Last updated: March 2026.
1. Data Controller
The data controller for your personal data is My Holiday Circle, located at Ulica Ruža 12, 10000 Zagreb, Croatia. Contact details:
- Email: hello@myholidaycircle.com
- Phone: +385 91 234 5678
This Privacy Policy has been prepared in accordance with the General Data Protection Regulation (GDPR — Regulation EU 2016/679) and the Croatian Data Protection Implementation Act (OG 42/18).
2. What Data We Collect
We collect the following categories of personal data:
a) Data you provide to us
- Contact details: first and last name, email address, phone number (optional) — when you submit an inquiry or message through our contact form
- Order data: first and last name, email address, phone number, delivery address, notes — when you place an order or product inquiry
- Newsletter: email address — when you subscribe to our newsletter
b) Data we collect automatically
- Usage data: IP address, browser type and version, operating system, pages visited, access time, referring URL
- Cookies: small text files stored on your device by your browser (see Section 7 for details)
3. Purposes and Legal Basis for Processing
We process your personal data for the following purposes:
| Processing Purpose | Legal Basis | Data Categories |
|---|
| Responding to your inquiries and messages | Performance of a contract / Legitimate interest | Name, email, phone, message content |
| Processing and delivering orders | Performance of a contract | Name, email, phone, address, order data |
| Sending order and payment confirmations by email | Performance of a contract | Name, email, order and payment details |
| Sending newsletters | Consent | Email |
| Improving and analyzing Site usage | Legitimate interest | Usage data, cookies |
4. Data Sharing with Third Parties
We do not sell, rent, or share your personal data with third parties for marketing purposes. We only share your data with:
- Croatian Postal Service / courier services: first name, last name, and delivery address — solely for the purpose of delivering your order
- Resend (email delivery service): your email address and name — solely for sending order confirmations and inquiry responses
- Legal requirements: when required by applicable laws of the Republic of Croatia and the European Union
5. International Data Transfers
Our email delivery service (Resend) operates outside the European Union. Data transfers are conducted in compliance with the GDPR, using Standard Contractual Clauses that provide an adequate level of data protection.
6. How Long We Keep Your Data
- Order data: 5 years after order completion (in accordance with tax and accounting regulations)
- Inquiries and messages: 2 years after last contact
- Newsletter: until you withdraw consent (you can unsubscribe at any time via the link in our emails)
- Usage data: 13 months
7. Cookies
We use the following types of cookies:
- Essential cookies: necessary for the basic functioning of the Site (e.g., language preferences, cart contents). These cannot be disabled.
- Analytical cookies: help us understand how you use the Site (anonymous data). These can be disabled in your browser settings.
You can manage cookies through your browser settings. Disabling cookies may affect the functionality of the Site.
8. Your Rights
In accordance with the GDPR, you have the following rights:
- Right of access: you can request a copy of the personal data we hold about you
- Right to rectification: you can request correction of inaccurate or incomplete data
- Right to erasure: you can request deletion of your data (“right to be forgotten”)
- Right to restriction of processing: you can request that we limit processing in certain circumstances
- Right to data portability: you can request transfer of your data to another controller
- Right to object: you can object to processing based on legitimate interest
- Right to withdraw consent: for processing based on consent (e.g., newsletter), you may withdraw consent at any time
To exercise these rights, contact us at hello@myholidaycircle.com. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (AZOP) at azop.hr.
9. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration, including:
- HTTPS encryption for all communications between your browser and our Site
- Restricted access to personal data within our organization
- Regular security system updates
10. Children’s Rights
Our Site and services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you become aware that a child has submitted data to us, please contact us and we will promptly delete it.
11. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy. Significant changes will be posted on the Site. We recommend reviewing this page periodically. The date of the last update is indicated at the top.
12. Contact
For any questions regarding the processing of your personal data, please contact us:
- Email: hello@myholidaycircle.com
- Phone: +385 91 234 5678
- Address: Ulica Ruža 12, 10000 Zagreb, Croatia