Privacy policy

Personal data includes any data relating to an identified natural person or other data by which a person can be identified. We collect and process different types of your personal data, depending on our relationship with you and services you use.

When you book accomodation, you enter into an agreement for accommodation service with us. We collect information about you that are necessary to establish a contractual relationship and make the reservation. Prior to your arrival, we will collect and process information necessary to provide you with the best possible service and to prepare ourselves for your arrival.

In any case, we collect and process your personal data for legitimate purposes and based on valid legal grounds, which you can read more about in the Legal Basis for Personal Data Processing section below.

Personal data we collect (including, but not limited to):

• full name, gender, preferred gender pronoun, date of birth, Personal Identification Number (OIB), and similar identifiers, as well as data found on personal identification documents (ID card, passport, or driver’s license);
• address, email address, phone number, language preference;
• payment information and account or credit/debit card details;
• information regarding you stay, including arrival and departure dates, purchased goods and services, specific requests, preferences for certain services (e.g., cleaning), dialled telephone numbers;
• marketing data, including information about your contact preferences;
• technical data such as IP address, login data, location data, time zone, browser type and version, operating system, and other data about the technology you use to access our website and how you interact with it, our products, and services.

Special categories of personal data

As a general rule, we do not collect special categories of personal data, such as data concerning race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, data concerning health, genetic or biometric data, or data concerning criminal offenses. However, we may collect and process your health data when it relates to allergies you have informed us about (e.g., before or during the consumption of food in our restaurant) in order to fulfil our contractual obligation and with your explicit consent. Additionally, as part of providing spa and wellness services, we may collect health-related data, again with your explicit consent. Furthermore, if you have made publicly available any data from special categories of personal data, we may also collect and process such data.

We are a business entity engaged in providing, among other services and activities, hospitality accommodation services. In course of our operations and activities, we collect various types of your personal data, depending on our relationship with you and the reasons for our communication. We collect your personal data directly from you, indirectly, or automatically.

Directly from You

We collect your personal data directly from you (including, in some cases, special categories of personal data):

• when you book an accommodation reservation, submit a request, or otherwise provide us with your personal data;
• in the registration process (check-in and check-out activities);
• when you make a payment;
• when you have any additional requests or complaints;
• when you communicate with us on social media or via email;
• during your stay at our hotel or when using our services (restaurant, spa, wellness);
• when you inform us about your preferences and allergies in relation to our restaurant services;
• when you as u guest attend events organized by us;
• when you leave comments about your stay;
• when you provide us with your contact information;
• when you join our loyalty program;
• when you contact us in relation to the job applications and/or you submit to us an open job application.

Please note that this is a general list of cases and scenarios in which we may collect personal data from you, and the specific data collected may vary depending on the circumstances and the services provided.

Indirectly

We collect your personal data indirectly when it is provided to us by another legal or natural person, for example, if the data about you is provided to us by our business partner, or an agency or intermediary through which you have arranged an accommodation service in our hotels (e.g. accommodation booking platform). We may also obtain data about you from your payment service provider or advertising service provider or if another person makes a booking for you. When reservation is made for you by another person, we consider that the latter person has your consent or is relying on an applicable legal basis to provide us with your personal data.

Where you provide personal data of third parties (for example, names and contact details of your family members in connection with bookings or family memberships), you confirm that you have their consent or rely on applicable legal basis to provide their personal data to us. We recommend referring them to this Privacy Notice.

Automatically

We collect your personal data through automated systems, for the purpose of improving our service or for security, for example, we record certain data about your device when you connect to our network (for security reasons and to enable you to use the free internet), when you use this website we collect certain information about how you use our site, as well as device data (such as IP address, browser type), electronic systems in our rooms record the time of you entering the room, our telephone devices in our hotel rooms automatically record incoming and outgoing calls, etc.

In order to respect the lawfulness of processing personal data, we process personal data only if and to the extent that at least one of the following is met:

1. you gave your consent for processing of your personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which you are a party or in order to take certain actions at your request prior to the conclusion of the contract;
3. processing is necessary to comply with our legal obligations as the controller;
4. processing is necessary to protect the vital interests of you or other natural persons;
5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
6. processing is necessary for the legitimate interests pursued by us or 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, in particular where the data subject is a child.

We usually process your personal data in cases where processing is necessary or on the basis of:

1. for the purpose of performing a contract, for example, when you make a reservation for accommodation at our hotel, you enter into an agreement for accommodation service with us. We collect information and data about you that is necessary for us to establish a contractual relationship, make a reservation, and later fulfil our contractual obligation.
2. for compliance with legal obligations, for example, issuing invoices and other documentation in accordance with accounting regulations, registering guests in the e-Visitor system, which we also do to comply with our legal obligation.
3. with your consent:
   1. when you have shared with us health data, biometric data, data about disabilities, sensitive data from official identification documents if applicable, data about religious or philosophical beliefs, sexual orientation, political views etc.,
   2. when you join our loyalty program,
   3. for any other purposes for which we have obtained your explicit consent, in accordance with applicable laws.
4. based on our legitimate interests, for example, to protect property and for security reasons, we use surveillance cameras to record shared areas in our facilities (e.g., reception), or for guest record keeping, communication and business management when we contact a guest via their email address or by delivering a leaflet to request completion of a guest satisfaction survey or questionnaire, or when we send promotional offers (direct marketing). We rely on legitimate interests as a basis only if our legitimate interests as the data controller are not overridden by the interests or fundamental rights and freedoms of the data subject that require the protection of personal data, especially if the data subject is a child.

However, for certain types of personal data processing, multiple legal bases may be applicable. For example, when booking an accommodation at our hotel, we process your personal data (identification, contact, and financial data) based on three legal bases: the performance of a contract, compliance with a legal obligation and legitimate interests.

Ever once in a while we would like to use your personal data to send you our marketing messages and information that we think may be of interest to you, including, but not limited to information about our hotel, tours, new products and services, news about our membership program, satisfaction surveys, offers and promotions, etc (direct marketing). The latter will be sent to you either by email, SMS/MMS messages, phone calls, push notifications etc., all based on a legitimate interest.

Please be informed that you may choose not to receive any kind of communication from A’mare Hotel (including direct marketing communication) and you can opt-out from receiving such communications at any time, free of charge, by following the unsubscribe instructions contained in such communications or by sending a written request by e-mail to: management@hotelamare.com

Also, for purpose of our strategic planning and improving our service, we use statistical data analysis. This means that, based on a legitimate interest, we will process the data we have collected and processed about you on other legal basis – for another purpose. When we process your data for statistical purposes, we continue to use it exclusively in an aggregated, depersonalised form. This means that this data can no longer be linked to you in any way and no longer represents your personal data.

We and our service providers use various technologies to collect information, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our site and your experience. We do not use this data to identify you, nor do we use third party cookies for this purpose. Some cookies we collect last only during your use of our site, and some last a little longer, so that we can recognise you when you access our site again. For more information about cookies, and how to disable them, please see our Cookies Policy.

We share your personal data with others only when it is permitted by the law, when it is necessary in order for us to fulfil our contractual obligation or in cases where you have agreed to share your personal data with a third party (e.g. in the case of using cookies). Below please find few examples of when we will share your personal data with other recipients:

• with the e-Visitor system, in accordance with the regulations on the provision of hospitality services and the manner of keeping a list and registration of tourists;
• with service providers for the reservation system and the guest database system that we use in our business, with whom we have concluded appropriate data processing agreements;
• with payment service providers with whom we have concluded agreements on the processing of personal data;
• in case of an investment, a merger or acquisition in the future, we may share your personal data with the new owners of the company, and certain personal data may also be transferred during the purchasing process, to potential customers and their advisors, as part of the due diligence process;
• with advisory service providers, consultants, professional advisors such as attorneys at law, auditors, or accountants, marketing and market research agencies, technical support service providers and IT consultants, etc.