PRIVACY POLICY

1. INTRODUCTION

1.1 This privacy policy of Imperial Spirits Festival (“policy”) describes how LIBURNIA RIVIERA HOTELS JOINT STOCK COMPANY (hereinafter also referred to as “LRH” “we,” “us,” “our”) collects and processes data about you when you visit our website (https://imperial-spirits.com/). By the continuous use of this website, you agree to the processing of your data in accordance with this policy.

1.2 LRH respects your privacy and are committed to protecting your personal details. The collection and storage of information is conducted in accordance with the provisions of the Personal Data Protection Act. Please note, that we reserve the right to change the terms and conditions of the privacy policy, under which this site is offered at any time. At every touch point or guest interaction, also by conducting every aspect of our business, we may collect personal data.

This privacy policy describes what data we collect, the ways we process them and the purposes we use them for, as well as your rights associated with your data.

1. a) Responsible for data processing:

Company: Liburnia Riviera Hoteli d.d. Opatija

Abbreviated name: LRH d.d.

Headquarters: Opatija, Ulica maršala Tita 198

OIB /personal identification number/: 15573308024

The Data Protection Officer is available at the e-mail: dpo@liburnia.hr

1. b) If we use the services of external service providers for the processing of your personal data, we are talking about the processing (of personal data) per order. In this case, we are responsible for the protection of your personal data. During the processing of your personal data, we may use service providers outside the EU. We will do so only if for that third country exists is a decision of the European Commission on the adequacy of that country, or if we contracted with the service provider appropriate warranties or adherence to binding regulations on the protection of personal data.

“Personal data” means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number, email) as a natural person. Before providing us with this information, we recommend that you read this document describing our customer privacy protection policy.

We may use your personal information (hereinafter referred to as “PI”) for marketing purposes. If required by applicable law, you will be requested to give your prior express consent to receive such marketing materials. We may also collect and keep information and records related to conversations, including recording, or monitoring reservation center calls.

By accessing and using our website (this includes: viewing, transmitting, caching or storing this site, or any of its services, functions, materials or content) this means you have read and agreed to each and all the terms and conditions. If you do not agree with the terms and conditions, you may not use this site for any further purpose.

2. THE PERSONAL DATA WE COLLECT AND HOW WE USE IT

2.1 Data you share with us: When you visit our website, correspond with us, participate in one of our promotions or surveys, you may be providing us with information about yourself. This may include information that allows us to draw conclusions about your person (“personal data”). If we ask you to provide specific data, we collect the data that is listed in the respective forms or on the respective pages. In addition, you may also provide us with further information at your own request when you contact us or interact with us in any other way.

2.2. If you decide to purchase our packages, you will be redirected to our external websites.
For the purpose of buying packages that include accommodation and festival tickets you will be redirected on the Liburnia Riviera Hoteli d.d. Opatija website (https://www.liburnia.hr/ ), and thereby the Liburnia Riviera Hoteli d.d. will be responsible for processing your data according to its privacy policy (https://www.liburnia.hr/en/privacy).

If you decide to buy tickets for the festival on our website you will be redirected to our external service provider Eventim d.o.o. (https://www.eventim.hr/en/), and thereby there are responsible for managing, processing and storing your billing and payment data (https://www.eventim.hr/en/dpp/dpp.html).

2.3. If you decide to subscribe to one of our newsletters, we will collect your name and email address.

2.3 The personal information you provide will be used to enable you to use our website and services. We also use this information for administration and troubleshooting purposes and to send you marketing materials (if you have consented to receive marketing materials from us). As explained in Section 2.7 below, we may use this data for other purposes when combined with other data we collect about you.

2.4 Data that is collected automatically. When you visit our website, we may automatically collect the following data: IP address, location, browser plug-in types and versions, operating system and operating platform, information about your visit, including URL clickstream (sequence of page views) to, through and from our site, products you view or search for, download errors, length of visit to certain pages, and interactions between pages. Automatic data collection is conducted using various technologies, including “cookies”.

2.5 We use the information that is automatically collected from us (1) to administer our site for internal activities, including troubleshooting purposes; (2) to ensure that content on our sites is presented as effectively as possible for you and your end devices; (3) as part of our efforts to ensure the protection and security of our site; (4) to measure and understand the effectiveness of the advertising we deliver to you and others and to provide you with relevant advertising; and (5) to make suggestions and recommendations to you and other users of our website about goods and services that may be of interest to you or them.

2.6 We may receive information about you when you use one of the other services we offer on this website or when you have provided information to other affiliates. We also work closely with third parties (including, for example, business partners, sub-contractors for technical services, and delivery services, advertising networks, analysis service providers, search engine operators ) and may obtain personal data about you from them (including publicly available data).

2.7 As permitted by law, we may combine this data from other sources, including social media sites, with data provided by you and collected by us, including data obtained through cookies. We may use this information and the aggregated data to learn more about your preferences as our customer, to improve your user experience on our site, and to provide you with information, content, and offerings that are customized for you.

3. TRANSFER AND DISCLOSURE OF DATA

3.1 We may share your information with companies affiliated with LRH and third parties specified in this policy for the purposes specified in this policy. Where appropriate, we may also share your information with third parties if: (1) it is necessary to involve an external service provider to facilitate or enhance our services; (2) it is expressly requested by you (e.g., social networking sites); (3) it is required by court order or legal or regulatory requirement; (4) it is in connection with the sale or transfer of a business; (5) it is necessary to enforce our Terms of Service; (6) it is necessary to protect the privacy and security of our users, consumers, and third parties; and (7) it is necessary to protect our rights and property and the rights and property of our guests and third parties.

3.2 For our events, we use a system for access control and (cashless) payment systems. In this process, personal data (first name, last name, date of birth, email address) is collected and processed to enable you to recharge your NFC medium (bracelet, card) before the respective event. Your data will be passed on to payment providers for the return transfer of your remaining credit. For event tickets our selling platform is Eventim d.o.o.,( https://www.eventim.hr/en/) and thereby they are responsible for data collection and processing  (https://www.eventim.hr/en/dpp/dpp.html).

4. OPT-IN OR OPT-OUT OF DIRECT MARKETING

4.1 We and selected third parties may use the information you give us on our website for direct marketing purposes, to send you updates, newsletters, event notifications, or any other information that we think may interest you. Where required by law, we will obtain your consent before sending direct marketing material. In any event, we will provide you with the opportunity to opt-out of any communications we send you.

5. ANALYSIS AND ADS

5.1 We use third-party programs to make the ads we show you on our site or our affiliates’ sites more relevant and interesting to you. For this purpose, we use cookies, web beacons, or similar technologies to collect data about your usage patterns and to provide you with interest-based advertising.

5.2 We also use third-party tools, including Facebook Custom Audience and similar tools provided by Facebook, to advertise on other sites (including social networking sites such as Facebook). Facebook Custom Audience is a tool offered by Facebook that assigns a customer/visitor of Imperial Spirits Festival
to a Facebook user to advertise on the Facebook platform. For this purpose, we share your data with the relevant providers (e.g., Facebook) and use cookies or similar technologies on our website to analyze the effectiveness of our advertising on other websites. You can find more information about how Facebook uses data by clicking on the following link: https://www.facebook.com/privacy/explanation.

6. NEWSLETTER

We use your information in the following marketing purposes:

• To send you regular news related to our products and services. You may, quickly, easily and at any time, unsubscribe from receiving notifications via email – simply click on the link “Unsubscribe” stated in each newsletter.
• Based on your information, you may be presented with personalized offers on our website, in the mobile applications or even on other sites/applications (including social networks), and the content of the page displayed to you may be personalized. They may include offers that can be booked directly through our website, or other offers and products of third parties which we think you might like.
• When you participate in other promotional activities (such as competitions, loyalty programs or prize games), the relevant information will be used for the administration of these promotional activities.

7. COOKIES AND OTHER TECHNOLOGIES

7.1 We collect data automatically using “cookies.” A cookie is a text file containing a small amount of data that a website can send to your browser, and which is then stored on your computer as an anonymous tag to identify your computer but not you. Some of the pages of our website use cookies to provide you with a better service when you return to the website. You can set your browser to notify you before you receive a cookie, giving you the opportunity to decide whether to accept it. You can also set your browser to turn off cookies. If you do so, some services on our website may not function properly.

7.2 We use the following cookies on our website and/or our app:

• Essential cookies . These are cookies that we require to operate our website and app. We also include among these cookies a combination of Google Analytics and proprietary tracking cookies that allow us to attribute purchases to partners, which is necessary for us to be able to fulfil our obligations under these agreements as our business model relies on it. This data is intended for internal use only and short expiry periods are set. You can contact us at dpo@liburnia.hr for further information.
• Analytical/performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website and app when they are using it. This helps us to improve the way our website and app works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Where this information is used for any marketing purposes, we will ask for your consent first.
• Marketing cookies. These are cookies that are used to target advertising to a user (behavioural targeting), including Facebook Conversion API through which data will be shared with us and/or our event partners for marketing purposes, as well as being shared with Facebook/Meta.

7.3. Data collected via the Google Analytics service

LRH uses a data analysis service called Google Analytics on its website, which is provided by Google Inc. based in Mountain View, California, USA. Using Google Analytics allows us to view data about a visitor to the website, which includes, but are not limited to, the number of visits to the website, the source from which it is visited and the time the visitor spent on it. This information is depersonalized, anonymized, and displayed in numbers that cannot be associated with a particular person. Such information is used exclusively for statistical purposes to adapt our services and the website itself to the needs of users and visitors.

These data are stored and used for the entire time until the visitor decides to exclude the said platform in the sense that their activity on the Imperial Spirits Festival website cannot be further analyzed. You as a visitor and user of our website can therefore be excluded from the scope of Google Analytics used on Imperial Spirits Festival website by visiting the opt-out page of Google Analytics itself and downloading the plug-in program for your Internet browser that will allow you to be excluded, at the following link: support.google.com/analytics/answer/181881

GOOGLE ADS CONVERSION TRACKING AND REMARKETING

Our websites use the Google Ads conversion tracking and Google Ads remarketing services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Ads conversion tracking is used by us to capture specific customer actions (such as clicking on an advertisement, page call-ups, clicks on specific links) and to analyzse them. We use Google Ads Remarketing to display individualized advertising messages to you for our products on partner websites of Google.

For this purpose, both services insert cookies and similar technologies. The data accrued in this context may be transmitted by Google for analysis to a server in the USA and stored there. Should personal data be transmitted to the USA, Google has acceded to the EU-US Privacy Shield.

If you use a Google account, Google may – depending on the settings saved in your Google account – link your web and app browser history with your Google account and use information from your Google account to personalise advertisements. If you do not wish for this allocation to the Google account, it will be necessary for you to log out before calling up our contact page at Google.

As set out above, you can so configure your browser that it rejects cookies. Additionally, in the cookie settings of Google’s Privacy Statement, you can prevent Google cookies from being used for advertising purposes.

You can find more detailed information on this matter in Google’s Privacy Statement.

Google Privacy Policy: http://www.google.com/intl/en/privacy/

GOOGLE SIGNALS

Google signals are session data from sites and apps that Google associates with users who have signed in to their Google accounts, and who have turned on Ads Personalization. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing, and cross-device conversion export to Ads.”

When the Google Signals feature is activated, more information could be gathered in the following areas:

1. Cross-platform reporting. Google Analytics connects data about devices and user activities from different sessions using Google Signals or User ID data, which allows understanding of user behavior at each step of the conversion process, from initial contact to conversion and beyond.
2. Google Analytics data allows creating of remarketing audiences that could be shared with your linked advertising accounts.
3. Advertising reporting features. Google Analytics collects information per your tracking-code configuration, which includes data from Google Signals and Google advertising cookies if they are present.
4. Demographics & Interests. Google Analytics collects additional information about demographics and interests from Device IDs and from users who are signed in to their Google accounts and who have turned on Ads Personalization.
   
   

What is Google Signals used for?

• Google Signals allows an understanding of users’ online behavior. For example, you can see how users discover your website, browse some products, do they use a computer or a mobile phone if they buy a product instantly, or do they return to your website later to complete a purchase.
• Here are some practical examples what we do with Google Signals:
• Cross-device user accounts report. Accurately collect and report the number of users instead of devices, which include 1-Day, 7-Day, 30-Day activities.
• Audience targeting. Understand and target different groups of users based on the different device combinations they use, which allows us to focus resources on the most valuable set of users.
• Funnel analysis. Understand the customer journey across devices by analyzing user-based reports, including active users, funnels, and paths, which allows us to optimize the user experience through the path of completing a purchase.
• Allocate budgets. Understand cross-device marketing performance, including different channels and campaigns, and optimize ad spend for the most valuable choice.
• Cross-device remarketing. Allows the offering of highly relevant ads based on cross-device usage.

GOOGLE TAG MANAGER

Our website uses Google Tag Manager, a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). The Tag Manager is used to manage tracking tools and other services, so-called website tags. A tag is an element that is stored in the source code of our website in order to record, for example, predefined usage data, such as an IP address. The Google Tag Manager does not use cookies and does not collect any personal data. The Google Tag Manager triggers other tags that may collect data. Some of the data is stored on a Google server in the USA. If personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield. If deactivation has been made at the domain or cookie level, it will remain in effect for all tracking tags implemented with Google Tag Manager.

For more information, please refer to the privacy policy and Google’s further information about Tag Manager.

7.3 When you use our website for the first time you are given the opportunity to accept or decline cookies which are not strictly necessary.  By using the tick boxes on the cookie banner, you are consenting to or declining our use of cookies by category as set out in this policy. You can also change your cookie consents at any time by accessing the cookie banner. You can set up your preferences the first time you visit our website and at any time through our cookie banner

7.4 Please note that when you access or use our services through third-party websites, such as our event partners’ websites, we may share some information with them when you perform certain actions in the purchase flow. We will not use any cookies or pixels for these purposes. These third parties or event partners will only be able to use this data for marketing purposes if you provide your consent on their website. We may not be able to erase your data in new sessions if there is no way for us to identify you.

8. LINKS TO OTHER WEBSITES AND SOCIAL MEDIA

8.1 Links to other websites are provided for information purposes only. Other websites are beyond our control and are not covered by this policy. If you visit other websites via the links provided, the operators of those websites may collect information about you, which may be used by the operators in accordance with their privacy policy in a manner that may differ from our policy.

8.2 Some pages on our website may contain third-party content, applications, or plug-ins that track your use of content, applications, or plug-ins and/or that optimize your use of content, applications, or plug-ins. For example, if you share an article on our site using a social media share button (such as Facebook, Youtube, Instagram, etc.), the social network that created the button will record the activity.

9. DATA STORAGE

9.1 We will not store your data longer than necessary for our business purposes or as required by law. However, please note that we may retain some data when necessary to comply with our legal obligations, such as for tax and accounting purposes.

10. YOUR RIGHTS

10.1 If you would like a copy of any personal information we hold about you, or to correct or amend any inaccurate information or have it deleted, please contact us at the address below. Before we can respond to your request, we may ask you to verify your identity and provide further details about your request. We will attempt to process your request within a reasonable time and in any event within the period required by law.

10.2 It is your responsibility to ensure that the information you provide is true, correct, complete, and up to date. You can also have us update your personal information by contacting us at the address below.

11. DATA SECURITY

11.1 We use appropriate security measures to protect your personal data stored by us against unauthorized access, unauthorized collection, use, publication, duplication, modification, or deletion. All data that you provide us with is stored on secure servers.

11.2 a) Right to rectification.

If we process your personal data that are incomplete or inaccurate, you can request from us correction or amendment of the data at any time.

1. b) Right to erasure

You can request from us erasure of your personal data if we have processed them unlawfully, or if that processing represents a disproportionate infringement in your protected interests. Please take into consideration that there exist reasons that prevent immediate erasure, such as statutory obligations.

1. c) Right to the possibility of data transfer:

You may request from us to deliver the data that you have entrusted to us for archiving purposes to you in a structured form (in a common machine-readable format).

1. d) Right of access

You can get a confirmation from us on whether your personal data are processed. If such personal data are being processed, you can get access to these data and the following information: information on the purpose of the processing, on the categories of the personal data concerned, on the recipients or categories of recipients to whom personal data are disclosed or will be disclosed, on the estimated period in which personal data will be stored or on the criteria that were used for the determination of that period, on the existence of your rights that are listed in this paragraph of the policy, on the existence of automated decision making, including drafting profiles and information on the logic of the processing, on the importance and the predicted consequences of processing, on the protective measures if the personal data are transferred to third countries or international organization.

1. e) Right to limit processing: You can request from us the restriction of the processing of your data:

if you dispute the accuracy of the data during the period that allows us to verify the accuracy of these data

– if the data processing was unlawful, but you refuse erasure and instead request data restriction

– if the data are no longer required for the intended purposes, but you still require them to meet legal requirements or

– if you filed a complaint about the distribution of these data.

1. f) Right to object:

If we distribute your data in order to execute the tasks of public interest or tasks of public authorities or if we refer to our legitimate interests during their processing, you can submit a complaint against such data processing if there is interest of protecting your data.

1. g) Right to appeal

If it is your opinion that during the processing of your data we violated Croatian or European regulations on data protection, please contact us in order to clarify any inquiries. You certainly have the right to submit a complaint to the Croatian Agency for Data Protection, or in the event of change of applicable regulations, you may submit a complaint to another body, which will take over its jurisdiction, and from May 25th, 2018, this complaint may be submitted to the supervisory body within the EU as well.

1. h) Exercise the right:

If you would like to exercise any of the above-mentioned rights, please contact us by using our contact information stated in the introductory provisions of this policy.

1. i) Authentication of identity:

In case of doubt, we may require additional information to verify your identity. We do so to protect your rights and private sphere.

1. j) Abuse of rights: If you use these rights too often and with an evident intent of misuse, we may charge an administrative fee, or refuse to process your request.

12. TRANSMISSION VIA THE INTERNET

12.1 Since the Internet offers a global environment, the collection and processing of personal data via the Internet necessarily involves the international transfer of data. Although we usually store personal data that we collect about you through our website in your region (for example, in the European Economic Area for European visitors), your personal data may also be transferred to parties outside your region (where different data protection laws apply). In this case, we will ensure that the transfer is carried out in compliance with contractual or other measures to protect the data.

13. USE OF THE WEBSITE BY MINORS

13.1 If you are under 18 years of age it is forbidden to browse the website or purchase products and services from Imperial Spirits Festival.

14. QUESTIONS CONCERNING THE POLICY

14.1 This website is maintained by LRH. If you have any questions, concerns, or complaints regarding this policy or our handling of your information, please email us at dpo@liburnia.hr.