PRIVACY POLICY

Last updated: 9 September 2026

Villa Silvia respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how personal data is collected, used, stored and protected when you visit vilasilvia.com, contact us, submit an enquiry or booking request, or stay at Villa Silvia.

It also explains the legal bases for processing, the circumstances in which information may be shared and the rights available to you under applicable European Union and Croatian data-protection law.

1. Data Controller

The controller responsible for the processing of personal data described in this Privacy Policy is:

Silvia Deklić
Villa Silvia

Krančići 94
52464 Kaštelir
Croatia

Email: silvia.deklic@gmail.com
Telephone: +385 98 177 2490
Website: vilasilvia.com

For any questions concerning this Privacy Policy or the processing of your personal data, you may contact Villa Silvia using the details above.

2. Applicable Data Protection Framework

Personal data is processed in accordance with applicable European Union and Croatian legislation, including in particular:

• Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR)
• the Croatian Act on the Implementation of the General Data Protection Regulation
• applicable Croatian electronic communications legislation
• applicable Croatian tourism legislation relating to guest registration
• other applicable Croatian and European Union legislation

3. Principles of Processing

Personal data is processed in accordance with the principles established by the GDPR.

This means that personal data must be:

• processed lawfully, fairly and transparently
• collected for specified, explicit and legitimate purposes
• limited to what is necessary for those purposes
• accurate and, where necessary, kept up to date
• retained only for as long as necessary
• appropriately protected against unauthorised or unlawful processing, loss, destruction or damage

4. Personal Data We Collect

The information collected depends on how you interact with Villa Silvia.

General contact enquiries

When you use the general contact form or contact Villa Silvia directly, we may process:

• first name
• last name
• email address
• subject of your enquiry
• content of your message
• other information you voluntarily provide

Stay and booking enquiries

When you submit a stay enquiry through the website, we may process:

• first name
• last name
• email address
• telephone number
• requested check-in date
• requested check-out date
• number of adults
• number of children
• message or special notes
• subsequent correspondence regarding the requested stay

Confirmed reservations

Where an enquiry results in a confirmed reservation, we may additionally process:

• confirmed dates of stay
• number and composition of guests
• agreed accommodation price
• booking status
• payment status
• booking conditions
• cancellation or modification information
• arrival and departure information
• correspondence concerning the reservation

Guest registration information

Where required by Croatian law, Villa Silvia processes the information necessary for statutory guest registration through the national eVisitor system.

Technical data

When the website is accessed, certain technical data may be processed automatically, including:

• IP address
• browser type and version
• device type
• operating system
• date and time of access
• requested pages
• technical and security logs
• cookie and privacy preferences

5. No Payments Through This Website

Villa Silvia does not accept or process payments through vilasilvia.com.

The website does not operate an online payment gateway.

Villa Silvia does not collect through this website:

• credit-card numbers
• debit-card numbers
• CVV or CVC codes
• card authentication information
• online banking passwords
• other payment credentials

Submitting an enquiry or booking request through the website does not result in any charge or payment.

Where payment is required after a reservation has been agreed, the applicable amount, payment method and payment instructions are communicated directly to the guest outside vilasilvia.com.

Visitors should never submit payment-card details through website contact forms or ordinary email.

Where payment is subsequently made by bank transfer or another separately agreed method, information required to identify and administer that payment may appear in banking or accounting records.

6. How We Receive Personal Data

Personal data may be obtained in several ways.

Directly from you

For example, when you:

• submit a contact form
• submit a stay enquiry
• send us an email
• contact us by telephone
• communicate with us regarding a reservation
• provide information necessary for your stay

From another guest

The person organising a stay may provide information concerning other members of the travelling group where this is necessary to administer the reservation or comply with legal guest-registration obligations.

From third-party booking platforms

Where a reservation is made through an independent accommodation or booking platform, Villa Silvia may receive the information required to administer that reservation.

Automatically

Certain technical information may be generated when you access or use the website.

7. Purposes and Legal Bases for Processing

Villa Silvia processes personal data only where an appropriate legal basis exists.

Responding to general enquiries

Information submitted by email, telephone or through the contact form is processed in order to respond to your communication.

Legal basis: Article 6(1)(f) GDPR, legitimate interest in responding to genuine enquiries, or Article 6(1)(b) GDPR where the enquiry concerns possible accommodation or another pre-contractual request.

Processing stay and booking enquiries

Information submitted through the stay enquiry form is processed to:

• check requested dates
• check availability
• understand the number of guests
• answer questions concerning the stay
• communicate applicable conditions
• prepare a possible reservation

Legal basis: Article 6(1)(b) GDPR, taking steps at your request prior to entering into a contract.

Managing confirmed reservations

Where a reservation is confirmed, information is processed to:

• administer the reservation
• prepare the property for arrival
• communicate with guests
• provide accommodation
• manage requested changes
• manage arrival and departure

Legal basis: Article 6(1)(b) GDPR, performance of a contract.

Legal obligations

Certain information is processed because Villa Silvia is required to comply with Croatian tourism, accounting, tax and other applicable laws.

Legal basis: Article 6(1)(c) GDPR.

Website administration and security

Technical information may be processed to:

• maintain website functionality
• protect the website against misuse
• detect security incidents
• investigate technical errors
• protect systems and servers

Legal basis: Article 6(1)(f) GDPR, legitimate interest in maintaining a secure and reliable website.

Optional technologies

Where a particular technology requires consent, processing occurs only after valid consent has been obtained.

Legal basis: Article 6(1)(a) GDPR together with applicable electronic communications legislation.

8. Booking and Stay Enquiries

The booking form available on vilasilvia.com is an enquiry form, not an online checkout.

Submitting the form:

• does not constitute payment
• does not guarantee availability
• does not automatically confirm a reservation
• does not collect payment-card information
• does not automatically charge the visitor

After receiving an enquiry, Villa Silvia communicates directly with the prospective guest regarding the requested stay.

9. Guest Registration and eVisitor

Villa Silvia is required to comply with Croatian statutory guest-registration requirements.

Guests staying at Villa Silvia may therefore be required to provide information contained in an identity document in order to be registered through the national eVisitor system.

The information processed for this purpose is limited to the information required by applicable Croatian law.

Legal basis: Article 6(1)(c) GDPR, compliance with a legal obligation.

10. Payments Arranged Outside the Website

Where payment relates to a confirmed reservation, payment is arranged outside vilasilvia.com.

Depending on the agreed method, information such as the following may appear in banking, administrative or accounting records:

• payer name
• amount paid
• payment date
• payment reference
• payment status

Such information is processed only where necessary to administer the reservation or comply with applicable accounting, tax and legal requirements.

Payment-card details are not collected or processed through vilasilvia.com.

11. Cookies and Similar Technologies

vilasilvia.com may use cookies or similar technologies.

Strictly necessary technologies

Technologies that are necessary for the operation, security or functionality explicitly requested by a visitor may be used without optional consent where permitted by applicable law.

This may include technologies required to:

• operate basic website functionality
• maintain website security
• remember privacy choices
• remember certain interface preferences

Optional technologies

Where technologies are used for purposes such as:

• analytics
• advertising
• marketing
• profiling
• cross-site tracking

they must remain inactive until valid consent has been obtained where such consent is legally required.

Visitors must be able to refuse optional technologies as easily as they can accept them.

Consent may also be changed or withdrawn later.

Further information concerning the specific cookies and similar technologies used on vilasilvia.com should be available through the website's Cookie Policy and cookie settings.

12. OpenStreetMap and Map Functionality

vilasilvia.com uses an interactive map based on OpenStreetMap to display the location of Villa Silvia and nearby points of interest.

When map content is loaded, technical information such as your IP address, browser information and request information may be transmitted to the provider responsible for delivering the relevant map resources.

The purpose of this processing is to provide the requested interactive map functionality.

Where the technical implementation of a mapping service requires consent under applicable law, the relevant external content should be loaded only after that consent has been obtained.

The website may also contain links to external mapping services. When you voluntarily follow an external link, the privacy terms of the relevant provider apply.

13. Email and Telephone Communication

If you communicate with Villa Silvia by email or telephone, information relating to the communication may be retained where reasonably necessary to:

• answer your enquiry
• administer a reservation
• organise your stay
• resolve questions
• manage complaints
• preserve necessary business records
• establish, exercise or defend legal claims

Information provided for an enquiry is not automatically used for unrelated marketing.

14. Third-Party Booking Platforms

Villa Silvia may also be available through independent booking or accommodation platforms.

If you interact with or make a reservation through such a platform, that platform independently processes personal data according to its own privacy policy.

Villa Silvia may receive information necessary to:

• identify the reservation
• communicate with the guest
• provide the accommodation
• comply with legal obligations

Payments handled by third-party booking platforms or their payment partners are not processed through vilasilvia.com.

15. Recipients of Personal Data

Personal data is not disclosed to third parties unless there is a legitimate reason for doing so.

Depending on the circumstances, categories of recipients may include:

• hosting and IT service providers
• website maintenance providers
• email service providers
• reservation-management providers, where applicable
• accountants
• professional advisers
• banks in connection with payments arranged outside the website
• Croatian tourism authorities
• the eVisitor system
• competent public authorities where disclosure is required by law

Where a service provider processes personal data on behalf of Villa Silvia, appropriate data-protection requirements apply.

16. International Data Transfers

Where a service provider processes personal data outside the European Economic Area, Villa Silvia will rely on an appropriate transfer mechanism where required under the GDPR.

Depending on the recipient and destination, this may include:

• a European Commission adequacy decision
• Standard Contractual Clauses
• another lawful transfer mechanism recognised under European Union law

Additional safeguards may be implemented where necessary.

17. Data Retention

Personal data is retained only for as long as necessary for the relevant purpose or as required by applicable law.

Enquiries that do not result in a reservation

Information is retained for a reasonable period necessary to answer the enquiry, deal with possible follow-up communication and protect legitimate legal interests.

Confirmed reservations

Booking and guest information may be retained during the reservation and afterwards for the periods required by applicable tourism, accounting, tax and other legal obligations.

eVisitor

Information processed through eVisitor is subject to the statutory retention rules governing that system.

Technical information

Website and security logs are retained only for as long as reasonably necessary for security, troubleshooting and investigation.

Legal claims

Relevant personal data may be retained until applicable limitation periods expire where necessary to establish, exercise or defend legal claims.

When information is no longer required, it is deleted, anonymised or otherwise handled in accordance with applicable law.

18. Your Rights

Subject to the requirements and exceptions provided by the GDPR, you may have the following rights.

Right of access

You may request confirmation as to whether your personal data is being processed and access the personal data relating to you.

Right to rectification

You may request correction of inaccurate information and completion of incomplete personal data.

Right to erasure

You may request deletion of personal data where the conditions under the GDPR are satisfied.

The right to deletion does not apply where continued processing is required by law or another GDPR exception applies.

Right to restriction of processing

You may request restriction of processing under the circumstances established by the GDPR.

Right to data portability

Where applicable, you may request personal data you provided in a structured, commonly used and machine-readable format.

Right to object

Where processing is based on legitimate interests, you may object to that processing in accordance with Article 21 GDPR.

Right to withdraw consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing undertaken before consent was withdrawn.

19. Exercising Your Rights

Requests relating to your personal data may be sent to:

silvia.deklic@gmail.com

or by post to:

Silvia Deklić
Villa Silvia
Krančići 94
52464 Kaštelir
Croatia

We may request additional information where reasonably necessary to confirm the identity of the person making the request.

Requests are handled in accordance with the procedures and time limits prescribed by the GDPR.

20. Right to Lodge a Complaint

If you believe that your personal data has been processed in violation of applicable data-protection law, you have the right to lodge a complaint with the Croatian supervisory authority:

Agencija za zaštitu osobnih podataka (AZOP)
Ulica Metela Ožegovića 16
10000 Zagreb
Croatia

Website: azop.hr

You may also have the right to contact another competent supervisory authority within the European Economic Area.

21. Automated Decision-Making

Villa Silvia does not currently make decisions producing legal or similarly significant effects concerning individuals solely by automated means.

Booking enquiries are not automatically accepted or rejected through automated profiling.

22. Direct Marketing

Submitting an enquiry or booking request does not automatically subscribe you to marketing communications.

Villa Silvia does not use information submitted through booking or contact forms for unrelated marketing unless:

• you have separately and validly consented to receiving such communication, or
• another appropriate legal basis exists

Where consent is used for marketing, it may be withdrawn at any time.

23. Personal Data Relating to Children

Booking enquiries and reservations must be made by an adult with legal capacity to enter into the relevant accommodation agreement.

Information relating to children may nevertheless need to be processed where necessary for:

• administration of a family stay
• calculation or organisation of occupancy
• statutory guest registration
• compliance with Croatian law

Only information reasonably necessary for those purposes should be processed.

Villa Silvia does not use children's personal data for direct marketing.

24. Special Categories of Personal Data

Villa Silvia does not normally request sensitive or special-category personal data through the website.

Visitors are asked not to provide information concerning health, religion, political opinions, biometric data or other sensitive circumstances unless such information is genuinely necessary for a specific request.

Where special-category information is exceptionally processed, this will occur only where an appropriate legal basis under the GDPR exists.

25. Security

Villa Silvia uses appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access
• accidental loss
• unlawful disclosure
• alteration
• destruction
• misuse

Security measures are selected according to the nature of the processing and associated risks.

No electronic system can provide an absolute guarantee of security.

26. Personal Data Breaches

Any suspected personal data breach will be assessed and handled in accordance with the GDPR.

Where legally required, the competent supervisory authority will be notified without undue delay and, where feasible, within 72 hours after becoming aware of a reportable breach.

Where a breach is likely to result in a high risk to the rights and freedoms of affected individuals, those individuals will also be informed where required by law.

27. External Websites

vilasilvia.com may contain links to external websites operated by independent third parties.

Villa Silvia is not responsible for independent processing carried out by those external providers.

Visitors should review the privacy information of any third-party service they choose to access.

28. Requirement to Provide Personal Data

Providing personal information through a general contact form is voluntary.

However, certain information is necessary to:

• answer a booking enquiry
• identify the person making an enquiry
• prepare a reservation
• provide accommodation
• satisfy statutory guest-registration requirements

If required information is not provided, Villa Silvia may be unable to process the relevant request or reservation.

29. No Sale of Personal Data

Villa Silvia does not sell or rent personal data to third parties.

Personal data is disclosed only where a lawful purpose and legal basis exist.

30. Changes to this Privacy Policy

Villa Silvia may update this Privacy Policy where:

• the website changes
• website functionality changes
• new third-party services are introduced
• processing practices change
• legal requirements change

The current version will always be published on this page together with its latest revision date.

Last updated: 9 September 2026