With this statement, we would like to provide you with more detailed data on processing your personal data regarding the conclusion and execution of Contracts for providing our nautical services that are specified and all listed on our website www.yachtman-holidays.com as well as all rights you are intitled to regarding processing your personal data.
Who is responsible for processing your personal data?
As we determine the purpose and means of processing your personal data, we are, in accordance with the General Data Protection Regulation (Regulation 2016/679), responsible for processing your personal data, namely: HORVAT TURIZAM Ltd, Croatia, Zagreb, Kutinska 4, VAT no. HR26227941488 represented by Director Miroslav Horvat, Tel: +385 01 3770 150; e-mail: firstname.lastname@example.org. For questions about processing your personal data or about realization your data protection rights, please contact us at email@example.com or by post at HORVAT TURIZAM Ltd, 10000 Zagreb, Kutinska 4, Croatia.
For what purposes and on what legal basis do we process your personal data?
We process your personal data in accordance with the General Data Protection Regulation and other valid privacy regulations. We process your personal data for the purposes stated in this document in accordance with the following legal bases:
Precontract procedures, concluding and executing Contracts
By using or registering on www.yachtman-holidays.com you agree to process your personal data listed in the registration form, as well as data about orders or Contracts, as well as data available in the payment process and other data. We will not use or make available to third parties any personal data collected, unless such special law allows it or is necessary for the purpose of fulfilling the Contractual obligations. All our employees and business partners are responsible for respecting the privacy principles.
The personal data you provide us through our published forms on the web site or by Contract signing and / or other documentation is processed to determine your needs and requirements in order to provide you with other services that represent our core business. We handle personal data for the purpose of assessing the risks we take and on which basis we will decide whether we can provide you with our services. If you enter into a Contract with us or provide us with the appropriate form and / or request, we will process your personal data for the purpose of executing the Contract.
Fulfilment of legal obligations
We may process your personal data in order to meet our obligations under statutory tax and accounting regulations.
We have the right to process your personal data for the purposes of our legitimate interests under the condition that our interests are stronger than your interests or your fundamental rights and freedom that require the protection of personal data. We will of course consider your reasonable expectations of personal data processing based on your Contractual or other relation with us. Our legitimate interest is, for example, processing of personal data for the purpose of direct marketing, contacting, providing services, doing business, prevention and detection of fraud or other criminal or misdemeanour offenses and other purposes listed below. We may also process your personal data for statistical purposes in order to obtain statistical data related to our business while we look at the fact that processing of personal data for statistical purposes does not allow your identification.
Your data is collected and processed for the following purposes:
- for your use of services
- to provide services and to execute your requests
- to provide you with content and recommendations based on your activity on the website
- advertising and sending of promotional materials
- to improve our business and the development of the services provided to you
- to evaluate and analyse activities on this web site, our market, users, products and services
- for communication with you
- to analyse how people (including You) use our services and content to improve them and develop new products and services tailored to the user's wishes
- for other purposes with your consent
Which categories of personal data are processed?
We process personal data we have collected from you through our published forms, requests, Contracts or other documentation, including your basic data (e.g. name and surname, residence, personal number, e-mail, phone number), Contract details, payment data and / or debts toward us. Since we only collect data that is necessary for achieving a particular purpose, in some cases it is possible to achieve the purpose of processing and using a smaller amount of data than previously described.
Transfer of data to third parties
If it’s necessary to achieve the previously mentioned purposes of processing, or if it’s determined by the regulations, your personal data may be transferred to private and legal entity, public authorities or other bodies (receivers). Regardless of which recipients we provide your personal data to, we will only provide the data necessary to achieve the specific purpose of processing. The following recipients can be:
- insurance company
- charter company
- Ministry of Maritime Affairs
- an external accounting service
- airline companies
Business partners and third parties closely related to execution of the Contract
Given the nature of our agency and brokerage activity that necessarily involves contacting and exchanging data with a wide range of third parties, your personal data may be disclosed to third parties, but solely for the purpose of executing the Contract we have concluded with you. For example, personal data will in some cases be forwarded to other agencies, charter companies, port authorities and similar. Since we provide our services worldwide in such cases, personal data may also be provided to recipients in third countries.
Public authorities, courts and other recipients
Your personal data may also be submitted to the public authorities for the purpose of carrying out their official duties, such as the Ministry of Finance, the Ministry of Internal Affairs, the State Attorney's Office, as well as the trade court, the public notary, or in some cases your personal data may also be provided to other recipients, private and legal entities who are in business relation with us more broadly in connection with the conclusion and execution of Contract (e.g. print service providers, providers of postal and courier services, translators, IT service providers, lawyers, notaries, etc.). If we are engaged in processing your personal data by other private and legal entity, who will process your personal data exclusively on our behalf and according to our instructions (processors), we will engage only those processing agents based on a written Contract that will adequately guarantee the implementation of the appropriate technical and organizational measures that meet the requirements of the General Data Protection Regulation and other regulations about data protection that will ensure the protection of your rights.
Where will your personal data be processed?
Your personal data will be processed in Croatia within our company, also in Sweden in our partner company, our promotor: Scandinavian Yacht Travel, Nedre Långvinkelsgatan 43, 252 34 Helsingborg, Sweden, tel: +46 735 26 37 13, e-mail: firstname.lastname@example.org.
Depending on the sailing destination you choose your personal data can be provided to recipients in third countries necessary to meet our Contractual obligations.
How long do we keep your personal data?
We keep your personal data for as long as is necessary to meet the purpose for which they are processed unless we are bound by additional statutory deadlines or accounting regulations. In addition, we keep personal data as long as there is a possibility to set legal requirements based on the Contract concluded, including the statutory period (e.g. for the possibility of foreclosure) after final court, administrative or other appropriate proceeding initiated to exercise rights and obligations related to the sale of goods. If we process certain personal data with a consent, we will delete your personal data in case of withdrawal of the consent, unless there is another legal basis for processing or processing of your personal data is necessary for the establishment, execution or defence of legal requirements.
What are the consequences if you don’t provide us with your personal data?
In certain cases, your personal data is required for us to perform our core business. If you don’t provide us with your personal data or if you don’t provide enough data required, we will not be able to sign a Contract and will not be able to fulfil our obligations under the Contract. Please pay particular attention to the fact that if we fail to fulfil our obligations under the Contract due to the lack of your personal information’s we will not be liable for the non-fulfilment of the Contractual obligation. In cases prescribed by special regulations, refusal of providing certain personal data may result in us being unable to sign Contract with you.
What are your rights in dealing with personal data processing?
Subject to the terms of the General Data Protection Regulation, you have the following rights regarding processing of your personal data:
- Right to access - the right to obtain data on how we process your personal data and, if such personal data are being processed the access to personal data and other information like purpose of processing, storage info; where and how long, submission to third countries etc.
- Right to rectification - the right to correct inaccuracies and the right to supplement incomplete personal data
- Right to erasure – “Right to be forgotten” - the right to delete personal data relating to you if your personal data is no longer necessary for the purposes for which it was collected or otherwise processed, if you have withdrawn your consent for processing and if there is no other legal basis for processing or if your personal data is unlawfully processed etc. This right has limitations and cannot be applied if processing your personal data is necessary for the execution or defence of legal requirements or for fulfilling our legal obligations that require processing according to the regulations that oblige us.
- Right to restriction of processing - the right to request a restriction on the processing of your personal data (e.g. when you dispute the accuracy of the data or when you oppose to deleting the illegally processed data).
- Right to object - the right to object on processing your personal data based on our legitimate interest, including profiling. In this case, we may process personal data that relates to you solely if we prove that our legitimate interest for processing goes beyond your interests, rights and freedoms or to establish, enforce or defend the legal requirements.
- Right to data portability - the right to receive and transfer data to another Data Protection Officer if you have provided us with the personal data in a structured form and in a commonly used and electronically readable format if the processing is carried out by automated means and based on the agreement or Contract.
- Automated decision making - the right that on automated processing, including the creation of a profile, that produces legal effects pertaining to you or in a similar way significantly affects you, unless such a decision is necessary for the conclusion or performance of your Contract, if permitted by EU law or by national law which prescribes the appropriate measures to protect the rights and freedoms of such legitimate interests of the respondent or based on the express consent of the respondent
- Right to withdraw consent - if personal data processing is based on your consent, you have the right, without any consequences, to withdraw your consent at any time by submitting a written notice to our Data Protection Officer in our headquarters. In that case, we will no longer be able to process your personal data unless there is another legal basis for their processing. Withdrawal is valid from the moment it’s submitted to us, meaning that it doesn’t affect the legitimacy of processing your personal data in the period from giving your consent until it is withdrawn. You can contact our Data Protection Officer to exercise all your rights regarding processing of personal data. In order to act in accordance to your claim we have the right to request additional data to confirm your identity. If your identity can not be verified, we have the right to refuse the action on your request. If your requirements for realization of the law are manifestly unfounded or excessive, especially because of their frequent repetition, we have the right to charge you a reasonable fee or refuse to act on your request.
- The right to file a complaint to the supervisory body - if you consider that processing of your personal data is not in accordance with General Data Protection Regulation you have the right to file a complaint with the supervisory body in your resident state, residence of your workplace or in the state where the violation happened. In Republic of Croatia supervisory body is the General Data Protection Agency (www.azop.hr). Without prejudice to your right to file a complaint with the supervisory body, we suggest that you contact our Data Protection Officer before any complaints are made to clarify any disputed issues.
Data processing information are available at all time at:
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