ETF Travel d.o.o. (hereinafter: “ETF Travel”) respects the privacy of its users, clients and travellers and is committed to handling personal data responsibly and transparently.
Through this Privacy Policy, we wish to inform you about which personal data we collect and process, the purposes for which we use it, the legal bases for such processing, to whom we may disclose it, how long we retain it, and what rights you have in relation to your personal data.
This Privacy Policy applies to personal data that we collect through the ETF Travel website, contact forms, email, telephone communications, and in the course of providing and organising our services.

The data controller responsible for the processing of personal data is:

ETF Travel d.o.o.
Ulica javora 2
10 255 Stupnički Obrež
Business premises: Karlovačka cesta 2E
10 000 Zagreb
Personal Identification Number (OIB): 11347132761
Tourist agency registration number: 1825/2026
E-mail: info@etftravel.com

For any questions relating to the processing and protection of personal data, you may contact us via the following email address: info@etftravel.com.

2. Who does the Privacy Policy apply to?

This Privacy Policy applies to the personal data of persons who:

– visit the ETF Travel website;
– submit enquiries for personalised travel arrangements;
– submit enquiries via the contact form;
– submit enquiries for charter flights;
– contact ETF Travel by email or telephone;
– use or contract services organised by ETF Travel;
– travel as part of a service organised by ETF Travel, including cases where the traveller’s data has been provided by another person, for example, a tour organiser or a person travelling together with them.

3. What personal data do we collect?
The type of data we collect depends on how you communicate with us and which service you are requesting.

3.1. Contact Form
Through the contact form, we may collect:
first name;
last name;
email address;
message content.

3.2. Charter Flight Inquiry
When submitting an inquiry for a charter flight, we may collect:
first and last name;
company or organisation name;
e-mail address;
contact telephone number;
departure airport;
destination airport;
departure date;
return date;
number of passengers;
message content.

3.3. Personalised Travel Inquiry
When submitting an inquiry for a personalised trip, we may collect:
first and last name;
e-mail address;
contact telephone number;
desired destination;
approximate travel dates;
number of nights;
number of adult travellers;
number of children;
ages of the children;
place of departure;
approximate travel budget;
preferred hotel category;
any other information provided by the user in the message or inquiry.

3.4. Data Required for Travel Organisation

If you request the organisation of a specific trip or other services, we may process additional data necessary for the provision of the service, including traveller and travel-related information that you provide to us or that is necessary for booking and providing the service. The scope of the data depends on the type of travel and the specific service you request.

ETF Travel endeavours to collect only data that are adequate, relevant, and necessary for the specific purpose of processing.

4. How Do We Collect Personal Data?
We most often obtain personal data directly from you, for example when you:
complete a contact form;
submit an inquiry for a personalised trip;
submit an inquiry for a charter flight;
contact us by e-mail or telephone;
request a quotation or the organisation of a trip;
provide data necessary for the provision of travel services.
In certain cases, we may also receive personal data from another person who organises or books a trip on behalf of multiple travellers. In such cases, we process the data to the extent necessary to provide the requested service and in accordance with applicable laws and regulations.

5. Purposes of Processing Personal Data
We process your personal data for the following purposes:
Processing and Responding to Inquiries
We use your data to respond to your inquiry, contact you, provide the requested information, and prepare an appropriate offer.

Organisation and Provision of Travel Services
The data may be used to organise travel, including airline tickets, accommodation, transfers, charter flights, personalised trips, and other services you request.

Communication with Users
We use your data for communication relating to your inquiry, offer, booking, or travel arrangements.

Performance of Contractual and Pre-Contractual Obligations
Data are processed where necessary to take steps at your request prior to entering into a contract or to perform a contract you have entered into with ETF Travel.

Compliance with Legal Obligations
We process and retain certain data where necessary to comply with legal, accounting, tax, or other obligations applicable to ETF Travel.

Protection of Rights and Legitimate Interests
Where necessary and permitted, data may be processed to protect ETF Travel’s legitimate interests, for example to prevent misuse, resolve disputes, establish or defend legal claims, and protect the security of information systems.

6. Legal Bases for Processing

Depending on the specific purpose, ETF Travel processes personal data on the basis of one or more of the following legal bases:
taking steps at the request of the data subject prior to entering into a contract;
performance of a contract;
compliance with a legal obligation;
ETF Travel’s legitimate interests, where such processing is permitted and those interests are not overridden by the rights and freedoms of the data subject;
consent, where consent is required for the specific processing activity.
For example, when you request a travel quotation via a contact form, the processing of data necessary to respond to your inquiry and prepare the quotation is based on the need to take steps at your request prior to entering into a contract.
Where a particular processing activity is based on consent, consent is voluntary and may be withdrawn at any time. The withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
This Privacy Policy does not in itself constitute consent to the processing of personal data. Where consent is required for a particular processing activity, consent will be obtained in an appropriate manner and separately.

7. Is Providing Personal Data Mandatory?

Providing data through contact forms is generally necessary for us to respond to your inquiry and provide the requested service. The mandatory fields in each form are determined based on the data required to process the specific request.
If you do not provide the data necessary to process your inquiry or provide the requested service, ETF Travel may not be able to respond to your request, prepare a quotation, or arrange the requested service.

8. To Whom May We Disclose Personal Data?

ETF Travel may, where necessary for achieving a specific purpose and in accordance with applicable laws and regulations, disclose personal data to relevant service providers and partners.
Depending on the type of travel and service, recipients may include:
airlines;
hotels and other accommodation providers;
providers of transfers and other forms of transportation;
other providers of travel and tourism services;
business partners involved in the provision of a specific trip;
providers of IT, hosting, security, and other technical services who process data on behalf of ETF Travel, where applicable;
accounting, legal, and other professional advisers, where necessary;
competent state authorities and other public bodies where ETF Travel is legally required to disclose such data.
Data are disclosed only to the extent necessary for the specific purpose.
Where a third party processes personal data on behalf of ETF Travel, ETF Travel regulates its relationship with such processor in accordance with applicable data protection laws and regulations.

9. Transfer of Personal Data Outside the EU

ETF Travel does not intend to routinely transfer personal data outside the European Economic Area (EEA).
However, given the international nature of the travel and services organised by ETF Travel, in certain cases it may be necessary to provide certain personal data to a service provider located outside the European Economic Area, for example for the provision of travel, accommodation, or another service requested by the user.
In such cases, ETF Travel takes appropriate measures to ensure that the transfer is carried out in accordance with the GDPR, including the use of appropriate safeguards for the protection of personal data where required.
Information about a specific transfer and the safeguards applied may be provided to the user upon request, where applicable.

10. How Long Do We Retain Personal Data?

ETF Travel retains personal data only for as long as necessary to fulfil the purpose for which they were collected, or for the period required to comply with legal obligations, protect legitimate interests, or establish, exercise, or defend legal claims.
The retention period depends on the type of data and the purpose for which they are processed.
Data from Contact Inquiries
Data submitted through contact forms are retained for the period necessary to process the inquiry and for any subsequent communication related to that inquiry. If an inquiry does not result in a further business relationship, the data will be deleted after the expiry of a reasonable period necessary for processing and any subsequent action, unless there is another legal basis for their continued retention.
Data Related to the Organisation and Provision of Travel Services
Data relating to quotations, bookings, contracts, invoices, and other business documents are retained for the period necessary to fulfil contractual obligations and for the retention periods prescribed by applicable laws.
Data Necessary for Establishing or Defending Legal Claims
Where necessary for establishing, exercising, or defending legal claims, certain data may be retained until the expiry of the applicable limitation periods or until the relevant proceedings have been finally concluded. ETF Travel regularly reviews the need for continued retention of data and, upon expiry of the applicable retention period, deletes, destroys, or anonymises the data, unless there is another legal basis for retaining them.

11. Cookies and Similar Technologies

The ETF Travel website uses cookies and similar technologies.
Depending on their purpose, the website may use technologies associated with services such as:
– Google Analytics;
– Google Tag Manager;
– YouTube;
– Google Maps;
– Google reCAPTCHA.
Certain technologies may process data that enable the identification or tracking of users, and where required, their use is subject to the user’s appropriate consent. Detailed information about the types of cookies, their purposes, providers, retention periods, and available options for managing settings is available in the **Cookie Settings**.
Users can manage their cookie preferences through the consent management mechanism available on the website.

12. Automated Decision-Making and Profiling
ETF Travel does not make decisions that produce legal or similarly significant effects for users solely on the basis of automated processing of personal data, including profiling.

13. Security of Personal Data
ETF Travel implements appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or unauthorised access. Access to personal data is restricted to persons who require such access to perform their business duties, as well as to service providers who process the data in accordance with appropriate contractual and legal obligations.

14. Your Rights
Depending on the circumstances of the particular processing activity, you have the following rights:

Right of Access
You may request confirmation as to whether your personal data are being processed and, if so, access to such data and information about their processing.

Right to Rectification
If your personal data are inaccurate or incomplete, you may request that they be corrected or supplemented.

Right to Erasure
Under certain circumstances, you may request the erasure of your personal data. This right is not absolute and does not apply where there is a legal or other permitted basis for the continued processing or retention of the data.

Right to Restriction of Processing
Under certain circumstances, you may request the restriction of the processing of your personal data.

Right to Data Portability
Where the conditions set out in the GDPR are met, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transmit those data to another controller.

Right to Object
Where the processing is based on ETF Travel’s legitimate interest, you have the right to object to such processing on grounds relating to your particular situation.

Right to Withdraw Consent
Where the processing is based on your consent, you may withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Right to Lodge a Complaint with a Supervisory Authority
If you believe that your personal data are being processed in violation of applicable data protection laws and regulations, you have the right to lodge a complaint with the Personal Data Protection Agency (AZOP).

15. How Can You Exercise Your Rights?
To exercise your rights or for any questions relating to the processing of your personal data, you may contact ETF Travel:
ETF Travel d.o.o.
Business premises: Karlovačka cesta 2E
10 000 Zagreb
E-mail: info@etftravel.com
You may submit your request by e-mail or in writing.
ETF Travel will respond to your request without undue delay and, as a rule, no later than one month from receipt of the request. In the event of the complexity of the request or a large number of requests, the time limit may, where the applicable conditions are met, be extended by an additional two months, in which case we will inform you of the extension in a timely manner.
To protect your data, we may request additional information necessary to verify your identity.

16. Right to Lodge a Complaint with the Personal Data Protection Agency
If you believe that the processing of your personal data has infringed the GDPR or other applicable data protection laws and regulations, you have the right to lodge a complaint with the competent supervisory authority.
The competent supervisory authority in the Republic of Croatia is:
Personal Data Protection Agency (AZOP)
Ulica Metela Ožegovića 16
10 000 Zagreb
E-mail: azop@azop.hr
The right to lodge a complaint does not affect any other administrative or judicial remedies available to you.

17. Amendments to the Privacy Policy
ETF Travel may occasionally amend or supplement this Privacy Policy in order to reflect changes in its business operations, technology, or applicable legislation. The current version of the Privacy Policy will always be available on the ETF Travel website.
In the event of significant changes affecting the manner in which personal data is processed, ETF Travel will, where necessary, take appropriate measures to ensure that users are informed of such changes in a timely manner.

18. Contact

For any questions regarding the protection of personal data and the manner in which ETF Travel processes your personal data, you may contact us at:

ETF Travel d.o.o.
Business premises: Karlovačka cesta 2E
10 000 Zagreb
E-mail: info@etftravel.com

Effective date: 15 September 2026
Last updated: 15 September 2026″