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PRIVACY POLICY

1. General Information

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Somar Travel is a brand of Greenspire d.o.o. za evente, ugostiteljstvo i usluge, turistička agencija (Zajerci 64a, 52402 Cerovlje, Croatia; VAT: HR62506877435). MANO, obrt za čišćenje i održavanje, vl. Manuela Žuhović, offers eco-cleaning and property-maintenance services. Greenspire d.o.o. and MANO are separate legal entities and separate controllers. Each entity processes only the personal data related to its own services: Greenspire d.o.o. handles accommodation and booking inquiries (Somar Travel), and MANO handles cleaning, maintenance, landscaping, and pool-care inquiries. Where it is unclear which entity your inquiry concerns, we will ask you. This website is a shared platform promoting both services.

We are committed to protecting your privacy in compliance with Regulation (EU) 2016/679 (GDPR) and the Croatian Personal Data Protection Act (Zakon o zaštiti osobnih podataka).

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2. Data We Collect and How We Collect It

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This website works as a promotional catalog: you cannot create a user account or complete financial transactions on it. We collect data in two ways:

  • Information You Provide Voluntarily: When you submit an inquiry through our contact forms or send us an email, we collect the personal details you choose to share—such as your name, email address, phone number, and details regarding your accommodation preferences.

  • Automated Information (Cookies & Web Analytics): Our website is hosted on the Wix.com platform. Wix collects certain technical information when you browse, including your IP address, browser type, device information, and session data (such as page response times and visit duration). For details on which cookies are used and how to manage your consent, see the cookie settings banner on this website.

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3. Purpose and Legal Basis

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We process your personal data only on one of the legal bases set out in Article 6(1) GDPR:

a) Purpose - Responding to your inquiries, checking availability, and preparing personalized quotes (Somar Travel or MANO) 

Legal basis - Steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR)
b) Purpose - Customer support and professional assistance before and after a confirmed booking or service

Legal basis - Performance of a contract (Art. 6(1)(b) GDPR)
c) Purpose - Monitoring, analysing, and improving the website    

Legal basis - Our legitimate interest in operating and improving our website (Art. 6(1)(f) GDPR), balanced against your rights
d) Purpose - Marketing emails or newsletters, if you opt in    

Legal basis - Your consent (Art. 6(1)(a) GDPR), withdrawable at any time
e) Purpose - Complying with tourism, tax, accounting, and other legal obligations (e.g. e-Visitor guest registration)    

Legal basis - Legal obligation (Art. 6(1)© GDPR)

We do not sell, rent, or trade your contact information.​

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4. How and Where Your Data Is Stored

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  • Wix.com infrastructure. As our hosting provider, Wix stores website and interaction data on secure servers protected by industry-standard security measures. Wix acts as a data processor; its data-processing terms apply.

  • Our communication (email). Inquiry details are transmitted to our corporate email inboxes. Depending on the type of your inquiry, the responsible controller (Greenspire d.o.o. for travel and booking; MANO for maintenance) accesses and processes your data.

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We do not transfer your personal data outside the EU/EEA unless adequate safeguards are in place. Where a processor (such as Wix) processes data outside the EEA, transfers rely on the European Commission’s Standard Contractual Clauses or an adequacy decision.

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5. How Long Do We Keep Your Data​

 

  • Inquiries that do not lead to a booking or service: kept for up to 12 months, unless you ask us to delete them sooner.​ 

  • Data relating to a concluded booking or service: kept for the duration of the contractual relationship plus the period required by Croatian accounting and tax law (generally 11 years for accounting records), or as required for the establishment, exercise, or defence of legal claims.

  • Guest registration data (e-Visitor): kept and submitted only as required by the Croatian register of tourists law and then retained per those rules.

  • Marketing consent records: kept until you withdraw consent, plus a short period to document the withdrawal.

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6. Your Rights

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Under the GDPR, you have, at any time and free of charge, the right to:

  • access the personal data we hold about you (Art. 15);

  • rectify inaccurate or incomplete data (Art. 16);

  • erase your data (“right to be forgotten”, Art. 17);

  • restrict processing (Art. 18);

  • data portability — receive data you provided to us in a structured, commonly used, machine-readable format, and have it transferred to another controller where technically feasible (Art. 20);

  • object to processing based on our legitimate interests (Art. 21);

  • withdraw consent at any time for processing based on consent, without affecting the lawfulness of processing before withdrawal (Art. 7(3)).

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If you wish to exercise any of these rights, contact us at:

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We will respond within one month of receiving your request. That period may be extended by two further months for complex requests, in which case we will inform you within one month.

Right to lodge a complaint. If you believe we have processed your personal data unlawfully, you may lodge a complaint with the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka, AZOP), Selska cesta 112, 10000 Zagreb, azop@azop.hr, https://azop.hr — or with the supervisory authority of your place of residence in the EU.

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6. Policy Updates

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We may update this privacy policy to reflect operational or legal changes. The current version is always published on this website with its effective date. If a change affects processing carried out on the basis of your consent, we will ask for new consent where required; changes never apply retroactively to data we have already processed on a valid basis.

Contact for privacy matters: Greenspire d.o.o., Zajerci 64a, 52402 Cerovlje, Croatia

· book@somartravel.com · +385 97 632 8668 ·

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