INTRODUCTORY PROVISIONS
Two Rivers, Gornje Pokupje 30, 47280, Ozalj, Croatia, respects your privacy and the safety of your personal data. The collection, use, and processing of your personal data is carried out in accordance with these Privacy policies and with the applicable legal provisions, including Regulation (EU) 2016/679 as of 27 April 2016 (hereinafter: General Regulation) and the Croatian Act on the Implementation of the General Data Protection Regulation (Official Gazette NN 42/2018).
In accordance with the principle of transparency, these Policies are intended to provide respondents with accurate, complete information about which of their personal data is collected, used, provided or otherwise processed by Two Rivers, as well as to which extent this data is processed or will be processed. Likewise, the aim of these policies is to introduce individuals who use this internet portal to the risks, rules, protective measures, and rights related to the processing of their personal data and the manner in which to exercise their rights as regards its processing.
These rules are valid and applicable regarding the collection, processing, and protection of your personal data, as well as the use of cookies and other similar analytical tools when visiting, registering, and using internet portals and all of their sub-domains, web pages and mobile phone applications that belong to the aforementioned domain names owned by Two Rivers. Software applications we provide you for use on personal computers or mobile devices when sending e-mails containing a link to these Privacy Rules, during the registration process and when communicating with you while you are a guest at one of our facilities.
The general rules and conditions of the Two Rivers are defined by separate rules and general conditions of use, and these rules and conditions shall be applied in everything not covered by the current Rules, under the condition that they are not in opposition to the provisions of these Privacy policies.
PERSONAL DATA
Personal data is any data that can be used to confirm your identity. Through its online services, Two Rivers can collect some of the following personal data:
– First name, last name, home address, date of birth, personal identification number, personal ID number or number of other identification documents, citizenship;
– Data on your stay, including data on the facility in which you are staying, date of arrival, date of departure, products or services purchased, information on your preferences for services (room type, etc.);
– Data on ordered services
– Data on the loyalty program;
– Additional information about you that we might receive from third parties with whom we do business (e.g. travel agencies, tour operators).
LEGAL BASIS FOR THE COLLECTION OF PERSONAL DATA
Two Rivers collects and processes your personal data only if one of the assumptions listed below is fulfilled:
We have your consent
Example: receiving our newsletter
If you wish to receive our newsletter, you will click the check box on the Two Rivers Internet Portal indicating that you wish to receive the newsletter, and you will enter the e-mail address to which you wish to receive the newsletter.
Processing is necessary to execute an agreement to which the respondent is a party or to take measures at the request of the respondent prior to concluding an agreement
Example: online booking
When booking accommodation at one of Two River’s facilities via the Two Rivers Internet Portal in order for us to offer the services required.
Processing is required in order to fulfill the legal obligations of the data processor
Example: forwarding data to the eVisitor system
Two Rivers is required to register every guest with the eVisitor system in order to pay sojourn tax and register their stay in Croatia.
Processing is required for the legitimate interests of the data processor or a third party
Example: in order to personalize your experience
Two Rivers may use your personal data to improve its understanding of your interests in order to offer you other services or products that might interest you. This allows us to adjust our communication to make it relevant and more interesting to you.
Two Rivers may collect personal data for other legally expected reasons, such as e.g. when processing is required in order to protect the key interests of the respondent or other physical persons.
PERSONAL DATA THAT IS COLLECTED
Two Rivers collects data during the use of its services or during access to the Two Rivers Internet Portals:
(I) When booking accommodation and purchasing other products or services, the following are collected:
First name, last name, home address, e-mail address, telephone number, and personal identification number. Information about services (or products) purchased
(II) When accessing the Two Rivers Internet Portals, the following are collected:
Data on your accommodation interests;
Information on the use of the web page;
Information on clicks on our advertisements, including those published on other websites;
Information on how you access digital services, e.g. operating system, web browser, IP address;
(III) When sending inquiries and offering support, consultations, or answers to complaints, surveys, and research, the following are collected:
The data you provide us when booking or purchasing services, including your first name, last name, and e-mail address, or if you are logged in via a social network, then your name, user name, and contact data. The content of digital communications, as well as which links you clicked on during communication
The content of your complaints
(IV) When registering for our newsletter, the following is collected:
Name, surname, home address (country), e-mail address, date of birth, special interests of the guest, family status, gender, language of communication, and hobbies
(V) When registering for our newsletter, the following is collected:
First name, last name, home address, e-mail address, telephone number, personal identification number, data on a personal identification document
Information on services (or products) purchased
Guest complaints and comments
(VI) When joining the loyalty program, the following is collected:
Name, surname, home address (country, city, postal code, street, and house number), mobile phone number, e-mail address, date of birth, special interests of the guest, family status, gender, password, the language of communication and hobbies
In addition to directly from respondents, Two Rivers can collect personal data from other sources under the following circumstances:
– From specialized firms that offer information (e.g. credit rating agencies), business partners (e.g. tour operators), and public registers (trade register);
– If booking is carried out via a social network e.g. Facebook, Google+, you accept that we may use your user data, e.g. first name, last name, e-mail address, or other information you have chosen to share;
– Via video surveillance at Two Rivers facilities.
In situations in which you give Two Rivers the personal data of other persons, the following must be taken into account:
– Two Rivers uses the data of other persons you provide to us, such as e.g. persons included in your booking;
– When you provide data on other persons, you must be sure that they have consented to this and that you have the authority to do so in their name. Whenever possible, you must make sure that they are familiar with the processing of personal data from these Privacy rules.
HOW YOUR PERSONAL DATA IS USED
Two Rivers processes the data collected to fulfill the purpose for which the data was provided, and/or to fulfill relevant regulations or legitimate interests arising from or tied to the use of the Two Rivers Internet Portal and the offering of desired services.
In accordance with this, Two Rivers may use your personal data:
– To offer services you have required, e.g. booking accommodation;
– To offer information you seek related to the services we offer;
– To simplify the use of the Two Rivers Internet Portal by eliminating the need to frequently enter the same data;
– To aid in making content as relevant as possible to your interests, or to adjust the internet portal to your personal tendencies and interests – if you do not wish to receive personalized content, you are always able to complain by changing your online settings, or by contacting us via telephone or e-mail to update our data;
– To send notifications about important news concerning the internet portal;
– To prevent fraud or other forbidden or illegal activities;
– To protect the safety and integrity of the Two Rivers Internet Portal or those of other Two Rivers companies;
– For marketing and promotional purposes:
- In order to understand you as a client as best as possible and to adjust our services and marketing communication, Two Rivers may combine personal data collected during the sales of services with data collected via our websites, applications, or other sources,
- To send you notifications about new services, updates to services, events, and special offers we believe you may be interested in;
- To send you notifications about other companies and products we believe you may be interested in, but only if you have agreed to this type of communication beforehand,
- Marketing research to improve our services, in which case you are always free to refuse to cooperate.
WHO CAN SEE YOUR DATA
Two Rivers does not sell, rent or lend your data to third parties.
Two Rivers may share your data with trusted partners who perform particular functions for us, such as e.g. IT systems maintenance and applications, marketing campaigns, and payment processing.
Particular personal data is provided to government bodies on the basis of legal requirements such as e.g. registering guests with the eVisitor system to pay sojourn tax, create guest lists and register foreign visitors.
In any case, when Two Rivers must share collected personal data, we demand that it is protected and not used for marketing purposes.
HOW TO PROTECT YOUR RIGHTS
You have the right to ask for a copy of all the personal data of yours we have collected, while the data we have collected during your booking is visible in the booking itself. You may write to us if you wish for a copy of the other data we have collected from you, in which case you should list all details in order to help us identify and locate your personal data. Delivery of this data is free, but Two Rivers retains the right to charge a reasonable fee for special requests, such as extra copies, special formatting, etc.
We want all your data to be correct and updated. If you notice that some of your data is inaccurate, please inform us.
Also, we would like to remind you of your right to ask for your personal data to be corrected or deleted, as well as your right to oppose the processing of your personal data. Two Rivers will correct or erase your personal data unless we are required to retain it out of legitimate legal or business interests.
If you have a complaint about the processing, using, or storing of your personal data, feel free to contact us. If you are not satisfied with our response, you may contact the Croatian Personal Data Protection Agency.
All requests or complaints related to personal data collected by Two Rivers are to be submitted in writing to the personal data protection agent. The request must contain the e-mail address you provided during check-in, as well as the e-mail address to which you wish to receive a response (if it is different from the e-mail address from which you sent the request). Two Rivers will e-mail your data within a reasonable time frame to the e-mail address provided in the request.
We must point out that, prior to responding to your request, we may ask you for more information to confirm your identity. Also, we may ask you for more information to confirm whether you have the approval to file a request if you are doing so in someone else’s name.
SAFETY OF YOUR PERSONAL INFORMATION
We are completely dedicated to protecting data from unauthorized access, distribution, or erasure, regardless of where it is stored or processed or of the format in which it is stored. Two Rivers uses the services of trusted IT partners, who are required to apply high IT protection standards.
Two Rivers applies recognised data security standards:
– We carry out technical and organizational protection measures based on risk,
– We minimize data exposure,
– We check collected information, storage, and processing methods,
– Whenever possible, we pseudonymize and anonymize data,
– We test organizational and technical protection measures,
– We limit access to personal data to our employees, contract workers, and representatives, for whom the use of personal data is limited and controlled on the basis of user tasks, and who are required to respect strict contractual confidentiality obligations.
Two Rivers takes all measures to identify problems, as well as measures to minimize potential damages.
Please do not forget that you are also our partner in data security. We invite you to take steps to make your personal data safe (including your password) and to always log out of our internet portal after use.
If the personal data we process is transferred outside the European Union and the European Economic Community as a necessity for the technical completion of services sought by users, then Two Rivers will take reasonable measures to ensure that the persons outside the EU with whom the data is shared take appropriate measures to protect this data and to offer protection in accordance with these Privacy Rules.
PERIOD FOR WHICH PERSONAL DATA IS STORED
The period for which Two Rivers stores your personal data is limited to a strict minimum, and in accordance with this, Two Rivers defines the periods for which it stores or periodically checks particular personal data in order for it not to be kept longer than is necessary to fulfill the purposes for which it was collected.
After this period is over, Two Rivers will erase the personal data. However, if this data is necessary to create statistical indicators, analyses, archiving or some other legitimate interest of Two Rivers, all measures will be taken to ensure that this personal data is anonymized.
USE OF COOKIES
Two Rivers uses tools to analyze the use of the Two Rivers Internet Portal, through which we may collect particular data about you, thus gaining insight into the needs of our visitors and/or users, the goal of which is to improve the quality of our services.
Cookies are used for this purpose, as are some other tools.
The user and/or visitor may refuse or erase cookies through the relevant settings on their computer and the web browser they are using. However, this may prevent some functions of the Two Rivers Internet Portal from being fully usable.
The aforementioned tools collect and store some technical data, including user and/or visitor IP addresses.
LINKS TO OTHER WEBSITES
This website may contain links to other websites managed by Two Rivers or other organizations that have their own special privacy rules, so we inform you that you must familiarise yourself with their terms of use and privacy rules prior to providing them with any personal data, as Two Rivers cannot assume any liability for these web sites or the organizations that manage them.
SOCIAL NETWORKS
This website may use particular elements of social networks such as Facebook, Google+, Pinterest, etc, each of which has its own privacy rules, so we inform you that you must familiarise yourself with their terms of use and privacy rules prior to providing them with any personal data, as Two Rivers cannot assume any liability for these web sites or the organizations that manage them.
CHANGES TO THE PRIVACY POLICY
These Privacy Policy replace all prior versions.
The Privacy Policy was last updated in December 2022.
Two Rivers retains the right to change, modify and/or amend these Privacy Rules at any time. All changes to the Rules will be published on the Two Rivers Internet Portal; in the case of significant changes, you will be informed in a clear and understandable manner.