Privacy policy

Effective date: May 7th, 2018

  1. Data controller

The Plusculus putnicka agencija Ltd with its headquarters in Hvar, OIB: 39713869851 and the Croatian Gas Centre Ltd. OIB: 93249648961 (“PPA , “we” or “us”) respect your privacy and undertake to protect it during and after your visit to this website, its associated mobile website and any micro website (which may be administered on behalf of PPA by a third party that usually operates as a processor) and which can be accessed through this website (hereinafter: “Website” and “Websites”). Accordingly, PPA operate as the controller (“Controller”). This privacy policy (“Privacy Policy”) provides insight into our procedures regarding the processing of your personal data.

  1. Types of personal data that are processed

PPA collect and process personal data about you (e.g. information that can directly or indirectly identify you, in particular using identifiers such as name, email and IP address (“Personal data”), in cases such as when:

  • You use the Book now! form on our Website,
  • You use the contact form on our Website,
  • You provide comments or ask questions,
  • You seek information or use other features or function of the Website,
  • You contact us or connect with us through social media
  • We take photographs of events and activities we organize,
  • We contact you with regards to our products, services or events,

PPA will not collect Personal Data if you do not provide it voluntarily, except for certain Personal Data collected by information systems and programs used for operating the Website, the transmission of which is necessary for using Internet communication protocols (e.g., IP addresses when executing an order or application) and will not require more information than is needed to participate in certain activities. If you do not want to provide us with your Personal Data (besides Personal Data relating to the use of internet communication protocols that are usually collected when visiting the Website) you may still access our Website, but you may not be able to participate in certain events, properly register, activate or use a specific service, complete an order or get information about a particular event, apply for a job or contact us.

  1. Cookies
  • Google Analytics and Google Tag Manager

This Website utilises Google Analytics and Google Tag Manager, web analysis activities from Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”) that uses so-called cookies, i.e., small files stored on your computer. We collect the log information and information about how many visitors visited specific pages on the Website. Google analyses the use of the Website and cookies enable analysis of the visits to the Website by assigning a unique randomly generated ID to your device according to which your device is identified when visiting the Website later. The cookie is provided by Google and the lifespan is 24 months. If you visit this Website for the first time, a notice will be displayed on the webpage requesting that you provide consent to the use of cookies. If you provide your consent, we will store the cookie on your computer and the notice will not reappear during the lifespan of the cookie. After expiration of the cookie lifespan, or if the cookie is erased beforehand, the notice will reappear on your next visit to the Website and again the invitation to resubmit your consent will appear. The information that Google collects regarding your use of the Website (e.g., your entry URL, the webpages you visited on our Website, the web browser you are using, your language preferences, the operating system you are using, or the resolution of your display) are uploaded to Google’s server in the US, they are stored, analysed, and become available to us in an anonymous form. Data on your usage is not associated with your full IP address. We have activated on this Website Google’s IP anonymisation function so that the last 8 digits (type Ipv4) or the last 80 bits (type Ipv6) of your IP address are deleted.

Google has been certified in connection with the EU-US Privacy Shield so that data processing by Google in the United States is subject to an appropriate level of personal data protection. You can withdraw your consent for web analysis at any time by downloading and installing Google’s Browser Plugin. For more information about Google Analytics, please refer to Google Analytics Terms of Use, the Google Analytics Data Privacy and Security as well as Google’s Privacy Statement.

  • Social media

PPA collect Personal Data on their contacts from social media (Facebook, Google+) and contact them through messages, and also send promotions to specific anonymous target groups (gender, age, interest in travel topics).

  1. Purposes, legal basis for processing and possible consequences of non-disclosure of Personal Data

When you provide your Personal Data, we will restrict the use of Personal Data for the purpose for which they have been collected in accordance with the terms of this Privacy Policy. Use of your Personal Data includes:

  1. Take steps at your request before concluding a contract (e.g., answering your questions and comments, filling out your requests, submitting an application form or offer, receiving an offer, communicating with you about your Website activities, processing the application for an open job position or the job application);
  2. Execution of a contract to which you are a party (e.g., act in accordance to your application for a particular event or advertisement, provide access to specific areas and features on the Website, provide specific services);
  3. Investigating suspicion of fraud, harassment, physical threats, or other violations of any laws, rules or regulations, Website rules or the rights of third parties; or investigate any suspicious behaviour that we consider inappropriate;
  4. Compliance with the legal obligation to which PPA are subject (e.g., disclosures prescribed by law, regulation or a court order);
  5. For the purposes of or in connection with legal proceedings, establishment, defence or exercising of legal rights;
  6. Submitting ads or direct sales materials or conducting market research, performing data analytics or delivering commercial communications via electronic tools (SMS, e-mail, social media), regardless of whether automated (calls without an operator) or not, appropriate legal grounds, based on the legitimate interests or given consent of respondents;
  7. Photographing participants at events organised by PPA, based on the consent of participants, for the purpose of promoting events.

Providing Personal Data for the above purposes of 1 to 7 is voluntary, but any refusal to provide such data may prevent PPA from making a contract with you, responding to your requests, providing you with services, receiving from your and processing your application for a certain event and complying with the legal obligations that PPA are subject to.

The submission of Personal Data for purposes described in points 6 and 7 is also voluntary; failure to provide such Personal Data or objections to processing Personal Data based on the appropriate grounds related to your specific situation may prevent PPA from sending adverts or direct sales materials or conducting market research, data analytics or commercial communications. We may still contact you for administrative purposes, such as confirmation of an application, confirmation of an order, or requesting your further requests.

  1. Recipients

While strictly connected to the above-mentioned purposes, your Personal Data may be disclosed to:

  • Persons necessary for execution of orders, registering for events, delivering packages, send  electronic mail, removing redundant information from a list of recipients receiving services, analysing of data and providing marketing support, taking photographs of events, credit and debit card processing and the provision of customer services, who typically process Personal Data on behalf of PPA as processors;
  • Persons that maintain our IT systems,
  • Persons authorised by PPA for processing Personal Data, subject to the appropriate legal obligation of confidentiality (employees of PPA);
  • Bodies of PPA, subject to the appropriate contractual obligation of confidentiality;
  • Law enforcement departments and public authorities when required by governing law or in good faith (e.g., to comply with the provisions of laws or comply with legal proceedings in relation to PPA, protect and defend the rights or property of PPA and the Website, or in urgent circumstances, to protect the personal safety of PPA users, their Websites or the public);
  • Legal and financial counsellors of PPA in the event of the need to forward data for legal, tax and auditors proceedings,
  • Business partners for their requirements but only in accordance with the appropriate legal basis.
  1. Retention of data

PPA will process your Personal Data only as long as necessary to achieve the purposes described in Section 4. Regarding the purposes described in sections 4.6 and 4.7, your Personal Data will be processed until you exercise your right to object or until you withdraw your consent for the processing of your Personal Data. In addition to the foregoing, PPA will retain your Personal Data as required or permitted in accordance with governing laws (e.g., for at least 11 years, in accordance with the Accounting Act, keeping official documents based upon which data is entered into the diary or main ledger).

  1. Your rights

PPA hereby inform you that, in accordance and to the extent permitted by governing law, you have the right to request PPA access and correction or deletion of your Personal Data or limit processing related to your Personal Data and to object to relevant processing activities, transfer personal data and to file a complaint with the competent supervisory body (in the Republic of Croatia, the Croatian Personal Data Protection Agency). You also have the right to know the recipients or categories of recipients to whom your Personal Data was or will be disclosed, especially recipients in third countries.

  1. Links to other websites

The Website may contain links to other websites that are not owned, managed, or maintained by PPA. When you leave the Website, you should notice and read the privacy policy of each website you visit. Furthermore, you should independently assess the authenticity of any Website that appears or claims to be one of our Websites (including those associated with e-mail). Regardless of all links that may exist on the Website, unless otherwise stated, we do not control, recommend or refuse, and are not affiliated with, or subject to, these websites or their content, products, services or privacy policies. Downloading materials from certain websites may result in violation of intellectual property rights or infecting your computer system with viruses.

  1. Security practices

Security surrounding your Personal Data is exceptionally important to us, therefore we have set up the appropriate physical, electronic, and management procedures to protect the data we collect. However, due to inherent open nature of the Internet, we cannot guarantee that communication between you and us or the information stored on the Website or on our servers will be completely safe from unauthorised access by third parties. To the greatest extent permitted by governing law, we waiver all responsibility and all liability for any damages that you may incur due to loss, unauthorised access, misuse or alteration of any information you submit to the Website.

  1. Governing law/jurisdiction

All questions relating to the Website and this Privacy Policy are governed by Croatian law. You agree that in relation to proceedings with respect to the Website and this Privacy Policy, the sole jurisdiction is the courts in the Republic of Croatia. We do not warrant nor imply that the Website or content/materials on the Website are suitable for use outside the Republic of Croatia. Information provided on the Website regarding any service or product is only applicable to the Republic of Croatia and these services and products may not be available in all locations. If you are outside the Republic of Croatia, you are solely responsible for compliance with all governing local laws.

  1. Transfer of property

In the course of our business, we may sell or buy assets. If another entity acquires all or almost all of the assets of PPA, the Personal Data we have collected regarding users of the Website may be transferred to that person. Moreover, if any bankruptcy or restructuring process is initiated against us, such data may be considered our property and may be sold or transferred to third parties.

  1. Severability

If any provision of this Privacy Policy is considered invalid or unenforceable for any reason by any law or public policy, the provision shall not apply to the extent to which it is invalid or unenforceable and the other provisions shall continue to apply with full legal effect.

  1. Changes and updates to our Privacy Policy

PPA reserve the right to modify or update these Privacy Policy at any time and without prior notice. Please check from time to time for any changes or updates to our Privacy Policy, which will be published here and show on the first page of the Privacy Policy the date of coming into force if any changes or updates are made.

  1. Contact information

If you have any questions or comments regarding the Website or the Privacy Policy, you can contact us via our online form at www.hvarwinetours.com/contact or by email at info@hvartours.com, or telephone +385 21/741-824