Effective Date: January 1, 2026
In accordance with the EU General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), the Croatian Act on the Implementation of the General Data Protection Regulation (Zakon o provedbi Opće uredbe o zaštiti podataka, NN 42/18), the Croatian Electronic Communications Act (Zakon o elektroničkim komunikacijama), and other applicable local laws, this Article forms an integral part of the Terms and Conditions of Dubrovnik Transfer Service d.o.o. This Privacy Policy details how we collect, use, process, store, and safeguard personal data acquired through our website (www.dubrovniktransfer.eu), email communication, telephone calls, and direct booking channels for transportation services, private transfers, luxurious excursions, and day tours.
The entity responsible for processing your personal data (the Data Controller) is:
Company Name: Dubrovnik Transfer Service d.o.o.
Registered Address: Masarykov put 3D, 20000 Dubrovnik, Croatia
Official Email: info@dubrovniktransfer.eu
Contact Telephone: +385 99 4455 484
We only collect personal data that is strictly necessary to arrange, perform, and invoice your premium transport and tour requests. This includes:
Client & Passenger Contact Information: Full name, email address, mobile telephone number, and country of residence.
Transfer & Tour Logistics: Date and time of transfer, flight numbers (crucial for tracking delays), pickup and drop-off addresses, hotel or villa accommodations, route selections, and specific tour itinerary choices.
Special Service Data: Number of passengers, age/weight indicators specifically for requested child safety seats or booster seats, and accessibility requests or mobility constraints explicitly declared by the client.
Technical Data: IP address, web browser type, operating system, and system security logs collected via our server architecture and security filters.
We process personal data based on the explicit legal grounds defined in Article 6 of the GDPR:
Performance of a Contract (Art. 6(1)(b) GDPR): Processing is necessary to take steps at your request prior to entering into a contract (e.g., providing quotes) and for the performance of the transport contract itself (e.g., executing the airport transfer or excursion). Without this data, we cannot fulfill the services.
Compliance with Legal Obligations (Art. 6(1)(c) GDPR): We are legally mandated by Croatian corporate and tax laws (e.g., the General Tax Act / Opći porezni zakon) to issue fiscalized invoices and retain ledger records containing your name, address, and transaction history.
Legitimate Interests (Art. 6(1)(f) GDPR): We process standard technical logs to maintain the security, stability, integrity, and anti-fraud validation of our web booking systems.
Your personal data is stored within secure local databases and EU-based data centers. Data retention periods are strictly guided by legal necessities:
Operational Records: General transfer inquiries, quotation emails, and travel coordination records that do not lead to an executed service are retained for a maximum of twenty-four (24) months from the last communication, or are deleted sooner upon client request.
Fiscal and Invoicing Records: Pursuant to Article 57 of the Croatian General Tax Act, all data linked to finalized bookings, accounting ledger transactions, and official fiscalized invoices must be securely archived for eleven (11) years following the end of the calendar year in which the transaction occurred.
Dubrovnik Transfer Service d.o.o. does not sell, lease, or distribute customer details to third parties for commercial or marketing gains. Data is exclusively transferred to trusted entities under strict confidential bounds:
Operational Providers: Assigned professional chauffeurs, specialized tour guides, and legally contracted partner transport providers who execute the physical transit lines or excursions.
Professional Services: Authorized accounting professionals inside the Republic of Croatia managing tax reporting, along with IT maintenance and secure hosting agencies acting as Data Processors.
Legal Authorities: Croatian Tax Authorities (Porezna uprava), law enforcement authorities, or judicial courts when legally bound by official national mandates.
Our web platform (www.dubrovniktransfer.eu) values client privacy and actively restricts excessive digital footprints:
Cookies: We do not utilize any advertising, analytical tracking, behavioral profiling, or remarketing cookies. Our site utilizes only strictly necessary functional cookies required for core platform navigation, form submissions, and structural security.
Cloudflare Turnstile (spam and bot protection): Our booking page uses Cloudflare Turnstile, a service of Cloudflare, Inc. (USA), to tell real visitors apart from automated spam and attacks. When the booking page loads, Turnstile receives technical data from your browser and device: your IP address, the browser type and version, operating system and settings, and how the page was loaded and used. It uses this data only to check that the form is being sent by a person. It is not used for advertising or to build a profile of you. The legal basis is our legitimate interest in keeping the booking forms secure and free of abuse (Art. 6(1)(f) GDPR). Cloudflare may process this data in the USA. The transfer is covered by Cloudflare's certification under the EU–U.S. Data Privacy Framework and by the EU Standard Contractual Clauses in its data processing agreement. For more information, see Cloudflare's Privacy Policy.
Under the EU GDPR, clients hold comprehensive rights regarding their personal data, which can be exercised at any time by emailing info@dubrovniktransfer.eu:
Right of Access: The right to request formal confirmation and clear copies regarding what data we hold on you.
Right to Rectification: The right to immediately correct any erroneous, incomplete, or out-of-date personal identifiers.
Right to Erasure: The right to demand erasure ('right to be forgotten'), provided the data is no longer necessary for an active contract and its deletion does not conflict with the 11-year Croatian fiscal retention laws.
Right to Restriction, Objection, and Portability: The right to restrict processing, object to specific data processing paths, and request the transfer of your structured files to another controller.
If you believe that Dubrovnik Transfer Service d.o.o. has processed your personal data in violation of the EU GDPR or Croatian data protocols, you have the absolute right to lodge a formal complaint with the competent national regulatory authority in Croatia:
Authority Name: Agencija za zaštitu osobnih podataka (AZOP)
Postal Address: Selska cesta 136, 10000 Zagreb, Croatia
Telephone: +385 (0)1 4609 000
Email: azop@azop.hr
Website: www.azop.hr