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Privacy Policy


Villa Dubrovnik d.d.


Privacy notice for customers of Villa Dubrovnik d.d.

(in accordance with Article 13 of EU Regulation 679/2016)


This privacy notice explains how Villa Dubrovnik d.d., Vlaha Bukovca 6, 20000 Dubrovnik (Villa Dubrovnik), as data controller, processes the personal data concerning you that are provided by you or third parties and/or collected during Villa Dubrovnik’s activities.

This Privacy notice additionally informs you that Doğuş Otel İşletmeciliği ve Yön. Hiz. A.Ş., (“Dogus Otel”), a Dogus Tourism Group company, in its capacity as data controller, processes the personal data concerning you when storing and sharing your data within Dogus Tourism Group, as well as when performing Group sales and marketing activities. For Dogus Otel’s processing activities please refer to the Privacy notice [·] of Dogus Otel to be found on [·]. 

Personal data processed

We collect, store, and use your personal data, which includes your personal details (name, date, and place of birth), contact details (phone number, email address, and postal address), tax code, nationality, profession, employment details (only company name), and business contact details (business phone, email, fax, mailing address, etc.). We also collect, store and use data on your personal preferences, which includes food and communication preferences, accommodation and spending details, transportation/travel details, membership number, details on insurance, credit card and invoice details and other types of information that you choose to provide to us or that we are obliged or allowed to obtain about you.


Purposes of the processing

Your personal data may be processed for the following purposes:

(a) to fulfil the obligations provided by law and regulations, including obligations to tax authorities and obligations concerning public health, law and order, and public safety

(b) to preliminarily assess fulfilment of the requirements to provide you products and services, to correctly and punctually fulfill all the obligations arising from the contractual relationship with you, to provide customer care and to protect credit positions deriving from it

(c) for management, accounting, and administrative purposes

(d) for sending newsletters, advertising material, and other communications on new products/services and updates/news on existing products/services, and for carrying out surveys, including on customer satisfaction

(e) to analyze/predict aspects concerning your personal preferences, interests, and behavior, including your use of Villa Dubrovnik’s website, in order to offer products and services tailored to you and to provide personalized advertising


The legal bases for processing personal data are:

- for purpose (a): the fulfilment of legal obligations

- for purposes (b) and (c): the entering into of a contract with you, as a customer, or, at your request, the implementation of pre-contractual measures

- for purpose (d): Villa Dubrovnik’s legitimate interest (as stated by Recital 47 of Regulation 679/2016)

- for purpose (e): your consent


Nature of providing the requested data

Providing your personal data for the purposes under points (a), (b), and (c), is required. Refusal to provide the requested data or its inaccuracy may prevent Villa Dubrovnik from providing you products and/or services and from establishing a contractual relationship with you.


The provision of personal data for the pursuit of the purposes referred to in point (e) above is optional; however, refusal to provide the data for these purposes may prevent from providing you additional products/services.


Methods and place of processing and place of storage of personal data

Your personal data will be processed in accordance with the principles of correctness, lawfulness, and transparency.


Rest assured that we maintain appropriate security, technical, and organizational measures that ensure a level of security appropriate to the risk of unauthorized access to, and accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, personal data transmitted, stored or otherwise processed.


Your personal data will be processed manually or electronically using automated tools that ensure the security and confidentiality of the data.


Processed data are stored at our registered office or at the office of any external providers we entrust to store personal data. If you wish to know the list of our external providers, please contact us.


We will process only personal data necessary for the above purposes. The people authorized to the data processing will immediately delete or make anonymous personal data unnecessary for the above purposes.


Data retention period

Your personal data will be kept by us:

- for contractual purposes: for the entire duration of your contractual relationship with Villa Dubrovnik and for 6 years thereafter.

- for the purpose of sending newsletters, advertising material, and other communications on new products/services and updates/news on existing products/services, and for the purpose of carrying out surveys, including on customer satisfaction: for 24 months from their collection, unless it is necessary under, or permitted by, applicable laws to keep them longer.

- for the purpose of analyzing/predicting aspects concerning your personal preferences, interests and behavior in order to offer products/services tailored to you and to provide personalized advertising: for 12 months from their collection, unless it is necessary under, or permitted by, applicable laws to keep them longer.

- For financial and tax-wise purposes we keep you data for 10 years, commencing from their collection date.

The data will be deleted or rendered anonymous at the end of the above-listed periods.


Data dissemination, sharing and communication

Personal data will be disseminated only to the extent necessary for Villa Dubrovnik to fulfil the obligations provided by law or regulations and/or to fulfil its obligations arising from the contractual relationship with you.


Your data may be processed by our employees authorized to the data processing for the purposes set out above. Villa Dubrovnik may appoint external data processors to manage customer relationship databases; to send newsletters; to provide call center, credit recovery, logistics and telematics payment services; and to carry out profiling and surveys, including on customer satisfaction.


Your data may be shared with professionals, law firms, and notaries (notaries are professionals) (including in countries outside the EU), for auditing and due diligence activities. The above entities/individuals will act as autonomous data controllers or data processors.


Dogus Otel may additionally share your personal data among members of the Dogus Tourism Group and Dogus Otel’s service providers.


The list of the above entities/individuals is kept up-to-date, and you can access it at our office on request.


Transfer of data outside the EU

Your data may be transferred, in line with the purposes described in this Privacy notice, to one or more databases controlled by Dogus Otel located in Turkey and other third countries outside the EU/EEA.


In accordance with the GDPR, we use appropriate safeguards for such transfers – the EU standard contractual clauses. To obtain a copy of theses clauses or additional information on our third-country data transfers, you may send your request to


Right to access, correct, and supplement data and object to processing and to submit complaints

You have the right to obtain confirmation of the existence or non-existence of personal data relating to you.


You also have the right to be informed of the following:

- the origin of the personal data

- the purpose and methods of data processing

- the logic applied to the data processed electronically

- the identity of the data controller and the data processors

- the identity of the individuals or categories of individuals to whom your personal data may be sent to or who may acquire your data as appointed representatives of our company in your country of residence or as individuals authorized to process your data


You equally have the right to:

(a) have your data updated, corrected, and supplemented

(b) have the processing of your persona data restricted any unlawfully processed data erased, made anonymous or blocked

(c) require a declaration attesting that the people/companies we communicate or disseminate your data to have been notified and given full details of any of the operations under points (a) and (b) above having been carried out, unless this proves impossible or implies an effort that is clearly disproportionate to the right to be protected

(d) obtain, in a structured format commonly used and readable by electronic devices, the personal data provided you give us and to have the data transmitted, directly or through (Company Name), to another data controller (known as data portability)


You also have the right to object, in whole or in part, to:

- the processing, on legitimate grounds, of your personal data, including data relevant for the purpose they were collected

- the processing of your personal data to carry out profiling, to send you advertising material and direct sales messages and to conduct market or commercial communication surveys


To exercise your above rights, please email our Data Protection Officer at:


If you believe that we or a person/company we have communicated your data to has violated your rights, you may file a complaint with the Croatian Data Protection Agency, Martićeva 14, 10 000 Zagreb,


Contact details of the Data Controller and Data Protection Officer

Villa Dubrovnik acts as the Data Controller of your personal data, whose registered office is at Vlaha Bukovca 6, 20000 Dubrovnik. Please email to contact us in this respect.


Villa Dubrovnik’s data protection officer can be contacted at


If you need more information on how to exercise your above rights, please contact the Data Protection Officer at