Data protection



This privacy policy applies to data processing by:


Sunside Apartments Pula

Nada Zubak

Cerella 6 entrance

52100 Pula

Email: info@sunside-apartments-pula.eu

 

1. Protecting your data is important to us!


We want you to feel secure regarding the protection of your personal data when visiting our website. We want you to know when we collect which data and how we use it. We have implemented technical and organizational measures to ensure that data protection regulations are observed by both us and any external service providers we engage.


2. Processing of personal data and the nature and purpose of its use


Personal data is any data that allows for the identification of you by reasonable means, e.g., details such as name, address, telephone number, email address, date of birth.


a. Visit website


When you access our website, your internet browser automatically sends various pieces of information to our website's server. This information is stored temporarily.


This includes, as standard, the following:

  • IP address of the requesting computer,
  • Date and time of access,
  • Name and URL of the retrieved file,
  • Website from which access is made (referrer URL),
  • Device information
  • browser used and, if applicable, the operating system of your computer as well as the name of your access provider.


We process the aforementioned data for the following purposes:

  • Ensuring a smooth connection to the website,
  • Ensuring a comfortable user experience on our website,
  • Evaluation of system security and stability as well as
  • for other administrative purposes.


The legal basis for data processing is Article 6(1)(f) GDPR. Our legitimate interest arises from the purposes of data collection listed above. Furthermore, we use cookies and analytics tools when you visit our website. You can find more detailed information about this in this privacy policy.


b. Booking inquiries and email contact


If you make a booking request via our website, we need your personal data so that we can send you an offer, fulfill our other contractual obligations and process your requests.


The provision of personal data is partly necessary for the conclusion of the contract. Failure to provide this data will result in the contract not being concluded. Processing is based on Article 6(1)(b) GDPR and is necessary for the performance of the contract to be concluded with you (e.g., name, address, email, date of birth). Your data will not be disclosed to third parties without your explicit consent. The only exceptions are our service partners, on whom we rely to fulfill our contractual obligations, and service providers whom we use for order processing. In addition to the recipients already named in this privacy policy, these include, for example, tourist registration offices, payment service providers (banks), web hosting providers, and IT service providers. The scope of data transfer is limited to the minimum necessary.


c. Contact


If you have any questions, please feel free to contact us. A valid email address is required so we know who is contacting us and can respond. Data processing for the purpose of contacting you is based on your freely given consent in accordance with Article 6(1)(a) of the GDPR. The personal data collected for contacting you will be automatically deleted once your inquiry has been resolved.


3. Cookies


We and our partners use cookies to provide our services. This also applies when you visit our website or access our services. A cookie is a small data packet that is assigned to your device (e.g., laptop, tablet, smartphone) when you visit a website. Cookies are useful and can be used for various purposes. These include, for example, easier navigation between different pages, the automatic activation of certain functions, saving your settings, and optimized access to our services. The use of cookies also allows us to collect statistical information about your use of our services and to make your experience more convenient.


We use so-called "session cookies" to recognize that you have already visited individual pages of our website. These are automatically deleted when you leave our site.


Furthermore, we also use "persistent cookies" to optimize user-friendliness. These cookies are stored on your device for a specific, predetermined period. When you revisit our site to use our services, it is automatically recognized that you have already been here and what entries and settings you have made, so you don't have to enter them again.


Secondly, we use "third-party cookies" which are set by other online services that are represented with their own content on the page you are visiting. These can be, for example, external web analytics companies that record and analyze access to our website.


Cookies store information related to the specific device you are using. This does not mean that we gain direct knowledge of your identity. Most browsers accept cookies automatically. However, you can configure your browser to prevent cookies from being stored on your computer or to always display a notification before a new cookie is created. Completely disabling cookies may prevent you from fully utilizing all the features of our website.


The tool we use is based on Snowplow Analytics technology. The data we collect about website usage includes, for example, how often users visit the website and which areas are accessed. The tool we use does not collect any personal data and is used by our web hosting provider and service provider solely to improve their own services.

The data processed by cookies is necessary for the aforementioned purposes to protect our legitimate interests and those of third parties in accordance with Art. 6 I S.1 lit. f GDPR.


4. Cookie consent with Usercentrics


This website uses Usercentrics' cookie consent technology to obtain your consent to the storage of certain cookies on your device or the use of certain technologies and to document this in accordance with data protection regulations. The provider of this technology is Usercentrics GmbH, Rosental 4, 80331 Munich, website: https://usercentrics.com/de/ (hereinafter referred to as "Usercentrics").


When you visit our website, the following personal data is transferred to Usercentrics: your consent(s) or the withdrawal of your consent(s), your IP address, information about your browser, information about your device, and the time of your visit to the website. Furthermore, Usercentrics stores a cookie in your browser to associate your given consent(s) or their withdrawal with you. The data collected in this way is stored until you request its deletion, delete the Usercentrics cookie yourself, or the purpose for data storage no longer applies. Mandatory legal retention obligations remain unaffected. Usercentrics is used to obtain the legally required consent(s) for the use of certain technologies. The legal basis for this is Article 6(1)(c) GDPR.


5. Use of script libraries (Google Web Fonts)


To ensure our content is displayed correctly and attractively in every browser, we use script and font libraries such as Google Web Fonts (https://www.google.com/webfonts) for this website. Google Web Fonts are cached in your browser, so they only need to be loaded once. If your browser does not support Google Web Fonts or blocks access to them, the content will be displayed in a standard font. When script or font libraries are accessed, a connection is automatically established with the library provider. Theoretically, this provider could collect data. Currently, it is unknown whether and for what purpose the providers of the respective libraries actually collect data.

Here you can find the privacy policy of the operator of the Google library: https://www.google.com/policies/privacy .


6. Analysis of user behavior using the web analytics service 1&1 WebAnalytics


This website uses the analytics services of 1&1 WebAnalytics. The provider is 1&1 IONOS SE, Elgendorfer Straße 57, D – 56410 Montabaur. As part of the analysis with 1&1 IONOS SE, visitor numbers and behavior (e.g., number of page views, duration of a website visit, bounce rates), visitor sources (i.e., the website from which the visitor came), visitor locations, and technical data (browser and operating system versions) are analyzed. For this purpose, 1&1 IONOS SE stores the following data in particular:


  • Referrer (previously visited website)
  • requested website or file
  • Browser type and browser version
  • Operating system used
  • Device type used
  • Time of access
  • IP address in anonymized form (used only to determine the location of access)


According to 1&1 IONOS SE, data collection is completely anonymized, meaning it cannot be traced back to individual persons. 1&1 WebAnalytics does not use cookies. The data is collected either via a pixel or a log file, according to 1&1 IONOS SE. The storage and analysis of the data is based on Article 6 Paragraph 1 Letter f of the GDPR. The website operator has a legitimate interest in the statistical analysis of user behavior in order to optimize both its website and its advertising. If corresponding consent has been obtained, processing is carried out exclusively on the basis of Article 6 Paragraph 1 Letter a of the GDPR; this consent can be revoked at any time.


For further information on data collection and processing by 1&1 WebAnalytics, please see the following links:

https://www.ionos.de/hilfe/datenschutz/datenverarbeitung-von-webseitenbesuchern-ihres-11-ionos-produktes/webanalytics/


https://www.ionos.de/terms-gtc/terms-privacy/


 7. belegungskalender-kostenlos.de


This website uses HTML code from www.belegungskalender-kosenlos.de to display our available apartments. We do not transfer any of your personal data to this calendar. Below the calendar is a link that leads to the website of the availability calendar provider, and we have no control over its content. Therefore, we cannot assume any responsibility for this external content. The respective provider or operator of the linked pages is always responsible for their content. If you visit third-party websites via our site, please refer to their respective privacy policies.


8. cloudfront.net


This website uses the CloudFront Content Delivery Network (CDN). This is a service provided by Amazon Europe Core S.à rl (Société à responsabilité limitée), 5 Rue Plaetis, L-2338, Luxembourg. The CloudFront CDN provides duplicates of website data on various Amazon Web Services (AWS) servers. This results in faster website loading times, increased reliability, and enhanced protection against data loss. Some of the images embedded on this website are retrieved from the CloudFront CDN when the page is accessed. This retrieval process transmits information about your use of our website (such as your IP address) to Amazon servers, where it is stored for the duration of processing. The use of Amazon Web Services and the Amazon CloudFront CDN is in the interest of increased website reliability, enhanced protection against data loss, and improved website loading speed. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. You can find out more about Amazon Web Services' data protection measures at: https://aws.amazon.com/de/compliance/data-privacy-faq/?nc=sn&loc=4


9. gstatic.com


This website uses gstatic.com, a web service provided by Alphabet Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. This domain is used by Google to load static content into a different domain name in order to reduce bandwidth usage and improve network performance for the end user. In this context, your browser may transmit personal data to gstatic. The legal basis for this processing is Article 6(1)(f) GDPR. The legitimate interest lies in ensuring the proper functioning of the website. Gstatic has self-certified under the EU-US Privacy Shield Framework (see www.privacyshield.gov/list). The data will be deleted as soon as the purpose for which it was collected has been fulfilled.


For more information on how the transferred data is handled, please see Gstatic's privacy policy: policies.google.com/privacy. You can prevent Gstatic from collecting and processing your data by disabling script execution in your browser or by installing a script blocker.


10. Data protection regulations regarding the use of Instagram


We maintain publicly accessible profiles on the social network Instagram. The Instagram service is one of the Facebook products provided by Facebook Ireland Limited (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). Social networks are able to analyze your user behavior and process certain information about you when you visit our Instagram pages.

Please note that using the Instagram page is at your own risk. This applies in particular to interactive features such as commenting, sharing, or rating. Facebook processes personal data related to your account, your IP address, and the devices you use. Cookies are used for data collection; these are small files that are stored on your devices. If you have an Instagram profile and are logged in, the data is stored and analyzed across multiple devices. Facebook describes what information it receives and how it is used in its Instagram Data Policy: https://de-de.facebook.com/help/instagram/519522125107875. There you will also find information on how to contact Facebook and how to object to this data processing.

Facebook provides us, as operators of Instagram pages, with statistical information (so-called "Instagram Insights"), such as accounts reached, content interactions, total number of followers, number of shares, gender and age distribution, origin by country and city, language, and clicks. This "Instagram Insights" is provided to us anonymously. The processing of this data serves our legitimate interest in evaluating actions on our Instagram page and improving our content based on these insights. The legal basis for this is Article 6(1)(f) GDPR.


When you visit our Instagram page, you trigger the processing of your personal data. In this case, we are jointly responsible with Facebook for these data processing operations within the meaning of Article 26 GDPR. You can generally assert your rights (right of access pursuant to Article 15 GDPR, right to rectification pursuant to Article 16 GDPR, right to erasure pursuant to Article 17 GDPR, right to restriction of processing pursuant to Article 18 GDPR, right to data portability pursuant to Article 20 GDPR, and right to lodge a complaint pursuant to Article 77 GDPR) against both us and Facebook. Since only Facebook has full access to user data, and we, as the page operator, have no influence on the generation and display of statistics, we can only forward your request to Facebook and therefore recommend that you contact Facebook directly. Should you require assistance, please contact us by email.


This website does not use any Instagram plugins, but only social bookmarks (buttons with the Instagram icon). These are integrated into the website as links to Instagram. Clicking on the embedded graphic redirects the user to the Instagram page. If you are logged into Instagram, a cookie containing your Instagram ID will be stored on your device, allowing Facebook to track that you visited this page and how you used it. Through Instagram buttons embedded in websites, Facebook can record your visits to these pages and associate them with your Instagram profile. If you wish to prevent this, you should log out of Instagram, delete cookies stored on your device, and close and restart your browser before visiting our site. Information on how to manage or delete information about you can be found here: https://de-de.facebook.com/about/privacy#


11. Google reCAPTCHA


We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. The service provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”). reCAPTCHA verifies whether data entered on our websites (e.g., in a contact form) is entered by a human or is being misused by automated, machine processing. The query involves sending the IP address and, if applicable, other data required by Google for the reCAPTCHA service to Google. For this purpose, your input is transmitted to Google and further processed there. reCAPTCHA analyzes the behavior of visitors to our website based on various characteristics. This analysis begins as soon as the website visitor enters the website. To do this, reCAPTCHA evaluates various pieces of information (including the IP address, the visitor's time spent on our various pages, and mouse movements). This data collected during the analysis is forwarded to Google. However, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on our behalf to evaluate your use of this service. The IP address transmitted by your browser as part of reCAPTCHA will not be merged with other Google data. Your data may also be transferred to the USA. For data transfers to the USA, there is an adequacy decision by the EU Commission, the "Privacy Shield". Google participates in the "Privacy Shield" and has committed to its requirements. By submitting the query, you consent to the processing of your data. The processing is based on Article 6(1)(a) GDPR with your consent.

The IP address transmitted by your browser as part of reCAPTCHA is not merged with other Google data. Google's separate privacy policy applies to this data.

The reCAPTCHA analysis runs entirely in the background. Data processing is based on Article 6(1)(f) GDPR. We have a legitimate interest in protecting our website from abusive automated access and spam contact requests.

Further information on Google's privacy policy can be found at: https://policies.google.com/privacy?hl=de and https://www.google.com/recaptcha/intro/android.html.


12. Data security


To protect your data, our website uses the widely used SSL (Secure Socket Layer) protocol in conjunction with the highest level of encryption supported by your internet browser. This is typically 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can recognize whether a particular page of our website is transmitted in encrypted form by the closed padlock symbol in the lower status bar of your browser.


We also employ appropriate technical and organizational security measures to protect your data against manipulation, loss, destruction, or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments. Although we take reasonable steps to protect data, we cannot be held responsible for the actions of those who gain unauthorized access to or misuse our website, and we make no express or implied warranty that we can prevent such access.


13. Transfer of data outside the European Economic Area


Please note that some recipients may not be located within the European Economic Area. If this is the case, we will only transfer your data to countries approved by the European Commission as having an adequate level of data protection, or we will ensure an adequate level of data protection through a legal agreement.

14. Storage duration


We store your data for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our policies. Even after the contract has been fully fulfilled, your data will be stored for the duration of the warranty period, in accordance with applicable legal retention periods, particularly those under Croatian tax and commercial law. If you have not consented to further processing and use, your data will be deleted after the retention period expires. We may, at any time and at our sole discretion, correct, complete, or remove incomplete or inaccurate data.


15. Disclosure of data to third parties


Except as explained in this privacy policy, your data will only be disclosed to third parties without your explicit consent if there is a legal obligation to do so or if required by an official or judicial order.


16. Data collection by third parties


This policy only covers the use and disclosure of data we collect from you. If you post data on other websites or disclose it to third parties online, other terms and conditions may apply. Therefore, always read the terms and conditions and privacy policies carefully before disclosing any data.


This privacy policy does not apply to the business practices of companies that we do not own or control, or to individuals other than our employees and staff, including third parties to whom we disclose this data as described in this privacy policy.


17. Legal reporting obligation (eVisitor system in Croatia)


As a registered private landlord in Croatia, we are legally obliged under the Croatian Hospitality Act (Zakon o ugostiteljskoj djelatnosti) to collect and report the personal data of all guests staying in our apartments.


  • Data collected: First and last name, nationality, date of birth, place of birth, gender, type and number of identification document (identity card or passport) and the exact booking period.
  • Purpose and legal basis: The data collection and subsequent reporting in the central state system eVisitor is carried out to fulfill our legal obligations (Art. 6 para. 1 lit. c GDPR) and for the proper billing of the tourist tax (Turistička pristojba).
  • Recipients of the data: The data will be transmitted in encrypted form to the Croatian Tourist Board (Hrvatska turistička zajednica) and to the Croatian Ministry of Tourism and Sport.
  • Storage period: In accordance with the applicable legal regulations of the Republic of Croatia, the data in the eVisitor system must be stored and retained for 10 years.


18. Rights of data subjects


You have the right to access, rectification, erasure, withdrawal of consent, restriction of processing of your data, and data portability. If your personal data is processed on the basis of legitimate interests pursuant to Article 6(1)(f) GDPR, you have the right to object to the processing of your personal data pursuant to Article 21 GDPR, provided there are grounds relating to your particular situation, and to data processing for direct marketing purposes. Pursuant to Article 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data is unlawful.


If you wish to exercise your aforementioned rights, simply send us an email.


19. Updates and changes to this privacy policy


Due to the ongoing development of our website or changes in legal or regulatory requirements, it may become necessary to amend this privacy policy. The current privacy policy can be accessed and printed from our online shop at any time.



20. Questions, suggestions, complaints


If you have any questions about our privacy policy or the processing of your personal data, please contact us directly at: info@sunside-apartments-pula.eu


This privacy policy is current as of May 2024.