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User of the webpage or in general, the services of the Villa Sebenico, owner Family Grubišić, Grubišići 39, 22000 Bilice - Šibenik, is a legal or natural person which in any way, both directly and indirectly, uses or has used, accesses or has accessed the webpage or used the services (hereinafter: “User”).

Webpage means all webpages and their sections under the domain.


This Privacy Policy regulates the terms and conditions concerning the handling practice regarding the User’s personal data and explain methods of collecting, processing and protection of personal data.

In the Villa Sebenico, owner Family Grubišić, Grubišići 39, 22000 Bilice - Šibenik, we know how much the privacy and personal data protection is important to our users and therefore we want to be clear on our collecting, use and storage of personal data.

This Privacy Policy is applicable to any webpage under the domain which is the property of Villa Sebenico, owner Family Grubišić, Grubišići 39, 22000 Bilice - Šibenik, or to any access of services provided via the internet, regardless of whether the users use computer, smartphone, tablet or other smart device for the access.

By using these webpages, the Users express their consent with the terms and conditions presented here and agree to the use of the webpage and other services provided via the internet in accordance with them.

The right of use of these webpages and services is a personal right of the User that cannot be transferred in any way to other natural or legal persons.

The User is personally responsible for the protection of passwords, where they exist as such.

The User is acquainted with the fact that sometimes there are technical issues during normal operation of the Internet network which can cause an interruption of services or other events that are beyond Publisher’s control and for which reason he isn’t responsible for any loss of data that can occur during the transmission of information on the Internet or any other event that can occur during the provision of Publisher’s services.

Amendments to the Privacy Policy

The Publisher retains the right to amend or abolish any segment of his business including, and without limitations, availability period, content as well as equipment necessary to access or use the Web sites. Likewise, the Publisher can stop sending information or a part of the information, can change or cancel any mode of data transmission, and can change data transmission speeds, as well as any other of their characteristics.

The Publisher retains the right to, if he deems it necessary, at any moment and without prior notice, abolish or amend any provision of hereby mentioned Privacy Policy. If the Privacy Policy is amended and the User continues to use our services or the Web sites, it shall be considered that he agrees to the amended Privacy Policy. Any eventual amendment or annulment of the Privacy Policy comes into effect towards third parties immediately after its publication on Web sites. Any User’s use of the Web sites in question, besides familiarising himself with the amendments to the Privacy Policy after such amendments have been made shall be considered as agreeing to them.

We encourage every User to carefully read the Privacy Policy, as well as all other provisions in order to find out the procedure regarding his personal data every time he uses our services or the web site

It is important that the User follows all updates to this Privacy Policy and other provisions regarding the use of the web site and services. Even though we are not obliged to, we can inform Users about particular amendments to this Privacy Policy by publication or by sending an e-mail. The newest version of this Privacy Policy shall always be available here and the User can check the date of amendment in order for him to know when the last update was.

How do we collect data?

We collect the User’s personal data when the User sends it or allows us to use it. For example, via the form on the web site, by e-mail, by phone, by post or in writing or through social networks through which the User can contact us. In exceptional cases and when permitted by the law, we can obtain User data from other sources.

Which data do we collect?

In order for us to respond to specific User inquiries, to personalise the content for the User, adjust advertising messages in accordance with the interests or behaviour of the User and to improve user experience in general, we collect the following data:

The data that the User provides directly and that we collect via web site’s forms, by e-mail, through social networks or by phone.

  • Name and surname
  • E-mail address
  • Adress, PO BOX number, City
  • Telephone number
  • User’s message or inquiry

Data about the User’s use of web site, including the data about devices and systems through which the User accesses the web site like type of device, type of operating system, internet browser, IP address, pixels and other data concerning the systems with which the User accesses the web site.

Statistical logs data which through cookies track User’s behaviour on the web site, diagnostic and analytic data, data about the User’s course and steps on the web site. Likewise, they include information and data about User’s activity and interaction with the web site, which we use to better understand the needs of Users or possible problems with the purpose of improving User experience on the web site. You can read more about how we use the data stored in cookies here.

Data about the use of e-mail which imply the time of opening the response sent by e-mail, number of openings and number of clicks on the response sent by e-mail.

Data obtained from a third party which imply User data and other publicly available sourced permitted by the law, for example, social networks and we can combine them with other data that we receive from the User.

Other data which we can collect about the User, about his use of the web site or his use of our services and which type and method of collecting will be explained at the place where they’re collected and will be processed with the User’s consent. The User can refuse to provide certain personal data, but that could have an effect on the possibilities of use of certain services. The User is obliged to provide certain data, and Villa Sebenico, owner Family Grubišić, Grubišići 39, 22000 Bilice - Šibenik, as the controller is obliged to process them according to The Act.

How do we use data?

Personal data obtained from the User can be used for the following purposes:

  • Regarding the use of our services, that is the possibilities of responding to Users’ specific inquiries.
  • In order to make contact regarding procedures, which can include data processing for the purpose of drafting a business plan or offer.
  • In order to improve general user experience on the Web site, to understand the Users’ wishes and needs and to improve our services.
  • In order to provide more relevant advertisement, that is deliver adverts that are in accordance with the Users’ interests or are based on the Users’ behaviour and activity on the Web site
  • To send promotional notices by e-mail, like notices of special offers, benefits, deals, discounts and educational materials.
  • For analytic and statistical processing in order to better understand how the Users use our services and web site.
  • To research and analyse the market and clients in order to understand the market needs better and find out more about our clients so we can offer them the most relevant communication and better service in general.
  • In order to share personal data with our data processing Contract performers like our IT and infrastructural partners, marketing partners, bookkeeping service or accommodation arrangement partners.
  • For the necessary processing obliged under The Act and other acts.

We use applications/platforms which are our data processing contractual processors and with which we have a Contract on use and protection of personal data with the purpose of processing Users’ personal data.

G Suite – Platform that serves for a whole set of Google business applications. We use business applications to safeguard business documents which can also contain Users’ personal data, e-mail communication with partners and potential and existing users of our services.

How do we store data?

We store Users’ data on our own servers located in Croatia and on the servers of cloud service suppliers that are located in the EU and the USA.

We store and process only that data and from those users which have given personal consent for their processing and for purposes that do not fall out of scope of the purposes mentioned in this Privacy Policy. In case of exceptional storage and data processing that falls out of scope of this Privacy Policy, the User will be notified prior to such case. Personal data privacy protection is permanent and we undertake all protection measures of the data in question in accordance with the General Data Protection Regulation.

Pursuant to The Accounting Act the accounting data is safeguarded for 11 years.

For more information about where and for how long Users’ data are stored please contact us at

How do we protect Users’ personal data?

We take Users’ personal data and its protection seriously and permanently apply corresponding organisational, physical and technical measures in order to protect all personal data that we collect.

We have undertaken a series of measures for the purpose of personal data protection:

  • The Ordinance on Villa Sebenico, owner Family Grubišić, Grubišići 39, 22000 Bilice - Šibenik, clients data protection and processing.
  • An estimate of the risk and security of computer equipment and servers which are used to store personal data.
  • The use of safe and reliable servers to store data.
  • Careful and responsible choice of Processing performers and signing data protection contracts with all data processing performers.
  • Employee training on the importance of confidentiality, maintaining security and privacy and the conduct regarding the Users’ personal data.
  • Appointing the person responsible (Officer) for the protection and safeguarding of personal data.

We will not deliver, transfer or provide Users’ personal data to third parties, except to those which are mentioned in this Privacy Policy and to those with which we have a Personal data protection contract. Exceptionally, we can deliver data to a third party if it is necessary to protect the User’s vital interests, obligatory by law, necessary for the purpose of legal proceedings, expressly requested by the User or necessary to respond to his request.

Personal data for which the basis or consent to process doesn’t exist anymore can be kept for the purposes of statistics or the keeping of communication history, but we will not process the data in question in any way and we will safeguard them from any unauthorised access or use.

It must be noted that, regardless of the measures of personal data protection we’ve undertaken, no web site, electronic transfer, computer network or wireless network are completely safe.

What are Users’ rights with regards to personal data?

The User can exercise his rights regarding the personal data in processing at any given moment without stating a reason, except regarding the data we collect pursuant to The Act. Those rights imply:

  • The right of access of personal data and the purposes of their processing
  • The right to change personal data
  • The right to delete personal data
  • The right to limited processing of personal data and the right to change the purpose of processing
  • The right to send personal data
  • The right to withdraw the consent for personal data processing

The user can exercise his rights by sending a message at

Contact us

In case you have any questions regarding personal data protection or processing, please contact us at or at the address Villa Sebenico, owner Family Grubišić, Grubišići 39, 22000 Bilice - Šibenik.

In case you believe that with regards to your data we do not act in accordance with The Personal Data Protection Act and the GDPR Regulation and if this cannot be resolved in cooperation with us, you can file a complaint to the competent authority – The Personal Data Protection Agency.

Last amendment: 04.11.2020.