Castellana understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. DEFINITIONS AND INTERPRETATION
In this Policy the following terms shall have the following meanings:
|„Account“||means an account required to access and/or use certain areas and features of Our Site|
|„Cookie“||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below|
|„Cookie law“||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
2. INFORMATION ABOUT US
Our Site is owned and operated by castellana.com.hr
Postal Address: Kastelir, 71 – 52464 Kastelir Istra – HRVATSKA
E-mail Address: privacy @ Castellana
We are regulated by Italian Personal Data Protection Agency (AZOP).
3. WHAT DOES THIS POLICY COVER?
4. WHAT IS PERSONAL DATA?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. WHAT ARE MY RIGHTS?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and provide better user experience. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Data Protection Officer.
6. WHAT DATA DO WE COLLECT?
- Contact information (such as name, email address, mailing address, and phone number, date of birth, profession);
- Payment information (including payment card numbers, billing address, and bank account information);
- Demographic data (such as age, gender, country, and preferred language);
- Information related to your reservation, stay, or visit to a Castellana property (where you have stayed, date of arrival and departure, and goods and services purchased);
- Loyalty program member information, profile or password details and any copies of your correspondence if you contact us
- Copies of your correspondence if you contact us;
- Your interests and preferences;
- Information collected through the use of closed circuit television systems, card key and other security systems; and
- Information related to your use and interaction with our website like IP address, location, web browser type and version, operating system, a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
7. HOW DO YOU USE MY PERSONAL DATA?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will and may be used for the following purposes:
- Automatic Information: When you use or interact with our website and/or use any apps that we may make available on our website, we receive and store information generated by your activity and information automatically collected from your browser or mobile device. For example, like many websites, we obtain certain information when your web browser accesses our website including your IP address, browser type, operating system, mobile network data, pages viewed and access times. This information helps us to communicate with our customers and better understand them.
- Security Systems: When you visit our managed properties, information may be collected about you through such properties’ closed circuit television systems, electronic key cards and other security systems.
- Information from Other Sources: We may receive information about you from other sources, such as public databases, joint marketing partners, and other third parties. This may include information from your travel agent, airline, credit card, and other partners.
- Age Limitations:Castellana does not knowingly collect personally identifiable information from our websites from any person under the age of 18.Castellana may collect personally identifiable information from people under the age of 18 as part of the guest registration process, but always with the consent of such person’s parent or guardian.
- Providing and managing your Account
- Providing and managing your access to Our Site
- Personalising and tailoring your experience on Our Site
- Delivering our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking on the UNSUBSCRIBE link in the email footer or sending us a personal email asking us to unsubscribe you.
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use automated system[s] for carrying out certain kinds of decision-making and providing better user experience. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15. The following automated decision-making method(s) may be used:
- If you fill out a web form on our site, your information will be stored in our CMS and CRM system and some amount of your past browsing on our site may be available to us to determine your interests. We may use this information to more effectively engage with you and improve our site. However, if you use private browsing, you may provide us your information without making your past browsing activity available to us. If you do not wish for us to have your personal information, please do not fill out any of the web forms on this site.
- If you provide your email address and consent for email marketing, some information is collected about when/if the email was opened and what links were clicked. This information is used to assess the engagement and success of an email campaign. Clicking on a link in any of these emails may cause you to be personally identified on our site and may cause some part of your past browsing history on our site to be available to our personnel so we may more effectively engage with you and improve our site. If you do not wish for this tracking to occur, you can unsubscribe from our mailings or use private browsing mode to avoid tracking.
8. HOW LONG WILL YOU KEEP MY PERSONAL DATA?
To the extent permissible by applicable law, we will retain your personal information for such period as necessary to satisfy or to fulfill the following:
- the purposes for which that personal information was provided,
- an identifiable and ongoing business need, including record keeping,
- a specific legal or regulatory requirement, and/or
- a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings
Where there is no sufficient justification to retain such personal information, such personal information will be safely and securely deleted, disposed of, anonymised and/or blocked.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. At the time we no longer need your personal information for any business or legal purpose, we will delete it. We retain the personal information we process on behalf of our customers as long as we have an agreement with them to process that data, subject always to applicable legal requirements.
9. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus UK, Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures.
10. DO YOU SHARE MY PERSONAL DATA?
We may share your personal data with other companies in our group for providing the service. This includes subsidiaries We may sometimes contract with the following third parties to supply certain products and services. These may include payment processing and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just safely and securely and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority
11. HOW CAN I CONTROL MY PERSONAL DATA?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and, at the point of providing your details and by managing your Account).
12. CAN I WITHHOLD INFORMATION?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. HOW CAN I ACCESS MY PERSONAL DATA?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for providing a better user experience. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Certain features of Our Site depend on First Party Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Before Third Party Cookies are placed on your computer or device, you will be shown a notice requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you.
The following first-party Cookies may be placed on your computer or device:
|Functional Cookies (strictly necessary)||If you click the button on the cookie banner, a cookie prevents showing the banner again. If using a contact form, a session cookie is set.|
|Google Analytics (not strictly necassary)||We use Google Analytics to collect information about how visitors use our site. For example, we collect details of the site where the visitor has come from and the total number of times a visitor has been to our website. This may include user location information. We may use Google Analytics Advertising features for remarketing purposes. You can opt-out from being tracked by Google Analytics by installing the Google Analytics Opt-Out Browser add-on for your current web browser. Learn more: https://policies.google.com/privacy?hl=en|
|Hotjar (not strictly necessary)||Hotjar is an analytics and feedback tool that we use to understand how our website is used and improve usability. Hotjar sets cookies to help us track behavior across pages. The cookies carry no personally identifiable information. Learn more: https://www.hotjar.com/legal/policies/cookie-information|
and the following third-party Cookies may be placed on your computer or device:
|Google AdWords||We may use Google AdWords to help us deliver advertising and measure the effectiveness of our campaigns. We may also use this tool to collect location information, create audience segments, and for remarketing purposes. Click here to learn more or set your preferences. Learn more: https://policies.google.com/privacy?hl=en|
|Google Dynamic Remarketing||We use these tracking tools to track user behaviour over time and across third-party sites to improve the effectiveness of our online advertising. We collect information about what ads users view and whether they click on the ads. We use this information to improve and customise our advertising. Click here to learn more or set your preferences. Learn more: https://policies.google.com/privacy?hl=en|
|Google Tag Manager||We use Google Tag Manager in order to track user behavior, traffic analysis and marketing optimization. This includes managing third party tags. Click here to learn more or set your preferences. Learn more: https://policies.google.com/privacy?hl=en|
|Facebook Connect and Facebook Custom Audience||We use this technology to allow users to share their experiences with our websites on Facebook and to measure the effectiveness of our marketing campaigns. To opt-out, log out of your Facebook account and visit aboutads.info/choices.|
|Zendesk||We use this cookie to understand visitor and user preferences and improve their experience and track and analyze usage, navigational and other statistical information. If you disable cookies, you may still visit the Website and use the Services, but your ability use some features or areas of our Websites or Services may be limited. Learn more: https://www.zendesk.com/company/cookie-policy/|
|MyFonts Counter||We use a web font from myfonts.com. Due to the license terms, a page-view tracking is performed by counting the number of visits to our website for statistical purposes and transmitting them to MyFonts. Learn more: https://www.myfonts.com/info/terms-and-conditions|
|TradeDesk||The Trade Desk is an online demand-side platform that provides buying tools for digital media buyers. The conversion pixel we add allows us to track performance and derive insights for media investments made. Learn more: https://thetradedesk.com/general/privacy-policy#optout|
|Adform||Adform’s technology is used to create and deliver rich and diverse online marketing. They can be used for the following tasks: displaying ads in a sequence, displaying particular products in response to interest, displaying ads based on statistical probabilities, or deciding if an ad should be shown based on responses to the above techniques. Learn more: https://site.adform.com/uncategorized/product-and-services-privacy-policy/|
|AddThis||These cookies provide user measurement and analytics features, as well as managing user sharing preferences. Learn more: http://www.addthis.com/privacy/privacy-policy|
|SiteScout||This cookie is used to track the success of your campaign by reporting back an action that the user has completed on your website after arriving through an advertisement. Learn more: http://www.sitescout.com/privacy|
|LiveIntent||To provide you with advertising that is as relevant and useful as possible. Some of the online ads you may see may be based on the content of the page you’re visiting, some may be based on registration information you provide, and other ads may be customized based on predictions about your interests generated from your visits to other websites. Learn more: https://liveintent.com/privacy-policy/|
You can choose to disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. HOW DO I CONTACT YOU?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
E-mail Address: privacy @ Castellana
Postal Address: Kastelir, 71 – 52464 Kastelir Istra – HRVATSKA
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.