Privacy Policy


Date: 25.05.2018.


users of Dalmatia Luxury Hotels & Villas, owned by Unique Property Group d.d., like everyone else whose data is processed on any basis by the hotel, the General Data Protection Regulation (EU 2016/679, hereinafter: Regulation) has been in force since May 25th 2018, which is binding and directly applicable in all Member States of the European Union, including Republic of Croatia.

According to Regulation, Unique d.o.o. is responsible for the protection of personal data of persons whose information are processed and implements appropriate technical, personnel and organizational measures to enable effective application of data protection principles, in order to ensure a level of safety which is in accordance with the requirements of the regulations on personal data protection, which is commensurate with the risks associated with the processing of personal data, so as to ensure such protection which prevents the accidental or unlawful destruction, lost, alteration, unauthorized disclosure of personal information or unauthorized access to personal data that has been transferred, stored or otherwise processed.

This Policy applies to any processing of information available to Dalmatia Luxury Hotels & Villas.

Dalmatia Luxury Hotels & Villas, as the Controller of your data, respects your privacy and undertakes to protect your personal data.

Dalmatia Luxury Hotels & Villas, within the framework of the implementation of this Policy, pays special attention to respecting the principles of data processing and processes data:

  • Lawfully – data processing is made possible when it is permitted by law and only within the limits permitted by law.
  • Fairly – by taking into account the specifics of each relationship, applying all appropriate measures for the protection of personal data and privacy in general, and allowing clients / guests to exercise their rights.
  • In a transparent manner – by informing clients / guests about the processing of personal data. From the beginning of data until the end of data processing.
  • By ensuring purpose limitation – personal data is processed only for the purposes for which they are collected.
  • By ensuring storage limitation – data must be stored in a form which permits identification of clients / guests no longer than is necessary for the purposes for which the personal data are processed and may be stored longer only when this is allowed by the Regulation.
  • By ensuring data minimisation – data is processed only when they are adequate, relevant and limited to what is necessary. A special attention is given not to collect data for which there is no justified need for processing.
  • By ensuring accountability – data must be accurate and kept up to date, and every reasonable step must be taken to erase inaccurate data.
  • With integrity and confidentiality – processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Transfer of data to third parties

The access to the personal data of clients / guests can be allowed to associates of Dalmatia Luxury Hotels & Villas if there is need for that. For example this associates can be IT providers, transfer and excursion or providers of other services. They store such data in their databases until due processing of such data is completed. These relations are regulated with special contracts regarding their powers and obligations during the processing of personal data.

Under certain circumstances, external parties and  Dalmatia Luxury Hotels & Villas  may jointly determine the purpose and manner of personal data processing. In that event, such external partners and Dalmatia Luxury Hotels & Villas will be considered joint data controllers. Joint data controllers, in their mutual relationship, determine their own responsibilities for acting in compliance with obligations prescribed by the Regulation in a transparent manner, especially with regard to the exercise of rights held by data subjects and their duty to process data in a transparent manner, unless their responsibilities are already established by law.

Should, within the data processing, data be transferred to third countries, Dalmatia Luxury Hotels & Villas will ensure the compliance with high standards of protection to in order to comply with the highest possible standard of personal data protection in accordance with the strict requirements of the Regulation. In this respect, Dalmatia Luxury Hotels & Villas will for all international transfers of personal data inform the data subject of its intent to transfer personal data to a third country or international organisation and the existence or absence of an adequacy decision by the European Commission. At the same time, the data subject will be referred to the to the appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available, as well as whether due transfer is subject to safeguards in accordance with Article 46 of the Regulation, the application of binding corporate rules in accordance with Article 47 of the Regulation or whether the Article 49 paragraph 1 sub-paragraph 2 of the Regulation applies. Any transfer of personal data to third countries will be carried out in accordance with Chapter V of the Regulation.

Purpose of data collection

Dalmatia Luxury Hotels & Villas is required to collect certain personal data in order to execute due accommodation contract and comply with regulations governing hospitality. However, Dalmatia Luxury Hotels & Villas may collect other or the same data for other purposes, primarily maintaining contact. Such purposes include:

  • direct marketing,
  • submission of bids,
  • organisation of prize games,
  • improvement and personalisation of services offered to guests,
  • protection of property and safety of individuals achieved through implementation of video surveillance measures.

Dalmatia Luxury Hotels & Villas  guarantees that collected data will be used only for the stated purposes, only depersonalised data can be used for statistical purposes.

Legal basis for collection

The legal basis for the stated collection purposes may be:

  • legal,
  • contractual,
  • key interests of clienst / guests,
  • legitimate interest overridden by interests of clienst / guests or
  • consent or explicit consent of clienst / guests depending on the purpose of processing and the type of personal data.

Points of data collection

Dalmatia Luxury Hotels & Villas  collects your data at:

  • booking of accommodation (booking through website or booking by phone call or e-mail),
  • conclusion of accommodation contract – registration at the reception desk, filling in the check in form,
  • subscribing to a free Wi-Fi,
  • application for loyalty programme membership (Members club),
  • completion of survey form for participation in prize games,
  • places under video surveillance.

Data storage period

Data that was lawfully collected by Dalmatia Luxury Hotels & Villas  is stored for a period of time prescribed by a particular law or other positive regulation.

Other information collected by Dalmatia Luxury Hotels & Villas  on the basis of client’s /guest’s explicit consent, legitimate interest or consent of the client / guest is stored in its guest database according to a specifically defined storage policy.

Rights of the data subject

Every clients / guest realizes certain rights (Article 12 – regulation 23):

  • the right to access information,
  • the right to rectification,
  • the right to be deleted,
  • the right to limit processing,
  • the right to data portability,
  • the right to object.

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

  • access to data, rectification of data or completion of incomplete data in all databases of personal data, upon which Dalmatia Luxury Hotels & Villas will grant you the access or rectify your data, depending on your request, in all its databases,
  • erasure (“right to be forgotten”) of personal data from all databases of personal data, upon which Dalmatia Luxury Hotels & Villas will erase such data from all its databases except those that Dalmatia Luxury Hotels & Villas  is required to maintain and keep on the basis of positive regulations and when there are no overriding legitimate reasons for processing or when processing is not necessary for the establishment, exercise or defence of legal claims,
  • restriction of processing of your data or lodge a complaint regarding the processing of such data,
  • transfer of data we have collected about you to you yourself or to third parties (“right to data portability”), in accordance with positive legal regulations,
  • withdrawal of consent, when data were given on the basis of consent, without any negative consequences,
  • to lodge a complaint with a supervisory authority – Personal Data Protection Agency (for more information, please visit

Please send your written request to the contact e-mail address of personal data protection officer at or by regular mail addressed to Unique d.o.o.,  114. brigade 10, Split, Republic of Croatia.

Personal data collected from persons who booked accommodation and guests

Dalmatia Luxury Hotels & Villas as the data controller, keeps personal data you are required to submit in order to be provided with accommodation services in its database solely for the purpose of concluding the accommodation contract and complying with legal requirements on provision and collection of personal data governing hospitality, and may use such data for other purposes allowed by positive regulations. In the event that you do not provide Dalmatia Luxury Hotels & Villas with minimum information required for the registration of guests in all relevant registers, Dalmatia Luxury Hotels & Villas will not be able to provide you with accommodation services in accordance with the contract and the law.

Personal data recorded by Dalmatia Luxury Hotels & Villas at the time of booking and filling in the registration card at arrival to the facility are collected on the basis of laws regulating hospitality and for the purpose of providing services to guests. These include the following data:

  • name and surname,
  • address of residence (Croatian citizens),
  • date of birth,
  • number, type and place of issue of identification document,
  • nationality,
  • hotel name and room number,
  • date of arrival and departure of guest,
  • credit card details,
  • gender.

Dalmatia Luxury Hotels & Villas stores such data in its database of guests and shares them with competent authorities of the Republic of Croatia through the E-visitor system (electronic registration system) in which such data is required to be stored for 10 years. In accordance with legal regulations Dalmatia Luxury Hotels & Villas stores all invoices issued to guests for 11 years.

Dalmatia Luxury Hotels & Villas  can at the time of booking or check in at the reception collect some additional information:

  • e-mail,
  • language,
  • credit card details,
  • telephone number.

Other information related to circumstances of your stay, such as the manner of travel, travel companions, marital status, number of children, pets and other interests, will also be collected when they are directly connected to the provision of accommodation services, but will be deleted after your departure from the accommodation facility.

Dalmatia Luxury Hotels & Villas has right to collect your personal dana (name and surname, e-mail adress), on the basis of consent on the check in form, and use for the purpose of direct marketing and of sole purpose of informing about the Dalmatia Luxury Hotels & Villas offers by e-mail. In this case, you have the right at any time and free of charge to require deletion (the right to be deleted).

Additionally, a person who wants to book an additional service (transfer, trip or excursion) gives special permission, consent to Dalmatia Luxury Hotels & Villas to trassfer dana such as:

  • name and surname,
  • mobile phone number,
  • nationality

to the third party, Dalmatia Luxury Hotels & Villas partner with whom has signed a cooperation agreement.

Dalmatia Luxury Hotels & Villas  also collects personal data through video surveillance systems.

Personal information collected by subscribing to a free Wi-Fi

Using the Internet access for guests you accept the logging and recording network activities while connected to the network.

Dalmatia Luxury Hotels & Villas, or the person entrusted  with maintainig job may see such information.

Personal data collected at participation in prize game / completion of survey form

Dalmatia Luxury Hotels & Villas  may periodically organize prize games, in which event it will collect your personal information only should you choose to participate in such prize game. Prize game rules will define which datas are neccesary for participation. These datas will be deleted within 2 years after prize game finishes.

In the event that you complete a survey form for participation in survey prize game by providing information which is not necessary for participation in the prize game  Dalmatia Luxury Hotels & Villas  will, nonetheless, be able to use all such depersonalised data for statistical purposes.

Data subject has the right to rectification of data and the right to be forgotten.

Cookies and online technologies

As with many other sites, our site may use “cookies” (small files that we save to your computer when you access our websites to enable basic or additional functionality of each site) or other technologies to help us deliver content specific to your interests, to process your reservations or requests, and/or to analyse your visiting patterns. Cookies, by themselves, cannot be used to reveal your personal identity. When you access our websites, such data is used by our server to identify features of your browser but cannot identify you personally.

We use several types of cookies:

  • Necessary cookies – they are necessary to enable the basic website functionalities and websites cannot function properly without them. This means that a website cannot be opened or displayed without these cookies. These cookies enable us to conduct a basic website analysis with the aim of improving website functionalities by using completely anonymous data, that is, such cookies are not based on your personal information or data that could be in any way linked with you personally. These cookies do not require consent, so we do not ask for your consent to use them.
  • Functional cookies – we use them to perform a more advanced website analysis. These cookies are used to analyse user behaviours and based on received anonymous data help us to conclude what website visitors prefer to see and browse, thus enabling us to customise the website and make its content and functionalities easier to use. We will ask for your consent to use these cookies.
  • Advertising cookies – we use them to analyse your interests and preferences and they help us to provide you with information you are interested in and create customised offers based on your use of Dalmatia Luxury Hotels & Villas website. We will ask for your consent to use these cookies.

Dalmatia Luxury Hotels & Villas stores cookies in the database and keeps them for up to 2 years for the purpose of providing information about special and personalised offers, news and events through online channels (e-mail, web, internet promotions).

Should you wish to change your cookie settings on the Dalmatia Luxury Hotels & Villas website, you can do so at any time. You can always delete cookies stored on your computer, thereby disabling further processing of your personal data through such technology.

Video surveillance system

Dalmatia Luxury Hotels & Villas, as the data controller, has the legitimate interest to implement video surveillance measures to protect property and persons in relation to certain workplace positions and statutory duty to install surveillance cameras that record employees and anyone moving within the surveillance camera field of view.

Dalmatia Luxury Hotels & Villas indicates all places where video surveillance system is installed in the prescribed manner.

Dalmatia Luxury Hotels & Villas is aware that the video recordings contain personal data of all the persons moving within the surveillance camera field of view, and therefore handles them with special care. Furthermore, we have implemented a security system and introduced availability and erasure policy regulated by internal Dalmatia Luxury Hotels & Villas rules on safety.

In the event of judicial and/or criminal proceedings, Dalmatia Luxury Hotels & Villas may use such video recordings. Access to personal data captured on video recordings may be granted to third parties, data processors and contractual partners of Dalmatia Luxury Hotels & Villas who are registered and qualified to provide services of personal and property protection and who do not use any of these data independently but participate in activities related to the security of central supervisory and alarm systems. All other details regarding video surveillance are subject to special regulations that govern that area.

Protecting the personal information of children

Dalmatia Luxury Hotels & Villas advises parents and guardians to teach their children the importance of being responsible when dealing with personal information on the internet. Dalmatia Luxury Hotels & Villas does not wish to collect and has no intention of collecting personal information of children. Personal information of children will be neither used nor divulged to third parties. A child may give his or her consent solely in relation to the provision of IT company services, whereby such child must be older than 16 years of age. Dalmatia Luxury Hotels & Villas may process all other information of children below the stated age limit and children under 18 years of age, except as expressly stated herein, only with the prior consent of the parent.

Dealing with personal data breaches

If you believe that Dalmatia Luxury Hotels & Villas has violated the provisions of the Data Protection Regulation during the processing of your personal data, you can contact the Personal Data Protection Officer of the Company to determine any disputes.

In case of personal data breach, you have the right to file a complaint to the Data Protection Agency, Martićeva 14, 10000 Zagreb.

If a personal data breach occurs and there is a chance that it poses a risk to the rights and freedoms of clients / guests, Dalmatia Luxury Hotels & Villas will notify the Personal Data Protection Agency, no later than 72 hours after realizing the breach. If there is a probability that the violation will cause a high risk for the rights and freedoms of the respondents, Dalmatia Luxury Hotels & Villas will inform the clients / guests about the violation of personal data in an appropriate and effective way.

Data change

You can contact us at any time to review your personal information, as well as for the purpose of updating, rectification or erasure of your data. Until such time, we will use your previously recorded data for the aforementioned purposes.

Your consent

When you in any way provide Dalmatia Luxury Hotels & Villas your consent, you guarantee that the information you have provided is accurate, that you are legally capable and authorised to dispose of the provided information and that you fully agree that Dalmatia Luxury Hotels & Villas may use and collect your information in accordance with the law and the terms of this privacy policy.

Technical and integrated data protection

Dalmatia Luxury Hotels & Villas, as the data controller, takes utmost care to meet the highest organisational and technical data protection standards.

Furthermore, Dalmatia Luxury Hotels & Villas takes the appropriate technical and organisational measures to ensure that only personal data necessary for each special purpose of processing are processed in an integrated way. Dalmatia Luxury Hotels & Villas imposes this measure to the amount of collected personal data, scope of their processing, storage period and their availability. Specifically, such measures ensure that personal data are not automatically, without personal intervention, made available to an unlimited number of persons.


This Privacy Policy is available at Company website and at reception desks of all our facilities.

Should we decide to make changes to our privacy policy, we will make available and publish such changes on the website and at reception desks of all our facilities.

The company has appointed a personal data protection officer who can be contacted through the address: or by regular mail addressed to Unique Property Group d.d., 114. brigade 10, 21000 Split, Republic of Croatia.

Mr. Tomislav Buljubašić