PRIVACY POLICY
Thank you very much for your interest in Lumbarda House.
Protecting your privacy when using our website www.lumbardahouse.com is particularly important to us. Therefore, we are providing you below with detailed information on the processing of your personal data.
All personal data collected by Lumbarda House via this website, as well as through other forms of direct, written or electronic communication in the course of our activities, are collected, processed and stored in accordance with this Privacy Policy and the applicable laws and regulations of the Republic of Croatia and the European Union.
Lumbarda House is entitled to use personal and anonymous data to the extent legally permitted, subject to the rights of users described below.
This Privacy Policy describes the personal data we collect, how we process it, the purposes for which it is used, and your rights regarding your personal data. By accessing or using this website, you acknowledge that you have read and understood the content of this Privacy Policy.
Please note that this Privacy Policy applies only to [www.lumbardahouse.com](http://www.lumbardahouse.com) and does not apply to websites controlled and operated by third parties. We recommend reviewing the privacy policies of any third-party websites you visit. Such websites are beyond our control, and Lumbarda House is not responsible for their content, privacy practices or data protection measures.
DATA SECURITY
Lumbarda House has implemented appropriate technical and organizational measures designed to protect your personal data against accidental or unlawful loss, misuse, alteration, disclosure or unauthorized access.
The security measures implemented are regularly reviewed and, where necessary, updated in accordance with technological developments and applicable data protection requirements.
Notwithstanding the above, users are responsible for ensuring that the devices, computers and internet connections they use to access our website are adequately protected and secure.
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay in accordance with applicable legal requirements. Where required by law, the relevant supervisory authority will also be notified within 72 hours of becoming aware of the breach.
COLLECTION AND PROCESSING OF PERSONAL DATA
2.1 Data Provided by You
When you contact or correspond with Lumbarda House through our website, email, contact forms or other communication channels, the personal data you provide may be collected and processed for the purposes described in this Privacy Policy.
Such information may include, depending on the nature of your communication, your first and last name, email address, telephone number and any other information you voluntarily provide to us.
We process this information in order to respond to your inquiries, provide requested information or services, communicate with you and fulfill any contractual or pre-contractual obligations.
2.2 Cookies
Our website may automatically collect certain information through the use of cookies.
A cookie is a small text file that stores certain information relating to your use of a website. Cookies are commonly used by websites to ensure proper functionality, improve user experience, remember preferences and, where applicable, analyze website usage.
When you first visit our website, cookies may be stored on your device through your internet browser. When you visit the website again using the same device and browser, the cookie and the information stored within it may be sent back to the website that created it (first-party cookie) or to another website or service to which it belongs (third-party cookie).
This enables the website to recognize that it has previously been visited using that browser and may, in some cases, adjust the content displayed.
Technically necessary cookies are used to ensure the proper functionality and security of our website.
Where processing is necessary for the functionality of the website, the legal basis may be Article 6(1)(f) of the General Data Protection Regulation (GDPR), based on our legitimate interest in providing a functional, secure and user-friendly website.
Data collected through technically necessary cookies is not used to create marketing profiles about you.
Session cookies are generally deleted when you close your browser. Persistent cookies remain stored on your device for a defined period, which may range from a few minutes to several months or years, depending on the type of cookie.
You can manage, restrict or delete cookies at any time through your browser settings. However, disabling certain technically necessary cookies may affect the functionality of some parts of our website.
For cookies that are not technically necessary, including analytics, advertising and marketing cookies, we request your consent where required by applicable law. You may withdraw or modify your consent at any time through the cookie settings available on our website.
GOOGLE ADSENSE AND ADVERTISING SERVICES
Where Google AdSense or other Google advertising services are used on [www.lumbardahouse.com](http://www.lumbardahouse.com), these services may be provided by Google and its affiliated companies.
Google advertising services may use cookies and similar technologies to display advertisements, measure their effectiveness, personalize content and advertisements, analyze website traffic and provide other advertising-related functionality.
Depending on your consent preferences, information about your use of our website may be shared with Google and other advertising, analytics or technology partners.
Such information may include technical data relating to your browser or device, IP address, website interactions and other identifiers used for advertising and analytics purposes.
Advertising and marketing cookies are used only after obtaining your consent where required under applicable law.
The legal basis for such processing is Article 6(1)(a) of the GDPR – your consent.
You may withdraw your consent at any time by changing your cookie preferences on our website. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
Where personal data is transferred outside the European Economic Area (EEA), appropriate safeguards required by applicable data protection law will be applied.
Further information about Google’s processing of personal data and applicable privacy practices can be found in Google’s Privacy Policy.
DATA BEING PROCESSED
Depending on how you interact with our website and services, Lumbarda House may process personal data including:
First and last name;
Email address;
Telephone number;
Information provided through contact or inquiry forms;
Information relating to reservations or accommodation inquiries;
Technical information relating to your browser, device and use of the website;
Cookie preferences and related identifiers;
Any other personal information you voluntarily provide to us.
We only collect and process personal data that is necessary for the relevant purpose.
NEWSLETTER REGISTRATION
If newsletter registration is available on [www.lumbardahouse.com](http://www.lumbardahouse.com) and you voluntarily subscribe to our newsletter, we may process the personal information provided during registration, such as your first name, last name and email address.
Purpose: To provide you with news, updates, special offers, information about Lumbarda House and invitations or information relating to future events and activities.
Legal basis: Article 6(1)(a) of the GDPR – your consent.
Estimated storage period: Your personal data will be stored until you withdraw your consent or unsubscribe from the newsletter, unless a longer retention period is required by law.
You may withdraw your consent and unsubscribe from the newsletter at any time using the unsubscribe option included in our communications or by contacting Lumbarda House directly.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
RETENTION OF PERSONAL DATA
Lumbarda House retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or for as long as required by applicable legal, accounting, contractual or regulatory obligations.
Where processing is based on your consent, the relevant personal data may be retained until you withdraw your consent, unless another legal basis requires or permits continued storage.
After the applicable retention period expires, personal data will be securely deleted, anonymized or otherwise disposed of in accordance with applicable regulations.
YOUR RIGHTS
Under the GDPR and applicable data protection legislation, you may have the following rights regarding your personal data:
The right to access your personal data;
The right to request correction of inaccurate or incomplete personal data;
The right to request deletion of your personal data where applicable;
The right to request restriction of processing;
The right to object to certain types of processing;
The right to data portability where applicable;
The right to withdraw consent at any time where processing is based on consent;
The right to lodge a complaint with the competent supervisory authority.
In Croatia, the competent supervisory authority is the Croatian Personal Data Protection Agency (AZOP).
To exercise any of your rights relating to personal data processed by Lumbarda House, you may contact us using the contact information provided on www.lumbardahouse.com.
CHANGES TO THIS PRIVACY POLICY
Lumbarda House reserves the right to amend or update this Privacy Policy when necessary to reflect changes in our services, website functionality, technologies used or applicable legal and regulatory requirements.
Any updated version of this Privacy Policy will be published on www.lumbardahouse.com.
We recommend reviewing this Privacy Policy periodically to stay informed about how we collect, process and protect your personal data.
CONTACT
If you have any questions regarding this Privacy Policy, the processing of your personal data or the exercise of your data protection rights, please contact Lumbarda House using the contact information provided on www.lumbardahouse.com.
RIGHTS OF DATA SUBJECTS
Under the General Data Protection Regulation (GDPR) and applicable Croatian data protection legislation, you may exercise the following rights regarding the processing of your personal data:
4.1. Right to Information and Access
You have the right to request confirmation as to whether Lumbarda House processes your personal data and, where such processing takes place, to request access to your personal data.
You may also request information regarding the purposes of processing, categories of personal data concerned, legal basis for processing, recipients or categories of recipients of the data, estimated storage period, and other rights relating to the processing of your personal data.
4.2. Right to Rectification
If we process personal data about you that is inaccurate, incomplete or outdated, you have the right to request that such data be corrected or supplemented without undue delay.
4.3. Right to Erasure
You may request the deletion of your personal data where one of the applicable legal grounds exists, including where:
the personal data is no longer necessary for the purposes for which it was collected or processed;
you withdraw your consent and there is no other legal basis for processing;
you object to the processing and there are no overriding legitimate grounds for continuing the processing;
your personal data has been unlawfully processed; or
the personal data must be deleted in order to comply with a legal obligation.
Please note that the right to erasure is not absolute. In certain circumstances, we may be required or permitted to retain your personal data, including where retention is necessary to comply with legal obligations, establish, exercise or defend legal claims, or comply with statutory retention requirements.
4.4. Right to Restriction of Processing
You have the right to request restriction of the processing of your personal data where:
you contest the accuracy of your personal data, for the period necessary for us to verify its accuracy;
the processing is unlawful, but you oppose the deletion of your personal data and request restriction of its use instead;
we no longer require the personal data for the purposes of processing, but you require it for the establishment, exercise or defence of legal claims; or
you have objected to processing and verification is pending as to whether our legitimate grounds override your interests, rights and freedoms.
Where processing has been restricted, your personal data will generally only be stored and will not otherwise be processed except with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another person, or for reasons of important public interest.
4.5. Right to Data Portability
You have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format where:
the processing is based on your consent or on a contract; and
the processing is carried out by automated means.
Where technically feasible, you may also request that your personal data be transmitted directly to another controller.
4.6. Right to Object
Where we process your personal data on the basis of our legitimate interests or for the performance of a task carried out in the public interest, you have the right to object to such processing on grounds relating to your particular situation.
Following your objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or unless the processing is necessary for the establishment, exercise or defence of legal claims.
Where your personal data is processed for direct marketing purposes, you have the right to object to such processing at any time and without providing a reason. If you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes.
4.7. Right to Lodge a Complaint
If you believe that the processing of your personal data infringes Croatian or European data protection legislation, you have the right to lodge a complaint with the competent supervisory authority.
In Croatia, the competent supervisory authority is:
Croatian Personal Data Protection Agency (AZOP)
You may also contact us directly before submitting a complaint so that we have an opportunity to review and address your concerns.
4.8. Right to Withdraw Consent
Where the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time.
The withdrawal of consent does not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal.
Following withdrawal, we will cease processing your personal data for the purposes covered by that consent unless another legal basis permits or requires us to continue processing it.
4.9. Exercise of Rights
If you wish to exercise any of the rights described above, please contact Lumbarda House using the contact details provided below.
We will process your request in accordance with the deadlines and requirements prescribed by applicable data protection legislation.
4.10. Identity Verification
Where we have reasonable doubts concerning the identity of the person making a request, we may ask you to provide additional information necessary to confirm your identity.
This measure is intended to protect your personal data, privacy and rights against unauthorized access or fraudulent requests.
4.11. Manifestly Unfounded or Excessive Requests
Exercising your rights under the GDPR is generally free of charge.
However, where requests are manifestly unfounded or excessive, particularly because of their repetitive character, we may, in accordance with applicable law:
charge a reasonable administrative fee taking into account the costs of providing the information, communication or taking the requested action; or
refuse to act on the request.
Where we refuse to act on a request, we will inform you of the reasons for doing so and of your right to lodge a complaint with the competent supervisory authority.
CONTACT DETAILS
If you have any questions regarding the processing of your personal data, wish to exercise any of your data protection rights, or wish to withdraw your consent to the processing of personal data collected through www.lumbardahouse.com, you may contact us using the following details:
Controller:
Lumbarda House