Privacy Statement

Last updated: 01/09/2023

Welcome to the VacaySharing platform, developed with the vision of connecting people through shared vacation home ownership that enhances both personal and leisure experiences. Our focus is on innovation, networking, and enhancing your vacation experience.

At VacaySharing, we recognize the importance of data privacy in gaining and retaining your trust, so we take it VERY SERIOUSLY. During any collection and processing of your personal data, we adhere to the following privacy protection principles:

• We respect your privacy and ensure you have control over your personal information 
• We collect only necessary information
• We use your personal data exclusively for the stated purposes
• We never sell, share or distribute your personal data, without your prior consent
• We continuously work on maintaining and finding ways to improve security and privacy protection

It is important to carefully read this Privacy Statement, as well as our Terms of Service, before you register on our Platform and share any personal data with us.

Introduction

In this Privacy Statement, we would like to inform you about which Personal Data (as defined below) we collect, for which purposes we use them, how we process them, whether, and if so, to which third parties this data is passed on, how long we store the data, what rights you have and how to exercise them. 

We process your Personal Data in accordance with applicable data protection laws, in particular the EU’s General Data Protection Regulation (“GDPR”), the Croatian national privacy protection laws and, when applicable, other privacy laws that may have an extraterritorial scope, depending on your place of residency. We monitor changes in the Privacy law landscape and shall definitively align with any changes new Privacy regulations bring.

Table of Content:

1. Personal Information
2. Data Controller
3. Personal Data, purposes and legal bases
4. Cookies
5. Disclosure and transfer of Personal Data
6. Retention period
7. Data protection and Information Security
8. Data subjects’ rights
9. Marketing communication
10. Miscellaneous

Personal Information 

“Personal Data” or “Personal Information” means any information relating to an identified or identifiable natural person (the “data subject”), including but not limited to its name, contact details, name, contact details, identification numbers, preferences, economic and social data.

Depending on whether you just visit our Platform or register to become a member, we collect different types of information. However, we always obtain your permission and it is always your choice to share this Personal Information with us. We generally collect only the minimum amount of Personal Information necessary to facilitate our matchmaking and co-living services (see more under Section 3 below).

Our Platform is not intended for persons younger than 18 years. If you are younger than 18 years old , please do not share any of your Personal Information with us! 

Data Controller

The Data Controller responsible for any processing of your Personal Information is:

Era Estetica d.o.o., 

Županići 4d

HR-10000 Zagreb

CROATIA

For any issue concerning or related with the processing of your Personal Data by VacaySharing, please contact us here: [email protected].

Personal Data, purposes and legal bases

When you register on the VacaySharing platform, we initially ask for your first and last name, email, and password. This basic information is necessary for creating your individual VacaySharing account. We process this information under the legal basis of contract performance (Article 6, par. 1b GDPR).

After registration, you have the option to enter additional details such as your location and vacation home preferences. This optional information helps us prioritize which types of vacation homes and locations to offer. We process this additional data under our legitimate interest to enhance the services offered to our members (Article 6, par. 1f GDPR).

Should you decide to apply for shared ownership of a vacation home, the process involves scheduling a call with our admin team. Once the details are agreed upon and enough participants are gathered, you can proceed to payment for securing your share. This part of the process is facilitated based on your consent.

Disclosure and transfer of Personal Data

We may share some of your Personal Data with third parties, such as:

• Legal advisors and facilitators for the formation of the co-ownership entity;
• Property management companies for your vacation home stay;
• Web hosting service providers to manage our platform;
• Financial advisors for contractual processes;
• Online payment processing providers to handle share purchases;
• Marketing service providers for customer engagement and service improvements;

In all these cases, whether these third party recipients act either as processors on our behalf, or as joint controllers, or as independent controllers, we ensure, to the maximum extent possible and within the limits of our responsibility as Data Controller, that they will treat as confidential your Personal Data that we disclose to them, they will take appropriate security measures, they will not further disclose this data and will generally comply with the legal data privacy framework. Under no circumstances do we assume responsibility for any unlawful use or processing of your Personal Data by the above recipients, which exceeds our limits of liability, as determined by applicable laws.

We do not transfer your Personal Information outside the European Economic Area (EEA). Should there ever be a need for such a transfer, you will be asked for your explicit consent in compliance with relevant legal provisions (Article 49 par. 1a GDPR).

Retention Period

We will retain your Personal Data for the minimum time necessary to fulfill the specific purposes for which we collected it. Typically, this means we will keep your information until you deactivate or delete your account on the VacaySharing app. However, certain types of Personal Data may be kept for an extended period if mandated by legal obligations or if there is a legitimate reason for doing so. For instance, invoices and other accounting-related data are stored for a period defined by applicable laws, usually for 12 years or more.

Data protection and Information Security

We consider the confidentiality, integrity and security of your Personal Information as crucial in order to build trustful relationships with our users . Therefore, principles and measures of data privacy by default and by design are built in the very core of our business. We are continuously taking into account the latest technological advances, assessing risks and adopting improvements to our Information Security systems in order to keep your information and Personal Data secure. We are complying with professional Information Security standards and we are continuously improving our technical and organizational measures to provide adequate levels of data protection. 

Data subjects’ rights

As data subjects, you have the following rights with respect to your Personal Information:

• the right of access;
• the right of rectification;
• the right of erasure (‘right to be forgotten’);
• the right to restriction of data processing;
• the right to data portability;
• the right to object;
• the right not to be subject to a decision based solely on automated processing, including profiling and
• the right to withdraw your consent, where the legal basis of processing is consent.

Please note that, depending on the purpose and the legal basis of the processing, some of the rights may not be exercisable in full. For example, we may not be able to fulfill a deletion request if there is a legal obligation for the retention of your Personal Data.

You can exercise your rights by contacting us at the following e-mail address: [email protected]. We will use our best efforts to respond promptly to any request regarding your Personal Data. If, due to the complexity of the request, more than one (1) month is needed in order to properly respond, we will promptly notify you about the delay and the reasons for the delay. Under no circumstances it will take more than two (2) months to respond to your request.

If you are not satisfied with our response or if you think that our processing of your Personal Information violates the applicable privacy laws, you can lodge a complaint with the competent supervisory authority. The contact information of the Croatian supervisory body is:

AGENCIJA ZA ZAŠTITU OSOBNIH PODATAKA (AZOP)

Selska cesta 136

HR – 10000 Zagreb

Telefon: +385 1 4609 000

e-mail: [email protected]

web: www.azop.hr

Marketing communication

We provide you with the opportunity, if you wish, to receive advertising and/or informational messages to your registered email address regarding our services, offers, new features and changes to our Platform (newsletters). Before sending any such communication, we will ask for your explicit consent. If you no longer wish to receive such messages, we may do so by pressing the unsubscribe button at the end of each newsletter or by contacting us at the following email address:[email protected].

Miscellaneous

We regularly improve our data protection, so we may update our Privacy Statement from time to time. You can review the most current version of the Privacy Statement at any time on this page. Registered users of our Platform shall be notified accordingly of any changes.

If any provision of this Privacy Statement is declared, totally or partially, null or ineffective, such nullity or ineffectiveness shall only affect such provision or the part thereof that is null or ineffective, while the Privacy Statement shall remain in force in all other respects and such provision shall be deemed totally or partially not included.

For any other subject matter that is not captured herein, the relevant provisions of our Terms of Service shall apply.

Cookie Policy

Under the section of Cookie Policy, we want to draw your attention to our detailed guidelines regarding the use of cookies on our website. Due to the intricacy and importance of this topic, we have dedicated an entire page to outline our practices and procedures regarding cookies.

We highly encourage you to visit and carefully review our Cookie Policy page to ensure you fully understand our practices and your rights in relation to cookies. Please be advised that continued use of our website constitutes your agreement to our Cookie Policy.

We appreciate your understanding and cooperation.