Primošten hoteli d.o.o., Primošten, Raduča 11, OIB: 20719186567, represented by the President of the Management Board Kornel Bodnar (hereinafter: PH), in Budapest, on February 11, 2021. brings this

Privacy Policy

PH takes care of your privacy and undertakes to protect it during the processing of your personal data as well as during and after your visit to this website

The Privacy Policy provides insight into our actions regarding the collection of information through the Pages and our use of information and applies exclusively to information collected through the Site and does not apply to information collected through any other source, including but not limited to Facebook@, Twitter@, YouTube@ and other third party and social media websites. If you do not agree with any of the terms of this Privacy Policy, do not use the Site(s) or provide us with any personal information.

Data controller:


      Address: RADUČA 11, 22202 PRIMOŠTEN

      T: 022 581 111

      F: 022 570 302



Data Protection Officer

PH has appointed a Data Protection Officer, who can be contacted at the following email address .

Web page

During the use of our website, IT systems and software procedures for managing this website download some personal data whose transfer is implicit in the use of Internet communication protocols, or information that is not related to certain individuals, but by its nature could, through processing and linking to third party data, enable user identification. The specified data category includes the IP address or domain names of the computer used by the users connecting to the website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, numeric code indicating the response status of the server (for example, successful, error, etc. ) and other parameters related to the operating system and users. These data are used only and exclusively to obtain anonymous statistics on the website and to check the correct functioning and are deleted immediately after processing.


Some websites store small text files on your computer for a better user experience on the website – the so-called cookies. Such sites are obliged to ask for your consent before storing cookies, as well as to enable the possibility of easily withdrawing consent to the use of cookies. It may happen that the use of certain functionalities of a website becomes disabled after the withdrawal of consent to the use of cookies.

A cookie is a file stored on your computer by a specific website you visit. The cookie informs the website that the „old“ user has reconnected by remembering his settings. Cookies further record your preferences and settings.

Cookies can store a wide range of information, but that information can only be stored if the user allows it – websites cannot access information that the user has not given them and cannot access other files on the user’s computer. Cookies do not contain any personal data or information that could identify you. The user, on the other hand, can change their settings on the Internet and thus choose whether to approve or reject requests to save cookies, whether to automatically delete saved cookies when closing the Internet browser, etc. By disabling cookies you decide whether to allow them to be stored on your computer. Cookie settings can be controlled and configured in your internet browser. For information on cookie settings, select the internet browser you are using.

Persistent or saved cookies are stored on a disk (your computer) and remain there even after you close your Internet browser. They store information such as your login name and password, so you don’t have to log in every time you visit a particular place.

Temporary cookies are temporarily stored on disk and are deleted after closing the Internet browser. With them, websites store temporary data such as items in the shopping cart.

„First party cookies“ come from websites that the user views and can be permanent or temporary. The websites use these cookies to store information that they will use again the next time the user visits that site.

Third-party cookies come from other, partner sites you view. Third parties may thus collect data on users of various websites and use them for marketing and analytical purposes.

Our site uses temporary cookies.

For your information, there are currently several websites for disabling the storage of cookies for various services, and you can find out more at the following links:

http: //

Types of personal data processed

The main business of PH is the provision of accommodation services in its hotels. In certain cases, we may ask you to provide us with Personal Information, for example when booking accommodation, giving comments or asking questions, requesting information, participating in a promotion, competition or using other features or functions of the Site. Therefore, PH collects and processes your personal data for various purposes with the ultimate goal of providing quality accommodation and related services all according to the highest standards of tourist companies.

PH, as the data controller, stores your personal data that you must provide in order to be provided with the accommodation service in its database for the purpose of fulfilling the accommodation contract and fulfilling the legal obligations related to the catering business. In the event that you do not provide PH with the minimum data required for booking accommodation and during the registration stay with all competent registers, PH will not be able to provide you with the accommodation reservation service or accommodation service in accordance with the contract and law.

Certain information is necessary in order to take action at the request of the respondent before concluding the accommodation contract. For example, before booking accommodation at the request of potential guests, offers for accommodation are sent, for the creation of which PH needs personal information, at least the name, surname and e-mail address in order to send an offer.

Personal data that PH collects when booking accommodation (reservations via the web or reservations by phone by calling the call center or reservations by accepting the offer via e-mail) in order to fulfill the reservation obligation are:

–              Name and surname of the reservation holder

–              Residence address (Croatian citizens)

–              Date of birth

–              Number, type of identification document and place of issue

–              Citizenship

–              Object name

–              Number of accommodation unit

–              Date of arrival and departure

–              Number of persons for whom accommodation and accommodation are reserved by rooms

–              Which persons are minors

–              Possibly other specifics depending on the request of the person booking the accommodation

–              E-mail if the person has it

–              Language

–              Phone

–              Membership in the loyalty program, if it affects the price of accommodation or collecting points

–            Method of payment and we accept Mastercard, Mastro, Visa cards. See more here .

In case of cancellation, we must save your data for the purpose of proving the reservation or cancellation.

Upon arrival at the facility, guests register at the reception, and their data are entered into the guest database from which data is automatically sent to the eVisitor system (a unique online information system for check-in and check-out of guests) to comply with legal obligations of PH.

The data collected are (data are subject to change due to changes in positive regulations):

–              Name and surname

–              Place, country and date of birth

–              Citizenship

–              Number and type of identification document

–              Residence (whereabouts) and address

–              Date and time of arrival or departure from the facility

–              Sex

–              Basis for exemption from payment of tourist tax or for reduction of payment of tourist tax

These data are processed by tourist boards and public authorities of the Republic of Croatia for the following legal purposes:

–              monitoring the fulfillment of the obligation to register and deregister tourists by the person   obliged to register and deregister (accommodation service provider);

–              records, calculation and collection of tourist tax;

–              keeping a book or a list of guests by the accommodation service provider and monitoring the implementation of the said obligation by the inspection bodies;

–              reports of aliens to the ministry in charge of internal affairs and monitoring of the execution of the stated obligation by inspection bodies;

–              keeping a list of tourists by tourist boards and statistical processing and reporting;

–              supervision over the operations of the accommodation service provider in the part related to the legality of performing activities or the provision of registered services and compliance with tax and other regulations on public benefits.

Since it is prescribed that the data for guest registration is entered on the basis of data from the identity card, ie travel or some other identity document, the guest is obliged to provide PH with such a document and provide all other information necessary for data entry, but not contained in such a document. Also, in order to exercise some rights and benefits, it is necessary to enclose (copies of) appropriate documents, certificates and documents by which such rights and benefits are proven and exercised.

Also, PH is obliged to keep all invoices, as well as the basis for issuing invoices issued to guests with personal data of the guest in accordance with legal regulations.

Other data related to the circumstances of your stay such as: mode of travel, who you are traveling with, marital status, number of children, pets, other interests, will also be collected and processed during your stay when they have a direct connection with the accommodation service.

Before, during and after the stay, PH as the processing manager has the right, based on the legitimate interest of you as a guest, to send via e-mail the so-called service emails – booking confirmations, reminders of the stay and other information closely related to the specific stay you have booked.

Also, during and after the stay, PH as the data controller has the right, based on the legitimate interest of you as a guest, to send questionnaires about satisfaction by e-mail, which they will process themselves or through associates. The primary purpose of the satisfaction questionnaire is to collect data on the service for the legitimate interest of improving the service by PH, and PH can depersonalize and process this data from the questionnaire for statistical purposes.

PH has the right based on a legitimate interest to collect certain data and use it for direct marketing purposes as described in the Newsletters section.

Service e-mails and e-mails with satisfaction questionnaires related to the specific stay of the guest are not considered newsletters for the purpose of sending offers and news to PH.

PH will not collect Personal Data during your visits to our Site if you do not provide it to us voluntarily, except for certain items of Personal Data collected through information systems and programs used to operate the Website, the transmission of which is inherent in the use of Internet communication protocols (eg IP addresses) and will not require more information than is necessary to participate in the activities on our Site.

We hereby advise you to read all privacy policies of all third parties, as well as the terms of use.

Purposes and basis of processing and possible consequences of not providing personal data

When you provide your Personal Information on the Site, we will restrict the use of Personal Information for the purpose for which it was collected in accordance with the terms of this Privacy Policy.

The use of your Personal Data may include taking action on your request prior to entering into a contract (e.g., answering all your questions and requests); enforce a contract to which you are a party, investigate suspected fraud, harassment, physical threats or other violations of any laws, rules or regulations, rules of the Site or rights of third parties; or investigate any suspicious behavior that we consider indecent, compliance with the legal obligation to which PH is subject, or for the purposes or in connection with legal proceedings, the establishment, defense or exercise of legal rights, to send notifications via electronic tools (SMS, e-mail, social network), whether automated (operatorless calls) or not (mail and operator calls), in accordance with the relevant legal grounds.

Recipients of personal data

Your Personal Information may be disclosed, in close connection with the above purposes, only:

–              To those entities that also need it to perform the service and maintenance, send mail and e-mail, remove duplicate information from the list of users and analyze data, and who usually process Personal Data on behalf of PH as processors; persons authorized by PH to process Personal Data, who are subject to an appropriate legal obligation of confidentiality (PH employees); law enforcement and public authorities when required by applicable law or in good faith (eg to comply with the provisions of the law or to comply with legal proceedings; to protect and defend the rights or property of PH and this Site, or, in urgent circumstances, to act to protect the personal safety of PH users, its Sites or the public); business partners for their needs only in accordance with the relevant legal basis.

Transfer of personal data to third countries

PH does not transfer Personal Data to third countries. If the need arises, PH will take all necessary legal actions and protections in accordance with applicable law.

Deadlines in which data are processed

PH will process your Personal Data only for the time necessary to achieve the purpose. PH will retain your Personal Data exclusively and only for the time necessary or permitted in accordance with the applicable legal regulations governing the field of personal data protection and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter: the General Data Protection Regulation) and the Act implementing the General Data Protection Regulation (Official Gazette No. 42/18), in force dated 25 May 2018) (hereinafter: the Law).

Your rights

PH informs you that, to the extent permitted by applicable law, you have at all times

–              the right to data access and data insight

–              the right to be informed about the processing of personal data

–              the right to data portability

–              the right to withdraw consent

–              the right to object

–              the right to correct and change personal data in the event that the data are incomplete or inaccurate

–              the right to erasure in cases such as termination of the purpose of processing, withdrawal of consent or in the case of an objection

The complaint can be submitted to the competent supervisory body, the Agency for Personal Data Protection, based in Zagreb. You also have the right to know all recipients to whom your Personal Information has been or will be disclosed.

We are not able to delete your data if they are needed to calculate the cost of works, and we can process them only until the statute of limitations in accordance with applicable laws governing legal relations, in the event of proceedings for forced collection of unpaid receivables, if filed a complaint against a product or service within an open period, until the final completion of the complaint procedure in accordance with the applicable legal regulations (eg the Consumer Protection Act, etc.). Whenever possible and applicable, your personal information may be anonymized.

We do not use service providers outside the EU to process your personal data.

Our Site may sometimes contain links to other websites (hereinafter: Friendly Sites) that are not owned, operated or maintained by PH. We encourage you to read the privacy policy and terms of each website you visit. Although PH seeks to place only links to websites that share its high standards and respect for privacy, we are not responsible for the content, security or practices of other websites. You should review the privacy and cookie policies on these websites to find out how your personal information will be used.

Caution! Downloading material from certain websites may result in an infringement of intellectual property rights or put your computer system at risk of various computer attacks and malware.

Protecting the privacy of persons under 16 years of age

PH takes child privacy protection seriously. PH collects Personal Data from persons under the age of 16 in accordance with applicable legal regulations. Persons under the age of 16 should have the consent of a parent / legal representative before providing any Personal Information to the Site or PH.

In the event that PH learns that the personal data sent to him relates to a person under the age of 16 without the valid consent of a parent / legal representative, PH will, immediately upon learning and without delay, do the following: delete this personal data from its files as soon as possible and ensure, in the event that deletion is not possible, that this personal data is no longer used for any purpose and will not be disclosed to any third party.

Video surveillance

PH, as the data controller, has a legitimate interest in implementing video surveillance measures to protect property and persons, and to install surveillance cameras in its facilities that record employees and all persons moving within the perimeter of the surveillance camera.

PH indicates in the prescribed manner all places where video surveillance is installed.

PH is aware that the videos contain personal data of all persons moving in the perimeter of the camera (guests, employees, business partners, etc.), and therefore keeps them with special care, has a regulated system of security, availability and deletion policy, which is regulated by the internal regulations on video surveillance of PH.

Videos are permanently deleted after a maximum of 2 months from the date of creation. Exceptionally, videos are kept longer if they are the evidence in procedures before the competent state authorities.

In the event of court and / or criminal proceedings, PH may use the said videos. Insight into personal data on videos may also have third parties, processors, contractual partners of PH registered and professional for the provision of services for the protection of persons and property, who in no way use the data independently but take care of the security of central monitoring and reporting systems. Special regulations governing the area apply to all other details related to video surveillance.

In case you want to exercise any of your respondents‘ rights or have additional questions about the protection of your personal data, you can contact our appointed data protection officer via e-mail


PH is extremely committed to the security of your Personal Data. We have set up and maintained procedures to protect the personal information we collect.

However, due to the nature of the Internet, we cannot guarantee that communication between you and us or information stored on the Site or on our servers will be completely secure from unauthorized access by third parties, such as computer and Internet attackers. Your use of the Site constitutes your agreement to this risk.

In order to protect your personal data from unauthorized access, use or accidental loss, we carry out all technical and organizational security procedures in accordance with our capabilities and the rules of the General Regulation on Personal Data Protection by ensuring that only authorized data processors have access to your personal data only when necessary and in accordance with the purpose of collecting personal data.

Examples of such procedures include, but are not limited to:

  • protection of office documents and archives
  • data destruction
  • rules of conduct for employees and determination of access rights
  • obtain statements of confidentiality and consent from employees and external associates in all cases where legally required
  • arranging contractual relations with external service providers
  • monitoring, review and maintenance of IT infrastructure
  • backing up
  • use of original computer programs and regular updates
  • protection of computers with antivirus programs as part of antivirus policy
  • the rule of not opening emails from unknown, potentially dangerous sources
  • periodic assessments of the personal data protection management system and numerous other measures

To the fullest extent permitted by applicable law, we disclaim all liability and liability for any damages (including, but not limited to, any and all direct, special, indirect, consequential or punishable losses or other damages of any kind, whether contractual (including fundamental breach), non-contractual (including, but not limited to, negligence), and lost profits that you may have suffered as a result of any loss, unauthorized access, misuse, or alteration of any information you submit to the Site).

All matters relating to the Site and / or these Privacy Policy are governed by Croatian law, without reference to the principles of private international law. By using our Site, you agree with the exclusive territorial jurisdiction of the court with actual jurisdiction in the Republic of Croatia.

If any provision of this Privacy Policy is considered or declared invalid, illegal or unenforceable for any reason, such provision shall not apply to the extent that it is invalid or unenforceable and the other provisions shall continue to apply with full legal effect.

PH reserves the right to change or update these Privacy Policy at any time and without prior notice. Please check all changes to our Privacy Policy from time to time.


If you have any further questions or comments or want to exercise any of your rights, please contact us by sending a request to the e-mail address .

The protection of your rights is our priority and we will respond to your request for the exercise of rights, as soon as possible, respecting the prescribed period of 30 days from the date of receipt of the request.

Primošten hoteli d.o.o.

Kornel Bodnar

President of the Management Board