This Privacy Policy describes the general approach to the processing of personal data of visitors and guests of Jelly & Star Apartments Pula. Processing is carried out in accordance with the General Data Protection Regulation (GDPR) and applicable Croatian legislation.

1. Data controller

The controller of personal data is Nataša Luk, Krležina 39, 52100 Pula, Croatia. Contact: [email protected].

2. What data is collected

This website does not have a contact form. With your prior consent, the website uses Google Analytics for statistical monitoring of visits (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 in the eVisitor system, the following data is collected: first and last name, type and number of the identification document, sex, country and place of residence, country of birth, citizenship and date of birth, dates of arrival and departure, and the tourist tax category (e.g. for persons with disabilities), pursuant to the Croatian Tourist Tax Act (Zakon o turističkoj pristojbi, Official Gazette “Narodne novine” 52/19, 32/20, 42/20), the Ordinance on the eVisitor System (Pravilnik o sustavu eVisitor, Narodne novine 43/20) and the Aliens Act (Zakon o strancima, Narodne novine 133/20, 114/22, 151/22, 40/25, 55/26). Providing this data is a legal obligation; without it, accommodation cannot be provided.

3. Purpose of processing

Data is processed to handle the booking and communicate with the guest, to register and deregister the guest’s stay in the eVisitor system, to monitor payment of the tourist tax, and for statistical purposes, in accordance with the regulations governing the tourist tax and the registration of tourists.

Processing of personal data for registration in the eVisitor system is based on a legal obligation (Art. 6(1)(c) GDPR; Tourist Tax Act, Narodne novine 52/19, 32/20, 42/20; Ordinance on the eVisitor System, Narodne novine 43/20; Aliens Act, Narodne novine 133/20, 114/22, 151/22, 40/25, 55/26), 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 the performance of the accommodation contract (Art. 6(1)(b) GDPR). Data required for accounting and tax obligations is processed on the basis of a legal obligation (Art. 6(1)(c) GDPR).

5. Third parties and recipients

Bookings are processed through the Rentlio Booking Engine, which acts as a processor on our behalf. Data collected for the registration of a stay is forwarded to tourist boards via the eVisitor system and is accessible to the competent authorities involved in this process: the ministry responsible for tourism and the Tourist Inspectorate, the Ministry of the Interior, and the Ministry of Finance — Customs Administration. A complaint or objection regarding the processing of personal data in the eVisitor system may be submitted to the competent 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 website traffic — number of visitors, pages viewed, and similar. Google Analytics sets cookies (e.g. _ga, _ga_*) only after the visitor has explicitly accepted the consent banner displayed on the website; 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 can withdraw at any time via the “Cookie settings” link in the website footer; withdrawal does not affect the lawfulness of processing carried out before withdrawal. Data may be processed on servers outside the European Economic Area, subject to the safeguards applied by Google (e.g. the EU-US Data Privacy Framework or standard contractual clauses). The default retention period for user and event data in Google Analytics is 14 months. More information on data processing by Google is available in Google’s Privacy Policy.

7. Data retention

Personal data collected for the registration of a stay is retained for the periods prescribed by the Tourist Tax Act and related regulations (currently 10 years). Data provided through direct contact (email, phone) is retained only for as long as necessary to handle the inquiry 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, rectification or erasure, restriction of processing, and data portability, and to object to processing, to the extent permitted by applicable regulations (e.g. the legal obligation to retain data for tourist tax registration). Where processing is based on consent, the guest may withdraw it at any time. 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, Agencija za zaštitu osobnih podataka), the supervisory authority for data protection in the Republic of Croatia, or with the supervisory authority of the Member State where they have their habitual residence or place of work.

9. Contact

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