Privacy policy

CONTENTS

GENERAL SECTION 

• DATA CONTROLLER AND REGULATORY FRAMEWORK 
• SCOPE OF APPLICATION 
• DATA PROTECTION OFFICER 
• PERSONAL DATA PROTECTION PRINCIPLES 
• LAWFULNESS OF PERSONAL DATA PROCESSING 
• TYPES OF PERSONAL DATA PROCESSED
• TRANSFERRING DATA TO THIRD PARTIES 
• DATA RETENTION PERIOD
• DATA SUBJECT RIGHTS 
• PROTECTION OF PERSONAL DATA OF CHILDREN
• SOURCES OF PERSONAL DATA 
• TECHNICAL AND ORGANIZATIONAL DATA PROTECTION MEASURES
• ACTIONS TAKEN IN THE EVENT OF A PERSONAL DATA BREACH 

SPECIAL SECTION

• ACCOMMODATION AT OUR FACILITIES (hotels, apartments, camps) 
• EXCHANGE OFFICES 
• EXCURSIONS, CONCERTS, TRANSFERS AND OTHER SERVCIES 
• LOYALTY PROGRAM MEMBERSHIP 
• CONTEST / SURVEY QUESTIONNAIRE FORM 
• JOB APPLICANTS AND EMPLOYEES 
• STAFF SELECTION 
• EMPLOYMENT RELATIONSHIP AND OTHER COMPARABLE RELATIONSHIPS
• BUSINESS PARTNERS 
• RETENTION PERIOD 
• PUBLIC NOTICES 
• NEWSLETTERS 
• VIDEO SURVEILLANCE 
• WEBSITES, COOKIES AND INTERNET TECHNOLOGIES 
• FINAL PROVISIONS

General Section – Basic Information

Controller and Regulatory Framework

In its role as a controller, KAMP SLATINA undertakes to protect your personal data. We collect, process and store your personal data pursuant to the provisions of REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, i.e. the General Data Protection Regulation – GDPR (“Regulation”), the Act on the Implementation of the General Data Protection Regulation (Official Gazette, 42/2018), and other relevant regulations applicable in the Republic of Croatia.

Scope of Application

Data Protection Officer

All requests delivered to the address of our DPO which do not concern personal data protection, such as job applications, letters of inquiry for reservation of accommodation at our facilities, and similar, will be forwarded directly to the competent business divisions, sectors and/or departments of KAMP SLATINA. In such cases, the DPO will not provide a special answer to the sender. . 

Personal Data Protection Principles

• lawfully  – the processing is considered possible if and to the extent it is permitted by law;
• fairly – taking into account the specific circumstances of each individual relationship, implementing all appropriate safeguards to ensure protection of personal data and privacy in general, and allowing the data subjects to exercise their rights;
• transparently – data subjects are informed about the processing of their personal data; more precisely, they are informed about all aspects of data processing at the time the data are collected and are ensured a simple and quick access to their data throughout the period during which their data are processed, including the possibility of checking the relevant data and receiving a copy of the same pursuant to the provisions of the Regulation; access to certain information may be restricted, but only if such restriction is prescribed by law or if necessary for the purpose of protecting third parties;
• ensuring purpose limitation  – personal data are processed only for the purpose for which they have been collected; they may be processed for other purposes as well, but only if the conditions defined in the Regulation are met; more precisely, to process data for other (related) purposes, the following must be considered: (a) any link between the purposes for which the personal data have been collected and the purposes of the intended further processing; (b) the context in which the personal data have been collected, in particular regarding the relationship between the data subjects and KAMP SLATINA; (c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to Article 9 of the Regulation, or whether personal data related to criminal convictions and offenses are processed, pursuant to Article 10 of the Regulation; (d) the possible consequences of the intended further processing for data subjects; and (e) the existence of appropriate safeguards;
• ensuring storage limitation – the data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; they may be kept for longer periods, but only if permitted by the Regulatio
• ensuring data minimization – only such data which are adequate, relevant and limited to what is necessary are processed; in particular, we are very careful not to collect any data in respect of which no justification for processing exists;
• ensuring accuracy – we take reasonable steps to ensure that the data are accurate and kept up to date, and that all inaccurate data are erased or rectified;
• ensuring integrity and confidentiality – we ensure appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures; the relevant measures are applied taking into consideration the risks associated with different types of data processing.

Lawfulness of Personal Data Processing

• the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; this is the most frequent purpose for which the data concerning data subjects are processed; this type of processing rests on the grounds of an existing or potential contractual relationship;
• the processing is necessary for compliance with a legal obligation to which the controller is subject; as a legal entity, KAMP SLATINA is subject to a number of obligations prescribed by various regulations; this particular obligation refers primarily to the collection of data, but very often also includes submission of data to state authorities;
• the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, taking into consideration the reasonable expectations of the data subject based on his or her relationship with the controller, in particular where the data subject is a child; in cases where it relies on this legal basis, KAMP SLATINA assesses whether the processing is appropriate considering the business needs, takes steps to minimize invasiveness as well as makes sure that the interests of the data subject do not override the legitimate interests of KAMP SLATINA or some third party; the purposes for which this type of processing may be performed include, for example, administrative purposes, computer network security protection, direct marketing, operational improvements; data subjects have the right to object to the processing of their data in any of the mentioned circumstances;
• the processing is necessary in order to protect the vital interests of the data subject or of another natural person; the right to personal data protection is not an absolute right; KAMP SLATINA regards that right as equal to other fundamental rights and applies the principle of proportionality in the determination of the same; KAMP SLATINA accepts the possibility that, in certain situations, it may be necessary to process personal data to protect the vital interests of the data subject or of another natural person;
• the data subject has consented to the processing of his/her personal data for one or more special purposes; in cases where it processes personal data relying on consent, KAMP SLATINA takes steps to ensure that such cases refer to situations in which the act giving, refusing to give or withdrawing consent does not produce any, formal or informal, consequences; where the processing is based on consent, the data subject has the right to withdraw his/her consent at any time without negative consequences; such withdrawal will not affect the lawfulness of the processing based on consent before its withdrawal.

Type of Personal Data Processed

Data Concerning Criminal Convictions and Offenses: if and to the extent permitted by law, KAMP SLATINA may also process personal data concerning criminal convictions and offenses, e.g. employee non-conviction certificates.

Personal data that do not belong to either of the two previously mentioned groups: the personal data that do not belong to either of the two previously mentioned groups in fact account for the largest part of the data that we process, including primarily identification and contact details, e.g. first and last name, PIN, and the data created when the data subjects move within the facilities or on the premises under video surveillance.

Transferring Data to Third Parties

Data Retention Period

Data Subject Rights

• your personal data are no longer necessary in relation to the purposes for which we have collected or otherwise processed them,
• you have withdrawn your consent on which the processing is based and there is no other legal ground for the processing,
• you have objected to the processing of your personal data and we have no overriding legitimate grounds for the processing,
• the personal data have been unlawfully processed,
• the personal data have to be erased to comply with a legal obligation.

• file a complaint with the Data Protection Officer (DPO), or
• lodge a complaint with the supervisory authority (i.e. Personal Data Protection Agency) if they believe that their data protection rights have been violated.

Protection of Personal Data of Children

Sources of Personal Data

Technical and Organizational Data Protection Measures

KAMP SLATINA, as the controller, takes care that the highest technical and organizational data protection standards are applied. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons posed by the processing, KAMP SLATINA implements appropriate technical and organizational measures, both at the time of the determination of the means for processing and at the time of the processing itself, to ensure effective application of the data-protection principles.

Actions Taken in the Event of a Personal data Breach

Special Section

ACCOMMODATION AT OUR FACILITIES (hotels, apartments, camps)

• first and last name of the person for whom the reservation is made,
• first and last name of other guests to which the reservation refers,
• permanent address (in the case of Croatian citizens),
• date of birth,
• identification document number, type and place of issue,
• citizenship,
• name of the facility,
• accommodation unit number,
• check-in and check-out dates,
• number of persons for which accommodation is reserved and room assignment,
• number and identity of underage children,
• possible other specific details, as requested by the person making the reservation,
• e-mail address, if any, 
• preferred language of communication,
• phone number,
• membership in the LH&V Premium Club and/or the Camping Cres & Lošinj Club Loyalty Program, where it affects the accommodation rates,
• payment method.

• first and last name,
• city, country and date of birth,
• citizenship
• identification document number and type,
• permanent (temporary) residence and address,
• date and time of arrival to (check-in) and departure from (check-out) the facility,
• gender,
• basis for exemption from the obligation to pay sojourn tax, or for a reduction in the sojourn tax fee.

• checking compliance with the obligation to submit guest check-in and check-out information in the case of entities subject to such requirement (i.e. accommodation service providers),
• keeping a record of, charging and collecting the sojourn tax,
• maintaining a guest register or a list of guests by accommodation service providers and checking compliance with the said obligation by the relevant inspection authorities,
• registering foreign nationals with the Ministry of Internal Affairs and checking compliance with the said obligation by the relevant inspection authorities,
• maintaining a list of tourists by travel agencies, and statistical analysis and reporting,
• supervising the operations of accommodation service providers in the part that refers to the lawfulness of the registered activity, i.e. services, and checking compliance with tax regulations and other regulations relating to public duties.

EXCHANGE OFFICES

EXCURSIONS, CONCERTS, TRANSFERS AND OTHER SERVICES

• first and last name,
• contact details (phone and/or e-mail address),
• other data closely associated with the service(s) to be provided (e.g. flight number, if a transfer service from the airport to the KAMP SLATINA facility is requested; or gender, citizenship, date of birth, and identification document type and number to ensure compliance with the statutory provisions associated with crossing the state borders, if you want a cross-border flight)

MEMBERSHIP IN LOYALTY PROGRAMS

Camping Cres & Lošinj Club

CONTEST / QUESTIONNAIRE FORM

JOB APPLICANTS AND EMPLOYEES

• staff selection, which includes collection and further processing of the relevant job application and supporting documents, testing and evaluation, gathering and analysis of applicant data from publicly available sources, including the applicant data publicly disclosed by the applicant himself or herself, if relevant in terms of the risk associated with a specific position;
• reputation risk mitigation, which includes collection and analysis of information concerning employees and persons who are in a relationship with KAMP SLATINA which is comparable to an employment relationship from publicly available sources, including such which is publicly disclosed by the data subject himself or herself, if relevant in terms of the risk associated with a specific position;
• contract conclusion, i.e. the data are processed for the purpose of concluding an employment contract, a service contract, a student employment contract, a contract with regard to participation in practical or occupational training, a scholarship contract with persons who are not in an employment relationship with KAMP SLATINA, or in any other comparable relationship;
• exercising financial and other rights, in which case the processing of data is necessary for the purpose of exercising financial and other rights of employees, persons in a comparable relationship and other persons (e.g. children, spouses or insurance beneficiaries), e.g. the right to participate in the Active Labor Market Policy measures (i.e. Permanent Seasonal Worker, and other), or certain additional rights defined in the collective contract of KAMP SLATINA in case of special circumstances (e.g. the birth of a child), etc.;
• contract performance, in which case the processing of data is necessary for the purpose of ensuring contract performance on the part of the data subject, including the performance of work duties, the associated monitoring and all the relevant measures ensuring performance of work duties;
• registration of stay, in which case the processing of data is necessary when the data subjects are accommodated in private facilities intended for workers for the purpose of registering their stay with the competent authorities;
• performance management, which includes the collection and processing of information concerning the achievement of predefined goals, timely achievement of goals, additional analyses performed for the purpose of defining future goals, managing human resources and determining the amount of remuneration, as well as concerning other relevant measures;
• remuneration, which includes the processing of data associated with employee remuneration, i.e. payment of the fixed and variable parts of remuneration, and in certain situations the processing of data concerning the breaches of ethical and other internal rules, the data from the performance management system, the data concerning education and training program attendance, and any other relevant data;
• education and training, which includes the processing of data performed for the purpose of ensuring education and training to persons working under the management of KAMP SLATINA, the processing of data performed in connection with knowledge testing and the preparatory activities associated with the application and registration of data subjects for participation in such programs, the processing of data for the purpose of analyzing the acquired knowledge and the processing of other information relevant in terms of organization and implementation of education and training programs, and further actions following program completion;
• drafting employee reports, which includes the drafting of reports for the purpose of complying with the statutory obligations of KAMP SLATINA, for the purpose of exercising certain rights, for the purpose of fulfilling our obligations in cases where certain additional employee benefits, budgets, etc. are allocated and claimed;
• provision of information, which includes the collection and processing of data for the purpose of providing quality and timely information to applicants about job openings and active application processes, i.e. career opportunities at KAMP SLATINA; collection and processing of data for the purpose of providing quality and timely information to all employees of KAMP SLATINA about the newly introduced changes or special notices relevant in the context of exercising the rights arising from the employment relationship or other important notices issued in connection with the general developments and activities performed within KAMP SLATINA in the context of exercising the rights arising from the employment relationship or some other comparable relationship; for this purpose and with the aim of ensuring quick and efficient provision of information, the relevant information is delivered over the phone and/or to the official e-mail address(es) of employees or their private e-mail address(es) if they have consented to the use of the same for that purpose; furthermore, KAMP SLATINA may offer to its employees the possibility of using certain applications providing various information and news about KAMP SLATINA and other companies within the JADRANKA GROUP and/or its partners, which the employees voluntarily install on their mobile devices;
• protection or people and property, which includes the monitoring of entrances/exits from business premises; the use of official mobile devices, computer equipment, the Internet and phone connections, vehicles; the offices and other property of KAMP SLATINA; and access to the property of guests as prescribed by internal acts;
• termination of employment, which includes the processing of data for the purpose of terminating the employment relationship or some other comparable relationship, and for the purpose of complying with the relevant statutory and contractual obligations;
• ethical conduct monitoring, which includes the processing of data used in the context of any procedure performed for the purpose of assessing compliance with the regulations concerning ethical conduct and protection of dignity, or actions taken as part of other disciplinary procedures, regardless of whether the data subject is the person who has been reported or the person who has reported someone else;
• safety at work, in which case the processing of data may be necessary for the purpose of complying with special safety-at-work regulations, including the alcohol blood test and testing for other addictive substances in accordance with the applicable regulations. 

Staff Selection

As a potential employer, KAMP SLATINA collects, processes and stores information concerning the persons applying for positions at KAMP SLATINA. We keep the relevant data in the applicant database relying on the fact that they have provided such data voluntarily:

• by completing an online application form which serves as a CV of a sort,
• by applying via e-mail, 
• by visiting our Human Resources Sector and completing the relevant application forms,
• or in some other manner.

• open applications, in which case applicant data will be stored and processed for the purpose of contacting the applicants in connection with employment during a period of 10 (ten) years relying on the legitimate interest of KAMP SLATINA;
• applications for specific jobs, in which case the application process has a defined deadline and the applicant data are stored and processed during the application process and for a period of 5 months following its completion for the purpose of contacting the applicant in connection with the position for which he or she has applied; applications of this kind are archived for a period of 10 (ten) years; during that period, KAMP SLATINA may also contact the applicant, relying on its legitimate interest, in the case of some other job opens for which he or she has the necessary qualifications and meets all other requirements

Employment Relationship and Other Comparable Relationships

BUSINESS PARTNERS

• In connection with the processing of data subject information, KAMP SLATINA has identified the following purposes of processing:
• contract conclusion, in which case the data are processed for the purpose of concluding a contract in connection with any segment of operations of 
• KAMP SLATINA (e.g. for the purpose of sending inquiries, special offers, requesting information concerning contract signatories, sending tender documents for the legal entities represented by the data subjects, and similar);
• contract performance, in which case the processing in necessary for the purpose of performing a contract, including the fulfilment of contractual obligations, the associated monitoring activities and the measures required to ensure execution of obligations (e.g. in connection with defining the time and place of delivery of equipment in accordance with the contract; or defining the location to which invoices will be sent, etc.);
• provision of information, which includes the collection and processing of data for the purpose of ensuring quality and timely provision of information. 

• first and last name,
• e-mail,
• phone number,
• function performed within the legal entity which the data subject represents (e.g. a sales representative, an administrative secretary, and similar),
• profession, if the data subject is a natural person with whom a contractual relationship is established (e.g. singer, painter, photographer, attorney, medical doctor, etc.),
• in certain cases, letters of recommendation and CVs (e.g. for consultants),
• details provided in blank promissory notes, promissory notes and bills of exchange,
• bank account no. (IBAN), if the business partner is a natural person with whom a contractual relationship is established,
• other information depending on the nature of the business relationship. 

• expressions of interest in establishing a business relationship received from data subjects
  
• details provided by data subjects in connection with the sale of products/services of KAMP SLATINA, or the purchase of products/services of our business partners (e.g. fairs, congresses, and similar),
  
• business correspondence associated with a particular former or current business relationship (e.g. correspondence conducted for the purpose of contract performance),
  
• publicly disclosed information (e.g. information entered in the court register, published on the website of business partners, in magazines, bulletins, and similar). 

Retention Period

PUBLIC NOTICES

NEWSLETTERS

• the date of the data subject’s last stay at our facilities, or termination of other business relationship with us, where the newsletters are sent relying on a legitimate interest; or
• the date on which the data subject has given us his or her consent, where the newsletters are sent on the basis of consent. 

VIDEO SURVEILLANCE

WEBSITES, COOKIES AND INTERNET TECHNOLOGIES 

• strictly necessary cookies – they enable a website to function; a website cannot function without these cookies (it cannot be opened and may not even be visible); strictly necessary cookies are used for the transmission of communication and are necessary for providing information society services explicitly requested by the user; these cookies also enable the basic analysis of a website with the aim of improving its functioning based on fully anonymized data, i.e. not your personal data or any data which can in any manner be attributed to you; your consent is not necessary for placing the cookies of this type on your device, and is therefore not requested;
  
• functionality cookies – these cookies enable a more advanced analysis of the functioning of a website; they are used to analyze user behavior; the collected anonymized data are used to determine the preferences and interests of website visitors, which allows us to customize our websites and make access to the website content and use of the website functionalities as simple as possible; the cookies of this type may not be placed on your device without your consent;
  
• marketing cookies – these cookies are used to analyze your interests and preferences for the purpose of informing you about special or personalized offers, sending you the news and notifications of events organized via online channels (e-mail, internet, web campaigns); you will be requested to provide your consent to enable the use of cookies of this type. 

• permanent (stored) cookies – these cookies remain on your computer even after you close the web browser; they are used by the websites to store data, such as username and password, language settings or cookie preferences, so that you do not have to enter them each time you visit a particular website; the cookies of this type can stay on your computer or mobile device for days, months, or even years;
  
• temporary (session) cookies - these cookies are deleted once the web browser is closed; they are used by the websites to store temporary data, such as the last few pages you have opened while visiting a particular website or the items you have put in your shopping cart while visiting a website which serves as a specialized online store.
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FINAL PROVISIONS