Draft template — to be reviewed and completed by the owner and a qualified lawyer before launch.

Who we are

This privacy policy applies to the website www.adriondmc.com, operated by Adrion custom travel agency d.o.o., Radnička cesta 80, 10000 Zagreb, Croatia (OIB: 85095965318). We are the data controller for any personal data you choose to submit to us. For privacy-related questions, contact us at info@adriondmc.com.

How our enquiry form works

The enquiry form on this website submits directly to our systems. When you send it, your name, email address and the details of your enquiry are transmitted to our database (Google Cloud Firestore) and delivered to our team’s inbox by our email provider (Resend). We use what you send us only to reply to your enquiry and, where you go on to book, to arrange your journey. [[Confirm that Data Processing Agreements are in place with Google Cloud and Resend, and that both are reflected in the International transfers section below.]]

What data we receive and why

When you choose to contact us, you may share your name, email address, message content, and travel preferences. We use this information solely to respond to your enquiry and, where you proceed to book, to organise your journey. We do not use it for any other purpose without your explicit agreement.

Lawful basis for processing

Processing is based on our legitimate interest in responding to an enquiry that you have initiated (Article 6(1)(f) GDPR). Where processing is required to take steps at your request prior to entering a contract, the basis is Article 6(1)(b) GDPR. [[Confirm with your lawyer which basis applies at each stage of the booking process.]]

Data retention

We retain your personal data for as long as necessary to manage your enquiry or journey, and for [[RETENTION PERIOD — e.g. 5 years]] thereafter for legal and accounting obligations. After that period, data is securely deleted or anonymised. [[Confirm retention period with your lawyer, having regard to Croatian accounting law and applicable travel regulations.]]

Hosting and infrastructure

The www.adriondmc.com website is hosted on and delivered via Cloudflare, Inc., which may process connection metadata (such as IP addresses and request logs) as part of its content delivery and security service. [[Confirm that a Data Processing Agreement (DPA) is in place with Cloudflare — see Cloudflare’s standard DPA at cloudflare.com/trust-hub.]]

Cookies and tracking

This website does not use advertising trackers or remarketing pixels. It uses one analytics provider (PostHog, EU-hosted) to understand how the site is used. If you accept analytics cookies, PostHog records your visits across sessions using a cookie. If you decline, PostHog still counts the visit, but cookielessly and anonymously — nothing is stored on your device and no profile is built. You can change your choice at any time.

The site also loads a small number of third-party services needed to provide its features: an embedded map (Mapbox), web fonts (Google Fonts), a yacht-charter availability search embedded from Booking Manager (booking-manager.com, MMK Systems d.o.o.) on the Charters page, and an accommodation availability search embedded from Adriagate on the Luxury Accommodation page. These providers may receive your IP address and technical request data in order to serve their content. [[Confirm with counsel whether the anonymous, cookieless analytics described above may lawfully run without consent, and document each provider’s role and data location.]]

Data sharing

We do not sell, rent, or share your personal data with third parties for marketing purposes. Where necessary to arrange your journey, we may share relevant details (e.g. your name and itinerary) with guides, accommodation providers, transport operators, or activity partners. These partners receive only the information required to deliver the service you have booked. [[Identify and list key processors/partners as required.]]

International transfers

[[Confirm whether any personal data is transferred outside the EEA (e.g. via any US-hosted services) and, if so, state the safeguard in place — Standard Contractual Clauses, adequacy decision, or other.]]

Your rights

Under the GDPR, you have the right to access the personal data we hold about you, to request correction of inaccurate data, to request erasure of your data (subject to legal obligations), to object to processing, and to request restriction of processing. To exercise any of these rights, write to us at info@adriondmc.com. We will respond within 30 days. You also have the right to lodge a complaint with the Croatian data protection supervisory authority, the Agencija za zaštitu osobnih podataka (AZOP), at azop.hr.

Changes to this policy

We may update this policy when the website’s functionality changes — for example, if a form backend or analytics is added. Material changes will be reflected in the updated date at the top of this page. We encourage you to review this page periodically.

Last updated: [[DATE]]