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Privacy Policy

With the following Privacy Policy, we would like to give you as a "data subject" an overview of the processing of your Personal Data by us and your rights under Croatia`s Act on Implementation of the General Data Protection Regulation (“AIGDPR”) and the General Data Protection Act (“GDPR”).

 

In principle, it is possible to use our website without entering Personal Data. However, if you want to use our services, processing of Personal Data could become necessary. If the processing of Personal Data is necessary and there is no legal basis for such processing, we will generally obtain your consent.

 

What is Personal Data?

Personal Data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

Person responsible and Data Controller

The person responsible for the processing of Personal Data is:

 

Travel & Learn

Matije Gupca 51,

43000 Bjelovar

Croatia

 

If you have any questions, you can reach us at info@travel-and-learn.com or by using our contact form.

 

Legal basis for processing

Our legal basis for collecting and using your Personal Data as described in this Privacy Policy depends on the Personal Data involved and the specific context in which we collect it. Generally, your Personal Data will be collected and processed by us on one or more of the following legal bases:

 

  • Your consent,

  • Compliance with contractual obligations,

  • Compliance with legal obligations, and

  • On the basis of our legitimate interests.

 

If you have any questions or need more information about the legal basis for the collection of your Personal Data, please contact us.

 

General Principles

  1. Security

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognise an encrypted connection by the fact that the address line of the browser contains a "https://" instead of a "http://" and by the lock symbol in your browser. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

 

We have also implemented numerous technical and organizational measures to ensure the most complete protection of Personal Data processed through this website. Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed.

 

Further, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered.

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     1. Retention and Storage

We will retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with Croatia`s Statutory Retention Periods and other applicable laws for up to 6 years.

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      2. Minors

Persons under the age of 16 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

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     3. Automated decision-making

Automated decision-making including profiling does not take place.

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     4. Do Not Sell

We do not sell your Personal Data.

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     5. Special Category Data

Unless specifically required and consent is obtained, for a particular service, we do not process Special Category Data.

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     6. Social Media

We are present on social media on the basis of our legitimate interest. If you contact us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis for the use of the relevant social media platform is our legitimate interest, your consent or, in the case of a (pre) contractual relationship with us, the initiation of a contractual service, if any.

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     7. International Transfer

In the course of our website operation, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside Croatia and the EEA. Where we transfer data outside Croatia and the EEA, we ensure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.

 

     8. Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions.

 

We are however entitled to outsource the processing of your Personal Data in whole or in part to external service providers acting as processors within the framework of the above-mentioned legal provisions. The service providers commissioned by us will process your data exclusively in accordance with our instructions and the above-mentioned legal provisions. Doing so we always make sure that service providers commissioned by us are carefully selected, follow strict contractual regulations, technical and organizational measures, and additional controls by us.

 

We may also disclose Personal Data to third parties if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfill our legitimate interests.

 

Processing of Personal Data by us

     9. Log files

Each time a user accesses our website and each time a file is retrieved, data about this process is temporarily processed in a log file. In detail, the following data is stored for each access/retrieval: a) Date and time of the retrieval (time stamp), as well as the IP address of the accessing device or server, b) request details and destination address (protocol version, HTTP method, referrer, User Agent string), c) name of the retrieved file and transferred data volume (requested URL incl. query string, size in bytes) and d) Message as to whether the retrieval was successful (HTTP status code).

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On the basis of our legitimate interest in a secure website, we store this data to protect against attacks for up to 7 days beyond the time of your visit. This data is analyzed and required for legal and criminal prosecution in the event of attacks on communications technology. The data is deleted as soon as it is no longer required for the performance of tasks.

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     10.  Cookies

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information on cookies, please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

 

     11. Hosting

To provide our website, we use the services of Wix.com Ltd who processes all data to be processed in connection with the operation of this website on our behalf. The legal basis is our legitimate interest.

 

     12. Contacting us

Personal Data is processed depending on the contact method. In addition to your name and e-mail address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is processed for the purpose of dealing with your request and the legal basis is your consent. The use of your IP address takes place exclusively in the context of law enforcement and security measures in compliance with our legal requirements.

 

For the Chat, we use Ascend by Wix. We have no influence on the processing of data by Wix and no possibility to influence it.

 

      13. Registration, Contact and Intake Forms

To provide our Forms, we are using Workforms by monday.com. All entries made by you will be processed on monday.com`s servers. monday.com stores a cookie in your browser that contains a unique ID. This cookie stores various information such as your language settings. monday.com is used on the basis of our legitimate interest in planning, organizing and scheduling our services, taking into account your data and your consent. The processing is carried out exclusively on the basis of your consent which can be revoked at any time. The data you enter in the form will remain with us until you request us to delete it or revoke your consent to store it or the purpose for storing the data no longer applies. Mandatory legal provisions - in particular retention periods - remain unaffected.

 

     14. When using our services

We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling, nor will it be shared with third parties. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.

 

The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.

 

Some of the data you choose to provide may be considered non-Personal Data and/or “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data.

 

Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

 

Unless otherwise specified the purposes of processing are contractual performance and service, contact requests and communication, office and organizational procedures, administration, and response to requests, visit action evaluation. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your Consent.

 

You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your request to us in writing to info@travel-and-learn.com.

 

f) Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

 

Third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("content").

 

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

 

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:

 

 

Your Rights and Privileges

   15. Privacy rights

Under the AIGDPR and GDPR, you can exercise the following rights:

  • Right to information

  • Right to rectification

  • Right to object to processing

  • Right to deletion

  • Right to data portability

  • Right of objection

  • Right to withdraw consent

  • Right to complain to a supervisory authority

  • Right not to be subject to a decision based solely on automated processing.

 

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to request the erasure or rectification of Personal Data we hold about you, or to exercise any of your other rights as a data subject, please contact us.

 

     16. Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

 

     17. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

 

      18. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

 

    19. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The competent data protection authority in Croatia is: Agencija za zaštitu osobnih podataka (Personal Data Protection Agency), Selska cesta 136 HR - 10 000 Zagreb www.azop.hr

 

Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise the Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. This Privacy Policy was last updated on Monday, 30 January 2023.

 

If you would like to contact us regarding our privacy practices for any reason, please use the details provided above.

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