About Us and This
Policy
SALVE REGINA-MARIJA
BISTRICA d.o.o., VAT ID (OIB): 00925470789, with its registered office at
Trpinjska ulica 9, 10000 Zagreb, Croatia (hereinafter referred to as the
“Controller”), operates the website hotelkaj.hr and provides hotel,
hospitality, wellness, conference, event and related tourism services of Hotel
Kaj.
This Privacy Policy
explains in a clear and understandable manner which personal data we collect,
for what purposes we use it, on what legal basis we process it, with whom we
may share it, how long we retain it, and what rights you have regarding the processing
of your personal data.
We process personal data
in accordance with the General Data Protection Regulation (GDPR), the Croatian
Act on the Implementation of the General Data Protection Regulation, and other
applicable laws and regulations of the Republic of Croatia.
If you have any questions
regarding the processing of personal data, you may contact us by e-mail at kaj@salveregina.hr or by post at:
SALVE REGINA-MARIJA
BISTRICA d.o.o.
Trpinjska ulica 9
10000 Zagreb
Croatia
What Data We Collect
While using our website,
communicating with us, making accommodation reservations, staying at the hotel,
or using our services, we may collect different categories of personal data,
depending on your relationship with us.
Website Usage Data
When you visit
hotelkaj.hr, we may automatically collect certain technical information about
your device and website usage, such as:
- IP address
- Device type
- Browser type
- Operating system
- Language settings
- Pages visited
- Date and duration of visit
- Referral source
- Interactions with website content
We use this information
for website security, technical maintenance, traffic analysis, and improving
the user experience.
Data You Provide to Us
When you contact us via a
web form, e-mail, telephone, or any other communication channel, we may process
the information you voluntarily provide, including:
- First and last name
- E-mail address
- Telephone number
- Contents of your message
- Information regarding the requested service
- Information necessary for preparing an offer
or responding to your enquiry
We use this information
to respond to your enquiry, prepare an offer, provide the requested
information, or continue communication initiated by you.
Reservation and Stay
Information
When you submit an
accommodation enquiry, make a reservation, or use hotel services, we may
process data necessary for handling and fulfilling your reservation, including:
- First and last name
- Contact details
- Address or country of residence
- Arrival and departure dates
- Arrival and departure times
- Number of guests
- Room or service type
- Special requests
- Payment-related information
- Reservation-related communication
- Information required for invoicing
We use PHOBS, a booking
and property management system (PMS), for reservation processing. PHOBS enables
the management of enquiries, reservation confirmations, reservation
administration, and related hotel operations. Personal data is processed within
PHOBS only to the extent necessary for booking management, confirmation,
amendments, billing, and fulfilment of reservations.
Guest Registration
Data
As an accommodation
provider, we are legally required to collect and process certain guest
information for the purpose of registering and deregistering tourists in the
relevant official systems, including the eVisitor system of the Republic of
Croatia.
The following data may be
collected and processed:
- Accommodation facility
- Date and time of arrival
- Date and time of departure
- Type and number of identification document
- First and last name
- Country and city of residence
- Nationality
- Tourist tax category
- Method of arrival
- Type of service provided
- Other information required by applicable laws
and regulations
This processing is based
on our legal obligations, and the data is retained for the periods prescribed
by applicable legislation.
Payment Information
When you pay for our
services, we process the information necessary to execute and record payments,
issue invoices, and comply with accounting and tax obligations.
For online payments, we
use MONRI WSPay. Payment card and other payment-related information are
processed through the secure systems of the payment service provider.
As a rule, Hotel Kaj does
not have access to full payment card details, except where such access is
necessary and legally permitted for reservation processing, pre-authorisation,
payment collection, or compliance with contractual and legal obligations.
Newsletter and
Marketing Communications
If you subscribe to our
newsletter or provide consent to receive marketing communications, we may
process:
- Your e-mail address
- Your first and last name (if provided)
- Information regarding the consent you have
given
- Information about your interaction with our
communications, where supported by the tools used
We send newsletters and
marketing communications only when we have an appropriate legal basis to do so,
most commonly your consent.
You may withdraw your
consent and unsubscribe from marketing communications at any time by clicking
the unsubscribe link included in our messages or by contacting us at kaj@salveregina.hr.
Special Requests and
Special Categories of Personal Data
If, during the
reservation process, communication with us, or your stay, you voluntarily
provide information regarding special needs, allergies, dietary restrictions,
disabilities, health conditions, or other circumstances relevant to the safe
and appropriate provision of services, such information will be processed with
particular care.
We use this information
solely to provide services tailored to your needs, such as adapting
accommodation, meals, wellness treatments, or other aspects of your stay.
Access to such
information is restricted to a limited number of authorised persons who require
the information in order to provide the requested service.
Video Surveillance
Certain areas of Hotel
Kaj are protected by a video surveillance system for the purposes of:
- Protection of persons and property
- Safety and security of guests, employees, and
visitors
- Prevention and detection of unlawful
activities
Areas under video
surveillance are clearly marked with appropriate notices.
Video recordings are
retained for a maximum period of 30 days, unless a longer retention period is
required for legal proceedings, evidentiary purposes, or the establishment,
exercise, or defence of legal claims.
Job Applicants
If you apply for a
position at Hotel Kaj or SALVE REGINA-MARIJA BISTRICA d.o.o., we may process
the information contained in your application, including:
- First and last name
- Contact details
- Curriculum Vitae (CV)
- Educational background
- Employment history
- Cover letter
- Any other information you choose to provide
This information is used
exclusively for recruitment purposes and candidate assessment.
Applicant data is
retained for the duration of the recruitment process and for an additional six
(6) months following its completion, unless you provide separate consent for
longer retention for future recruitment opportunities.
How We Use Your
Personal Data
We process personal data
for the following purposes:
Communication with You
To respond to enquiries,
provide requested information, send offers, process requests, and maintain
communication regarding our services.
Reservation Processing
and Service Delivery
To process accommodation
enquiries and reservations, confirm, amend or cancel reservations, provide
accommodation and related services, communicate before, during and after your
stay, collect payments, and issue invoices.
Compliance with Legal
Obligations
To register and
deregister guests, maintain records required under tourism regulations,
calculate and collect tourist taxes, comply with tax and accounting
obligations, and respond to requests from competent authorities.
Newsletters and
Promotion of Services
To send news, special
offers, accommodation packages, wellness offers, conference services, wedding
services, events, and other promotional communications where we have an
appropriate legal basis to do so.
Website Analytics and
Improvement
To understand visitor
behaviour, measure website performance, improve content, and enhance user
experience.
Advertising and
Campaign Performance Measurement
To measure conversions,
conduct remarketing activities, and display more relevant advertising where you
have provided consent.
Security, Fraud
Prevention and Protection of Rights
To protect our website,
information systems, guests, employees, property, business operations, and
legal interests.
Legal Bases for
Processing
We process personal data
only where there is a valid legal basis under applicable data protection
legislation.
Depending on the purpose
of processing, the legal basis may include:
- Your consent
- Performance of a contract
- Taking steps at your request before entering
into a contract
- Compliance with a legal obligation
- Protection of your vital interests
- Our legitimate interests, provided that such
interests do not override your rights and freedoms
Where processing is based
on consent, you have the right to withdraw your consent at any time.
Withdrawal of consent
does not affect the lawfulness of processing carried out before consent was
withdrawn.
Analytics, Advertising
and Third-Party Tools
The website hotelkaj.hr
uses various tools for analytics, advertising, campaign measurement, customer
relationship management, and website optimisation.
Google Analytics
Used to analyse website
traffic, visitor sources, user behaviour, and content performance.
Google Ads
Used to measure
advertising effectiveness, track conversions, and display relevant
advertisements.
Meta Ads / Meta Pixel
Used to measure the
effectiveness of Facebook and Instagram advertising campaigns, conduct
remarketing activities, and display more relevant advertisements.
HubSpot
Used for managing
contacts, forms, customer enquiries, and marketing communications.
Microsoft Clarity
Used to analyse user
behaviour and user experience, including clicks, navigation patterns, page
interactions, and technical issues encountered while using the website.
Cloudflare
Used for website
security, content delivery optimisation, technical protection, and processing
security identifiers necessary for the operation and protection of the website.
Microsoft Clarity may
process technical information relating to website usage and may generate
session recordings to help us understand how visitors interact with the
website.
Where technically
possible, information entered into forms should be masked or anonymised to
avoid unnecessary processing of personal data.
Google Ads, Meta Ads and
related marketing tools are used only with your consent to marketing cookies.
Google Analytics and
Microsoft Clarity are used only with your consent to analytical cookies, except
where processing is necessary for website security or essential website
functionality.
HubSpot
We use HubSpot to manage
contacts, forms, enquiries, customer relationships, and marketing
communications.
When you complete a form
on our website, subscribe to our newsletter, or contact us through available
digital channels, your personal data may be stored within the HubSpot platform.
This may include:
- First and last name
- E-mail address
- Telephone number
- Contents of enquiries
- Information regarding your interest in
specific services
- Communication history
We use this information
to respond to enquiries, provide requested services, prepare offers, maintain
communication records, and, where consent has been provided, send marketing
communications.
Personalised
Advertising
Subject to your consent,
we may use marketing cookies and similar technologies to measure advertising
effectiveness and display more relevant advertisements on Google, Facebook,
Instagram, and related advertising platforms.
This may include
information regarding:
- Pages you visited
- Offers you viewed
- Whether you started or completed a
reservation
- Which advertisement brought you to our
website
- Whether you completed a specific action, such
as submitting an enquiry, subscribing to a newsletter, or making a
reservation
Disclosure of Personal
Data
We do not sell your
personal data to third parties.
Personal data may be
shared only where necessary for the provision of our services, compliance with
legal obligations, protection of our business operations, or the establishment,
exercise, or defence of legal claims.
Your personal data may be
shared with:
- IT service, hosting, and cybersecurity
providers
- Website maintenance providers
- PHOBS, as our booking and property management
system (PMS) provider
- MONRI WSPay, as our payment service provider
- Accounting and tax advisors
- Legal advisors
- Google, Meta, Microsoft Clarity, HubSpot, and
other providers of digital tools, depending on your consent settings
- Providers of security and property protection
services
- Competent public authorities where disclosure
is required by law
- Other business partners where necessary for
the provision of requested services
We enter into appropriate
data processing agreements with our processors and require them to process
personal data only in accordance with our instructions and with appropriate
technical and organisational safeguards.
International
Transfers of Personal Data
Certain service providers
used by us, particularly digital platforms, analytical tools, and advertising
systems, may process personal data outside the European Union (EU) or the
European Economic Area (EEA).
Whenever such transfers
occur, we take appropriate measures to ensure compliance with the GDPR,
including:
- Standard Contractual Clauses approved by the
European Commission
- Adequacy Decisions adopted by the European
Commission
- Other legally recognised transfer safeguards
Data Retention Periods
We retain personal data
only for as long as necessary to fulfil the purposes for which it was
collected, unless a longer retention period is required by law or necessary for
the protection of our legal rights.
|
Type of Data
|
Retention Period
|
|
Enquiry data
|
For as long as
necessary to process the enquiry and maintain reasonable follow-up
communication
|
|
Reservation and stay
data
|
During the contractual
relationship and thereafter for periods required by accounting, tax, and
legal obligations
|
|
Guest registration data
|
As prescribed by
applicable legislation
|
|
Invoices and accounting
records
|
As required by tax and
accounting legislation
|
|
Newsletter data
|
Until consent is
withdrawn or the user unsubscribes
|
|
Marketing data based on
consent
|
Until consent is
withdrawn or the applicable retention period expires
|
|
Video surveillance
recordings
|
Up to 30 days unless
longer retention is required for legal proceedings or claims
|
|
Job applicant data
|
During the recruitment
process and for six (6) months thereafter unless consent for longer retention
has been provided
|
*Retention periods may be extended where
required by applicable law or for the establishment, exercise or defence of
legal claims.
Your Rights
Under the GDPR, you have
the following rights:
- Right of access to your personal data
- Right to rectification of inaccurate or
incomplete data
- Right to erasure ("right to be
forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing
- Right to withdraw consent at any time
- Right not to be subject to a decision based
solely on automated processing, including profiling, where such decision
produces legal effects or similarly significant effects
To exercise any of your
rights, please contact us at:
kaj@salveregina.hr
We will respond to your
request without undue delay and, in any event, within one month of receipt.
This period may be
extended by an additional two months where necessary due to the complexity or
number of requests. If so, we will inform you accordingly.
If you believe that the
processing of your personal data violates applicable data protection laws, you
have the right to lodge a complaint with the Croatian Personal Data Protection
Agency (AZOP).
Children's Privacy
Our website and services
are not intended for independent use by persons under the age of 16 without the
appropriate consent of a parent or legal guardian.
Where children's personal
data is processed in connection with accommodation services, guest
registration, family reservations, prize competitions, or other services, such
data is processed only to the extent necessary and lawful, with particular care
and protection.
Data Security
We implement appropriate
technical and organisational measures to protect personal data against
unauthorised access, loss, misuse, alteration, or destruction.
Such measures include:
- Restricted access to personal data
- Secure information systems
- Protection of communication channels and
infrastructure
- Data backup procedures
- Internal data protection procedures
- Confidentiality obligations
- Contractual safeguards with processors and
service providers
Personal Data Breaches
In the event of a
personal data breach, we act in accordance with the GDPR and our internal
procedures.
Where a breach is likely
to result in a risk to the rights and freedoms of individuals, we will notify
the competent supervisory authority without undue delay and, where feasible,
within 72 hours of becoming aware of the breach.
Where a breach is likely
to result in a high risk to the rights and freedoms of individuals, we will
also inform affected individuals unless an exemption under the GDPR applies.
Automated
Decision-Making and Profiling
We do not use personal
data for automated decision-making that produces legal effects concerning you
or similarly significantly affects you.
Certain analytical and
marketing tools may be used for audience segmentation, campaign performance
measurement, and the display of more relevant advertising, but only in
accordance with your consent preferences and applicable legislation.
Changes to This
Privacy Policy
We may update this
Privacy Policy from time to time to reflect changes in our services,
technologies, legal obligations, or data processing practices.
The latest version will
always be available on this website.
We encourage you to
review this Privacy Policy periodically to stay informed about how we process
and protect your personal data.
Cookie Policy
What Are Cookies?
Cookies are small text
files stored on your device when you visit a website.
Cookies enable the
website to function properly, remember your preferences, measure website
traffic, analyse user behaviour, improve user experience, and, subject to your
consent, display more relevant advertising.
In addition to cookies,
the website may use similar technologies such as pixels, tags, web beacons, and
browser local storage.
Types of Cookies We
Use
Necessary
Strictly necessary
cookies are essential for the operation of the website, maintaining security,
remembering your cookie preferences, and preventing abuse.
These cookies do not
require your consent because they are necessary for the functioning of the
website.
Analytics
Analytical cookies help
us understand how visitors use our website, which pages are visited most
frequently, how users navigate through content, and where improvements can be
made.
We use:
- Google Analytics
- Microsoft Clarity
These cookies are
activated only with your consent.
Marketing
Marketing cookies are
used to measure advertising effectiveness, conduct remarketing activities, and
display more relevant advertisements on Google, Facebook, Instagram, and
related platforms.
We use:
- Google Ads
- Meta Ads / Meta Pixel
These cookies are
activated only with your consent.
Functional
Functional cookies are
used to enhance user experience and support website functionality, including
forms, CRM integrations, and remembering certain preferences.
HubSpot cookies may be
used for these purposes.
Cookie List
Based on the current
website configuration, the following cookies may be used on hotelkaj.hr.
The actual list of
cookies may vary depending on:
- Your consent preferences
- Website configuration
- Third-party services active at the time of
your visit
- Updates implemented by third-party providers
|
Cookie Name
|
Provider / Domain
|
Purpose
|
Retention Period
|
Category
|
|
AcceptedCookieLevel-HotelKajV3
|
hotelkaj.hr
|
Stores the user's
cookie consent preferences
|
Approx. 12 months
|
Strictly Necessary
|
|
_ga
|
Google Analytics
|
Distinguishes users and
measures website traffic
|
Up to 2 years
|
Analytical
|
|
_ga_4TPEVVPS7H
|
Google Analytics
|
Maintains GA4 session
state and event tracking
|
Up to 2 years
|
Analytical
|
|
_gcl_au
|
Google Ads
|
Conversion tracking and
campaign performance measurement
|
Up to 3 months
|
Marketing
|
|
_fbp
|
Meta
|
Browser identification
for advertising and remarketing purposes
|
Up to 3 months
|
Marketing
|
|
_fbc
|
Meta
|
Connects Facebook ad
clicks with conversions
|
Up to 3 months
|
Marketing
|
|
_clck
|
Microsoft Clarity
|
Stores Clarity user ID
and preferences
|
Up to 12 months
|
Analytical
|
|
_clsk
|
Microsoft Clarity
|
Connects multiple page
views into a single session
|
Up to 1 day
|
Analytical
|
|
MUID
|
Microsoft
|
Microsoft user
identifier used for Clarity and related services
|
Up to 12 months
|
Analytical / Marketing
|
|
_cf_logged_in
|
Cloudflare
|
Security and
session-related functionality
|
Temporary
|
Strictly Necessary
|
|
CF_VERIFIED_DEVICE_*
|
Cloudflare
|
Device verification and
security protection
|
Up to 12 months
|
Strictly Necessary
|
|
cfz_google-analytics_v4
|
Cloudflare
|
Cloudflare integration
for Google Analytics
|
Up to 12 months
|
Analytical
|
|
cfz_facebook-pixel
|
Cloudflare
|
Cloudflare integration
for Meta Pixel
|
Up to 12 months
|
Marketing
|
|
cfz_adobe
|
Cloudflare
|
Cookie associated with
Adobe and Cloudflare integrations
|
Up to 12 months
|
Analytical / Functional
|
|
kndctr_..._AdobeOrg_identity
|
Adobe / Cloudflare
|
Adobe Identity
integration identifier
|
Up to 12 months
|
Analytical / Functional
|
|
sparrow_id
|
Cloudflare
|
Technical identifier
used by Cloudflare/Sparrow integrations
|
Up to 6 months
|
Functional / Analytical
|
Managing Cookies
When you first visit our
website, you may choose which categories of cookies you wish to accept.
You can change your
cookie preferences at any time through the:
- "Cookie Settings"
- "Manage Cookie Preferences"
links available on the
website.
You may choose to:
- Accept all cookies
- Reject all non-essential cookies
- Customise cookie preferences by category
Changes to your settings
apply from the moment they are made and do not affect processing that took
place while a previous consent was valid.
Third-Party Cookies
Our website may contain
content, services, or tools provided by third parties, including:
- Analytics services
- Advertising pixels
- Maps
- Video content
- Booking systems
- Payment systems
These third parties may
place their own cookies and process certain technical information in accordance
with their own privacy policies.
While we strive to ensure
that third-party cookies are activated only in accordance with your consent
preferences where required, we do not always have direct control over all
third-party cookies.
Contact Information
If you have any questions
regarding this Privacy Policy, Cookie Policy, or the processing of your
personal data, please contact us at:
SALVE REGINA-MARIJA
BISTRICA d.o.o.
Trpinjska ulica 9
10000 Zagreb
Croatia
E-mail: kaj@salveregina.hr
If you are not satisfied
with our response or believe that your personal data is being processed
unlawfully, you have the right to lodge a complaint with the Croatian Personal
Data Protection Agency (AZOP).
Last updated: 15 May 2026