Privacy Notice and Cookies

Information on the collection and processing of personal data Villas Borghetto, i.e. the legal entity F.I.N.M.A.V.I. d.o.o. (which manages Villas Borghetto) (hereinafter text: "Company") pays great attention to the protection and processing of personal data. In doing his registered activities The Company processes personal data in compliance with all relevant laws and regulations.

(1) The Controller is responsible for data processing:
F.I.N.M.A.V.I. d.o.o., Poreč - Parenzo, Trg slobode 5, ID number: 76642578753
phone: +385 91 428 4000
(2) The Data Protection Officer (DPO) is:
Sandra Moškun is available for contact:
phone 00385 9 428 40 00

(3) If the services of external providers are used to process F.I.N.M.A.V.I. d.o.o. Your personal data ("Processor"), it is about processing (personal data) by order. And in that case we are responsible for protection of your personal data. When processing your personal data, we do not use service provider outside the EU. Exceptionally, if it turns out to be necessary, we will do it only if it exists for that third country decision of the European Commission on adequacy or if we are with a service provider as a Processor have agreed on appropriate guarantees or compliance with binding regulations on the protection of personal data.

This Information on the collection and processing of personal data (hereinafter: "Information") describes which data we collect, how we process them and for what purposes we use them, as well as your rights related to Your data. The purpose of this Information is to inform you about all relevant collection features Your personal data, their processing and storage. The above applies to all personal data that you transmitted to us via electronic, written or verbal communication, or which were transmitted to us via travel agencies and/or other groups if you have a contractual or other similar relationship with them, as well as data collected from other sources.

Personal data we collect

We process the following personal data:

a) Your basic personal data that you or third parties make available to us on occasion reservations: Name, surname, country and city and address of residence, email address, phone number, child's age, name and the child's surname and date of birth, special requirements and habits, and the information of your companions; data required to make a reservation : credit card number, contact information in case of emergency : first and last name, number phone; other necessary data : e-mail address, health data :in case of a special request diet or the need for a doctor or related to epidemiological measures (COVID-19 etc.).

b) Guest check-in and check-out: Name and surname, date of birth, gender, personal document number (identity card, passport, driver's license), credit card number, country of birth, citizenship, visa number if the guest is subject to the visa regime, the border crossing, i.e. the place of entry into the Republic of Croatia, date of the guest's arrival at the facility and the date of departure.

c) Use of in-villa services: data on guest consumption during their stay in the villa. Data is collected about the type of service provided and the price, for example: room service, list of telephone calls, use of the minibar, use of a private chef and catering, bicycle rental, boat rental, home delivery, yoga, swimming lessons, data related to the use of the web - IP address, website visits, data from social networks and the like data regarding the use of Internet browsers and the like. Data on special requests are also collected the guest so that the Company can provide the service of the required quality.

d) Monitoring and improving the quality of services: first and last name, gender, age, country from which the guest comes and period of stay in the villa, assessment of a particular type of service, comment. Data collection is voluntary.

The purpose of collecting personal data and the legal basis of processing

The company determines the purpose and means of personal data processing and in this sense is considered the processing manager personal data. The main purpose of collecting personal data is a legal obligation and/or the conclusion of a contract execution of contracts on accommodation and the provision of hospitality and tourism services, or in order to took actions at your request before and during the contract. At the same time, the scope of personal data that we collect depends on the type of contract you intend to conclude or are concluding or the request to exercise rights (type services provided and price). Actions at your request before concluding the contract imply a check of yours requirements and needs, as necessary checking the adequacy or suitability of your products and services special circumstances, and all with the aim of making an offer and/or informative calculation.

If you are not contractual foreigner but a person exercising a right from an allotment contract, a contract with a travel agency and the like, the purpose of collecting your personal data is to fulfill the Company's obligations arising from the contract or the collection of your data is necessary in order to conclude the contract or identify the users, for example, with Internet platforms for online booking. In this case, the scope of personal data which we collect depends on the type of request and the information that will be needed to make the request fulfilled. The purpose of personal data processing may be the Company's obligation to fulfill the contracted services such service provider.

We process your basic personal data and guest registration and check out data based on the law obligations to enter those listed in the eVISITOR system, in accordance with the regulations on the way of keeping a list of tourists, and on the form and content of the tourist application form to the tourist community and the Tourist Fee Act or for other purposes Ministry of the Interior in accordance with the Foreigner Act, and the provision of the above information is necessary at the time of booking (in case of amendments and additions to the regulations and/or new regulations, they are immediately applied and to this Information). We delete the specified data after transfer to the eVISITOR system, or after submits data to the MUP.

As a result of the above, the collection of personal data with regard to the defined purpose represents a legal and contractual obligation and condition necessary for concluding a contract. If you refuse to provide certain information, we will not be able to fulfill their legal or contractual obligations, which will result in the impossibility of concluding a contract of accommodation and hospitality and tourism services or the impossibility of fulfilling obligations under the contract.

We need the data required to perform the contractual obligation to use our services in order to make an advance payment for confirmed reservation, in accordance with the Company's internal rules, and it is not possible to make a reservation and therefore not to make a contract without disclosing the specified information, which is kept until termination of the contract on the provision of accommodation.

The credit card number is collected because it is needed to conclude and execute the contract with the guest. It is used as insurance for the payment of accommodation costs and other services that could arise in the event that the guest does not settle the debt to the Company. The specified data is also used to pay for the service.

Data on the use of our services are subject to collection and processing for the purpose of fulfilling contractual obligations. Data on the guest's consumption during the stay in villas are also collected for the execution of the contract with the guest and so that an invoice could be issued for the services rendered.

In case of emergency, we process contact data on the basis of legitimate interests or potential situations when it is necessary and urgent to convey certain relevant information to people close to you (in case extraordinary circumstances such as illness, accident, etc.). Other necessary data, i.e. e- mail address, we process on the basis of a legitimate interest in quality communication between contractual parties in the purpose of fulfilling all aspects of the contract, i.e. easier communication in terms of the organization of your arrival and the reservation of the accommodation itself, which data we also delete upon termination of the service contract accommodation.

Website analysis

By using the Villas Borghetto website, you agree to the collection and processing methods data described in this Privacy Policy.

When analyzing the Villas Borghetto website, we use Google Tag Manager, Google Analytics Universal 3 and Google Analytics 4, Google Ads conversion tracking code, Facebook Ads conversion tracking code and Hubspot.

Google Tag Manager is the system through which all user tracking codes are implemented and it serves primarily for implementing codes on the website and does not collect personal data.

The Google Analytics Universal 3 and Google Analytics 4 system tracks user data in the form of traffic channels which users come to the website, their behavior on the page (which pages they viewed, how many time spent and similar), and user results (number of clicks on phone numbers, number of clicks on email addresses, the number of sent inquiries and the like). As such, the system does not collect personal data of the user, if it occursstorage of IP addresses of users, they are necessarily anonymized. It is about the so-called "first party" cookies. Using this system, we also do "remarketing" campaigns, i.e. when the user leaves our website once, we display him ads on external portals. Each user has the option of (not) giving consent to the so-called cookies for marketing on our cookie banner when you first visit our website, consent to marketing also implies consent for remarketing campaigns.

The Google Ads conversion tracking code is used for better optimization of the Google Ads campaigns that we carry out and he belongs to the so-called "third party" cookies. We do not collect user personal data using this system.

We use the Facebook Ads conversion tracking code for better optimization of Facebook campaigns that we implement and it belongs to "third party" cookies. We do not collect personal data using this system users, but we also do remarketing campaigns. Each user has the option of (not) giving consent to the so-called marketing cookies on our cookie banner when you first visit our website, consent to marketing also includes consent for remarketing campaigns.

We use the Hubspot system as a CRM and the data of users who have filled out the contact forms go to it website. The contact forms on the website belong to the Hubspot system. Through the Hubspot system we also conduct newsletter (email) campaigns.

Special categories of personal data

In principle, the following types of personal data are not processed: racial or ethnic data origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of unique identification of an individual and data related to health, sex life and sexual orientation of the individual.

The above categories of personal data may be processed by the Company in the following situations:

1) guest has given express consent to the processing of these personal data for one or more specific purposes, unless the applicable regulations state that such consent does not produce effect;

2) processing is necessary to protect life important interests of the respondent or another individual if the guest is physically or legally unable to give consent;

3) the processing refers to personal data that is obviously published by the guest,

4) the processing is necessary for the purposes of significant public interest on the basis of applicable regulations which is proportionate to the desired goal and which respect the essence of the right to data protection and ensure appropriate and specific measures for the protection of fundamental rights and interests of the respondents;

5) processing is necessary for the purpose of preventive medicine, medical diagnosis, provision health or social care or treatment or management of health or social care systems and services based on applicable regulations.

All your personal data that you or a third party have transferred to us are processed in accordance with the purpose of their processing (at the same time, please note that if you are traveling with children under the age of 16, their personal data regardless of the basis, we process only on the basis of your express consent).

There is a possibility of using an internal network of surveillance cameras and other security measures in ours facilities, through which they can take pictures or record pictures of guests and process information related to yours location while you are in our facility (via keys-cards and other technologies), and all for legitimate purposes in the interest of preserving security.

Links to third-party websites and services

Our website and our mobile programs, wi-fi network and IPTV system record data about your use in for the purpose of issuing invoices and contain links to third-party websites. Please note that we are not responsible for the collection, use, maintenance, exchange or publication of such data and information third parties. If you provide information on or use third-party websites, the rules apply about the privacy and terms of use of those websites. We recommend that you read before providing personal information the privacy policies of the websites you visit.

The company will take all reasonable measures to protect your personal data from unauthorized access, disclosure, alteration or destruction, and to keep personal information as accurate and up-to- date as possible. We require from our partners and service providers with whom we share personal information to invest reasonable efforts to maintain the confidentiality of your personal data. For online transactions we apply reasonable level of technological measures to protect the personal information you share with us through our website. At the same time, of course, we must take into account that no security system or internet system data transmission cannot guarantee complete security.

Legitimate interests of the Company as the purpose of personal data processing

We will process your personal data for the needs of our legitimate interests, except when it is necessary to do so your interests or your fundamental rights and freedoms that require personal protection should take precedence over interests data. The Company's legitimate interest in this sense is the processing of personal data in order to provide our service in fully adapted to your needs and wishes.We can also use the given data for our own internal statistical and analytical purposes.

You can object to this legitimate interest of the Company at any time, and in that case your data More we will not process for this purpose, and this will not affect the legality of the processing until the day of withdrawal. In every case, we must have your express consent for direct marketing.


Consent is the legal basis for collecting personal data for monitoring the quality of services. Society cares about your opinion on the services provided, and for this purpose we ask you to fill in the so- called quality questionnaires in order to could evaluate us. The above allows us to analyze various aspects of our service so that we can develop and improve even more.

On the questionnaire, the guest is informed that the provision of any personal data is voluntary. A guest decides whether to fill out the questionnaire or not, that is, if he fills it out, he decides himself whether to list personal information data and which. If the processing of the aforementioned data is based on your consent, we process the data until you withdraw the relevant consent or request the deletion of the above.

Accordingly, based on your consent, we may also process other personal data outside of those mentioned in this Information. In connection with the above, we note that in accordance with the applicable regulations, however, the Company does not carry out deletion despite the request of the respondent to the extent that the processing of such data is necessary for:

a) to comply with the legal obligation that requires processing and to which obligation the company is subject to, or for the performance of a task of public interest,

b) in order to exercise the right to freedom expression and information;

c) due to public interest in the field of public health

d) for purposes of public interest, historical or scientific research or for statistical purposes, i.e. for the realization or defense of legal claim

In the case of granting marketing consent for which we ask for your express consent, your personal data exceptionally, they can be the subject of automated processing based on which your profile will be created for the purpose analysis of services provided and realized rights and for the purpose of improving the quality of the business relationship.

Automated decision-making, which includes the creation of profiles, will be carried out in cases of creation of yours client profile for the purpose of analyzing the services provided and realized rights and for the purpose of improving quality business relationship and data processing based on consent for marketing purposes with the aim of improvement the quality of business relations and marketing and to inform you about benefits and news in a targeted manner from our offer. If such processing of personal data is not necessary for the conclusion or execution of a contract, you have the right to request that the outcome of the processing be decided by an employee of the Company, the right to express one's own points of view and the right to challenge the decision made by automated processing. This way too please note that the use of your personal data for marketing purposes is only possible on the basis of your express consent. If you give us the said consent, we will inform you about everything in a timely manner benefits, discounts, events and associated services that we believe would be of use to you interest. You can withdraw said consent at any time by notifying us via of the contact specified in the introductory part of this Information.

To whom your personal data will be disclosed

The company ensures that your personal data is processed exclusively for the purposes stated here in document. The purpose of personal data processing will require that your personal data be disclosed and that it in addition to the Company, it is processed by other companies and persons in the capacity of processor. Categories of processors to which your data will be disclosed include state and public authorities in accordance with the law obligations of the Company, health institutions, providers of IT and legal services, service providers delivery and the like. We can forward the collected personal data to entrepreneurs who provide services that could be of interest to you, and according to your request (e.g. regarding bicycle rental, boat rental, etc.). Personal data processors, with the exception of state and public authorities, process data exclusively according to the Company's instructions, respecting technical and organizational measures to ensure protection your rights.

Where your personal data will be processed

The processing of your personal data will be carried out within the European Economic Area (except can also be carried out outside the European Economic Area), but in any case it will be carried out from processor whose responsibilities and obligations are personal data protection and applicable technical and organizational protection measures prescribed by the contractual relationship in accordance with all legal regulations that regulate the protection of personal data.

Period in which personal data will be stored

Your personal data will be stored only for as long as is necessary to fulfill the purpose for which it was created. The period of storage of personal data depends on the purpose of collection. If it's about assembly contracts on accommodation, in-villa services and the provision of hospitality and tourism services, that period will be determined by the duration of the contract itself, i.e. the billing of those services in terms of legal obligation document storage. The extension of this period is prescribed by the Company's internal rules, which in turn depend on by the statute of limitations for claims, or these periods may be extended in accordance with the law defined retention periods, such as in the case of accounting documents.

Rights in relation to collected personal data

In connection with the data that you have disclosed to us, you have (I) the right to view the personal data that is being processed, (II) the right to correct or delete personal data, (III) the right to restrict processing, (IV) the right to objection to the processing, (V) the right to transfer the data to another data controller, (VI) the right to withdraw consent, (VII) the right to submit a complaint to the supervisory authority. To exercise all the rights listed here, simply inform us according to the contacts according to the introductory information of this Information.

For more information, our Privacy Policy is available on our website data.

The right to submit a complaint to the supervisory authority

At any time, you can submit an objection to the processing of your personal data to the competent supervisory authority body in accordance with the Act on the Implementation of the General Regulation on the Protection of Personal Data or another positive regulation which regulates the protection of personal data and determines supervisory powers regarding the processing of personal data.

Other information

We may change the information from time to time. When we make material changes to this Information, we will post a link to the amended Information on the home page of our website. Any changes in the Information will become valid after the publication of the changed Information on the website.

This Information on the collection and processing of personal data is applied in accordance with EU Regulation 2016/679 of the European Parliament and the Council on the protection of individuals in connection with the processing of personal data and freedom of movement of such data from April 27, 2016 (General Data Protection Regulation - GDPR) and in accordance with the Law on the Implementation of the General Regulation on Data Protection (Official Gazette 42/2018).



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