About us and privacy policy

The controller of personal data is Marina Sunčani Resort d.o.o., Trpinjska ulica 9, 10000 Zagreb, Croatia, OIB: 62722583511. The marina is operated under the name Molum Marine Club, at Obala kralja Tomislava bb, 23207 Sveti Filip i Jakov, Croatia.

This Policy clarifies in straightforward terms the manner in which we collect, use and protect your personal data when you visit the molummarine.com website, when you contact us via the contact form or e-mail, when you request or use our services at the marina or when you move around the marina area that is under video surveillance.

Please take the time to read this Policy in full. If you do not agree with this policy, we suggest that you do not use this website and do not provide us with your personal data. By continuing to use this website and our services, you confirm that you have read and understood this Policy.

 

Which personal data do we collect?

The data you provide to us

When contacting us via the website, by email or by phone, you will usually provide us with information such as your name and surname, email address, telephone number, details of the vessel and information related to your inquiry or reservation (e.g. desired arrival time, duration of the berth, number of people or special requests). Should a contract be concluded, we may also request information necessary for contractual and accounting purposes, such as company name, address and OIB. This information is necessary for the preparation and conclusion of the contract.

Furthermore, when contracting and reserving a berth, as part of the berth reservation form, in addition to your identification data, you are required to provide us with basic and technical information about your vessel, so that we can determine a suitable place for it in our marina.

Upon subscribing to the newsletter, we collect your email address so that we can send you relevant news and special offers. We collect this information with your consent.

Data collected automatically via the website

When you visit our website, certain technical information about your device and how you use the website is automatically recorded. This includes browser type, language, approximate location based on IP address, time of visit, and the pages viewed. This information is collected without the use of cookies or similar technologies.

We utilise tools such as Google Analytics, Microsoft Clarity, Google Ads and Meta Pixel (Facebook/Instagram) for analytics and advertising. They provide valuable insights into the frequency of website visits, the most engaging sections, and the effectiveness of our online campaigns. These technologies are only activated upon receipt of explicit consent via the cookie banner.

Video surveillance data

The Molum Marine Club area is partially covered by a video surveillance system. The primary function of the cameras is to protect people, vessels and property, and to enhance security within the marina. Notices are posted at the entrances to the monitored areas to inform visitors that the area is under video surveillance.

Please be advised that the videos may contain footage of your face, vehicle and vessel registration plates, and information about your movements within the monitored area.

Data from the contractual relationship

Should you conclude berth contract or other contract with us, we will process the data necessary for the conclusion and execution of said contract. This will include identification data, contact data, vessel data, the duration of the contract, the services used and payments made. This data is also retained within our accounting and tax records, in accordance with the prescribed time limits set out in the relevant legislation and regulations.

 

How and on what basis do we use your data?

We process data for a clearly defined purpose and only when we have an appropriate legal basis for it.

When contacting us with an inquiry, requesting a quote or concluding a contract, we use your data to respond to you, prepare and perform a contract for a connection or some other service. This processing is based on the execution of the contract or taking actions at your request before concluding a contract.

In order to comply with legal obligations, such as maintaining business records and accounting documents, as well as responding to requests from relevant authorities, it is necessary to process some of the data. In such cases, the legal basis arises from the relevant laws and regulations.

We carry out certain processing operations on the basis of our legitimate interest, for example to protect persons and property through video surveillance, to improve system security, to prevent abuse and for internal administration and business planning. In doing so, we always take into account the balance between our legitimate interest and your rights and freedoms. Where necessary, we implement additional safeguards and are guided by the principle of data minimisation.

With regard to the use of cookies and similar technologies for the purpose of newsletters, advanced analytics and personalised advertising, we ask for your explicit consent. You have the option to withdraw your consent at any time, either via the unsubscribe link in each marketing message or by changing your cookie settings on the website. Withdrawing your consent does not affect the lawfulness of the processing before withdrawal.

 

Technology tracking and advertising

We use cookies and similar technologies on the website for basic functionality, to understand how it is used and to measure the effectiveness of our advertising campaigns. Tag and script management is carried out through a tag management system.

By selecting the option to accept analytical cookies, you will enable Google Analytics and Microsoft Clarity to generate anonymous statistics regarding visits and user behaviour on the site. The data is displayed in aggregate form and we do not attempt to identify you individually through these tools.

With your consent, we can also use Google Ads and Meta Pixel to measure the success of our advertisements, and to occasionally show advertisements related to ours to users who have already visited our site. This data is also used for machine learning of advertising systems. These tools can connect data about your use of our site with other information that the providers of these services already have. However, we do not have access to internal profiles and data.

All advanced tracking and advertising functions (analytics and marketing) are GDPR compliant and are only activated when you explicitly allow them via the cookie banner. You have the option to change your choice at any time.

 

Who do we share personal data with?

Rest assured that we do not sell your personal data to third parties. We only share anonymised and pseudo-anonymised data when it is necessary to provide services or when we are required to do so by law. This includes, for example, IT service and hosting providers, external collaborators who maintain our information systems, accounting services, providers of analytical and advertising services (such as Google and Meta) and competent authorities when required by law or official procedure.

We only enter into data processing contracts with partners who process personal data on our behalf, and these contracts ensure that your data is used exclusively for the purpose of providing a specific service, with an appropriate level of protection.

 

Data transfer outside the EU/EEA

Certain service providers (such as Google and Meta) may process data in countries outside the European Union or the European Economic Area, where the level of protection of personal data may be different than in the EU. In such cases, we rely on mechanisms provided for by the GDPR, such as standard contractual clauses or other appropriate safeguards, to ensure the adequacy of data protection.

 

How long do we retain data?

We only retain personal data for as long as is necessary to fulfil the purpose for which it was collected or as required by applicable regulations. Please be advised that data from your inquiries and communications with us is generally kept for up to one year after the end of the communication, unless a longer period is required to protect legal interests. Please be advised that data from contracts and accounting documents is retained for the duration of the contractual relationship and for a minimum period specified by tax and accounting regulations. Video recordings from surveillance cameras are usually kept for a short period of time (maximum 60 days), except in the case of an incident or proceedings before competent authorities, when certain recordings may be kept longer, until the proceedings are concluded.

Following the expiration of the required periods, we proceed with the deletion or anonymisation of the data, unless otherwise mandated by law.

 

How we protect your data

We implement appropriate technical and organisational measures to protect your data from unauthorised access, loss, alteration or misuse. This includes restricting data access to authorised persons, utilising secure servers and passwords, implementing regular system maintenance and upgrades, conducting regular backups, and, where applicable, implementing additional forms of protection such as encryption. We educate our employees internally about the importance of privacy protection and oblige them to confidentiality.

 

Your rights

In accordance with the General Data Protection Regulation, you have the right to request information regarding the processing of your personal data and access to that data. You also have the right to request the correction of inaccurate or incomplete data, the erasure of data where there is a legal basis for this, the restriction of processing, the portability of data in certain cases, and the objection to processing based on legitimate interest, including the right to object to processing for direct marketing purposes.

If the processing is based on your consent, you have the right to withdraw that consent at any time, without negative consequences for contracts already concluded or services you use. Withdrawing consent does not affect the lawfulness of the processing before withdrawal.

Should you wish to exercise your rights, you may do so by sending a request to the following email address: info-marina@molum.hr. Alternatively, you may send your request by post to the company's headquarters, indicating 'Data Protection' on the envelope. We endeavour to respond to all requests within a reasonable timeframe, typically within 30 days. However, we reserve the right to apply an administrative fee for unreasonable or frequently repeated requests.

Right to complain to the supervisory authority

Should you have concerns regarding the processing of your personal data, you have the right to file a complaint with the relevant supervisory authority – the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, Croatia, www.azop.hr.

 

Children

Please note that our website and services are not directed at anyone under the age of 16. We do not collect personal information from children without the consent of a parent or legal guardian. If you believe that a child has provided their own information without your consent, please contact us to have it deleted.

 

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example, due to changes in our business, legal requirements, or the introduction of new technologies. The updated version will be posted on this page, along with the effective date. We encourage you to review it periodically to stay informed about how we are protecting your information.

 

Cookie policy

What are cookies?

Cookies are small text files that a website saves on your device when you visit it. They allow the website to recognize your device and remember certain information, such as your preferred language, display settings, or whether you have already accepted or rejected certain categories of cookies. In addition to cookies, the website may also use similar technologies, such as pixel tags and local storage in the browser, which have similar purposes.

 

Why do we use cookies?

We primarily use cookies to ensure the proper functioning of the website and a pleasant user experience. Some cookies are essential for displaying content, remembering your language selection, or displaying the consent management interface correctly.

Additionally, with your consent, we use cookies to understand visit statistics and to measure the success of our advertising campaigns. Following a thorough analysis of the available data, we make adjustments to the content of the site and determine the most effective way to present our services.

 

What types of cookies do we use?

The following categories of cookies may be used on our website:

Essential cookies are required to enable basic website functionality. In the absence of these components, the content will be unable to load correctly, your cookie preferences will not be retained, and fundamental security mechanisms will be compromised. We do not request special permission for these cookies, but you may wish to limit them in your browser settings, which may result in some functions no longer working as expected.

Functional cookies help us remember your settings and choices, ensuring a more tailored user experience. For instance, they can be used to recall your preferred language or specific user settings.

Analytical cookies are used to better understand how the website is used – which pages are most visited, how long users stay on certain parts, and where they come from. For this purpose, we use Google Analytics as one of several tools. The data is processed in aggregate and pseudonymised form for statistical analysis purposes, not for your direct identification.

Marketing cookies allow us to measure the effectiveness of our advertisements and to occasionally show advertisements to people who have already shown interest in our services, for example by visiting our website. For this purpose, we may use Google Ads and Meta Pixel (so- called tracking pixels). These cookies are only set if you explicitly allow them.

List and classification of cookies we use

Essential cookies

Name

Duration

Purpose

Description

.AspNetCore.Antiforgery.xxx

Browser session

Form security

It prevents cross-site request forgery (CSRF) when submitting web forms, thus protecting the user and the site.

cookie-consent-tracking-allowed/denied

up to 1 year

Storing cookie choices

It remembers whether you have allowed/rejected tracking and marketing cookies, so that the banner does not constantly reappear.

UMB_SESSION

Browser session

Website session

It allows the server to recognize the same visit during a single session and display the content correctly.

AEC

about 6 months

Google service security

It helps prevent abuse (e.g. login fraud) and ensures that requests come from a real user.

SEARCH_SAMESITE

about 6 months

Cookie security

Increases security by sending cookies only in permitted situations (SameSite protection).

SOCS

about 2 years

Google privacy settings

It remembers your choices regarding cookies and privacy on Google services (eg embedded maps, fonts, etc.).

Analytical cookies

Name

Duration

Purpose

Description

_ga

2 years

Google Analytics – Visitor ID

Assigns a unique ID to the visitor so that statistics can be generated (number of visits, pages, duration of visit).

_ga_XXXXXXXXXX

2 years

Google Analytics - Sessions

It links multiple hits (page views, events) into a single session from the same user for more accurate reporting.

ADS_VISITOR_ID

up to 1–2 years

Internal visitor analytics

Assigns a unique ID to the visitor to analyze traffic and behavior on the web (without directly displaying ads).

_clck

1 year

Microsoft Clarity – User ID

Stores a unique user ID for Microsoft Clarity to identify returning visitors and analyze user behavior across multiple sessions.

_clsk

1 day

Microsoft Clarity – Session ID

Links multiple page views of a user into a single session in Microsoft Clarity to create heatmaps and session recordings.

 Marketing cookies

Name

Duration

Purpose

Description

_Secure-1PAPISID

up to 2 years

Google Ads / personalized advertising

It helps create a profile of users' interests and display personalized ads on Google and partner websites.

_Secure-1PSID

up to 2 years

Google Ads / personalized advertising

Identifies the user and is used to display relevant ads based on previous visits and actions.

_Secure-1PSIDCC

up to 1 year

Google Ads – security and advertising

It combines security and personalization of ads on Google domains.

_Secure-1PSIDTS

up to 2 years

Google Ads / profiling

Records information about the use of Google services to create an ad profile.

_Secure-3PAPISID

up to 2 years

Cross-site advertising

It is used to create interest profiles on various websites and display targeted ads.

_Secure-3PSID

up to 2 years

Cross-site advertising

It enables personalized ads on Google and partner sites.

_Secure-3PSIDCC

up to 1 year

Cross-site advertising

Supports serving targeted ads and measuring conversions across multiple sites.

_Secure-3PSIDTS

up to 2 years

Cross-site advertising

It stores user behaviour data for long-term profiling and remarketing.

APISID

up to 2 years

Google profile / advertisements

It stores user preferences and is used to customize ads on Google services.

HSID

up to 2 years

Security + advertising

It contains digitally signed and encrypted user ID records and is used for both abuse prevention and ad personalization.

NID

up to 6 months

Preferences and advertisements

It remembers settings (e.g. language, number of results) and is used to display personalized Google ads.

SAPISID

up to 2 years

Google profile / advertisements

Allows Google to build a profile of user interests for personalized content and ads.

SID

up to 2 years

Security + advertising

Contains an encrypted user ID; used both for abuse protection and to display targeted ads.

SIDCC

up to 1 year

Security + advertising

A security cookie that also supports ad personalization.

SSID

up to 2 years

Google profile / ads

It stores information about the use of Google services and is used to customize ads.

DV

up to 1 year

Google Ads – measurement and personalization

It is used to personalize ads and measure the effectiveness of ads on Google domains.

UULE

a few hours up to 1 day

Location advertisements

Sends approximate location (based on IP and location settings) to display localized results and ads.

How do you give and change consent?

Upon initial visit to our website, a cookie banner is displayed, allowing the user to select their preferred cookie settings. You have the option to change your choice at any time via the link at the footer of the page. The new setting will be applied from the moment of the change and will not affect data that was already collected while your previous choice was in effect.

 

Third-party cookies and data transfer

By allowing analytical and marketing cookies, certain data about your use of our website may be forwarded to service providers, such as Google and Meta (Facebook/Instagram). Please note that these providers may also process data on servers located outside the EU/EEA. In such cases, we endeavour to ensure an appropriate level of protection, leveraging mechanisms such as standard contractual clauses or other instruments outlined by the GDPR.

Please be aware that we do not have full control over how third parties use cookies and the data they collect through them. For more detailed information, please refer to the privacy and cookie policies of the service providers themselves.

 

How long do cookies last?

Some cookies are deleted as soon as the browser is closed (session cookies), while others are stored on the device for a certain period of time, until they expire or are manually deleted (persistent cookies). The duration depends on the purpose of the cookie and the settings of the individual tool, but generally ranges from a few minutes to a maximum of several years for certain marketing cookies.

You have the option to manually delete cookies at any time via your browser settings, as well as adjust your cookie settings on our site.

 

Changes to the Cookie Policy

This Cookie Policy may be updated from time to time, for example if we introduce new tools or change the way we use existing ones. The updated version will always be available on this page, with the date of the last modification indicated. We recommend that you review this statement periodically to stay informed about how we use cookies.

 

Contact

Should you have any queries pertaining to this Cookie Policy or personal data protection in general, please contact us at the following email address: info-marina@molum.hr. Alternatively, you can write to us at the company's headquarters, indicating that the message is regarding "Cookies and data protection".