal data are retained for the period necessary to achieve the purpose of processing or for the period prescribed by law.
- Reservation and guest stay data, including check-in and check-out information, are retained for a minimum of 2 years from the guest's departure, in accordance with the Ordinance on the Form, Content and Method of Keeping the Guest Register and Guest List, and for a maximum of 5 years from the end of the year of the guest's last stay.
- Invoices, accounting records and fiscal documents are retained for 11 years from the end of the year in which the document was created, in accordance with the Accounting Act and tax regulations.
- Payment card data are retained until the transaction has been completed and all charges settled, and for no longer than 14 days thereafter.
- Data collected through inquiries and communication with prospective guests are retained for up to 12 months after the communication has ended.
- Data relating to complaints and claims are retained for 12 months from the receipt of the complaint, in accordance with the Consumer Protection Act.
- Data collected on the basis of consent are retained until the consent is withdrawn.
- Video surveillance recordings are retained for a maximum period of 30 days.
- Call recordings from the reservation centre are retained for 15 months.
- Personal data collected and generated for the purpose of exercising rights and fulfilling obligations arising from a contractual relationship are retained until the expiry of the applicable limitation periods following the termination of the business relationship (5 years after the end of the business relationship).
- Shareholder data related to the convening and holding of the General Meeting are retained permanently.
Upon expiry of the above retention periods, all personal data are deleted or anonymised, unless their further retention is required by specific legal regulations or is necessary for the establishment, exercise or defence of legal claims of Jadran d.d.
11. Personal Data Protection Measures
Jadran d.d. applies appropriate technical and organizational measures to ensure the confidentiality, integrity, availability, and security of personal data, taking into account the nature, scope, context, and purposes of processing, as well as possible risks to the rights and freedoms of data subjects.
Protection measures include, among others, controlling and restricting access to personal data, protecting information and communication systems, managing user authorizations, recording access to systems, data backups, protecting network infrastructure, regularly updating security systems, and other appropriate security measures, depending on the type of data and assessed processing risks.
12. Available Rights
Depending on the legal basis and purpose of personal data processing, data subjects have the following rights:
- Right of access to data – the right to obtain confirmation as to whether personal data is being processed, access to personal data and information on the purpose, scope, and manner of processing, and the right to a copy of the data;
- Right to rectification – the right to request correction of inaccurate or completion of incomplete personal data;
- Right to erasure (“right to be forgotten”) – the right to request deletion of personal data that is no longer necessary for the purpose of processing or when there is no other legal basis for its processing and retention;
- Right to withdraw consent – where processing is based on consent, consent may be withdrawn at any time, without affecting the lawfulness of processing carried out before its withdrawal.
Where applicable, depending on the circumstances of a particular processing operation and its legal basis, the following rights are also available:
- Right to restriction of processing – for example, when the accuracy of personal data is contested or when the data is needed for the establishment, exercise, or defense of legal claims;
- Right to data portability – the right to receive personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller, where processing is based on consent or contract and is carried out by automated means;
- Right to object – the right to object at any time to the processing of personal data based on the legitimate interest of the data controller, including processing for direct marketing purposes;
- Right to object to automated decision-making – the right to object to a decision made solely by automated processing, including profiling, if such a decision produces legal effects or similarly significantly affects the data subject.
13. Contact
To exercise their rights or obtain additional information on the protection and processing of personal data, data subjects may contact the Data Protection Officer at: sluzbenik@jadran-crikvenica.hr or by post at: Bana Jelačića 16, 51260 Crikvenica, attn. Data Protection Officer.
Data subjects may lodge a complaint with the Croatian Personal Data Protection Agency (AZOP) at azop@azop.hr.
14. Document Version
This notice on the processing of personal data is regularly updated in accordance with applicable regulations, business practices, and the services of Jadran d.d.
Last updated: May 2026.