Sail Croatia d.o.o – Privacy Policy

Sail Croatia d.o.o Privacy Notice

  1. Introduction and who we are

 

Sail Croatia d.o.o (“Sail Croatia”, “we“, “our” or “us“) are strongly committed to being responsible custodians of the information you provide us and the information we collect in the course of operating our business.

This Privacy Notice explains how Sail Croatia, as a data controller, may collect,
use, share and protect information that we obtain about you directly or indirectly in accordance with
applicable data privacy laws.

Where you use our services, or your personal data is processed in connection with
such services, and we control the purpose for which such personal data is processed, Sail Croatia will be the
data controller of such information.

From time to time, there may be more than one data controller of your information
within our group where you have engaged different parts of our broader organisation to provide different or
jointly delivered services.

  1. Scope of Privacy Notice

This Privacy Notice explains and describes:

    • When this Privacy Notice applies.
    • How we collect your personal data.
    • How we use the personal data we collect.
    • How and when we may disclose personal
      data that we collect.
    • How long we hold your personal data.
    • How we protect your personal data and
      keep it secure.
    • What cookies are and how we use them.
    • Sensitive personal data.
    • Your legal choices and rights.
    • The status of this Privacy Notice and any
      changes that are made to it.
    • How to request further information.
    • Our contact details.
  1. When this Privacy Notice applies

This Privacy Notice applies:

    • to your use of any of our services where
      we are performing a data controller function;
    • where you apply to us for a job or work
      placement;
    • your supply of services to us where this
      involves any personal data; and/or
    • to any personal information collected
      from third parties where we are the controller of such information.
  1. How we collect your personal data

“Personal data” is any information
that can be used to identify you or that we can link to you.

Where you use our services, we will
collect personal data directly from you.

We may also collect personal data from third parties such as, information or
service providers, publicly available records, and the third parties described in section 6 (Disclosure of your
information) below.

To ensure that we carry out your instructions accurately, to help improve our
service and in the interest of security, we may monitor and/or record: (1) your telephone calls; (2) customer
activities using CCTV recording equipment in and around our premises; and (3) customer transactions and
activities on our website. All recordings are and shall remain our sole property.

We collect information that you voluntarily provide to us, including when you
communicate with us via email or other channels; when you make a booking with us, when you sign up for or
request that we send you newsletters, and when you respond to our communications or requests for information.
You are responsible for ensuring that other members of your party are aware of the content of our Privacy
Notice, and consent to your acting on their behalf in all your dealings with us.

The information you provide may include current and historical personal data
including your name, contact details, title, identification, details of any other persons travelling with you,
travel references, special needs, disabilities, dietary requirements, and enquiry/complaint details. We may
also collect personal data about your other dealings with us and our clients, including any contact we have
with you in person, by telephone, email or online.

We may collect information from other sources, such as social media platforms that
share information about how you interact with our social media content, and any information gathered through
these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social
media platform, which we strongly encourage you to review.

We will handle any unsolicited information in accordance with law, including
destroying or de-identifying such information where we are required to do so.

When you use our online services, we
may collect the following:

    • Information you provide by completing
      forms (this includes information you give us, submitting material, requesting services,
      entering competitions, registering for any of our online offerings or subscribing to our
      newsletters or other services).
    • Information you provide by your
      participation in competitions, live chats, message boards.
    • Information you provide to us if you
      contact us, for example to report a problem with our online services or raise a query or
      comment.
    • Details of visits made to our online
      services including, but not limited to, the volume of traffic received, logs (including, where
      available, the IP address and location of the device connecting to the online services and
      other technical information and identifiers about the device and the nature of the visit) and
      the resources accessed.
    • Where our online services require that
      you enter a password or other information in order to access certain features, we will collect
      such credentials when you enter them.

 

If you apply for a job or work placement with Sail Croatia then you may need
to provide information about your education, employment, racial background and state of health. As part of your
application you will be asked to provide your express consent to our use of this information to assess your
application and to allow us to carry out both recruitment analytics and any monitoring activities which may be
required of us under applicable law as an employer. We may also carry out screening checks (including
reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability
and criminal record checks) and consider you for other positions

  1. How we use your personal data

Depending upon the circumstances in which we gather your personal data, we may use
your information to provide you with services and information, or for any of the following purposes:

    • To provide you with Sail Croatia’s
      services (as noted above) that you request.
    • To respond to your enquiries.
    • To carry out our obligations arising from
      any contracts entered into between you and us.
    • To facilitate our internal business
      operations, including to fulfil our legal or regulatory requirements.
    • To maintain and develop our relationship
      with you.
    • For our business purposes, including data
      analysis, submitting invoices, detecting, preventing, and responding to actual or potential
      fraud, illegal activities, or intellectual property infringement.
    • To maintain and update our records
      including our database of contacts.
    • To provide you on an ongoing basis with
      information and services, including relevant marketing communications related to Sail Croatia,
      and other information or materials, that you request from us or which we feel may interest you
      where you have indicated that you would like to receive these from us.
    • To evaluate, recruit, and hire personnel.
    • To help us to improve our services,
      products or online services
    • To measure the popularity and
      effectiveness of services such as newsletters, in order to improve what we offer to you and
      other recipients.
    • To ensure that content from our online
      services is presented in the most effective and secure manner for you and the device on which
      you are accessing our services, and to troubleshoot, and improve such online services.
    • To allow you to use or access interactive
      features or secure areas of our online services, when you choose to do so.
    • For research, planning, service
      development, security or risk management.
    • As we believe reasonably necessary or
      appropriate to: comply with our legal obligations; respond to legal process or requests for
      information issued by government authorities or other third parties; or protector your, our, or
      others’ rights.

We may not be able to do some or all of these things without your personal data.

If at any time we intend to change the purpose for which we hold your personal
data, for example to offer you with a complimentary service that we may provide in the future, we will give you
prior information of that new purpose so you are aware of this.

  1. Disclosure of your information

We may, in providing our services and operating our business, allow access to your
personal data to the different entities within Sail Croatia’s group for our internal administrative purposes
such as billing, promoting our events and services, and providing you with services.

We may exchange your personal data with third-party service providers contracted to
Sail Croatia where any of the following apply:

    • You have consented to us sharing your
      personal data in this way.
    • We deem reasonably necessary to provide
      you with the services that you have required at any particular time.
    • Such sharing is provided for under
      contract, including our terms and conditions for any particular service that we may provide to
      you.
    • Such sharing is to law enforcement bodies
      or other government authority.
    • We need to enforce or apply our terms and
      conditions to which you have agreed (or other terms that have been agreed to apply to our
      relationship with you).
    • It is necessary to protect the rights and
      interests, property, or safety of Sail Croatia, our clients or others.
    • It is relevant in the circumstances to
      disclose the information to parties with whom we have co-promotional arrangements (such as
      jointly sponsored events, external venues, or caterers).
    • Our agents or contractors who assist us
      in providing our services require such information, for example in fulfilling requests for
      information, receiving and sending communications, updating marketing lists, analysing data,
      providing support services or in other tasks from time to time. Our agents and contractors will
      only use your information to the extent necessary to perform their functions.
    • We use third party service providers to
      provide services that involve data processing, for example archival, web-hosting, analytics
      providers in connection with the operation of our online services, event hosting, information
      technology providers, auditing, reference checking, professional advisory (including legal,
      accounting, financial and business consulting), mailing vendor, delivery, technology, website,
      research, banking, payment, client contact, data processing, insurance, forensic, litigation
      support, dispute resolution, crime prevention, customer care, credit checking, debt collection,
      marketing and security services.
    • All, or most, of the assets of Sail
      Croatia or any single business unit within Sail Croatia are merged with or acquired by a third
      party, or we expand or re-organise our business, in which case your personal data may form part
      of the transferred or merged assets.
    • We are under a legal, regulatory or
      professional obligation to do so (for example, in order to comply with a Court Order).

By booking your holiday with us you agree for insures, their agents and medical
staff to disclose relevant information (which may contain sensitive personal data as referenced in section 9)
to us in circumstances where we need to act in the interest of everyone in the group you are travelling with.
For example, if your illness is infectious we may need to make special arrangements for you and also ensure
that you do not return with the group immediately.

Any third parties that we may share your data with are obliged to keep your details
securely, and to use them only to fulfil the service they provide you on Sail Croatia’s behalf. When such third
parties no longer need your personal data to fulfil this service, they will dispose of such details in line
with Sail Croatia’s procedures unless they are themselves under a legal obligation to retain information
(provided that this will be in accordance with applicable data privacy laws). If we wish to pass your sensitive
personal data onto a third party we will only do so once we have obtained your consent, unless we are legally
required to do otherwise.

We also provide anonymous statistical information about users of our websites and
related usage information to reputable third parties, including analytics and search engine providers.

We own the database rights in the information collected via our online services. We
do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with
unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with
your express prior permission.

We may share information that does not reasonably identify you or your organisation
as permitted by applicable law.

  1. Retention of your data

We retain the information we collect no longer than is reasonably necessary to
fulfil the purposes that such data was originally collected in accordance with our internal data retention
polices or to comply with our legal and regulatory obligations.

A maintained copy of our retention policy is available upon request. Should you
wish to review our retention policy then please contact us in accordance with section 14 (Further information)
below

  1. Security

We take steps to hold information securely in electronic or physical form.

Our information security policy is supported by a variety of processes and
procedures, and we store information in access controlled premises or electronic databases requiring logins and
passwords. All employees, officers or contractors of Sail Croatia and third party providers with access to
confidential information are subject to access controls and confidentiality obligations, and we require our
third-party data storage providers to comply with appropriate information security industry standards.

Whilst we continually strive to ensure that our systems and controls are updated to
reflect technological changes, the transmission of information via the internet is not completely secure, and
as such we cannot guarantee the security of your data transmitted to our online services which is at your own
risk.

If you communicate with us using a non-secure web platforms, you assume the risks
that such communications between us are intercepted, not received, delayed, corrupted or are received by
persons other than the intended recipient.

Once we have received your information, we will take reasonable steps to use
procedures and security features to try to prevent unauthorised access, modification or disclosure.

You can help us to keep your information secure by ensuring that any user name or
password in relation to our online services is kept strictly personal to you and not be made available to any
other person.  You should stop using your username and password and notify us immediately if you suspect that
someone else may be using your user details or password

  1. Cookies Policy
    Our website and services delivered online use cookies and other similar
    technologies, for example, to distinguish you from other users when you browse our websites or use our
    online services and to allow us to improve our online services.

Cookies are small text files that are placed on your computer by websites that you
visit. They are widely used in order to make websites work, or work more efficiently to improve the user
experience, as well as to provide certain information to the owners of the site.

We may, for example, collect information about the type of device you use to access
our online services, the operating system and version, your IP address, your general geographic location as
indicated by your IP address, your browser type, the content you view and features you access on our online
services, the web pages you view immediately before and after you access our online services, whether and how
you interact with content available on our online services, and the search terms you enter on our online
services.

Sail Croatia’s website sets cookies which remain on your computer for differing
times. Some expire at the end of each session and some remain for longer so that when you return to our
website, you will have a better user experience.

Which cookies we use:

Detailed below are the cookies we use and why and how long they last.

Google Analytics

__utma: expires after 2 years

__utmb: expires after 30 minutes

__utmc: expires at end of the session

__utmz: expires after 2 years

__utmt: expires after 10 minutes

_ga: expires after 2 years

_gid: expires after 24 hours

_gat: expires after 1 minute

We collect standard internet log information and details of visitor behaviour
patterns by using Google Analytics cookies. We do this to compile reports and to help us find out things such
as the number of visitors to the various parts of our website, so that this can be improved. This information
does not identify visitors or collect any personal details. We do not make any attempt to find out the
identities of those visiting our websites. We will not associate any data gathered in this way with any
personal data from any source. For more information about Google Analytics cookies please see the link here.

We collect information relating to customer trends and patterns. This information
is often used in its aggregate form. We, including our group companies, may disclose aggregate statistics about
enquiries made, visitors, customers and sales in order to describe our services to prospective partners,
purchasers, advertisers and other reputable third parties and for other lawful purposes. No personally
identifying information is disclosed.

To provide website visitors with more choice on how their data is collected by
Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates
with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be
sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being
sent to the website itself or to other web analytics services. For more information about Google Analytics
Opt-out Brower Add-on please see the link here.

Google Tag Manager

_dc_gtm_xxx: expires at end of the session

This cookie is associated with using Google Tag Manager to load other scripts and
code into a page. Where it is used it may be regarded as Strictly Necessary as without it, other scripts may
not function correctly.

Google Optimize

_gaexp: expires after 90 days

Used to determine a user’s inclusion in an experiment and the expiry of experiments
a user has been included in.

Google Adwords

_gac: expires after 90 days

This advertising/targeting cookie collects information about your website activity,
such as the pages you have visited and the locations you have viewed, which may be used to improve the
performance of marketing content and campaigns and provide you with personalised adverts on Google platforms.

Cloudflare

__cfduid: expires after 5 years

“The “__cfduid cookie is set by the CloudFlare service to identify trusted web
traffic. It does not correspond to any user id in the web application, nor does the cookie store any personally
identifiable information.
https://support.cloudflare.com/hc/en-us/articles/200170156-What-does-the-CloudFlare-cfduid-cookie-do-“

Bing

_uetsid: expires after 30 minutes

_uetmsclkid: expires after 90 days

These first and third party advertising/targeting cookies collect information about
your website activity, such as the pages you have visited and the locations you have viewed, which may be used
to improve the performance of marketing content and campaigns and provide you with personalised adverts on Bing
platforms.

Facebook

fr: expires after 90 days

This advertising/targeting cookie collects information about your website activity,
such as the pages you have visited and the locations you have viewed, which may be used to improve the
performance of marketing content and campaigns and provide you with personalised adverts on Facebooks
platforms.

Zopim

__zlcmid: expires after 20 years

__zlcprivacy: expires after 1 year

These cookies are managed by Zopim, a tool which enables us to provide our live
chat service. It allows us to continue chatting with users across multiple pages.

Hotjar

_hjIncludedInSample: expires after 365 days

Hotjar is an analytics and feedback tool that we use to understand how our website
is used and improve usability. Hotjar sets cookies to help us track behaviour across pages and to control
visitor polls. The cookies carry no personally identifiable information.

Cookie Notification

cookiesDirective: expires after 2 years

Our Cookie Notification funtionality uses this cookie to record and hide the
acceptance of the cookie notification terms.

Control of cookies

Web browsers allow you to exercise some control of cookies through the browser
settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can
also help you to delete cookies when you close your browser. You should note however, that this may mean that
any opt-outs or preferences you set on our website will be lost. To find out more about cookies, including how
to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which includes
information on how to manage your settings for the major browser providers.

 

  1. Your Rights

Under applicable data protection legislation, we have a duty of care to ensure that
your personal data is accurate and up to date. Therefore, please contact us to update or correct your
information if this changes or if you believe that any information that we have collected about you is
inaccurate at customer-support@sail-croatia.com.

Where you have consented to our processing of certain personal data, you can at any
time withdraw such consent and/or tell us not to contact you with updates and information regarding our
products and services (or part of them) either at the point such information is collected, (by leaving the
relevant box unticked) or, where you do not wish us to continue to use your information in this way, by
following the unsubscribe instructions on any communications sent to you. Please note that where you withdraw
your consent we will no longer be able to provide you with the products or services that rely on having your
consent. You can also exercise this right at any time by contacting us using the contact details at the end of
this Privacy Notice.

You can request:

    • access to the personal data we hold about
      you
    • corrections or updates to your details;
    • the erasure of your personal data;
    • the portability of personal data that you
      have provided to us in a structured, commonly used and machine-readable format.

You also have the right to object to, or request the restriction of, our use of
your personal data.

If you would like to exercise any of the rights set out in this section, please
contact us using the details set out in section 14 (Further information) below.  We may refuse to provide
access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional
circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will
provide reasons for our decision.

If you make a privacy complaint, we will respond to let you know how your complaint
will be handled. We may ask you for further details, consult with other parties and keep records regarding your
complaint.

  1. Sensitive personal data

Certain information is defined as ‘sensitive’ (racial or ethnical origin, political
opinions, religious believes, trade union membership, physical or mental health, sexual life, biometric
information and criminal proceedings and offences). If we ever deal with sensitive personal information to
cater your needs or act in your interest, we will only use this information to provide the service you require
and we will ask for your explicit consent.

  1. Marketing

We will provide you with an “opt in” mechanism which will give you the opportunity
to positively indicate that you would like for us to send you further communications. At any time you can
“opt-out” through the link mechanism on any correspondence that we have with you so that you can opportunity
indicate that you do not want us to send you such further communications, or by emailing us at customer-support@sail-croatia.com. Once you have “opted-out” we will not send you any marketing material.

Opting-in will be up to you and, in addition, if you do not want us to use your
personal information for a particular purpose or disclose it to a third party, you may “opt out” at any time by
contacting us as provided below. Please note though, by opting-out, you may not be able to participate in
certain activities on our online services.

If you voluntarily decide to opt-in, we may from time to time contact you via post,
email, or text message with information on offers of goods and services, brochures, new products, forthcoming
events or competitions from our holiday divisions and our holiday group companies. Please note that some of our
websites will require you to agree to e-communications as a condition of booking. You will be given the
opportunity on every e-communication we send you to indicate that you no longer wish to receive our direct
marketing material.

  1. Status of this statement

Your provision of personal data to us or use of our online services constitutes
your acceptance of the terms of this Privacy Notice.

As technologies and information governance practices develop, and data privacy laws
(and surrounding guidance) evolve, we may need to revise this Privacy Notice. You should therefore review this
page regularly to ensure that you are aware of any changes to its terms.

We will post any Privacy Notice changes on this page and, if the changes are
significant or may materially impact upon your rights, we will provide a more prominent notice or contact you
by other means (including, for certain services, email notification of Privacy Notice changes).

  1. Further information

To find out more about Sail Croatia please visit https://www.sail-croatia.hr/.

Sail Croatia at your request, can confirm what information we hold about you and
how it is processed. If Sail Croatia does hold personal data about you, you can request the following
information by contacting us using the details below:

    • Identity and the contact details of the
      person or organisation that has determined how and why to process your data.
    • The purpose of the processing as well as
      the legal basis for processing.
    • If the processing is based on the
      legitimate interests of Sail Croatia or a third party, information about those interests.
    • The categories of personal data
      collected, stored and processed.
    • Recipient(s) or categories of recipients
      that the data is/will be disclosed to.
    • How long the data will be stored.
    • The source of personal data if it wasn’t
      collected directly from you.
    • Any details and information of automated
      decision making, such as profiling, and any meaningful information about the logic involved, as
      well as the significance and expected consequences of such processing.

In order to verify the identity of those who make a request to us, we will accept
the following forms of ID when information on your personal data is requested:

    • Passport,
    • Driving licence, Birth certificate,
    • Utility bill dated within the last 3
      months.
  1.   Contact

If you have any questions, concerns or comments about this Privacy Notice, or want
to submit a written complaint about how we handle your personal data, please contact us via any of the
following means:

Our contact details are as follows:

Contact address: Hrvojeva 6, 21000 Split, Hrvatska

Email: customer-support@sail-croatia.com

Tel: +385 (0)21 610 953

The Managing Director for Sail Croatia d.o.o is Grant Ro Seuren.