PRIVACY POLICY
- General
The protection of individual privacy provided by Linasi, d.o.o., presented as the “PRIVACY POLICY”, applies to users of the website www.linasiresort.com and guests and customers or visitors (hereinafter referred to as “the individual” or “you”) of Linasi Resort at Lačja vas 22A, 3331 Nazarje. This Privacy Policy is intended to inform you about the content, means and basis of collection, use and storage (hereinafter referred to as “processing”) of personal data and the rights you have in relation to your personal data.
Please read this document carefully. If you do not agree with this Privacy Policy, please leave this website and do not use our services. By using this website, you confirm that you agree with our Privacy Policy.
At Linasi, družba za upravljanje, d.o.o., Lačja vas 22A, 3331 Nazarje, we are committed to protecting and respecting your privacy and your rights in relation to the processing of your personal data, which is why we treat your personal data in accordance with all applicable laws and regulations governing the protection of personal data. When processing your personal data, we comply with the Personal Data Protection Act (Official Gazette of the Republic of Slovenia No. 163/22; hereinafter referred to as ”ZVOP-2”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as ”GDPR”). We use the data obtained exclusively for purposes related to our business.
2. Personal data controller
The controller of this website and/or your personal data is Linasi, družba za upravljanje, hereinafter referred to as ”Linasi d.o.o.” or ”we” or ”us”):
Company name: Linasi, družba za upravljanje, d.o.o.
Abbreviated company name: Linasi, d.o.o.
Seat of the company: Lačja vas 22A, 3331 Nazarje
Registration number: 9682473000
Tax number: SI 89066774
Representative: Irena Linasi (director)
Abbreviated company name: Linasi, d.o.o.
Seat of the company: Lačja vas 22A, 3331 Nazarje
Registration number: 9682473000
Tax number: SI 89066774
Representative: Irena Linasi (director)
3. Personal data processor
In principle, your personal data is processed only by our employees. All employees are bound by confidentiality.
In some cases, we also work with external service providers. We always enter into an appropriate data processing contract with the latter, committing them to an equal or higher level of security for your data.
The external contractors do not process your data for their own purposes, but in particular carry out processing for us:
- the provision of e-communication tools,
- the provision of accounting services,
- the provision of web services and other information technology (IT) services for the proper operation of our business (for example, providers of booking mechanisms),
Due to a legal obligation, we provide certain information about your overnight stay to the Agency of the Republic of Slovenia for Public Legal Records and Services (Agencija za javnopravne evidence in storitve Republike Slovenije; AJPES) and, upon a reasoned written request, to other state authorities that require us to do so for the purposes of conducting specific proceedings.
4. How do we collect your personal data?
We treat your data with the highest possible level of care. All personal data obtained from individuals is private and confidential.
We collect personal data in a booking form where the individual enters all personal data relevant to the reservation and our completion of the requested service.
In person, we collect the guest’s personal data at the time of check-in at the reception desk or when concluding a contract for the provision of our services.
We do not connect IP addresses to persons and each user of the website is anonymous. Anonymous data related to your use of our website is collected with the help of cookies and similar technologies. For more information about how we use these technologies to collect data related to you, please see our Cookie Policy.
5. What personal data is collected, purpose, and legal basis?
We collect personal data for the purposes of providing our services, fulfilling our contractual or legal obligations, protecting our interests and the interests of individuals, informing you about promotions and marketing activities and improving the quality of our services. The table below sets out in more detail how we process individual data and for what purposes.
5.1. Your name, surname, and contact information (address, e-mail address, telephone number), and, where the payer is a legal entity, the tax and registration number of that legal entity
| Purpose | Explanation and legal basis |
|---|---|
| 1. Preparation of offers and conclusion of contracts; 2. Direct communication with you regarding purchases of our services and qinquiries we receive from you. | In order to fulfil our obligations under the contract between us and you, we need your data. This is necessary for us to send you an offer, a booking confirmation, the products you have ordered (e.g. a voucher, a gift voucher) and to contact you regarding the completion of your purchase or the use of our services. Without this information, we cannot conclude or perform a contract with you or provide you with the products or services you have requested. The legal basis for the processing of the data is the contract for the accommodation or use of services – Article 6(1)(b) GDPR. |
| 3. Sending e-mails before and after the performance of the service provided | To inform you of your booked service and provide you with the details of your booking before your arrival, including instructions on how to handle your room key in case of self-check-in, and to get your feedback on your satisfaction with our service at the end of the service provided. We also want to ensure that you are aware of the additional services available to you during your stay and to take appropriate action in the event of your dissatisfaction. The legal basis for processing personal data is the legitimate interest of Linasi d.o.o. in providing a complete service to our guests – Article 6 (1) (f) GDPR. |
| 4. Sending letters, e-mails, or text messages with actual offers and news. | This communication is intended to keep you informed about our current offers, products or services. Sending letters to all existing customers is based on the legitimate interest of Linasi d.o.o. – Article 6(1) (f) GDPR or on the basis of your consent. The legal basis for sending emails is legitimate interest – Article 226(2) of the Electronic Communications Act (Official Gazette of the Republic of Slovenia, No. 130/22 as amended). The legal basis for sending messages is your consent – Article 6(1)(a) of the GDPR. You can refuse the use of your data for these purposes at any time, free of charge and easily. |
| 5. Sending personalised offers (via mail, e-mail, or text messages) based on your expressed interests or prvious purchases/use of our services | To receive a limited number of offers that are most relevant to you, requiring your consent. The legal basis for such data processing is consent – 6(1)(a) GDPR. You can withdraw the use of your data for these purposes at any time. |
5.2. Date of birth, sex, nationality, number and type of identification document
| Purpose | Explanation and legal basis |
|---|---|
| 1. Registration of temporary residence in case of staying with us; verification of age/age of majority; 2. Conclusion of contracts; 3. Sending personalised offers on special holidays (e.g. Women’s Day). | To meet the legal obligation to report daily guests and overnight stays to AJPES. In addition, we need to provide additional protection and restrict use in the case of minors. The legal basis is the Residence Registration Act (Official Gazette of the Republic of Slovenia, No. 52/16 as amended), in conjunction with Article 6(1)(c) of GDPR. We also need information about your date of birth, citizenship and identification document to conclude a contract for the provision of individual services (e.g. e-bike rental) between you and us, and in addition, in this way we can ensure safe use of our services – Article (6)(1)(b) GDPR. The legal basis for sending personalised offers on special holidays is your consent – Article 6(1)(a) GDPR. |
5.3. Credit card details (type of credit card, cardholder’s name, credit card number, expiry date)
| Purpose | Explanation and legal basis |
|---|---|
| 1. Payment and reimbursement arrangements | The processing of this data is necessary for the performance of the obligations under the contract between us and you. Without your credit card details, we cannot conclude or perform the accommodation or service contract or offer you our services. The legal basis is the performance of an accommodation or service contract – Article 6(1)(b) GDPR. We are also required to retain personal data for account purposes pursuant to the Value Added Tax Act, the Prevention of Money Laundering and Terrorist Financing Act, the Payment Services, Electronic Money Issuing Services and Payment Systems Act and the Tax Procedure Act – Article 6(1)(c) GDPR. |
5.4. Information about communications between us and you
| Purpose | Explanation and legal basis |
|---|---|
| 1. Ensuring optimal service and support | In order to provide you with the best level of service, we record your contact history with us. For example, we record your preferences regarding room type, floor, view or other special preferences of each guest, as well as any negative experiences. The legal basis is the accommodation or service contract – Article 6(1)(b) of the GDPR. Moreover, the recording of your negative experiences or compliments is in the legitimate interest of Linasi d.o.o., as this is the only way we can provide you with a quality service and a pleasant stay with us – Article 6(1)(f) of the GDPR. In the case of communication by telephone, we do not record the conversation. |
5.5. Information on booking, stay (including arrival and departure dates) and purchases or services
| Purpose | Explanation and legal basis |
|---|---|
| 1. Full performance of the service or purchase | We need this information to ensure that the services you have requested are provided properly or to ensure that the stay you have chosen with us is guaranteed. Without this information, we cannot conclude or perform a contract with you or provide you with the products or services you have requested. The legal basis is the contract for the accommodation or the use of the services. |
| 2. Complaint resolution | To verify the circumstances and details of your complaint and to resolve it effectively. The legal basis is the legitimate interest of Linasi d.o.o. and third parties in preventing damage to property and the misuse of payment and credit cards – Article 6(1)(f) of the GDPR. |
| 3. Sending personalised offers ( via mail, e-mail or messages) based on your expressed interests or previous purchases/use of services provided by us. | We send personalised offers in order to match your interests, subject to your consent. The legal basis is your consent – Article 6(1)(a) of the GDPR. You can withdraw your consent at any time. |
| 4. (Anonymised) analyses of purchases and services used in such a way that the identity of individuals cannot be discerned or identified | To best understand the wishes and needs of our customers and guests and adapt our services and offers accordingly. The legal basis is the legitimate interest of Linasi d.o.o., as this enables us to optimise our business and continuously improve our services – Article 6(1)(f) of the GDPR. |
5.6. Information you provide to ous in giveaways or special promotional activities
| Purpose | Explanation and legal basis |
|---|---|
| 1. Conducting giveaways and promotional activities | In order for us to check whether you meet the conditions to participate in the giveaway or promotional activity and to contact you regarding the giveaway or promotion – and, if you agree, to send you further promotional messages from our company. We also process the personal data of the winners in accordance with the rules of the respective giveaway for the purpose of fulfilling mutual rights and obligations under the giveaway. The legal basis is consent – Article 6(1)(a) of the GDPR, and with regard to the tax number, the Tax Procedure Act – Article 6(1)(c) of the GDPR. In the case of your consent to receive our offers, the legal basis is consent – Article 6(1)(a) of the GDPR, which you can withdraw at any time. |
6. Exceptions
Linasi d.o.o. also stores the data of its guests in order to protect its own legitimate interest in preventing damage to property and to protect its employees and other guests or users of our services. We therefore store data in the event that:
- you have not paid your bills upon check-out,
- you have damaged our property,
- you have behaved violently towards other guests and our staff.
In the event of non-payment of the invoice, the information is recorded in our central reservation system and the individual is asked to pay on the next visit and is refused accommodation in the event of non-payment. The information will also be forwarded to the competent court or prosecutor’s office and the police.
The data will be stored until the obligation has been paid, or in the case of incidents and aggression, for 3 years
or until the conclusion of the potentional misdemeanour or criminal proceedings.
or until the conclusion of the potentional misdemeanour or criminal proceedings.
7. Personal data retention period
We store personal data for as long as necessary to fulfil the purposes for which it was collected or further processed. The retention period depends on the legal basis on which the data was processed and the purpose of the processing.
Most of your personal data collected for the purpose of using our services or products are stored for the duration of the business relationship, plus the period during which legal claims in relation to the business relationship can be exercised (usually a period of 5 years, which is the general limitation period under the Code of Obligations). Where your data is stated on the issued invoice, we store it for a period of 10 years from the date of the invoice due to tax regulations.
However, where the processing of your personal data is based on your explicit consent, we will store your personal data for the period for which you have consented to the processing of your data or until you withdraw your consent. Upon your written withdrawal of consent, the data will be deleted.
In cases of legitimate interest, personal data is immediately anonymised where possible. Where this is not possible, we will only store your personal data for as long as is necessary to achieve the legitimate purpose. When this purpose is no longer applicable, we delete your data.
Exceptionally, we may process your personal data for longer if we are required to do so by the applicable regulations of the Republic of Slovenia.
8. Your rights
We provide you with a number of rights in relation to your personal data. You can exercise the following rights:
- the right to withdraw consent: If the processing of your data is based on your consent, you have the right to withdraw your consent at any time and in an simple way. You can withdraw your consent by written statement or by sending us an e-mail to podpora@linasiresort.com
- the right to know your own personal data: you can familiarise yourself with all your personal data collected in connection with you and its processing and check its legality;
- the right to correction or completion of personal data: we will correct or update your inaccurate personal data without undue delay;
- the right to deletion of personal data: you may request the deletion of your personal data and we will delete it without undue delay, to the extent permitted by applicable law ( despite your request, we will not be able to delete the data that we need to perform the contract you have concluded with us and the data that we need to comply with our legal obligations);
- the right to restriction of personal data: you can request that we restrict the processing of your data. We are obliged to do this where you dispute the accuracy of your personal data, where the processing is unlawful, where we no longer need your data for processing, but you need it to pursue, exercise or defend your legal claims, and where you lodge a potential objection in relation to the processing of your personal data;
- the right to portability: at your request, we send you the personal data you have provided to us in a structured, commonly used and machine-readable format, or we forward it to another controller of your choice (the latter applies where technically feasible). You may only exercise this right in cases where the processing is based on your consent or on the contract concluded between us and you;
- the right to object: you may object at any time to the processing of your personal data when it is based on our legitimate interests or those of a third party. In addition, you may object at any time to the processing of your personal data where it is processed for direct marketing purposes, including profiling, insofar as this is related to such direct marketing.
When exercising your rights, you must provide us with your name and sufficient information to enable us to identify you unequivocally in connection with the exercise of your rights.
Only you personally may exercise your rights in relation to your personal data, and another person on your behalf may only exercise your rights on the basis of your written authorisation. Before exercising a right, we will therefore verify the identity of the individual exercising the right.
You may only submit a request to exercise your rights in writing by post to Linasi, družba za upravljanje, d.o.o., Lačja vas 22A, 3331 Nazarje, Slovenia or by email to podpora@linasiresort.com. We will reply to you without undue delay or at the latest within one month.
If you consider that we have not dealt with your request properly, you have the right to lodge a complaint with the competent supervisory authority, the Information Commissioner of the Republic of Slovenia (address: Republic of Slovenia, Information Commissioner, Dunajska cesta 22, 1000 Ljubljana).
9. Transfer of your personal data
Your personal data is stored in databases within the EU and is therefore subject to appropriate security measures and rights in accordance with the GDPR.
Where we transfer data outside the EU, we only do so where that country also provides a satisfactory level of protection and adequate security mechanisms, provided that they ensure the rights of individuals and legal accountability to individuals. Before transferring data outside the EU, we assess the level of protection provided to personal data and take additional safeguards where necessary to ensure that the level of protection of personal data remains in line with the GDPR and ZVOP-2.
10. Personal data protection
We use technical and organisational security measures to protect your personal data against unlawful or unauthorised access or use, as well as against accidental loss or compromise of its integrity. These security measures include, but are not limited to, storing data in an encrypted database, protecting our information systems with antivirus and firewall software, updating and testing our security technologies. All measures are designed taking into account our own IT infrastructure, the potential impact on your privacy and in accordance with current standards and practices.
11. Other websites
Our website may occasionally contain links to and from the websites of our partner networks, advertisers or affiliates. If you follow a link to any of these websites, please note that these websites may each have their own privacy policies and that we accept no responsibility or liability for these privacy policies. Before you provide any personal information to these websites, we advise you to check their privacy policies.
12. Validity
The validity date is December 2024
Linasi d.o.o. reserves the right to change or amend this Privacy Policy without prior notice. Any changes or amendments will be posted on this website.