Privacy policy: privacy notice for guests and visitors to website

1. Introduction

We respect your privacy, and we are committed to protecting your personal data. In this document (“Privacy Notice”), we would like to provide you with clear and transparent information about which personal data we collect, as well as the legal basis we rely on when processing your personal data. Please read this document carefully; it contains our Privacy Policy and information on how we use your personal data when you visit our website, book accommodations, stay in one of our properties or if you communicate with us for other reasons. This Privacy Notice applies in all cases of processing your personal data, except in certain particular cases, in which case we will inform you about the way your personal data is processed by providing you with a special Privacy Notice on the processing of personal data, which will contain a Privacy Policy relating to these particular cases of personal data processing. If you have any questions, do not hesitate to contact us, as is described below in paragraph 4 – Contact information.

2. Versions and amendments

We will update this Privacy Notice from time to time to provide you with timely, accurate, and reliable information about how we collect and use your personal data. We will notify you of any changes to the way we process your personal data by updating our Privacy Policy and this Privacy Notice on the processing of personal data.

This Privacy Notice was updated on 1 April 2023.

3. About us

For the purposes of this Privacy Notice and applicable personal data protection provisions, including the General Data Protection Regulation (EU) 2016/679 (hereinafter: “GDPR”), the data controller and the company responsible for processing your personal data is MAISTRA d.d., with a registered seat in Rovinj, Obala Vladimira Nazora 6, PIN (OIB): 25190869349 (hereinafter: “Maistra” or “we”).

Based on a Business Cooperation Agreement, Maistra also provides the booking accommodation service for the company facilities of HUP-ZAGREB d.d., namely:

Hotel International;
Hotel Zonar Zagreb
Jadran Hotel;
Mlini Hotel;
Astarea Hotel;
Mlini Villas and Apartments;
Villas Srebreno; and
Srebreno Premium Apartments, (hereinafter: “HUP Properties”).

This means that if you book accommodation in one of the HUP-Zagreb Properties, in addition to Maistra, HUP-ZAGREB d.d. will also be responsible for the processing of your personal data as an independent data controller, with a registered seat in Zagreb, Trg Krešimira Ćosića 9, PIN (OIB): 66859264899 (hereinafter: “HUP” or “we”).

This Privacy Notice accordingly applies to the guests of Maistra and HUP-Zagreb Properties.

4. Contact information

If you have any questions related to the protection of your personal data, you can contact us by:

e-mail at dpo@maistra.hr
mail at the address Obala Vladimira Nazora 6, 52 210 Rovinj, attn. DPO.

If you are staying in one of the HUP-Zagreb Properties, you can also contact us by e-mail at dpo@hup-zagreb.hr or by mail at Trg Krešimira Ćosića 9, 10 000 Zagreb, attn. DPO.

5. Reasons for collecting personal data

MAISTRA d.d. is a company that, among other things, provides hospitality services.

We collect different types of personal data about you, depending on your relationship with us and the reasons for our communication.

6. Ways of collecting personal data

We collect your personal data directly from you, indirectly or automatically.

Directly from you

For example, in the following cases, we collect your personal data directly from you:

when you book accommodation, send us a request or otherwise provide us with your personal data;
at check-in and checkout;
when you make a payment;
when you make any additional requests or complaints (communication with our staff, including reception, waiting staff, housekeepers, and concierge services);
when you communicate with us on social media or by email;
during your stay in one of our properties or when using our services (restaurant, spa, wellness);
when you book a table in one of our restaurants and inform us about your preferences and allergies;
when, as a guest, you attend events we host;
when you participate in a prize game, contest, promotional campaign or survey;
when you leave comments about your stay;
when you leave us contact information;
when you join our loyalty programme;
when you use our app.

Indirectly

We collect your personal data indirectly when it is provided to us by another legal or natural person, for example, in the following cases:

if another person makes a booking for you;
if the data about you is provided to us by our business partner, or an agency or intermediary through which you have arranged an accommodation service in our hotels (e.g., travel agency, accommodation booking platform);
if we receive data about you from your airline;
we may also obtain data about you from your payment service provider;
we may also obtain data about you from our advertising service provider.

Automatically

We collect your personal data through automated systems, for the purpose of improving our service or for security, for example, in the following cases:

by you using this website, we collect certain information about how you use our site, as well as device data (such as IP address, browser type);
electronic systems in our rooms record the time of you entering the room;
in some of our properties, we record the use of the services and passes through electronic bracelets that you have received during check-in;
for security reasons and to enable you to use the free internet, we record certain data about your device when you connect to our network;
for security reasons, we can record your photo on our surveillance cameras when passing through public areas (reception, hallway).

7. The types of personal data we collect

Personal data includes any data relating to an identified natural person or other data by which a person can be identified. The data we collect and process about you depends on your relationship with us and the reasons for our communication.

Examples of personal data we collect are:

Identification data
First and last name, form of address, gender, date of birth, username, PIN (OIB), and similar identifiers and data indicated on an identity card or passport.
Contact information
Address, e-mail address, telephone number, preferred language information.
Financial data
Payment details and invoice or credit/debit card number.
Transaction data
Transaction data includes data about which of our services you have used, dates and descriptions of services (stays, food and beverage consumption, prices, spa and wellness services).
Technical data
Technical data includes IP addresses, login information, location data, time zone, browser type and version, operating system, and other data about the technology you use to access our website.
Usage data
Includes data on how you use our website, products and services.
Marketing data
This includes data about your contact preferences.
Data about your preferences
Data on what kind of room you want, type of bedding and similar special requirements.

Special categories of personal data

Special categories of personal data are data on race, ethnicity, religious or philosophical beliefs, sexual orientation, political views, union membership, data about your health, genetic and biometric data.

As a rule, we do not collect these types of data, or data on criminal offences, except in the following exceptional cases:

We collect and process your allergy-related health data, if you have advised us to do so, in order to fulfil a contract and on the basis of your express consent;
As part of the provision of spa and wellness services, we collect data related to health, so that we can fulfil a contract and on the basis of your express consent;
In the case of organising COVID-19 testing, in order to fulfil a contract and for the purpose of protecting public health.
If you have made any of the above data manifestly public.

8. Legal bases for the use of personal data

We process your personal data only if we have a valid legal basis for it. The most common legal bases we rely on will be the following:

Contract
- E.g. , when you book accommodation in one of our properties, you enter into a contract with us.
Legal obligation
- E.g., we check-in guests in the e-Visitor system in order to act in accordance with our legal obligation.
Legitimate interest
- In cases where your rights and freedoms do not prevail over our legitimate interests, we process your data, for example, in order to record via surveillance cameras shared areas in our properties (e.g. reception area) for the protection of property and security. We do not use your personal data under this legal basis if we have determined that this would adversely affect your privacy and that our legitimate interest does not prevail over the obligation to protect your rights and freedoms.
Consent
- As a rule, we do not rely on this legal basis, except in those situations where it is provided for by law and other legal bases are not applicable. For example, we process your data based on consent in the event of communication as part of our loyalty programme.

9. Your personal data

We collect different types of personal data about you, depending on your relationship with us and the services you use. In any case, we collect and process your personal data for legitimate purposes and on a valid legal basis.

By booking accommodation, you enter into an agreement on the provision of accommodation services with Maistra or HUP-Zagreb. We collect the information we need about you in order to establish a contractual relationship and to process a booking. Before your arrival, we will collect and process the information we need in order to provide you with the best and highest quality service and prepare for your arrival.

We also collect some data when you check into our facilities in order to fulfill our legal obligations.

In addition to collecting data to fulfil a contract and comply with our legal obligations, we process data because it is in our legitimate interest to do so, but only when our legitimate interest - based on the assessment we have made - does not prevail over the obligation to protect your privacy. Such situations are, for example, direct marketing or video-surveillance over public areas, such as the reception.

We rely on consent as a legal basis in exceptional cases, for example, when we ask you to provide your consent to join our loyalty programme.

For some types of data processing, several legal bases for data processing are applicable, depending on the circumstances and context. For example, when we process your personal data for the purpose of issuing invoices and billing accommodation, we do so both on a contractual basis and in order to comply with our obligations arising from accounting regulations.

We have listed some basic ways in which we collect your personal data in the table below.

Processing activity	Data type	Legal basis
Accommodation booking Booking the date of stay, choice of property and terms of payment, credit card guarantee or advance payment, making a booking, accepting the booking and sending a booking confirmation Booking management Preparation of documentation in accordance with accounting regulations	Identification data, contact information, payment information	Entering into a contract and providing a contractual service Legitimate interest (managing the business and managing products and services) Compliance with a legal obligation
Check-in/check-out Registration and check-out of a guest,, room allocation Guest registration in internal systems, pairing the guest with requested offers and services, data entry in the e-Visitor system Entering data on guest preferences and requirements, and further communication options.	Identification data, contact information, preference data, marketing data	Compliance with a legal obligation Providing a contractual service Legitimate interest (guest record keeping, communication and business management) Explicit consent (health and allergy data)
Booking services during the stay Choosing dates and ordering additional services during the stay – restaurants and bars, spa and wellness	Identification data, contact information, transaction data, marketing data	Providing contractual services Legitimate interest (guest record keeping, communication and business management) Explicit consent (health data)
Use of services during the stay Use of additional services during the stay – restaurants and bars, spa and wellness Monitoring the use of accommodation services during the stay (TV, minibar, room service)	Identification data, contact information, transaction data, marketing data	Providing contractual services. Legitimate interest (guest record keeping, communication and business management) Explicit consent (health data)
Complaints/requests Making additional requests at the reception during the stay (special wishes, deliveries and similar services) Using concierge services Complaints	Identification data, transaction data, preference data	Providing contractual services Legitimate interest (managing the business, managing staff and improving the service provided)
Answering queries Sending answers to guest inquiries	Identification data, contact information	Providing contractual services Legitimate interest (managing the business, managing staff, improving services, analytics)
Property security Surveillance cameras Electronic cards/keys	Identification data (recording, entrance to the room)	Legitimate interest (protection of security of property and persons)
Membership of loyalty programme Accessing the loyalty programme, sending promotional offers, collecting information on preferences in order to adjust the business and personalise offers	Identification data, contact information, preference data, marketing data	Consent Execution of contractual obligations related to your membership of the loyalty programme.
Direct marketing Contacting a guest at their e-mail address by sending offers for similar services in accordance with the provisions of the Electronic Communications Act.	Identification data, contact information, preference data, marketing data	Legitimate interest (managing the business, delivering information about our offers and services, personalisation of offers and recommendations of similar services)
Satisfaction surveys and questionnaires Contacting a guest at their e-mail address or delivering a flyer to request a guest to complete a guest satisfaction survey or questionnaire	Contact information	Legitimate interest (managing the business, informing about customer satisfaction in order to improve the service)
Payment, billing and refund Issuing invoices, payments, billing of receivables and refunds to guests	Identification data, contact information, financial data, transaction data	Providing contractual services Acting in accordance with a legal obligation
Participation in a prize game or prize contest Participation in a prize game or competition in accordance with defined rules	Contact information, identification data	Consent
Advertising Preparing and sending ads, monitoring the effectiveness of submitted ads.	Identification data, contact information, usage data, marketing data, technical data, preference data	Consent (for re-targeting) Legitimate interest (monitoring the effectiveness of ads business planning, developing marketing campaigns and business strategies)
Giving recommendations on accommodation and services Recommendation of accommodation and services to guests, personalisation of the service	Identification data, contact information, preference data	Providing contractual services Legitimate interest (personalisation of the service and ameliorating guest experience)
Enabling the use of the internet Connecting the guest to the internet	Technical data, usage data	Providing contractual services Legitimate interest (maintaining the security of IT systems)
Using the hotel app Using the hotel app to manage the services used during the stay Overview of invoices, transactions, food and beverage consumption	Contact information, identification data, usage data, transaction data, technical data	Legitimate interest (managing the business, enabling the guest to use all the functionalities of the stay in a clear manner and have an insight into the overview of costs and the security of the system)
Analytics and business planning Guest segmentation and analysis of guest behaviour regarding past stays and indicated preferences. Developing models for further planning, analysis and reports	Transaction data, contact information, preference data, marketing data	Legitimate interest (improving the service, creating bids, strategic business planning)
Incident monitoring Internal lists of guests who caused incidents and are undesirable guests in our facilities due to inappropriate behaviour (unpaid services, aggressive incidents towards staff or other guests, theft, vandalism)	Identity data, behaviour description	Legitimate interest (protection of security of property and persons) Establishment and defence of legal claims
Compensation claims Keeping records of guest compensation claims, incident description, communication with third parties	Identification data, contact information, incident data	Legitimate interest (protection of property and reputation) Establishment and defence of legal claims
COVID-19 testing Organising antigen and PCR testing of guests in cooperation with the epidemiological service	Identification data, contact information, health data	Providing contractual services Legitimate interest (protection of safety and health of others) Explicit consent Protection of public interest in terms of public health (obligation to disinfect premises and organise isolation)
BABY and MINI club / KIDS zone Organising entertainment of children and stay of children in rooms with communal games	Parent identification data, parent contact information, child age data, child health data	Providing contractual services Explicit consent
Website security protection Protection of our business and website security (debugging, data analysis, testing, system maintenance, support, reports)	Technical data, usage data	Legitimate interest (maintaining service continuity, network security and protection)
Analytical website monitoring Improving website functionality, recognising interests, service optimisation and marketing strategies	Technical data, usage data	Legitimate interest (business development, marketing strategy, strategic planning)
Social networks Communication through social media profiles	Identification data, contact information	Providing contractual services Legitimate interest (communication with guests, management of guest expectations, marketing strategy)
Restaurant bookings Restaurant table reservations. Online platform bookings at select Maistra restaurants (Cap Aureo signature restaurant, Wine Vault restaurant and Agli Amici Rovinj).	Identification data, contact information, form of address, preferences and allergies, payment data	Actions required to enter into a contract. Legitimate interest (personalisation of a service in order to provide guests with a better restaurant experience) Explicit consent (allergy and health data)
Mobile App Use Booking accommodation in the property of choice, check-in and checkout, restaurant bookings, room service, ordering special services (cleaning, repairs, etc.), account overview with transactions and food & beverage consumption, feedback on stay at the property, collecting preference data, information on loyalty programme	Identification data, contact information, form of address, preference data, payment details.Marketing data, technical data, usage data, financial data, transaction data	The consent given when installing or using the mobile app

10. Cookies

Our website collects cookies that contain certain information about how and in what way you use our website. Cookies are small text files that contain a unique identification and reference code that the web browser saves on your device and with which we can recognise you again when you access our website.

We do not use this data to identify you, nor do we use third party cookies for this purpose. Some cookies we collect last only during your use of our site, and some last a little longer, so that we can recognise you when you access our site again.

More information about cookies can be found here.

11. Direct marketing

Direct marketing is the sending of promotional offers in which we offer you similar services to your address or email address and via messaging apps or SMS.

Each such communication will include an easy option to unsubscribe (either by clicking a provided link or sending a specific message to a designated number) ensuring you can request not to be contacted in this manner again. In addition, you can contact us in writing at our email address: dpo@maistra.hr.

12. Personalisation and advertising

For the purpose of personalising the service, we use identification data, contact information and transaction data. At a general level, we may analyse the behaviour of our users and try to assess their specific interest. Based on this, we may group users, and based on such segmentation, we show personalised ads.

Just because you see one of our ads, it does not mean that Maistra created your profile, it is possible that we just rented advertising space and you happened to come across one of our ads. In cases where we send targeted ads, we do so on a retargeting basis, in collaboration with partners. Even then, this is not confirmation that Maistra has created your profile, but it is possible that our partner – e.g. Facebook or Google – based on other options and your use of other websites that Maistra does not have access to, estimated that you belong to a target group that might be interested in our ads.

Automatic data processing for advertising purposes does not affect your rights or our services that you may use.

13. Statistics

For the needs of our business, strategic planning and making important business decisions, we use statistical data analysis. This means that, based on a legitimate interest, we will process the data we have collected and processed about you on another legal basis, for example to comply with legal obligations or fulfil a contractual obligation, such as your age, nationality or the language you speak.

When we process your data for statistical purposes, we continue to use it exclusively in an aggregated, depersonalised form. This means that this data can no longer be linked to you in any way and no longer represents your personal data.

14. Recipients of personal data

We do not share your personal data with third parties for the purpose of advertising their services. We will not sell your personal data to third parties.

In certain cases, we will share your personal data with other recipients, as follows:

With affiliated companies or companies that are affiliated companies of Adris Grupa d.d., which is the majority shareholder of MAISTRA d.d. and HUP-ZAGREB d.d.;
In cases where it is necessary to share your personal data in order to fulfill a contract to which you are a party;
In cases where you have agreed to share your personal data with a third party (e.g. in the case of the use of cookies);
With judicial, tax, auditing and other competent authorities, when we have reason to believe that we are obliged by law and other regulations to share such data (for example, at the request of the tax authority or in connection with expected litigation);
With payment service providers with whom we have concluded agreements on the processing of personal data;
With hotel associations with which we have concluded agreements on the processing of personal data (e.g. Leading Hotels of the World);
With IT service providers with whom we have concluded appropriate data processing agreements, and whose systems we use in our business (e.g. PHOBS booking system (Phobs d.o.o.), Opera guest database (HRS International) and Laser Line (Laser Line d.o.o.), CRM system (BE-Terna d.o.o.), Microsoft Office 365, Superb restaurant booking service);
With the e-Visitor system, in accordance with the regulations on the provision of hospitality services and the manner of keeping a list and registration of tourists;
With other service providers who provide a specific service for us, including external consultants, investment advisory service providers, professional advisors such as auditors, lawyers or accountants, marketing and market research agencies, technical support service providers and IT consultants who conduct certain testing or work on developing technical solutions in our systems;
In case of a merger or takeover of Maistra or HUP-Zagreb d.d. in the future, we may share your personal data with the new owners of the company, and certain personal data may also be transferred during the purchasing process, to potential customers and their advisors, as part of the due diligence process.
With the mobile app service provider, if used

15. Cross-border data transfers

We want to ensure that your personal data is stored and transferred securely. Therefore, outside the European Economic Area (hereinafter: EEA), we will only transfer data if this complies with the applicable data protection regulations and if the means of transmission ensure an adequate level of security for your data, for example:

Transfer of data to a third country, based on a decision of the European Commission on adequacy, which establishes that the legislation of that country has ensured an adequate level of data protection; or
A Data Transfer Agreement concluded with a third party, which contains standard contractual clauses accepted by the European Commission for data transfer cases within the EEA, to controllers and processors in jurisdictions without an adequate level of data protection; or
if you have expressly consented to the data transfer.

When we transfer your data outside the EEA and in cases where the country or territory to which the data is transferred does not ensure an adequate level of data protection, we will take all reasonable steps to ensure that your data is treated securely and in accordance with the privacy policy contained in this Privacy Notice.

16. Security of personal data

We apply technical and organisational measures to ensure that your data is secure and to protect it from accidental or intentional unauthorised access, loss or modification. We have ensured that your data can be accessed only by those persons who have a business need for it, solely for the purposes that are permitted and of which you have been notified, and that these persons are obliged to keep your data confidential.

If you suspect any unauthorised use, loss or unauthorised access to your personal data, please notify us.

17. Data storage and retention periods

We store your data as long as it may be necessary in accordance with the purpose for which it was collected, including in order to comply with legal obligations. After the expiry of the retention period, we will delete the data, and in cases where this is not technically possible, we will make the data unreadable. In the event that we still need some data for legitimate business purposes after the retention period has expired, we will take appropriate steps to anonymise that data.

According to the law, we keep data on guests for at least two years after the year of stay, and we must keep data in the e-Visitor system for 10 years.

We keep data related to accounting regulations for 11 years. This includes invoices and bills that may contain your personal data.

If using a credit card to guarantee a reservation, we keep a record of credit card data in our system up to 30 days after you check out; if a credit card is charged in the amount of the guarantee, we store the data in accordance with accounting regulations.

If we use your credit card data for the purpose of guaranteeing your reservation, we will keep this information in our systems for a maximum period of 30 days after your check-out. If the guarantee is used and we charge your card, this information will be retained for a longer time period, in line with accounting regulations.

We store data based on our legitimate interest in accordance with justified and reasonable business needs.

We keep data related to surveillance videos for up to six months.

We store the data we collect on the basis of consent, until the consent is withdrawn.

18. Your rights regarding the processing of personal data

Access. You have the right to access your personal data at any time by sending a request requesting that we provide you with all your personal data that we process.

Restriction of processing. You have the right to object to certain processing activities, for example, if we process your personal data on the basis of a legitimate interest.

Portability. You have the right to request a transfer of personal data to another service provider – in practice, this means that you have the right to request that we provide you with all personal data that we process in a machine-readable format or to request that we provide it directly to another company.

Rectification. You have the right to request an update, rectification or supplementation of your personal data at any time.

Erasure. You have the right to request the deletion of your personal data. We will comply with your request if we do not have a legal obligation or a valid reason of a legal or business nature for which we should continue to keep it.

Withdrawal of consent. In the event that we process your data on the basis of consent, you are entitled to withdraw your consent at any time. We will stop processing personal data collected on this legal basis without delay.

You can make all requests by sending a written request to the business address MAISTRA d.d. in Rovinj, Obala Vladimira Nazora 6 (attn. DPO) or by e-mail to dpo@maistra.hr. If you are staying in properties in Zagreb or Dubrovnik, you can also send a written request by e-mail to dpo@hup-zagreb.hr or by mail to the address HUP-ZAGREB d.d., in Zagreb, Trg Krešimira Ćosića 9 (attn. DPO).

Complaint. You are also entitled to submit a complaint to the local supervisory authority for data protection – the Croatian Personal Data Protection Agency, at the address:

Agencija za zaštitu osobnih podataka
Selska cesta 136
HR – 10 000 Zagreb
Tel. +385 (01) 4609-000
Fax. + 385 (01) 4609-099
E-mail: azop@azop.hr**
Web: www.azop.hr**

We inform you that we will keep records of our communication so that we can resolve any issue you contact us about as efficiently as possible.

We process your rights free of charge, and we will only exceptionally charge you the administrative cost of processing the request, in accordance with the provisions of the GDPR. In that case, we will notify you before the cost is incurred.

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