PRIVACY POLICY

Hotel Boutique Le Premier d.o.o., based in Zagreb, Ulica kralja Držislava 5, OIB: 56624772586 (hereinafter: Hotel Boutique Le Premier), respects the privacy of each person whose personal information is collected. We would like to inform you which personal information Hotel Boutique Le Premier collects, how we protect this information and what are your rights.

Hotel Boutique Le Premier holds all copyrights on the use of photographs, texts and other published materials in the sense of positive legal regulations of the Republic of Croatia. Photographs, texts and other materials may not be published, sold, publicly or privately advertised or used in any other way without the consent of Hotel Boutique Le Premier.

Basic information

Scope of application

This Policy applies to any processing of personal data by Hotel Boutique Le Premier, unless other Hotel Boutique Le Premier policy prescribes otherwise. Exceptionally, with regards to the processing of data of guests and users of Hotel Boutique Le Premier services, this Policy prevails over all other policies when such other policies prescribe rights and obligations regarding the processing of data in a different manner.

Data controller and legal framework

Hotel Boutique Le Premier, as the Controller of your data, respects your privacy and undertakes to protect your personal data. The collection and storage of data is carried out in accordance with the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Act on Implementation of the General Data Protection Regulation (Official Gazette, No. 42/2018) and other regulations governing this area that are applicable in Republic of Croatia.

Data protection officer

Hotel Boutique Le Premier has appointed a personal data protection coordinator, who can be contacted, at any time, at the e-mail address: zastita.podataka@lepremier.hr or by regular mail addressed to Hotel Boutique Le Premier d.o.o., Ulica kralja Držislava 5, 10000 Zagreb.

Implementation of data-protection principles

Hotel Boutique Le Premier, 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 data subjects to exercise their rights.
• In a transparent manner – by informing data subjects about the processing of personal data. From the beginning of data collection itself, when data subjects are informed about all aspects of data processing, until the end of data processing, data subjects are in accordance with the provisions of the Regulation granted a simple and quick access to their own data, including the ability to inspect and obtain a copy thereof. The access to certain information may be restricted only when this is required by law or necessary for the protection of third parties.
• By ensuring purpose limitation – personal data is processed for the purposes for which they are collected and may be processed for other purposes only when the requirements laid down in the Regulation are fulfilled. Data may be processed for duplicate purposes only by taking into account (a) any link between the purposes for which the personal data have been collected and the purposes of the intended further processing; (b) the context in which the personal data have been collected, in particular regarding the relationship between data subjects and Hotel Boutique Le Premier;
• (c) the nature of the personal data, in particular whether special categories of personal data are processed, pursuant to Article 9 of the Regulation, or whether personal data related to criminal convictions and offences are processed, pursuant to Article 10 of the Regulation; (d) the possible consequences of the intended further processing for data subjects; and (e) the existence of appropriate safeguards.
• By ensuring storage limitation – data must be stored in a form which permits identification of data subjects for 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. Relevant measures are applied taking into account the risk related to each type of data processing.

Transfer of data to third parties

The access to the personal data of guests, where necessary and to a limited extent, may also be granted to third party processors, who store such data in their databases until due processing of such data is completed. We will conclude a detailed contract with such parties regarding their powers and obligations during the processing of personal data, in accordance with the requirements of the Regulation.

Should, within the data processing, data be transferred to third countries, Hotel Boutique Le Premier 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, Hotel Boutique Le Premier 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

Hotel Boutique Le Premier is required to collect certain personal data in order to execute due accommodation contract and comply with regulations governing hospitality. However, Hotel Boutique Le Premier may collect other or the same data for other purposes, primarily maintaining contact. Such purposes include:

• Execution of accommodation contracts;
• Compliance with legal requirements and other applicable positive regulations governing hospitality;
• Direct marketing;
• Submission of bids;
• Organisation of promotional prize draws;
• Improvement and personalisation of services offered to guests;
• Protection of property and safety of individuals achieved through implementation of video surveillance measures.

Hotel Boutique Le Premier guarantees that collected data will be used only for the stated purposes.

Hotel Boutique Le Premier may use depersonalised data for statistical purposes.

 

Legal basis for collection

The legal basis for the stated collection purposes may be:

• Legal;
• Contractual;
• Key interests of data subjects
• Legitimate interest overridden by interests of data subjects; or
• Consent or explicit consent of data subject, depending on the purpose of processing and the type of personal data.

 

Points of data collection

Hotel Boutique Le Premier collects your data at:

• Booking of accommodation (booking through website or booking by phone call to our call centre);
• Conclusion of accommodation contract – registration at the reception desk, filling in the registration card;
• Subscription to our newsletter on the Hotel Boutique Le Premier website, including a free Wi-Fi login on the Hotel Boutique Le Premier;
• Places under video surveillance.

Data storage period

Data that was lawfully collected by Hotel Boutique Le Premier is stored for a period of time prescribed by a particular law or other positive regulation.

Data that was contractually collected by Hotel Boutique Le Premier is stored only for a period of time necessary to fulfil the contract or provide a service.

Information about the name, surname and e-mail address collected by Hotel Boutique Le Premier on the basis of your consent for direct marketing purposes is stored in its guest database for a period of 10 years.

Other information collected by Hotel Boutique Le Premier on the basis of guest’s explicit consent (mobile phone number, number of children, marital status, pets, interests, manner of travel, accommodation and destination preferences) is stored in its guest database for a period of 5 years.

Hotel Boutique Le Premier may, based on your explicit consent, also collect your web browsing data (so-called cookies) and store them in its database for a period of 2 years. Hotel Boutique Le Premier uses such data to inform you about special and personalised offers, news and events organised through online channels (e-mail, web, internet promotions).

Rights of the data subject

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 Hotel Boutique Le Premier 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 Hotel Boutique Le Premier will erase such data from all its databases except those that Hotel Boutique Le Premier 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 www.azop.hr).

Please send your written request to the contact e-mail address of personal data protection officer at zastita.podataka@lepremier.hr or by regular mail addressed to Hotel Boutique Le Premier d.o.o., Ulica kralja Držislava 5, 10000 Zagreb.

 

Personal data collected from persons who booked accommodation and guests

Hotel Boutique Le Premier, 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 Hotel Boutique Le Premier with minimum information required for the registration of guests in all relevant registers, Hotel Boutique Le Premier will not be able to provide you with accommodation services in accordance with the contract and the law.

Personal data recorded by Hotel Boutique Le Premier 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 (subject to change with regard to positive regulations):

• Name and surname;
• Address of residence (Croatian citizens);
• Date of birth;
• Number, type and place of issue of identification document;
• Nationality;
• Name of facility;
• Number of accommodation unit;
• Date of arrival and departure of guest;

Hotel Boutique Le Premier 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) through the E-visitor system (electronic registration system) in which such data is required to be stored for 10 years. Hotel Boutique Le Premier is also required to store all invoices issued to guests, including their personal information, for 11 years, in accordance with legal regulations.

Furthermore, in order to fulfil its contractual obligations, at the time of booking and filling in the registration card at arrival to the facility Hotel Boutique Le Premier collects the following information:

• E-mail addres.

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.

Hotel Boutique Le Premier, as the data controller, based on your consent has the right to store your personal information (name and surname, e-mail address) in its database of guests and use such information for the purpose of direct marketing done solely for the purpose of informing you about Hotel Boutique Le Premier offers and news by e- mail. Under these circumstances, you will have the right to request erasure (right to be forgotten) from the database for that purpose at any time and free of charge.

In addition, a person who books accommodation, that is, a guest, can give Hotel Boutique Le Premier a special permission, namely, consent, that all his or her information, such as:

• Name;
• Surname;
• E-mail address;
• Date of birth;
• Country;
• Other personal information collected during stay (for example, mobile phone number, telephone number, sex, number of children, marital status, language, pets, interests and activities enjoyed during stay, manner of travel, accommodation preferences, destination preferences, etc.);
• Other personal data collected during web browsing (so-called cookies), including the IP address;
• may be collected and used for further profiling of the data subject and for the purpose of maintaining contact and providing information about special and personalised offers, news and events organised by Hotel Boutique Le Premier through online channels (e-mail, web, internet promotions). In this event, the data subject has the right to at any time and free of charge withdraw his or her consent, including the consent for data processing for the purposes of creating a profile to the extent to which such processing is connected with direct marketing, whether in relation to initial or further processing, as well as the right to rectification of data and the right to be forgotten.

Data is stored in the Hotel Boutique Le Premier database of guests for 5 years.

Hotel Boutique Le Premier also collects personal data through the video surveillance system.
Personal information collected by subscribing to our newsletter, including a free Wi-Fi login on the Hotel Boutique Le Premier website

When a data subject subscribes to our newsletter, he or she will be given the option to provide the following additional information with his or her consent (in addition to his or her name, surname and e-mail address that Hotel Boutique Le Premier collects on the basis of legitimate interest):

• Sex
• Date of birth;
• Country;

While renewing his or her subscription to our newsletter, the data subject will be given the option to provide the following additional information with his or her consent:

• Street, house number, zip code, city;
• Telephone number;
• Mobile phone number;
• Interests;
• Manner of travel;
• Pets;
• Preferred accommodation.

Collected data are collected on the basis of an explicit consent for the purpose of providing information about special and personalised offers, news and events organised by Hotel Boutique Le Premier through online channels (e-mail, web, internet promotions).

Data is stored in the Hotel Boutique Le Premier database of guests for 5 years.

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

Cookies and online technologies

Use of cookies (Cookies)

This website and its online services can use cookies to improve their services.
The decision to allow the use of cookies on the website is entirely yours. It should be noted that the website only works optimally if the use of cookies is enabled.

What are cookies?

CookiesCookies) are small files that your browser saves to disk when visiting our website. This enables our website to recognize your computer the next time you visit us, to offer you a personalized experience while surfing. Cookies are not directed at spying on users and do not follow everything that a user does and is not malicious code or a virus. Also, cookies are not associated with unwanted messages or Spam, cannot save the password and are not intended exclusively for advertisements or advertising. Information such as your name or email address will not be saved – web pages cannot access your personal information and files on your computer.

In order to use “cookies” pursuant to REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the protection of individuals in connection with the processing of personal data and on the free movement of such data (General Data Protection Regulation), the Law on the implementation of the General Regulation, the Law on Electronic Communications, we need your consent.

 Types of cookies

• Session Cookies and Persistent Cookies
  • Session Cookies (Session Cookies) are temporary cookies that expire after you leave the Web page. These cookies are mandatory for the proper operation of certain applications or functionalities on this site.
  • Persistent Cookies (Persistent Cookies) are used to improve the experience of our users (e.g. memorizing login details, so you don’t have to type them every time you visit our Web site). These cookies remain in your browser’s cookie file for a long time. This time period will depend on the choice of settings on your Internet browser. Persistent cookies allow data to be uploaded to the Web server each time you visit the site.
• First and third party Cookies
  • First-Party Cookies (First-party Cookies) – published by this website. These cookies are often used for the proper operation of the Web site and for the memory of your Preferences on the Web site.
  • Third-Party Cookies (Third-party Cookies) are cookies that are set up by other websites or services such as i.e. Youtube. We don’t have access to any of these cookies. You need to consult the appropriate privacy policy of those third parties. If you are in the European Union, you can learn more about how third parties use these types of cookies at the following link: http://www.youronlinechoices.eu/.
• Essential and other Cookies
  • Essential Cookies are essential for the operation of our website and the use of its features and/or services. For example, they allow you to navigate the Web page and the ability to log in to secure areas. By using this website, you automatically give your consent to the use of the necessary cookies without which the website cannot function. These are PHPSESSID cookies and _exp Cookies.
  • Performance Cookies collect information about how visitors use our web page, for example, which pages visitors typically come from, and if they receive error messages from those pages. These cookies do not collect information that identifies visitors. All information collected by these cookies is anonymous. They are used only to improve the functioning of this web site.
  • Functional cookies allow our website to remember the choices and customizations you made during your visit and provide enhanced personal features. For example, memory changes to language settings or currency preferences. They can also be used to allow third parties to provide tools for social sharing and to remember your preferred sharing services.
  • Marketing cookies are used to track visitors through the Web site. It is intended to show advertisements that are relevant and interesting to the individual user, and thus more valuable for third party publishers and advertisers.

 

Cookies used on this website:

• PH_HPXY_CHECK	This cookie is used to save the information about the current session.	session	Necessary
  _gcl_au	Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services.	3 months	Analytics
  _ga	Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.	1 year 1 month 4 days	Analytics
  _gid	Google Analytics sets this cookie to store information on how visitors use a website while also creating an analytics report of the website’s performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously.	1 day	Analytics
  _gat_UA-*	Google Analytics sets this cookie for user behaviour tracking.	1 minute	Analytics
  _fbp	Facebook sets this cookie to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising after visiting the website.	3 months	Analytics
  elementor	The website’s WordPress theme uses this cookie. It allows the website owner to implement or change the website’s content in real-time.	Never	Necessary
  __hstc	The main cookie for tracking visitors. It contains the domain, hubspotutk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session)	6 months	Analytics
  hubspotutk	This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor.	6months	Analytics
  __hssc	This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.	30 min	Analytics
  __hssrc	Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. It contains the value “1” when present.	end of session	Analytics
  messagesUtk	his cookie is used to recognize visitors who chat with you via the chatflows tool. If the visitor leaves your site before they’re added as a contact, they will have this cookie associated with their browser.	6 months	Functional

 

How to accept or reject cookies

You can always block the use of some or all of the cookies that we use on our web site, but this may affect its functionality.

The cookie Settings box is located at the bottom of this page. Once you have selected the settings, you can reset the cookie settings at the bottom of this page at any time.

Additionally, you can accept or reject some or all of your cookies by customizing your browser’s settings. On the following links, you can find information about how to change the settings for some of the most commonly used Web browsers: Mozilla Firefox, Google Chrome, Microsoft Internet Explorer, Apple Safari, Opera. Some browsers allow you to surf in “anonymous” mode, limiting the amount of data set on your computer, and automatically erase the persistent cookies that are set on your device when you finish your browsing session. There are many third-party applications that you can add to your browser to block or manage cookies. You can also delete cookies that were previously placed in your browser by selecting the option to delete your browsing history and also include the option to delete cookies. For more information about cookies and adjusting your browser settings, you can find the www.allaboutcookies.org.

 

Video surveillance system

Hotel Boutique Le Premier, 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.

Hotel Boutique Le Premier indicates all places where video surveillance system is installed in the prescribed manner.

Hotel Boutique Le Premier 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 Hotel Boutique Le Premier rules on safety.

Video recordings are regularly rewritten and thus automatically deleted after a maximum of 15 days after they are recorded. Exceptionally, video recordings are kept longer when they serve as evidence in proceedings before competent state authorities. Extracted video recordings are stored in a centralised messaging system with extremely limited access.

In the event of judicial and/or criminal proceedings, Hotel Boutique Le Premier 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 Hotel Boutique Le Premier 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

Hotel Boutique Le Premier advises parents and guardians to teach their children the importance of being responsible when dealing with personal information on the internet. Hotel Boutique Le Premier 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. Hotel Boutique Le Premier 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.

Rectification of data

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 Hotel Boutique Le Premier with your information (booking, registration card …), 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 Hotel Boutique Le Premier may use and collect your information in accordance with the law and the terms of this privacy policy.

Technical and integrated data protection

Hotel Boutique Le Premier, as the data controller, takes utmost care to meet the highest organisational and technical data protection standards. We, therefore, taking into account state of the art developments, the cost of implementation and the nature, scope, context and purpose of processing, as well as the risks arising from data processing of various levels of probability and severity that may affect the rights or freedoms of natural persons, at the time of choosing the processing resources and at the time of the processing itself, take appropriate technical and organisational measures to enable the effective application of data protection principles.

Furthermore, Hotel Boutique Le Premier 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. Hotel Boutique Le Premier 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.

Records of processing activities

Hotel Boutique Le Premier, as the data controller, keeps records on processing activities involving the following data:

• Name and contact details of data controller or, where applicable, joint data controller, and data protection officer;
• Processing purposes;
• Description of data subject categories and personal data categories;
• Categories of recipients to whom personal data are or will be disclosed, including recipients in third countries or international organisations;
• Where applicable, the transfer of personal data to a third country or an international organisation, including the identification of such third country or international organisation and, in the event of transfer referred to in Article 49, paragraph 1, sub-paragraph 2, documentation on appropriate safeguards;
• When possible, planed deadlines for erasure of different categories of data;
• When possible, a general description of technical and organisational safeguards.

Personal data breach

Hotel Boutique Le Premier, as the data controller, ensures that in the event of personal data breach, the competent supervisory authority is notified of personal data breach without further delays and, if possible, at least 72 hours after such breach has occurred, unless it is not likely that such personal data breach will pose a risk to rights and freedoms of natural persons.

The report submitted to the supervisory authority must contain all information prescribed by the Regulation.

In the event of personal data breach that is likely to pose high risk to rights and freedoms of natural persons, Hotel Boutique Le Premier, as the data controller, will notify the data subject of such personal data breach without further delays. Data subjects will not be notified where the Regulation stipulates that such notification is not mandatory.

Data protection impact assessment

Where a type of processing in particular using new technologies, and taking into account the nature, scope, context and purposes of the processing, is likely to result in a high risk to the rights and freedoms of data subjects, Hotel Boutique Le Premier will, as the data controller, prior to the processing, carry out an assessment of the impact of the envisaged processing operations on the protection of personal data.

A single assessment may address a set of similar processing operations that present similar high risks.

Hotel Boutique Le Premier performs a data protection impact assessment in the event of:

• Systematic and extensive evaluation of personal aspects relating to natural persons which is based on automated processing, including profiling, and on which decisions are based that produce legal effects concerning the natural person or similarly significantly affect the natural person;
• Processing on a large scale of special categories of data referred to in Article 9, paragraph 1, or of personal data relating to criminal convictions and offences referred to in Article 10 of the Regulation;
• Systematic monitoring of a publicly accessible area on a large scale;
• Any other situation defined by the competent supervisory authority.

• Hotel Boutique Le Premier ensures an adequate involvement of data protection officers in the performance of impact assessment.

In accordance with the provisions of the Regulation and, when necessary, after the performance impact assessment, we will consult the supervisory authority prior to processing.

Transparency

This Privacy Policy is available at www.lepremier.hr and at the hotel reception desk.

Should we decide to make changes to our privacy policy, we will make available and publish such changes on the website www.lepremier.hr and at the hotel reception desk.