Privacy & Cookie Policy
Villa Spa Otium respects your privacy and is committed to protecting your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 – GDPR and applicable Croatian data protection legislation.
This Privacy Policy explains what personal data we collect, why we collect it, how it is used and protected, and what rights you have in relation to your personal data.
Data Controller
The controller responsible for the processing of personal data is:
Radeki Polje 30a
52206 Loborika / Pula
Croatia
Email: villaspaotium@gmail.com
Telephone: +41 76 566 28 74
You may contact us at any time regarding the processing of your personal data or the exercise of your privacy rights.
Personal Data We Collect
Depending on your interaction with Villa Spa Otium, we may process the following categories of personal data:
- name and surname;
- email address;
- telephone number;
- reservation and accommodation details;
- number and composition of guests;
- arrival and departure dates;
- communication relating to your reservation or stay;
- identification and registration information required by Croatian law and the eVisitor system;
- payment and invoice information necessary for accounting and legal obligations;
- technical information generated when using our website, such as IP address, browser and device information, where applicable;
- images recorded by the parking-area video surveillance system.
Purposes & Legal Basis for Processing
We process personal data only where there is an appropriate legal basis under applicable data protection law.
Performance of a Contract
Personal data may be processed in order to respond to an accommodation enquiry, prepare an offer, confirm and manage a reservation, communicate with guests and provide the accommodation services requested.
Legal Obligations
Certain personal data must be processed in order to comply with Croatian legal obligations, including guest registration, tourist records, accounting and tax requirements.
Legitimate Interests
Where appropriate, we may process personal data where necessary for our legitimate interests, including the security of guests, protection of persons and property, prevention of misuse, handling of complaints and the establishment, exercise or defence of legal claims.
Consent
Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
Guest Registration & eVisitor
As a registered accommodation provider in Croatia, Villa Spa Otium is legally required to register all persons staying at the property through the Croatian eVisitor system.
For this purpose, the following information may be required:
- name and surname;
- place, country and date of birth;
- nationality;
- type and number of identification document;
- residence or address where required;
- date and time of arrival and departure;
- sex;
- information relevant to exemption from or reduction of tourist tax, where applicable.
Required guest registration data is transmitted through the official eVisitor system and may be accessible to competent Croatian authorities where permitted or required by law.
Data contained in the official tourist registration records is retained in accordance with statutory retention requirements.
Identification Documents
Information from an identity card, passport or other valid identification document may be required in order to fulfil the statutory guest-registration obligations.
Where a guest voluntarily sends a photograph or copy of an identification document, for example by email or WhatsApp, it is used only for the purpose for which it was requested, primarily registration of the guest.
Whenever possible, only the information necessary for registration is recorded.
Personal Data of Children
Villa Spa Otium does not knowingly collect personal data of children for advertising or unrelated purposes.
However, children staying at the property must be registered in accordance with Croatian accommodation and tourist registration requirements.
Personal data relating to minors is processed only to the extent necessary for the accommodation service, legal registration requirements and other legitimate legal purposes.
Email, Telephone & WhatsApp Communication
If you contact Villa Spa Otium by email, telephone, contact form or WhatsApp, we process the information you provide in order to respond to your enquiry, manage your reservation and communicate with you regarding your stay.
When you choose to communicate through a third-party messaging service such as WhatsApp, information may also be processed by the provider of that service in accordance with its own privacy policy.
Communication records are retained only for as long as reasonably necessary for the purpose of the communication, reservation administration, dispute resolution or compliance with legal obligations.
Payments & Accounting
We may process information relating to payments, advance payments, refunds and invoices in order to administer your reservation and comply with accounting, tax and other legal requirements.
We do not intentionally collect or store complete payment-card details through this website unless a payment service specifically requires such processing.
Financial and accounting records are retained for the periods required by applicable Croatian law.
Video Surveillance
Villa Spa Otium operates video surveillance only in the parking area.
The purpose of the surveillance is the protection and security of our guests, their property and vehicles, as well as the protection of Villa Spa Otium and its property.
The legal basis for this processing is our legitimate interest in protecting persons and property, provided that the interests, rights and freedoms of individuals do not override that interest.
Video surveillance does not cover bedrooms, bathrooms, wellness facilities, swimming-pool areas or other areas intended for the private use of guests.
Appropriate signs informing visitors of video surveillance are displayed before entering the monitored area.
Access to recordings is restricted to authorised persons and recordings are protected against unauthorised access.
Recordings are retained only for the period necessary for the security purpose for which they were collected and are then automatically deleted or overwritten.
Recordings may be retained for a longer period where necessary as evidence in relation to an incident, damage, criminal offence, legal claim or proceeding before a competent authority.
Recordings may be provided to police, courts, insurers or other competent authorities where required or permitted by law.
Cookies & Website Technologies
The Villa Spa Otium website may use cookies and similar technologies to ensure the proper operation and security of the website and, where enabled, to improve its functionality.
Necessary Cookies
Necessary cookies are used where required for basic website functionality, security and technical operation. These cookies do not require consent where permitted by law.
Optional Cookies & Third-Party Services
Non-essential cookies, analytics, maps, embedded content or other third-party technologies will be used only where permitted by applicable law and, where required, after obtaining your consent.
Third-party services may receive technical information such as your IP address and device information when such services are enabled.
You may manage or withdraw your cookie consent through the cookie settings available on the website, where applicable.
Who May Receive Your Personal Data
Personal data is not sold.
Where necessary and legally permitted, personal data may be disclosed to:
- the Croatian eVisitor system and competent tourist or public authorities;
- tax, accounting or other competent authorities where required by law;
- accountants or professional advisers where necessary;
- website hosting, IT, communication and technical service providers acting on our behalf;
- payment or banking service providers where required to process payments or refunds;
- police, courts, insurers or other competent bodies where necessary to protect rights, persons or property or to comply with legal obligations.
Service providers who process personal data on our behalf are required to protect that data and use it only for authorised purposes.
International Data Transfers
Some technology or communication service providers may process personal data outside Croatia or the European Economic Area.
Where such transfers occur, appropriate safeguards required by applicable data protection law are used where necessary, such as an adequacy decision or approved contractual safeguards.
How Long We Keep Personal Data
Personal data is retained only for as long as necessary for the purpose for which it was collected or for the period required by applicable law.
- Guest registration information in eVisitor is retained according to the statutory retention period applicable to the official system.
- Accounting and tax documents are retained for the period required under applicable Croatian legislation.
- Reservation correspondence is retained only for as long as reasonably necessary for reservation administration, legal claims or compliance obligations.
- Identification-document images are deleted when they are no longer necessary for their intended purpose unless further retention is legally required.
- Video-surveillance recordings are kept only for the security purpose for which they were collected, unless an incident requires longer retention.
Data Security
Villa Spa Otium applies appropriate technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, accidental loss, destruction or misuse.
Access to personal data is limited to persons who require access for legitimate operational or legal purposes.
No method of electronic storage or transmission can guarantee absolute security; however, reasonable measures are maintained according to the nature and risk of the processing involved.
Your GDPR Rights
Subject to the conditions and limitations provided by law, you may have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete data;
- request erasure of personal data;
- request restriction of processing;
- object to processing based on legitimate interests;
- receive personal data in a portable format where the right to data portability applies;
- withdraw consent where processing is based on consent;
- lodge a complaint with the competent supervisory authority.
Requests regarding your personal data may be sent to: villaspaotium@gmail.com
Right to Lodge a Complaint
If you believe that your personal data has been processed unlawfully, you have the right to lodge a complaint with the Croatian supervisory authority:
Agencija za zaštitu osobnih podataka
Croatia
You may also contact Villa Spa Otium first so that we can attempt to resolve your concern directly.
Changes to This Privacy Policy
This Privacy Policy may be updated from time to time to reflect changes in our services, technology or applicable legal requirements.
The current version will always be published on the Villa Spa Otium website.