Privacy Policy
1. Who we are
This website is operated by Villa Sinodium, a private holiday villa located at Perina Glavica 4, Umljanović, Croatia. For any questions about this privacy policy or your personal data, contact us at mario.lela1@gmail.com.
2. What data we collect and why
This website is a static informational page. We do not collect personal data directly through forms or account registration. However, when you accept marketing cookies, third-party tracking tools may collect the following:
- Page views — which pages you visit and how long you spend on them.
- Contact interactions — whether you clicked an email or phone link in our Contact section.
- Technical data — browser type, device type, approximate location (country/city level), and referral source.
This data is collected solely to measure the effectiveness of our advertising and to understand how visitors find and use our site. We do not use it to build personal profiles or sell it to any third party.
3. Cookies and tracking technologies
We use a cookie consent banner. On your first visit, no marketing cookies are loaded. You can choose to:
- Accept — marketing scripts (Meta Pixel and optionally Google Analytics 4) will load and track your session as described above. Your choice is stored in your browser.
- Reject — no marketing scripts load. The site functions fully without them.
You can change your preference at any time by clearing your browser's local storage for this site.
4. Meta Pixel (Facebook)
If you accept cookies, we load the Meta Pixel — a piece of JavaScript provided by Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). The Pixel sends anonymised event data (page views and contact link clicks) to Meta's servers to help us measure the performance of any advertising we run on Facebook or Instagram.
Meta may combine this data with information it already holds about you if you have a Facebook account. Meta's use of this data is governed by their own privacy policy: facebook.com/privacy/policy.
The legal basis for this processing is your consent (GDPR Art. 6(1)(a)), given via the cookie banner.
5. Google Analytics 4 (optional)
We may also load Google Analytics 4 (provided by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland) behind the same consent gate. If active, it collects the same categories of data as described above and is governed by Google's privacy policy. IP anonymisation is enabled. The legal basis is your consent (GDPR Art. 6(1)(a)).
6. Data retention and transfers
We do not store your personal data on our own servers. Data collected via Meta Pixel is retained by Meta according to their data retention policies. Meta and Google may transfer data outside the European Economic Area; both companies rely on Standard Contractual Clauses approved by the European Commission for such transfers.
7. Your rights under GDPR
If you are in the European Economic Area or UK, you have the following rights regarding your personal data:
- Right of access (Art. 15) — you can request a copy of the data held about you.
- Right to rectification (Art. 16) — you can ask us to correct inaccurate data.
- Right to erasure (Art. 17) — you can ask us to delete your data ("right to be forgotten").
- Right to restriction (Art. 18) — you can ask us to limit how we process your data.
- Right to data portability (Art. 20) — you can request your data in a portable format.
- Right to object (Art. 21) — you can object to processing based on legitimate interests or for direct marketing purposes.
- Right to withdraw consent — where processing is based on consent, you can withdraw it at any time without affecting prior processing.
To exercise any of these rights, contact us at mario.lela1@gmail.com. We will respond within 30 days. You also have the right to lodge a complaint with your national data protection authority — in Croatia this is the Agency for Personal Data Protection (AZOP).
8. Third-party links
Our site includes links to Google Maps and external destination websites. Once you follow a link to another site, this privacy policy no longer applies. We encourage you to read the privacy policy of any site you visit.
9. Changes to this policy
We may update this policy as our use of tracking tools changes. The "Last updated" date at the top of this page will always reflect the most recent version. Continued use of the site after an update constitutes acceptance of the revised policy.
10. Contact
For any privacy-related questions or requests, email us at mario.lela1@gmail.com.