TODO This is a working draft and does not constitute a final legal document. Before publishing this site, the content must be reviewed with an accountant and/or legal adviser.

This privacy policy describes the general approach to processing the personal data of visitors and guests of Jelly & Star Apartments Pula. This is a working draft — the final text must be aligned with applicable regulations (including the General Data Protection Regulation, GDPR) with the help of a legal adviser before the site is published publicly.

1. Data controller

The data controller for personal data is Nataša Luk (Croatian personal tax number / OIB: 21456657414), Krležina 39, 52100 Pula, Croatia. Contact: [email protected].

2. What data is collected

This website does not include a contact form. With your prior consent, the site uses Google Analytics for statistical visitor tracking (see section 6, Cookies). Personal data (e.g. name, email address, phone number) is collected only when a guest contacts us directly by email, phone, or through the booking system (Rentlio Booking Engine).

When registering a stay through the eVisitor system, the following data is collected: first and last name, type and number of identification document, sex, country and city of residence, country of birth, citizenship and date of birth, and sojourn-tax category (e.g. for persons with disabilities), in accordance with the Sojourn Tax Act (Official Gazette 152/08, 59/09, 30/14) and the Aliens Act (Official Gazette 130/11).

3. Purpose of processing

Data is processed for the purpose of handling the booking and communicating with the guest, registering and deregistering the guest’s stay in the eVisitor system, supervision of sojourn tax payment, and statistical processing, in accordance with the regulations governing sojourn tax and tourist registration.

Processing of personal data for eVisitor registration is based on a legal obligation (Sojourn Tax Act, Official Gazette 152/08, 59/09 and 30/14; Aliens Act, Official Gazette 130/11; Regulation on the manner of keeping guest records, Official Gazette 126/15), for which the guest’s consent is not required. Processing of data collected through direct contact (email, phone) is based on taking steps at the guest’s request prior to entering into a contract, or on performance of the accommodation contract.

5. Third parties

Bookings are processed through the Rentlio Booking Engine. Data collected for stay registration is forwarded to Tourist Boards through the eVisitor system and is accessible to the relevant public authorities involved in this process: the Ministry of Tourism and Tourism Inspection, the Ministry of the Interior, and the Ministry of Finance — Customs Administration. A complaint regarding the processing of personal data in the eVisitor system may be submitted to the Tourist Board of the place of stay (Pula Tourist Board: [email protected]).

6. Cookies

This website uses Google Analytics (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) for statistical analysis of site traffic — number of visitors, pages viewed, and similar. Google Analytics sets cookies (e.g. _ga, _ga_*) only after a visitor explicitly accepts the consent banner shown on the site; without your consent, no cookies are set and no data is sent to Google.

The legal basis for this processing is your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time via the “Cookie settings” link in the site footer. Data may be processed on servers outside the European Economic Area, subject to safeguards applied by Google. The default retention period for user and event data in Google Analytics is 14 months. More information on Google’s data processing is available in Google’s Privacy Policy.

7. Data retention period

Personal data collected for stay registration is retained in accordance with the periods set out in the Sojourn Tax Act and related regulations. Data submitted through direct contact (email, phone) is retained only as long as necessary to handle the enquiry or booking, unless a longer retention period is required by law (e.g. accounting regulations).

8. Data subject rights

Under the General Data Protection Regulation (GDPR), a guest has the right to request access to their personal data, its rectification or erasure, restriction of processing, data portability, and to object to processing, to the extent permitted by applicable regulations (e.g. the legal obligation to retain data for sojourn-tax registration). Requests can be sent to [email protected]. A guest also has the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP), the supervisory authority for data protection in Croatia.

9. Contact

For any questions about privacy and the processing of personal data, contact us using the details on the Contact page.