PRIVACY STATEMENT

1. General

At HOTEL CUBO, tourism and hospitality, Ltd. and CUBO group, hospitality and tourism Ltd. (hereafter referred to as “CUBO GROUP” or “controller”), we respect your privacy and strive to achieve the highest level of protection for your personal data. In providing our services, we ensure that your data is processed in accordance with applicable European legislation (General Data Protection Regulation) and in accordance with the national legislation of the Republic of Slovenia (current personal data protection law, Electronic Communications Act, and Electronic Commerce Market Act).

The purpose of this Privacy Statement (hereafter: “Statement”) is to inform you about the purposes for which your personal data will be obtained, how it will be used, and what your rights are regarding the data we hold about you, and how to exercise them.

At CUBO group, we commit to all collected personal data being used in accordance with this Statement, ensuring that we will not sell, lend, or otherwise transmit your personal data to third parties, except in legally specified cases.

2. Data Controller

Your personal data is controlled by:

HOTEL CUBO, tourism and hospitality, Ltd., address: Slovenska cesta 15, SI-1000 Ljubljana, email: vop@hotelcubo.com; telephone number: 01 425 6000.

and

CUBO golf, tourism and hospitality, Ltd., address: Slovenska cesta 15, SI-1000 Ljubljana, email: vop@cubogolf.com; telephone number: 041 903 555.

All topics and content discussed concerning personal data protection are treated with strict confidentiality.

3. Purpose of Data Processing and Types of Personal Data

Personal data is any information that identifies you as a specific or identifiable individual. An individual is identifiable when they can be directly or indirectly identified, especially by referencing an identifier such as a name, identification number, location data, online identifier, or by referencing one or more factors specific to the individual’s physical, physiological, genetic, mental, economic, cultural, or social identity.

All personal data you provide to us will be treated confidentially and will be used solely for the purposes for which it was provided. If there arises a need to further process your data for another purpose, we will contact you in advance and request your prior written consent.

Visiting the Website:With each visit to our website, the web server’s log file (e.g., IP number – the number identifying a particular computer or other device on the web, browser version, time of visit, location data, or entry point to the internet) is automatically stored on the web server. We process this data for analysis purposes, which enables us to improve the content and user experience on our website and to keep statistics of visits to our website. We collect this data using cookies, for which we will ask for your consent before installing more invasive cookies, while certain other data may be collected based on our legitimate interests.

For more about our cookie policy on our websites, you can read the cookie notice posted on our website.

CUBO group processes the collected data separately and does not link it with other personal data of website users. A user of the websites cannot be uniquely identified solely by using this data at this moment and given the state of technology.

Hotel Reservation and Check-In:When booking a hotel room, CUBO group collects the following data from you:

• name and surname, address, country,
• company, company address,
• email address, phone number,
• credit card information (type of card, card number, cardholder, expiration date),
• stay details (arrival and departure dates, number of persons, special requests, room and other service preferences).

When checking in at the hotel, in addition to the above data, we also collect the following data:

• citizenship,
• number and type of identification document.

All collected data is gathered for the purpose of booking and checking into the hotel room. The legal basis for processing this data is our contractual relationship with you. As the processing of this data is necessary for the execution of the service itself, this data can be processed already based on the fact that you are entering into a contractual relationship with us. If you do not wish to provide us with this data, we cannot guarantee our services (you cannot book a hotel room via our website, phone, or intermediaries such as Booking.com).

To ensure special services and high quality of your stay at the hotel, the controller collects additional data about you (e.g., previous reservations, type of breakfast, various additional services, and requests for room specifics, etc.). The legal basis for processing this data is the performance of the contract; certain data is collected based on our legitimate interest to improve and promote new products and to ensure the most pleasant stay in the hotel, which is a vital interest of the controller.

Provided contact details may also be processed based on our legitimate interest for basic tailored communication with you via email, attempting to present you with relevant services and activities that might interest you based on your past interactions with us. We do not use any (automatic) profiling but merely select appropriate recipient groups for individual messages. You can unsubscribe from such communications at any time for free by sending an email to: varstvopodatkov@hotelcubo.com.

Restaurant Reservation:When booking a table at the HOTEL CUBO and CUBO golf restaurants, we collect the following data you provide voluntarily:

• name and surname,
• phone number and/or email address,
• desired date and time of reservation,
• number of persons.

All collected data is gathered for the purpose of reserving a table on the desired date and time. We collect contact details to inform you whether the restaurant reservation (table) for the desired date and time is possible, or to inform you about other important information related to your reservation (e.g., presenting the offer we are preparing for the desired date, cancellation of the reservation due to unforeseen events, etc.). The legal basis for processing this data is your voluntary provision of data (consent to processing).

Hall or Room Rental:When renting a hall or rooms in the hotel, HOTEL CUBO and CUBO golf collect the following data:

• name and surname,
• company/organization,
• phone number and email address,
• desired event date,
• package,
• number of participants and additional information.

All collected data is gathered for the purpose of preparing the offer or preparing and concluding the contract for the rental of the hall (rooms) in the hotel. The legal basis for processing this data is our contractual relationship with you. As the processing of this data is necessary for the execution of the service itself, this data can be processed already based on the fact that you are entering into a contractual relationship with us. If you do not wish to provide us with this data, we cannot guarantee our services.

Book Tee Time:Through our website, you can book a “Tee Time”. For this purpose, CUBO GOLF collects the following data:

• names of players,
• phone number,
• email address.

All collected data is gathered for the purpose of booking the desired date. We collect contact details to inform you whether the reservation for the desired date is possible or to inform you about other important information related to your reservation. The legal basis for processing this data is your voluntary provision of data (consent to processing).

Course Reservation:In the reservation program, we collect:

• name and surname,
• date of birth,
• gender, nationality,
• golf club and HCP,
• phone number, email address.

All collected data is gathered for the purpose of preparing the offer for booking the golf course on the desired date and time. We collect contact details to send you the offer or to inform you about other important information related to your reservation. The legal basis for processing this data is our contractual relationship with you. As the processing of this data is necessary for the execution of the service itself, this data can be processed already based on the fact that you are entering into a contractual relationship with us. If you do not wish to provide us with this data, we cannot guarantee our services (book a golf course).

Provided contact details may also be processed based on our legitimate interest for basic tailored communication with you via email, attempting to present you with relevant services and activities that might interest you based on your past interactions with us. We do not use any (automatic) profiling but merely select appropriate recipient groups for individual messages. You can unsubscribe from such communications at any time for free by sending an email to: info@cubogolf.com.

Processing Data When Purchasing a Season Pass:When purchasing a season pass, CUBO GOLF collects the following data:

• name and surname,
• address,
• postal code and city,
• email address and phone number,
• company name, address, postal code, city, tax number (only for business season pass applications),
• golf club and HCP,
• type of season pass,
• rental of equipment locker, wardrobe locker, golf cart,
• address of the payer (name and address on the invoice).

All collected data is gathered for the purpose of obtaining a (business) season pass and keeping records of season passes. The legal basis for processing this data is our contractual relationship with you. As the processing of this data is necessary for the execution of the service itself, this data can be processed already based on the fact that you are entering into a contractual relationship with us. If you do not wish to provide us with this data, we cannot guarantee our services (acquisition of a season pass).

If you choose to also receive electronic messages from CUBO GOLF, we will send notifications about news, special offers, course conditions, etc., to your email address. Direct marketing will be conducted based on your consent. You can unsubscribe from direct advertising via electronic means by sending an email to: info@cubogolf.com.

Processing Data When Purchasing a Gift Voucher:We also enable you to purchase gift vouchers through our website, by filling out the “Inquiry” form or buying a gift voucher in person at the reception. For this purpose, CUBO GOLF collects the following data:

• name and surname,
• email address,
• name and surname of the voucher recipient,
• desired amount and service.

All collected data is gathered for the purpose of preparing the gift voucher and keeping records of gift vouchers. The legal basis for processing this data is our contractual relationship with you. As the processing of this data is necessary for the execution of the service itself, this data can be processed already based on the fact that you are entering into a contractual relationship with us. If you do not wish to provide us with this data, we cannot guarantee our services (preparation of a gift voucher).

Registration for a Tournament:When you register for an organized tournament, we collect the following data:

• name and surname,
• phone number, email address,
• golf club, HCP.

All collected data is gathered for the purpose of keeping records of those registered for the golf tournament and for its execution. We collect contact details to inform you of important information and instructions related to the execution of the tournament. The legal basis for processing this data is our contractual relationship with you. As the processing of this data is necessary for the execution of the tournament itself, this data can be processed already based on the fact that you are entering into a contractual relationship with us. If you do not wish to provide us with this data, we cannot guarantee our services (register for the tournament).

The collected data will also be published on the golf portal and on the notice board in front of the hotel reception after the end of the tournament, and if necessary, also on the website of the course.

Renting Lockers and Other Services for Players:When you decide to rent a locker or when you request any service from the staff, we collect the following data:

• name and surname,
• locker number,
• phone number.

We collect data with the purpose of assigning you a locker or providing the requested service. The legal basis for collecting data is a contractual relationship or your consent, when you voluntarily provide us with data so we can contact you regarding the requested service.

Special Packages:When you decide to use special packages, coupons, credits, etc., we process the following personal data:

• name and surname,
• email address.

We collect data with the purpose of ensuring you can use special packages, coupons, and benefits. The legal basis is a contractual relationship or your consent. If you do not wish to provide us with names and surnames for using packages, coupons, credits, unfortunately, we will not be able to enable their use.

Provided contact details may also be processed based on our legitimate interest for basic tailored communication with you via email, attempting to present you with relevant services and activities that might interest you based on your past interactions with us. We do not use any (automatic) profiling but merely select appropriate recipient groups for individual messages. You can unsubscribe from such communications at any time for free by sending an email to: vop@hotelcubo.com.

Participation in Sweepstakes and Promotional Activities:Personal data that you provide when participating in a sweepstake or signing up for promotional activities is processed for the purposes of conducting the sweepstake or promotional activity. The collected data is deleted after the execution of the sweepstake or promotional activity, except in the case where you explicitly consent to receive advertising messages about our offers on the contact details provided during the registration for the sweepstake or promotional activity.

You can unsubscribe from such advertising at any time for free by sending an email to: vop@hotelcubo.com or vp@cubogroup.si.

Sending Inquiries to Our Contact Details:When you send an inquiry regarding our services to our contact details (address, email address, phone number), published on our website, we process your personal data exclusively for the purpose of responding to your question.

For this purpose, we only collect those personal data that you provide to us voluntarily. All data collected through our websites or otherwise communicated (e.g., using telecommunication means), are collected with the purpose of providing our services and for the purpose of our internal administration and managing our business.

Signing Up for Electronic Newsletters:You can also subscribe to receive current notifications and information about events at the hotel and restaurant, and interesting and useful tips on our website.

For such a defined purpose of direct marketing, we can inform you via email about new offerings that are directly related to our activity. We will inform you about new offerings as needed.

This data is processed based on your explicit consent, where you can revoke your consent to receive advertising messages at any time for free. To unsubscribe from direct advertising via electronic means, send an email to: vop@hotelcubo.com or vop@cubogroup.so

Social Networks:On our social media channels such as Facebook and Instagram, you can directly contact us using functions for commenting, sending messages, and chatting. Information that you send us in this way will be processed exclusively for the purpose of handling your comment, request, or question.

Based on legitimate interests, we have the right to manage our accounts on social media and the content we share on it, interact with visitors, and respond to your requests.

Additionally, our websites use plugins for social networks such as Facebook, Twitter, YouTube, Instagram, Linkedin (“plugins”). When using a service that uses plugins, data can be directly transferred from your device to the social network controller. We have no influence over the data collected by the plugin. If you are logged into a social network, your use of the service can be linked to your social network account. If you interact with the plugins, such as by liking, following, or sharing with others, or entering a comment, the data can automatically appear in your social network profile. Even if you are not logged into a social network account, it is possible that the plugins can send your IP address to social network controllers. Please consider this when using our services.

We explicitly emphasize that we have no influence over the extent, nature, and purpose of the processing of your personal data conducted by the social network service provider, so we refer you to the privacy policies of the social network service providers.

Processing Personal Data with Video Surveillance:HOTEL CUBO and CUBO golf conduct video surveillance in their premises for the purpose of preventing vandalism (protecting property), protecting people and employees, and ensuring control of entrances or exits in or out of the premises. The legitimate interests pursued by the company include protecting property and assets, ensuring the safety of people, and ensuring control of entrance or exit in or out of business premises. Where video surveillance is conducted, you are informed with an appropriate notice that you are entering a video-monitored area.

4. Data Users

We commit that we will not disclose your personal data to unauthorized third parties without your consent.

We inform you that we may entrust certain tasks related to your data to other persons (contractual processors). Contractual processors may process the entrusted data exclusively on our behalf and within the limits of our authorization (in a written contract or another legal act) and in accordance with the purposes defined in this Statement. Entrusted data is carefully protected by these contractual processors, who do not store it in stock, and do not use it for their own purposes.

Within the scope of legal competencies, your personal data may be disclosed to the following users of data:

• Police, Statistical Office of the Republic of Slovenia, and municipalities (all through the eTourism online application)
• providers of banking services and payment recovery services;
• accounting service, law firms, and other providers of legal and business advice;
• providers of information technology services within the framework of software maintenance and administration and website and application administrators and custodians;
• providers of cloud computing services and email messaging services (e.g., Mailchimp and others).

We commit that neither we nor other users of your personal data will transfer or convey them to a third country outside the European Union and/or European Economic Area or to an international organization without an appropriate level of protection.

5. Data Retention Period

We assure you that we retain your data only as long as necessary to fulfill the purpose for which the individual data were collected and further used. After the retention period has expired, we will effectively and permanently delete or anonymize your personal data so that your identification is no longer possible.

Those data that we process based on the law are stored for the period prescribed by the law. Data that we process due to the performance of a contractual or other relationship with you are stored for the period necessary to perform such a relationship and throughout the legal statute of limitations for claims from such a contracted relationship, except in case of a dispute related to the contractual relationship.

Personal data that we process based on your consent or legitimate interest, e.g., in the case of sending electronic newsletters, are stored permanently until the revocation of this consent from your side or until the request for cessation of processing, whereby we commit to verifying the existence of the purpose of processing personal data at regular time intervals.Data will be deleted before revocation only if the purpose of processing personal data has already been achieved (e.g., if we stopped sending electronic messages) or if so prescribed by law.

Personal data collected through the video surveillance system are stored for one month, thereafter and then irreversibly and permanently deleted. In the event of an incident, recordings may be kept for the duration of the statute of limitations.

For certain data processed for the realization of contracts, there is a different legal retention period (e.g., accounting or tax data). In these cases, the retention period is up to 10 years. During this time, data processing is limited.

6. Method of Protecting Your Data

HOTEL CUBO and CUBO golf are committed to protecting the personal data that you provide us through our website, via telecommunication channels, or in any other way. We commit to do everything possible to protect personal data from any breaches and misuse.

Once the need to keep data no longer exists, i.e., after fulfilling the purpose for which the data were collected, the data are immediately and irreversibly and permanently deleted.

7. Freedom of Choice

 You control the information you provide to us. If you decide not to provide certain data, then you will not be able to access certain places or functions on this website, nor can we respond to your inquiry or enter into a contractual relationship with you in such cases.

If you no longer wish to receive newsletters and offers via email, you can unsubscribe from receiving news/offers for free. To unsubscribe from direct advertising via electronic means, send an email with the content “UNSUBSCRIBE FROM RECEIVING NEWS” to: reception@hotelcubo.com or reception@cubogolf.com.

 

8. Your Rights

 HOTEL CUBO and CUBO golf ensure the realization of all your rights pertaining to the processing of your personal data under applicable legal regulations.

An individual to whom the personal data relate may at any time request from us:

• to confirm whether or not data concerning him or her are being processed and allow access to the personal data (i.e., insight and their transcription or copying);
• to provide information related to the processing of these data (e.g., about the purpose of processing, types of personal data, users to whom the personal data have been or will be disclosed, the anticipated period of data retention, about technical and organizational measures for data protection, etc.);
• to enable the correction of inaccurate personal data concerning him and allow him to complete incomplete personal data;
• to enable the right to delete personal data (the so-called right to be forgotten);
• to enable the right to limit processing;
• to enable the right to object to processing, if the processing of data is based on our legitimate interest, in which case we will continue processing your personal data only if we prove necessary legitimate reasons for processing that prevail over your interests, rights, and freedoms. You can object to the processing of personal data for direct marketing purposes without giving reasons, and we will immediately stop processing data in these purposes;
• to enable the right to data portability and provide him data in a commonly used and machine-readable format or forward them directly to another controller, whereby this applies only in the case of processing your personal data based on consent or contractual relationship; and
• to enable the right to withdraw consent, when personal data are processed based on your consent, whereby withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent at any time for free with a written statement sent to the controller by email:vop@hotelcubo.com or reception@hotelcubo.com. The withdrawal of consent for the processing of your personal data will have no negative consequences or sanctions.

 If you suspect that there are violations in the processing of your data under the legislation on the protection of personal data, you also have the right to file a complaint with the Information Commissioner of the Republic of Slovenia, at the address Dunajska cesta 22, 1000 Ljubljana, Slovenia, telephone number: 00 386 (0)1 230 97 30, email: gp.ip@ip-rs.si.

We will also provide you with other information related to your personal data that we process, in accordance with applicable legislation, upon your request.

We commit to responding to your request without undue delay, but no later than within the statutory deadlines.

9. Contact Person

 Questions about the confidentiality of your data, the way data are collected and processed, or your requests to exercise rights related to your data will be answered by the responsible person at HOTEL CUBO available at vop@hotelcubo.com and at CUBO golf at reception@cubogolf.com.

• Changes

We reserve the right to occasionally adapt this Statement to actual circumstances and legislation in the field of personal data protection as needed. For this reason, we ask you to check the current version before each submission of personal data to be informed of any changes and additions. We will also notify you of any changes that significantly affect the processing of your personal data in an appropriate manner (e.g., with a notice on our website, by email).

Version: 2/2022

Updated: 5.4.2022

COOKIES

What are cookies?Cookies are small text files in which data about a website visit is recorded.

The interaction between the web user and the website is faster and simpler with the help of cookies. The website remembers the individual’s preferences and experiences with their help, saving time and making browsing websites more efficient and enjoyable.

There are several reasons for using cookies, with their ability to store data about the status of a particular website (choice of language, number of displayed results, font size, currency, etc.), assist in the implementation of web services (registration, shopping cart contents, signing up for newsletters, video viewing, etc.), help collect data about the habits of web users (number of visits, content of interest to users, etc.). With their help, we try to improve your user experience and assess the effectiveness of the website design.

None of the cookies we use on our websites collect data that could personally identify you.

To be completely transparent, we have prepared a list of all the cookies we use and why. Please note that by continuing to use this website, you agree to our use of the described cookies.

HOTEL CUBO and CUBO golf may use the following types of cookies on their websites:

Which cookies does this website use?

Essential cookiesThese cookies are necessary to offer you the services available on this website as they enable basic functions such as page navigation and access to secure areas of the website. Without these cookies, the website cannot function properly. These cookies cannot be removed other than by not visiting our website.

Cookie Name	Purpose	Duration	Provider
_cfduid (x2)	For recognizing trustworthy web traffic, cookie ID for Cloudflare service	1 year	Tidio.co, Tidiochat.com

Statistics cookiesStatistics cookies help website owners understand how visitors use the website by anonymously collecting and reporting information.

Name of the Cookie	Purpose	Duration	Provider
_cfduid (x2)	For recognizing trusted web traffic, an ID cookie for the Cloudflare service	1 year	Tidio.co, Tidiochat.com

Statistics Cookies
Statistics cookies help website owners understand how visitors use the website by anonymously collecting and transmitting information.

Name of the Cookie	Purpose	Duration	Provider
_ga	Randomly generated unique number used to calculate data about our website’s visit	2 years	cubogroup.si
_gat	A Google Analytics service cookie used to limit hit frequency.	1 day	cubogroup.si
_gid	Randomly generated unique number used to calculate data about our website’s visit	1 day	cubogroup.si
collect	Cookie used to send Google Analytics data about the device the user is accessing from and their use of the website.	Session cookie – until the end of the session	google-analytics.com

Marketing Cookies
These are cookies that allow tracking your online activities. They are intended for advertising or showing more targeted ads that are relevant and interesting to the individual user.

Name of the Cookie	Purpose	Duration	Provider
NID	Randomly generated unique number that tracks the number of visits. For targeted advertising	6 months	google.com
rc::a	Cookie limits how many times the visitor is shown the same ad content. The cookie is also used to ensure the appropriate video ad is shown to a particular visitor.	Permanent	google.com
rc::b	Cookie limits how many times the visitor is shown the same ad content. The cookie is also used to ensure the appropriate video ad is shown to a particular visitor.	Session cookie – until the end of the session	google.com
rc::c	Cookie limits how many times the visitor is shown the same ad content. The cookie is also used to ensure the appropriate video ad is shown to a particular visitor.	Session cookie – until the end of the session	google.com
rc::d-15#

Unclassified Cookies
These are cookies that we will gradually classify.

Name of the Cookie	Purpose	Duration	Provider
buddyforms_wp_session	Pending	1 day	hotelcubo.com
https://api.instagram.com/v1/users/self/media/recent?count=33access_token=1996017138.aeeff59.3da99d98464c4d49bbd0dc38255ae069	Pending	Permanent	hotelcubo.com
Tidio_state_qa6c9sgz4kbfetaqxiv1jldohwykr3ta	Pending	Permanent	hotelcubo.com
Ulp-onload-#	Pending	Session cookie – until the end of the session	hotelcubo.com
Ulp-onscroll-#	Pending	Session cookie – until the end of the session	hotelcubo.com

How can you manage or delete cookies?
We will not use cookies to collect your personally identifiable information; however, if you wish, you can change your cookie settings in your computer or mobile device browser.

Most modern browsers allow you to accept or reject all cookies, accept or reject only certain types of cookies, or set a warning to be displayed when a site wants to save a cookie on your device. You can also delete cookies that the browser has already saved on your device.

Please note that if you disable cookies, not all website functionalities may work as effectively, the cookie usage warning will appear on each visit, and long-term this will negatively impact your user experience.

The process for changing cookie settings varies in each browser. You can find this information using the “Help” function, or visit www.aboutcookies.org, which clearly explains the process in all modern browsers.