Privacy policy

PRIVACY POLICY

 

KETY TRAVEL D.O.O., with its registered office in Poreč- Nova Vas, Porečka24a, and its branch in Poreč, Park O. Ban 2, OIB: 79811618739 (hereinafter: KETY TRAVEL), respects the privacy of every person whose personal data it collects. We would like to inform you about what personal data KETY TRAVEL collects, how we protect it and what your rights are.

KETY TRAVEL reserves all copyrights to the use of photographs, texts and other published materials, in accordance with the positive legal regulations in the Republic of Croatia. Photographs, texts and other materials may not be published, sold, publicly or privately published or used in any other way without the consent of KETY TRAVEL. Any failure to comply with the above conditions entails liability and the obligation to compensate KETY TRAVEL for non-pecuniary damage for the violation of individual materials.

Basic information

Scope of application

This Policy applies to all processing of personal data by KETY TRAVEL, unless otherwise stipulated in another KETY TRAVEL policy. Exceptionally, in relation to the processing of data of guests and users of KETY TRAVEL services, this Policy takes precedence over other policies if these policies stipulate different rights and obligations regarding data processing.

Data controller and legal framework

KETY TRAVEL, as the Data Controller of your data, respects your privacy and is committed to protecting your personal data. Data collection and storage are carried out in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Act on the Implementation of the General Data Protection Regulation (Official Gazette 42/2018) and other regulations governing the relevant area and applicable in the Republic of Croatia.

Data Protection Officer

KETY TRAVEL has appointed a Data Protection Officer who can be contacted at any time at the following address: [email protected] or by mail at Kety travel d.o.o.Porečka 24a, 52446 Nova vas, Republic of Croatia.

Application of data protection principles

KETY TRAVEL, within the framework of the application of this Policy, pays particular attention to respecting the principles of data processing and processes data:

Lawfully – processing will be possible if it is permitted by law and within the limits permitted by law.

Fairly – taking into account the specifics of each relationship, applying all adequate measures for the protection of personal data and privacy in general and not preventing the data subject from exercising their rights.
Transparently – informing data subjects about the processing of personal data. From the very collection of data, when data subjects are informed about all aspects of data processing, until the cessation of data processing, data subjects are provided with simple and quick access to their own data, which includes the possibility of viewing and obtaining a copy in accordance with the provisions of the Regulation. Certain information may be restricted only when required by law or when necessary for the protection of third parties.
With purpose limitation – processing personal data for the purposes for which they were collected and for other purposes if the conditions set out in the Regulation are met. Data may be processed for compatible purposes only taking into account

(a) any link between the purposes for which the personal data were collected and the purposes for which the intended further processing is carried out;

(b) the context in which the personal data were collected, in particular in relation to the relationship between the data subject and Kety travel;

(c) the nature of the personal data, in particular whether special categories of personal data pursuant to Article 9 of the Regulation or personal data relating to criminal convictions and offences pursuant to Article 10 of the Regulation are being processed;

(d) the likely consequences of the intended further processing for data subjects; and

(e) the existence of appropriate safeguards.

With storage limitation – storing data in a form that permits identification of data subjects only for as long as is necessary for the purposes for which the personal data are processed, and longer only if permitted by the Regulation.
With data minimization – processing data if it is adequate, relevant and limited to what is necessary. Particular care is taken to ensure that data is not collected for which there is no legitimate need for processing.
With accuracy – ensuring that data is accurate and up-to-date and deleting inaccurate data to the extent possible.
With integrity and confidentiality – providing appropriate technical and organizational security measures for personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage by applying appropriate technical or organizational measures. The relevant measures are applied taking into account the risks of each type of data processing.

Delivery of data to third parties

If necessary and to a limited extent, third parties, processors (for example, KETY TRAVEL associates who provide IT services or other services), may also have access to guests’ personal data, which they store in their databases until the processing is completed. With such

These entities shall enter into a detailed contract regarding their powers and obligations in the processing of personal data, in accordance with the requirements of the Regulation.

In certain situations, it is possible for external entities together with KETY TRAVEL to jointly determine the purposes and methods of processing personal data, in which case these external partners and Kety travel shall be joint controllers. In these relationships, the joint controllers shall determine in a transparent manner their responsibilities for complying with the obligations under the Regulation, in particular with regard to the exercise of the rights of the data subjects and their obligations to respect the transparency of processing, unless responsibilities are established by law.

If data processing involves the transfer of data to third countries, KETY TRAVEL shall ensure compliance with high standards of protection in order to respect the highest possible standard of personal data protection, in accordance with the strict requirements of the Regulation. In this regard, when international transfers of personal data are applied, KETY TRAVEL shall inform the data subject of the intention to transfer personal data to a third country or international organization and of the existence or absence of an adequacy decision by the European Commission. At the same time, the data subject will be informed of the appropriate or adequate safeguards and the means of obtaining a copy of them or the place where they are made available if the transfer is subject to appropriate safeguards under Article 46 of the Regulation, the application of binding corporate rules under Article 47 of the Regulation or if Article 49(1)(2) of the Regulation is applicable. Any transfer of personal data to third countries will be carried out in accordance with Chapter V of the Regulation.

Purpose of collection

Your personal data are collected and used only on the basis of the data you have voluntarily provided to KETY TRAVEL using kety-travel.hr. The collected personal data are stored in electronic and paper form, and all appropriate technical and organizational measures are applied to prevent the violation of personal data. KETY TRAVEL will use the e-mails received with your personal data only for the purpose of fulfilling your requests.

KETY TRAVEL is obliged to collect some of your personal data for the purpose of fulfilling the accommodation contract and due to regulations governing the tourism and hospitality industry, but KETY TRAVEL may collect some other or the same data for other purposes, primarily for the purpose of contact, namely:

fulfilling the accommodation contract
fulfilling the requirements of the law and other applicable positive regulations governing the tourism and hospitality industry
for the purpose of direct marketing
sending offers
for the purpose of issuing airline tickets
for the purpose of issuing transport tickets
when booking a rent-a-car, travel or other Kety Travel services
for the purpose of holding prize games
for the purpose of improving and personalizing the service to you as a guest
for the purpose of protecting property and the safety of individuals by applying video surveillance measures

KETY TRAVEL guarantees that the collected data will be used only for the stated purposes.

KETY TRAVEL may use depersonalized data for statistical purposes.

Legal basis for collection

The legal basis for the above collection purposes is:

legal,
contractual,
key interests of the data subject,
legitimate interest that is stronger than the interests of the data subject or
consent or explicit consent of the data subject, depending on the purpose of processing and the type of personal data

Places of data collection

KETY TRAVEL collects your data during:

reservation of accommodation or other services provided by KETY TRAVEL (reservations via the web or reservations via e-mail)
during the registration card
subscribing to the newsletter on the KETY TRAVEL website
joining the loyalty program membership
participating in the prize game by filling out the survey form
at places under video surveillance.

Data retention period

Data that KETY TRAVEL collects on the basis of the law is obliged to retain for the period of time specified by a particular law or other positive regulation.

Data that KETY TRAVEL collects on the basis of a contractual relationship will be retained only for as long as necessary for the purpose of fulfilling the contract or providing the service.

Data on the name, surname and e-mail address that KETY TRAVEL collects on the basis of legitimate interest for direct marketing purposes will be kept in its guest database for 10 years.

Other data that KETY TRAVEL collects on the basis of the guest’s express consent (mobile phone number, number of children, marital status, pets, interests, method of travel, accommodation preferences and preferences for destinations and services) will be kept in its guest database for 5 years.

LETY TRAVEL may also, based on your express consent, collect and store data on the content you view on the website (so-called cookies), and in that case it will keep them in its database for a period of 2 years. KETY TRAVEL will use the specified data for the purpose of informing you about special and personalized offers, news and events that it organizes via online channels (e-mail, web, internet promotion).

Rights of the data subjects

Regardless of the basis for data collection, you can at any time request free of charge:

access, modification or completion of data

aka in all personal data bases, on the basis of which KETY TRAVEL will enable access to or change your data in all its databases depending on your request,
deletion (“right to be forgotten”) of personal data in all personal data bases, on the basis of which KETY TRAVEL will delete you from all its databases, except from databases that KETY TRAVEL is obliged to have and keep based on positive regulations, and if there are no stronger legitimate reasons for the processing or if the processing is not necessary for the establishment, exercise or defense of legal claims,
restriction of the processing of your data or objection to the processing of such data
to have the data we have collected about you transferred to you or third parties (“right to data portability”), in accordance with positive legal regulations,
if the data is provided on the basis of consent, you can always withdraw that consent without negative consequences,
right to file a complaint with the supervisory authority – the Personal Data Protection Agency (more about this at www.azop.hr)

Send your written request to the contact address of the personal data protection officer: [email protected] or by mail to Keyt travel d.o.o.- Porečka24a,52446 Nova vas, Republic of Croatia.

Personal data collected from persons and guests who have booked accommodation and other hospitality and tourism services that we provide

Your personal data that you must provide in order to provide you with accommodation services, KETY TRAVEL, as the data controller, keeps in its database solely for the purpose of fulfilling the accommodation contract and fulfilling legal obligations of delivery, as well as collecting personal data related to tourism and hospitality activities, and may also use them for other purposes stipulated by positive regulations. In the event that you do not provide KETY TRAVEL with the minimum data required for guest registration in all relevant registers, KETY TRAVEL will not be able to provide you with accommodation services in accordance with the contract and the law.

Personal data that KETY TRAVEL records already at the time of booking and on the registration card upon arrival at the facility, have been collected pursuant to the laws governing the hospitality industry, and for the purpose of providing services to guests. This is the following data (which may change due to positive regulations):

name and surname
address of residence (Croatian citizens)
date of birth
number, type of identification document and place of issue
citizenship
name of facility
accommodation unit number
date of arrival and departure of the guest
gender

KETY TRAVEL stores the above data in its guest database and sends it to the E-visitor system (electronic guest registration system) to the competent authorities of the Republic of Croatia, and the above data must be stored in the system for 10 years. KETY TRAVEL is also obliged to store all invoices issued to guests with the guest’s personal data for 11 years, in accordance with legal regulations.

Only the data necessary for the implementation of the service will be available exclusively to partners in the implementation (e.g. accommodation, transport, insurance and travel companions). Payment data (e.g. bank card number, expiration date) are specially protected and will only be available to banks or card companies for the purpose of payment authorization.

Furthermore, in order to fulfill the contractual obligation, KETY TRAVEL collects the following data during the reservation, as well as on the registration card:

e-mail
language
phone.

Other data related to the circumstances of your stay, such as, for example: method of travel, who you are traveling with, marital status, number of children, pets, other interests, will also be collected if they have a direct connection with the provision of accommodation or some other service from our offer for the purpose of providing quality service, and will be deleted after your departure.

Your personal data (name and surname, e-mail address), KETY TRAVEL, as a data controller, has the right, based on legitimate interest, to collect it in its guest database and use it for the purpose of direct marketing and exclusively for the purpose of informing you about KETY TRAVEL’s offers and news via e-mail. In this case, you have the right to request deletion (right to be forgotten) from the database for this purpose at any time and free of charge.

During and after your stay, KETY TRAVEL sends you, as a guest, a satisfaction questionnaire via the e-mail we received from you, which, if you wish to complete it, i.e. exclusively with your consent, is processed by a company (TrustYou), which publicly publishes the data from the questionnaire according to its own rules and policies for which KETY TRAVEL is not responsible. The primary purpose of the satisfaction questionnaire is to collect data about the service in order to improve the service by KETY TRAVEL, and KETY TRAVEL depersonalizes and processes the data from the questionnaire for statistical purposes.

In addition, the person booking the accommodation, i.e. the guest, may give special permission, consent, to KETY TRAVEL, to all of their data, such as:

name
surname
e-mail
date of birth
country
other personal data collected during the stay (e.g. mobile phone number, telephone number, gender, number of children, marital status, language, pets, interests and activities during the stay, mode of travel, accommodation preferences, preferences

ija destinations, etc.)
other personal data collected when browsing the web (so-called cookies) including IP address.

collects and uses for further profiling of respondents and for the purpose of contacting and informing about special and personalized offers, news and events organized by KETY TRAVEL via online channels (e-mail, web, internet promotion). In this case, the respondent has the right to withdraw the given consent at any time, which includes processing for the purpose of creating a profile to the extent that it is related to such direct marketing, whether in relation to the initial or further processing, at any time and free of charge, as well as the right at any time to change data and the right to be forgotten.

The data is stored in the KETY TRAVEL guest database for 5 years.

KETY TRAVEL also collects personal data via the video surveillance system.

Personal data collected by signing up for the newsletter on the KETY TRAVEL website

When signing up for the newsletter, the respondent will have the option to provide the following additional data with consent (not including first and last name and e-mail address that KETY TRAVEL collects based on legitimate interest):

sex
date of birth
state
language.

When updating the subscription to the newsletter, the respondent will have the option to provide the following additional data with consent:

street, house number, postal code, city
phone number
mobile phone number
interests
mode of travel
pets
accommodation preference
destination preference.

The collected data is collected based on express consent for the purpose of informing about special and personalized offers, news and events organized by KETY TRAVEL via online channels (e-mail, web, internet promotion).

Data is stored in the KETY TRAVEL guest database for 5 years.

The respondent has the right to change data and the right to be forgotten.

Personal Data collected when joining loyalty membership (loyalty program membership)

By joining the loyalty membership, guests will collect points in the manner specified in the general conditions for Loyalty members, which are obtained when consuming the service through KETY TRAVEL. All terms of entry into loyalty membership, obligations of KETY TRAVEL and the rights of respondents are contained in the general conditions of Loyalty membership, which can be found at www.kety-travel.hr/loyalty. Entry into the loyalty membership is made solely on the basis of the guest’s request, the guest receives various benefits based on the specified membership, and the guest can exit the loyalty program at any time.

The data collected are:

name,
surname,
sex,
date of birth,
e-mail,
mobile number,
phone number,
address (street, house number, postal code, city and country).

KETY TRAVEL has the right, based on legitimate interest, to collect and use data on the e-mail address, name and surname of all loyalty members for the purpose of direct marketing and exclusively for the purpose of informing about offers and news of KETY TRAVEL via e-mail. In this case, the data subject has the right to object to such processing, including profiling to the extent related to such direct marketing, whether in relation to initial or further processing, at any time and free of charge.

In addition, the person accessing the membership can give special permission, consent, to KETY TRAVEL to share all of his/her data, but also:

other personal data collected during the possible stay (e.g. number of children, marital status, language, pets, interests and activities during the stay, method of travel, accommodation preference, destination preference, etc.)

KETY TRAVEL collects and uses data for further profiling of respondents and for the purpose of contacting and informing about special and personalized offers, news and events organized by KETY TRAVEL via online channels (e-mail, web, internet promotion). In this case, the data subject has the right to withdraw the consent given at any time, which includes processing for the purpose of creating a profile to the extent that it is related to such direct marketing, whether in relation to the initial or further processing, at any time and free of charge, as well as the right at any time to change the data and the right to be forgotten.

The above data is stored in the KETY TRAVEL guest database for 5 years.

Personal Data collected when participating in the prize game / filling out the survey form

KETY TRAVEL may occasionally organize prize games, in which case it will collect your personal data only if you decide to participate in the prize game. The data that will be collected in this way and that are necessary for participation in the prize game will be determined by the Prize Game Rules, for each separate prize game, and may be different. The data collected in this way will be used for the purpose of conducting the prize game, in accordance with the rules of the prize game, and deleted within 5 years after the end of the prize game.

In case you fill out the survey form for the prize game with data that is not necessary for participation in the prize game, (data may be different in different prize games), KETY TRAVEL may use all this depersonalized data for statistical purposes.

ke purposes.

Data on name, surname and e-mail address, which you fill in the survey form for the prize game, KETY TRAVEL has the right, based on legitimate interest, to collect and use for the purpose of direct marketing and exclusively for the purpose of informing about offers and news of KETY TRAVEL via e-mail . In this case, the data subject has the right to object to such processing, including profiling to the extent related to such direct marketing, whether in relation to initial or further processing, at any time and free of charge.

The above data is stored in the KETY TRAVEL guest database for 10 years.

The respondent has the right to change data and the right to be forgotten.

In addition, the person participating in the sweepstakes can give special permission, consent, to KETY TRAVEL that all his data provided by filling out the survey form for the sweepstakes (the data may be different in different sweepstakes) is collected and used by KETY TRAVEL for further profiling of the respondents and for the purpose contacting and informing about special and personalized offers, news and events organized by KETY TRAVEL via online channels (e-mail, web, internet promotion). In this case, the subject has the right to withdraw the given consent at any time, which includes processing for the purposes of creating a profile to the extent that it is related to such direct marketing, either in relation to initial or further processing, at any time and free of charge, as well as the right at any the era of data change and the right to be forgotten.

Data is stored in the KETY TRAVEL guest database for 5 years.

Why do we use your information?

The reasons for using your information (listed in the table below) vary depending on your relationship with us. At least one of the following legal grounds must apply when using your data:

we need to process the data to perform or enter into a contract with you
we have your consent to use the data
we need to use the data to comply with a legal obligation
we need to use the data for the purposes of our legitimate interests or legitimate interests third parties, without violating your interests and fundamental rights

In order to process special categories of personal data, we need to have additional justification for their processing and we only use them with your explicit consent, if you have made the data public, if the data relates to legal requirements or if they are necessary for reasons of substantial public interest.

Purpose of data processing

Legal basis for processing

Legitimate interest (where applicable)

Completing and managing your booking and related requests (if you book a holiday accommodation)

Contract

Consent

Legitimate interest

Record keeping and providing quality customer service

Advertising your holiday accommodation, transfer payments intended for you and providing related support services (if you provide accommodation services through us)

Agreement

Legitimate interests

Record keeping and providing quality customer service

For statistical purposes

Legitimate interests

Evaluating our services

Personalizing your future visits to our websites

Consent

Implementing promotional activities – except for sending you a brochure, we also use information about your reservations, searches, preferences on our website, favorites and interactions with our brochure to show you relevant and personalized ads on websites and social networks.

Legitimate interests

Consent

Identifying services that may be of interest to you and sending you notifications about them

Managing customer service inquiries and complaints

Legitimate interests

Improving services and resolving issues

Keeping records of your communications with us, including call recordings

Legitimate interests

Improving services, training staff and maintaining records

Managing your entries for competitions and other promotional activities

Consent

Sending inquiries for reviews about accommodation and/or services provided

Legitimate interests

Understanding perceptions of our society and improving services

Sending messages about services, e.g. about updates to our terms and conditions

Legitimate interests

Informing customers

Compliance with legal obligations, processes or requests

Legal obligation

Enforcing our booking terms and other agreements, including investigating any potential breach of agreement

Agreement

Legitimate interests

Protecting business

Detecting or preventing crime, including fraud

Legal obligation

Legitimate interests

Protecting business and customers

Assisting law enforcement and government agencies

Resolving security or technical issues

Contract

Legitimate interests

Protecting business and customers

Protecting the rights, property, or safety of our company, users, property owners, customers, employees, contractors, third parties, or the public Legal obligation

Contract

Legitimate interests

Protecting our business, customers, third parties or the public

Testing, developing and improving our services

Legitimate interests

Improving our business

Establishing, exercising or defending our legal rights

Legitimate interests

Protecting our business

Cookies and internet technologies

Like many other websites, ours may use “cookies” (small files that we store on your computer when you access our websites to enable basic or additional functionality of those websites) and other technologies that help us deliver content based on your interests, process reservations or requests, and/or analyze the characteristics of your visits. Cookies cannot be used to identify you personally. When you access our websites, this information identifies your browser characteristics to our servers, but not you.

We use different types of cookies:

Essential cookies – these are essential for the website to function and cannot function without them. This means that the website cannot be opened or displayed without these cookies. These cookies are used for the purpose of transmitting communication or are necessary for the provision of an information society service that is explicitly requested by the user of such a service. Also, these cookies will enable us to perform basic analysis of the website in order to improve the operation of the website using data that is completely anonymized, i.e. not based on your personal data or data that can be linked to you in any way. Your consent is not required and we do not ask for your consent for these cookies.
Functional cookies – we use them to conduct a more advanced analysis of the operation of the website. These cookies are used to analyze user behavior and, based on the anonymous data obtained, we can determine what website visitors want and view most, so we are then able to customize the website and make its content and functionality as easy to use as possible. We ask for your consent for these cookies.
Advertising cookies – we use them to analyze your interests and desires, and they serve us to provide you with information that is interesting to you and create offers tailored to your use of the KETY TRAVEL website. We ask for your consent for these cookies.

KETY TRAVEL stores cookies in the database and keeps them for a maximum of 2 years for the purpose of informing you about special and personalized offers, news and events organized via online channels (e-mail, internet, online promotions).

If you have changed your mind about the cookie settings on the Valamar website at any time, you can change them at the link: (link to cookie consent box). You can always delete cookies that are stored on your computer, thus preventing further processing of your personal data via such technology. Each internet browser has its own cookie deletion procedure, and here are the procedures for the most popular internet browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=hr

Mozilla Firefox: https://support.mozilla.org/hr/kb/Brisanje%20kola%C4%8Di%C4%87a

Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

Google Analytics (web analysis)

Our website uses Google Analytics, a web analysis service from Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze your use of the website. In general, the information generated by the cookie about your use of our website will be transmitted to Google and stored on servers in the USA. By activating IP anonymization on our website, your full IP address is sent to Google and shortened by a Google server in the USA. Google will use this information on our behalf to analyze your use of our website, to generate reports on website activity and to provide additional services, such as Google Adwords and Google DoubleClick, for use in connection with website and internet usage. Google will not associate your IP address with any other data held by Google.
We have concluded a data processing agreement with Google, which will act as a ‘data processor’ on our behalf. We have added code to our website with the function to ensure that IP addresses are collected anonymously. You can object to tracking by Google Analytics as described above by clicking on the “Disable Google Tracking” button at the bottom of this page. A cookie will be set that will prevent future data collection when you visit the website (so-called “opt-out cookie”). You can also prevent the storage of cookies by setting the appropriate settings on your browser as described above; please note that you will then not be able to use all the functions of our website to their full extent.
You can also prevent Google tracking

described above, by downloading and installing the browser extension (add-on/plugin) at:
https://tools.google.com/dlpage/gaoptout?hl=en-GB
Additional information on data protection for Google Analytics is available in Google’s data protection notice under “Google Analytics cookies”: https://tools.google.com/dlpage/gaoptout?hl=en-GB

Links

KETY TRAVEL’s websites contain links to other websites (e.g. Facebook, Instagram, hotels, airports, weather forecasts). Accordingly, we warn and ask users to take into account that Uniline cannot be responsible for respecting privacy on the aforementioned websites, therefore we encourage users to read the Privacy Statement of each website they access.

 

Video surveillance system

KETY TRAVEL as the data controller has a legitimate interest in implementing video surveillance measures to protect property and persons, and in relation to certain work positions and the legal obligation to install surveillance cameras that record employees and all persons moving within the field of view of the surveillance camera.

KETY TRAVEL marks all places where video surveillance is installed in a prescribed manner.

KETY TRAVEL is aware that videos contain personal data of all persons moving within the field of view of the camera, and therefore stores them with special care, has a system of security, availability and a policy for their deletion, which is regulated by the internal security rules of KETY TRAVEL

Video recordings are regularly overwritten so that they are automatically deleted after a maximum of 15 days from the date of recording. Exceptionally, videos are kept longer if they are evidence in proceedings before competent state bodies. Exempted videos will be stored in a central reporting system with extremely limited access.

In the event of conducting court and/or criminal proceedings, KETY TRAVEL may use the aforementioned videos. Personal data in the videos may also be accessed by third parties, processors, contractual partners of KETY TRAVEL registered and professional in providing services for the protection of persons and property, who do not use the said data independently in any way, but rather take care of the security of central surveillance and reporting systems. All other details related to video surveillance are subject to special regulations governing this area.

Protection of children’s personal data

KETY TRAVEL advises parents and guardians to teach children about the safe and responsible handling of personal data on the Internet. KETY TRAVEL does not want and does not intend to collect children’s personal data, will not use it in any way, or disclose it to third parties. A child can give their consent solely in relation to possible information society services, and that child is over 16 years of age. Any other processing of data of children below the specified age limit and other processing other than that expressly stated here, for children under 18 years of age, is permitted by KETY TRAVEL only with the prior consent of the parents.

Change of data

You can contact us at any time to review your personal data, as well as to update, correct or delete data. Until then, we use your previously recorded data for the above purposes.

Your consent

When providing information to KETY TRAVEL, in any way (reservation, registration card, etc.), you guarantee that the information you have provided is accurate, that you are legally competent and authorized to dispose of the information provided, and that you fully agree that KETY TRAVEL uses and collects your data in accordance with the law and the terms of this privacy policy.

Technical and integrated data protection

KETY TRAVEL, as the data controller, takes into account the highest organizational and technical standards of data protection. Therefore, taking into account the latest developments, the cost of implementation and the nature, scope, context and purposes of the processing, as well as the risks of varying degrees of probability and severity for the rights and freedoms of individuals arising from the processing of data, at the time of determining the means of processing and at the time of the processing itself, implements appropriate technical and organizational measures to enable the effective application of the principles of data protection.

KETY TRAVEL also implements appropriate technical and organizational measures to ensure that only personal data that are necessary for each specific processing purpose are processed in an integrated manner. VALAMAR RIVIERA applies this measure to the amount of personal data collected, the scope of their processing, the storage period and their availability. More specifically, such measures ensure that personal data are not automatically, without the intervention of the individual, accessible to an unlimited number of individuals.

Records of processing activities

KETY TRAVEL, as the controller, keeps records of processing activities with the following information:

name and contact details of the controller, if applicable, the joint controller, and the data protection officer;
the purposes of the processing;
a description of the categories of data subjects and categories of personal data;
the categories of recipients to whom the personal data have been disclosed or will be disclosed, including recipients in third

countries or international organisations;
where applicable, transfers of personal data to a third country or international organisation, including the identification of that third country or international organisation and, in the case of transfers pursuant to the second subparagraph of Article 49(1), documentation of the appropriate safeguards;
where possible, the time limits envisaged for the erasure of the different categories of data;
where possible, a general description of the technical and organisational security measures

Handling of personal data breaches

KETY TRAVEL as the controller shall ensure that in the event of a personal data breach, without undue delay and, where feasible, not later than 72 hours after having become aware of the breach, notify the competent supervisory authority of the personal data breach, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of individuals.

The report submitted to the supervisory authority shall contain all information in accordance with the Regulation.

In the event of a personal data breach which is likely to result in a high risk to the rights and freedoms of individuals, KETY TRAVEL as the controller shall notify the data subject of the personal data breach without undue delay. Data subjects will not be informed in cases where the Regulation provides that this is not mandatory.

Data protection impact assessment

If a type of processing, in particular by means of new technologies and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of data subjects, Valamar, as the controller, shall carry out an assessment of the impact of the envisaged processing operations on the protection of personal data prior to the processing.

One assessment may relate to a number of similar processing operations presenting similar high risks.

KETY TRAVEL shall carry out a data protection impact assessment in the case of:

systematic and extensive evaluation of personal aspects relating to natural persons based on automated processing, including profiling, and on the basis of which decisions are taken which produce legal effects concerning the natural person or similarly significantly affect the natural person;

large-scale processing of special categories of personal data referred to in Article 9(1) or data relating to criminal convictions and offences referred to in Article 10 of the Regulation;

systematic monitoring of a publicly available area on a large scale,

in other situations determined by the competent supervisory authority.

KETY TRAVEL ensures adequate involvement of the data protection officer in the impact assessment process.

In accordance with the provisions of the Regulation, if necessary, a prior consultation procedure with the supervisory authority will be carried out after the impact assessment process.

Transparency

This Privacy Policy is available on the website www.kety-travel.hr and also in our branch office.

In the event of changes to the privacy policy, a notice will be published on this website www.kety-travel.hr and in our branch office in order to inform users

Last modified. Poreč, 24.05.2018

 

 

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