PRIVACY POLICY AND COOKIE POLICY

Website: https://istriapartner.com
Last updated: 5 November 2026

1. Data Controller

The data controller responsible for the processing of personal data collected through istriapartner.com is:

Napoletano d.o.o.
Giuseppe Garibaldi 13
52470 Umag, Croatia
Company ID (OIB): 37410142819
E-mail: info@istriapartner.com
Website: https://istriapartner.com

Hereinafter referred to as Istria Partner or the Data Controller.

Napoletano d.o.o. respects the privacy of its users, guests, property owners, buyers, sellers and other business partners. Personal data is processed in accordance with the General Data Protection Regulation (GDPR), the Croatian Act on the Implementation of the General Data Protection Regulation and other applicable laws of the Republic of Croatia and the European Union.

This document sets out the Privacy Policy and Cookie Policy applicable to istriapartner.com.

2. What Personal Data Do We Collect?

Depending on the services you use, we may collect the following categories of personal data:

• First and last name.

• Residential or business address.

• E-mail address.

• Telephone number.

• Information required for tourist accommodation reservations.

• Arrival and departure dates and number of guests.

• Information necessary for communication with guests and property owners.

• Information about properties offered for rent, sale or purchase.

• Information required to prepare offers and conclude contracts.

• Information relating to business cooperation, contracts and services provided.

• Information submitted through contact forms and e-mail correspondence.

• Technical data such as IP address, browser type, device information and website usage data.

In connection with reservations and the provision of tourist services, we may also process additional information required to comply with legal obligations, including guest information where required under applicable tourism and hospitality regulations.

We do not collect information that is not necessary for the relevant purpose.

3. Why Do We Use Your Personal Data?

We process personal data depending on the type of service you use.

Tourism Services and Accommodation Reservations

We use personal data to:

• Receive and process accommodation enquiries.

• Prepare offers and provide information about accommodation availability.

• Communicate with guests before, during and after their stay.

• Organise reservations and confirm accommodation terms.

• Coordinate guest arrivals and departures.

• Provide necessary information to property owners or accommodation providers.

• Comply with legal obligations relating to tourism activities.

Legal basis: taking steps prior to entering into a contract, performance of a contract, legal obligations or legitimate interests, depending on the specific processing activity.

Property Management and Maintenance

We use personal data to:

• Communicate with property owners.

• Prepare offers and conclude property management agreements.

• Organise maintenance, cleaning and other services.

• Keep records of agreed and completed services.

• Handle financial and business communication with property owners.

Legal basis: performance of a contract, taking steps prior to entering into a contract and legitimate interests.

Real Estate Brokerage and Property Sales

We use personal data to:

• Receive enquiries from buyers and sellers.

• Provide information about available properties.

• Arrange property viewings.

• Connect interested buyers and sellers.

• Prepare offers and relevant documentation.

• Fulfil contractual and legal obligations relating to real estate brokerage.

Legal basis: taking steps prior to entering into a contract, performance of a contract, legal obligations or legitimate interests.

Communication and Contact Forms

Information submitted through contact forms, e-mail or telephone is used to respond to enquiries, prepare offers and continue business communication.

Legal basis: taking steps prior to entering into a contract, performance of a contract or legitimate interests.

Marketing and Newsletters

If you subscribe to our newsletter or provide the required consent, we may use your e-mail address to send news, offers and information about our tourism services and real estate properties.

You may withdraw your consent at any time by using the unsubscribe link or contacting us at our e-mail address.

Legal basis: consent or another appropriate legal basis permitted under applicable law.

Legal and Accounting Obligations

We process personal data to issue invoices, maintain business records, fulfil tax obligations and comply with other statutory requirements.

Legal basis: legal obligation.

4. Who Do We Share Your Personal Data With?

We do not sell your personal data to third parties or use it for unauthorised marketing purposes.

We may share personal data with trusted business partners where necessary to provide our services, including:

• Owners of tourist accommodation and accommodation providers.

• Service providers involved in organising guests' stays, where necessary.

• Reservation platforms and accommodation management system providers.

• Website hosting, maintenance and technical support providers.

• E-mail and newsletter service providers.

• Accounting and bookkeeping service providers.

• Banks and payment service providers, where necessary.

• Lawyers, notaries and other professional advisers, where necessary for contractual performance or the protection of legal interests.

• Competent public authorities where required by law.

For tourist accommodation reservations, we may share data with external booking platforms and other service providers involved in the reservation process.

Any sharing of personal data is limited to what is necessary for the relevant purpose.

5. Transfers of Personal Data to Other Countries

Personal data is generally processed within the European Economic Area.

If we use platforms or service providers that process personal data outside the European Economic Area, transfers are carried out in accordance with the GDPR and subject to appropriate safeguards.

When using external booking platforms, their own privacy policies may also apply.

6. How Long Do We Retain Personal Data?

We retain personal data only for as long as necessary to fulfil the purpose of processing or for as long as required by law.

Indicative retention periods:

• Tourist reservation information: throughout the reservation and thereafter for the periods necessary to fulfil legal obligations and address potential legal claims.

• Guest information: for the periods prescribed by applicable tourism and other regulations.

• Property owner and business partner information: throughout the business relationship and thereafter for the periods necessary to fulfil legal and contractual obligations.

• Buyer and seller information: throughout the brokerage relationship and thereafter in accordance with applicable legal retention periods.

• Contact and enquiry information: for as long as necessary to process the enquiry and maintain communication.

• Newsletter information: until consent is withdrawn or the user unsubscribes.

• Accounting and tax information: for the periods prescribed by law.

• Technical data and cookies: according to the retention periods of individual cookies and the policies of the services used.

Once the applicable retention period expires, personal data is deleted, anonymised or securely disposed of, unless another lawful basis requires its retention.

7. Your Rights Regarding Personal Data

Under the GDPR, you have the right to:

• Request access to your personal data.

• Request the correction of inaccurate or incomplete data.

• Request the erasure of personal data where the legal requirements are met.

• Request the restriction of processing.

• Request the transfer of your data to another data controller where the legal requirements are met.

• Object to processing based on legitimate interests.

• Withdraw your consent at any time.

• Not be subject to a decision based solely on automated processing, including profiling, where the conditions set out in the GDPR are met.

To exercise your rights, please contact us at info@partner-realestate.com.

You also have the right to lodge a complaint with the supervisory authority:

Croatian Personal Data Protection Agency (AZOP)
Selska cesta 136
10000 Zagreb, Croatia
E-mail: azop@azop.hr
Website: https://azop.hr

8. Personal Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, destruction or disclosure.

Access to personal data is restricted to individuals who need such access to perform their business duties.

9. What Are Cookies?

Cookies are small text files stored on your computer, tablet or mobile device when you visit a website.

They are used to ensure that the website functions correctly, remember your selected preferences and, with your consent, analyse website traffic and support marketing activities.

Cookies may process information such as your IP address, browser identifier, pages visited and information about how you use the website.

10. Types of Cookies

The following categories of cookies may be used on our website:

Strictly Necessary Cookies

These cookies are required for the basic operation of the website, security, navigation, submission of contact forms and other essential functions.

They do not require consent where they are technically necessary to provide a service explicitly requested by the user.

Functional Cookies

These cookies allow the website to remember your preferences and improve your browsing experience.

Where they are not necessary for the basic operation of the website, they are activated only with your consent.

Analytical Cookies

These cookies may be used to monitor website traffic, analyse how visitors use the website and improve the quality of our services.

They are activated only after you have given your consent.

Marketing Cookies

These cookies may be used to measure advertising effectiveness, display relevant advertisements and understand visitors' interests.

They are activated only after you have given your consent.

The specific cookies, their providers and retention periods are displayed in the cookie settings, depending on the tools actually installed and used.

11. Managing Cookies and Consent

When you first visit our website, a cookie notice is displayed, allowing you to:

• Accept all cookies.

• Reject all non-essential cookies.

• Select individual cookie categories.

Strictly necessary cookies may remain active without consent. All other categories remain disabled until you provide the appropriate consent.

You may change or withdraw your decision at any time through the cookie settings available on the website.

Continuing to browse the website does not constitute consent to the use of non-essential cookies.

12. External Links and Booking Platforms

Our website may contain links to external booking platforms, property advertising portals and other websites.

When you access an external website, that website's own privacy and cookie policies apply to your subsequent use of its services.

Napoletano d.o.o. is not responsible for personal data processing independently carried out by external service providers, except to the extent that liability applies under applicable law.

13. Changes to the Privacy Policy and Cookie Policy

We reserve the right to amend this document to reflect changes in legislation, business operations or website functionality.

All changes will be published on this page together with the date of the latest update.

14. Contact

For any questions regarding personal data protection, the use of cookies or the exercise of your rights, please contact us:

Napoletano d.o.o. - Istria Partner
Giuseppe Garibaldi 13, 52470 Umag, Croatia
E-mail: info@istriapartner.com
Website: https://istriapartner.com