Last updated: October 2026
1. About Us and the Purpose of this Policy
Avangardni Servis d.o.o., Dolska 4, 20000 Dubrovnik, Croatia, OIB (Personal Identification Number): 25030544593, MBS (Company Registration Number): 090024517 (hereinafter referred to as Avangardni Servis, Avantgarde Service, we, us, or the Data Controller) respects the privacy of its clients, travellers, business partners and visitors to the website www.avantgardeservice.com.
Data Controller contact details:
Avangardni Servis d.o.o.
Dolska 4
20000 Dubrovnik, Croatia
E-mail: hello@avantgardeservice.com
Phone: +385 99 203 46 51
Website: www.avantgardeservice.com
This Policy explains what personal data we collect, how we collect it, for what purposes and on what legal basis we process it, to whom we may disclose it, how long we retain it, how we protect it, and what rights individuals have in relation to the personal data we process.
We process personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR), applicable Croatian legislation and other applicable data protection regulations.
2. Principles of Personal Data Processing
We process personal data lawfully, fairly and transparently and collect it only for specified, explicit and legitimate purposes.
We collect only data that is adequate and necessary for the purpose for which it is processed, take reasonable steps to ensure that it is accurate and up to date, and do not retain it for longer than necessary or required by law.
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or unauthorised disclosure.
3. How We Collect Personal Data
We may obtain personal data:
directly from a client or traveller by e-mail, telephone, in person or through an enquiry form on our website;
during the preparation of an offer, reservation and contracting of a trip or individual travel service;
during the provision of the contracted service;
from a person booking or contracting travel services on behalf of other travellers;
from a travel agency, tour operator, DMC, business partner or other legal or natural person contracting our services on behalf of travellers;
from service providers involved in the delivery of travel arrangements, where necessary for the performance of the contracted service;
in connection with payments, invoices, refunds, complaints and claims;
automatically, to a limited extent, when our website is used, through technical data and cookies, where applicable.
Where we receive a traveller's personal data from a person arranging travel on their behalf or from a business partner, we expect that person to be authorised to provide the data necessary for the organisation and delivery of the travel arrangements.
4. Personal Data We May Collect
Depending on the service we provide, we may process:
first and last name;
address and country of residence;
telephone number and e-mail address;
date of birth or age, where required for a reservation or the application of a particular fare;
nationality;
passport or identity document number and details, where required for the delivery of travel arrangements or by law;
information concerning travel, reservations, accommodation, transfers, activities and other contracted services;
information required for issuing invoices and recording payments;
company information and business contact details when dealing with legal entities;
the content of communications relating to an enquiry, reservation, performance of a service, complaint or claim;
special traveller requests necessary for the proper delivery of travel arrangements.
In certain circumstances, a traveller may voluntarily provide us with information concerning health, disability, dietary requirements, allergies, religious dietary requirements or other special circumstances where such information is necessary to arrange an appropriate service.
We process such data only where an appropriate legal basis exists and only to the extent necessary to fulfil the traveller's request.
We do not request more personal data than is necessary for the particular service.
5. Purposes and Legal Bases for Processing
5.1. Enquiries and Preparation of Offers
We use the information you provide when making an enquiry in order to respond to your request, prepare an appropriate offer and communicate with you throughout the planning process.
The legal basis is taking steps at the request of the data subject prior to entering into a contract or, depending on the circumstances, our legitimate interest in responding to business enquiries.
5.2. Reservations and Performance of Contracted Services
We process personal data for the purpose of reserving and arranging accommodation, transportation, excursions, activities, guiding services, charter services and other travel services, as well as communicating with clients and travellers before, during and after their trip.
The legal basis is the performance of a contract or taking steps prior to entering into a contract.
5.3. Legal, Tax and Accounting Obligations
We process and retain certain information in order to comply with obligations arising from tax, accounting, tourism and other applicable legislation.
The legal basis is compliance with a legal obligation to which the Data Controller is subject.
5.4. Payments, Refunds and Financial Records
We process information concerning completed payments in order to match payments with reservations, issue appropriate financial documentation, process any applicable refunds and maintain business records required by law.
5.5. Complaints, Claims and Legal Matters
We may process personal data for the purpose of handling complaints and claims, establishing facts relating to the performance of services and establishing, exercising or defending legal claims.
5.6. Direct Marketing
We send promotional communications and offers only where an appropriate legal basis exists.
Where marketing is based on consent, consent may be withdrawn at any time without affecting the lawfulness of processing carried out before its withdrawal.
We do not sell personal data to third parties.
6. Credit and Debit Card Payments – Monri Pay-by-Link
Avantgarde Service does not operate a web shop and does not enable the direct entry of credit or debit card details on its website.
Where card payment is available for an agreed service, we may send the client an individual payment link (Pay-by-Link). Card payments are processed through the secure payment system of Monri Payments d.o.o.
The information required to authorise and process a card transaction is entered by the client directly into Monri's secure payment environment.
Avangardni Servis d.o.o. does not collect or store full credit or debit card numbers, CVV/CVC security codes or other card authentication data.
Avangardni Servis may only receive information required for business records, identification and matching of a completed payment with the relevant reservation or service, such as the payer's name, transaction amount and date, payment status, transaction reference and limited information concerning the payment method, to the extent such information is made available to the merchant by the payment service provider.
Monri Payments d.o.o. processes the information required to complete card transactions in accordance with applicable data protection legislation, card scheme rules and appropriate security standards.
Card information is processed within Monri's secure payment environment. Avangardni Servis d.o.o. does not have access to clients' full card details and does not store such information in its information systems.
Transaction information received by Avangardni Servis is processed for the purposes of recording payments, issuing appropriate financial documentation, processing any applicable refunds, resolving complaints or claims, and complying with statutory accounting and tax obligations.
7. Recipients of Personal Data
For the purpose of providing contracted travel arrangements or other services, we may disclose personal data, only to the extent necessary, to appropriate recipients, including:
hotels, villas and other accommodation providers;
transportation and transfer providers;
shipping companies, charter companies and other transportation providers;
tourist guides;
excursion and activity providers;
restaurants and other service providers where necessary for reservations or guests' special requirements;
national parks, attractions and other providers of reserved services;
partner travel agencies and DMC partners involved in the delivery of travel arrangements;
payment service providers and financial institutions;
IT, hosting, communications, accounting and other business service providers processing data in accordance with our instructions and applicable legislation;
competent government, tax, judicial, police, border or other authorities where we are legally required to disclose such information.
We disclose personal data only to the extent necessary for the relevant purpose.
8. Transfers of Personal Data Outside the European Economic Area
Avantgarde Service organises travel and provides travel services in countries outside the European Economic Area.
Where it is necessary for the delivery of contracted travel arrangements to provide personal data to a hotel, transportation provider, travel agency, guide or other service provider in a third country, personal data may be transferred outside the European Economic Area.
Such transfers are limited to the information necessary to reserve and provide the particular service and are carried out in accordance with applicable rules governing international transfers of personal data.
Where applicable, we use an appropriate transfer mechanism provided for under the GDPR or another appropriate legal basis for a transfer necessary for the performance of a contract in the traveller's interest.
9. Retention of Personal Data
We do not retain personal data for longer than is necessary for the purpose for which it was collected.
Information relating to enquiries and offers that do not result in a reservation is retained for a reasonable period necessary to conclude the communication and allow for a possible continuation of the enquiry. It is subsequently deleted or anonymised unless another legal basis exists for its continued retention.
Information relating to reservations and completed travel arrangements is retained for the duration of the contractual relationship and, following its completion, for as long as necessary to comply with legal obligations, handle potential complaints and protect legal interests.
Invoices, payment information and other accounting and tax documentation are retained for the periods prescribed by applicable accounting and tax legislation.
Information processed on the basis of consent is retained until consent is withdrawn or until the purpose for which consent was given ceases to exist, unless another legal basis exists for its continued retention.
Information necessary for the establishment, exercise or defence of legal claims may be retained until the expiry of the applicable limitation periods or until the final conclusion of the relevant proceedings.
Upon expiry of the applicable retention period, personal data is deleted, anonymised or otherwise removed from active use unless its continued retention is required by law.
10. Data Security and Confidentiality
We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
Access to personal data is limited to persons who require it in order to perform their duties.
We require employees, associates and data processors to respect the confidentiality and protection of personal data.
The transmission of information through our website is protected by appropriate technical security measures.
Card information is processed within the secure payment environment of Monri Payments d.o.o. and is not stored in the information systems of Avangardni Servis d.o.o.
11. Cookies and Website Usage Data
Our website may use strictly necessary cookies required for its proper operation.
If we use analytical, marketing or other cookies that are not strictly necessary for the functioning of the website, they are used only in accordance with applicable rules and, where required, after obtaining the user's prior consent.
More detailed information about cookies, their purposes and duration is available through the relevant cookie notice or cookie settings on the website.
12. Your Rights
In accordance with the GDPR and depending on the legal basis and circumstances of the particular processing activity, you have the right to:
request access to your personal data;
request the correction of inaccurate or incomplete data;
request the deletion of personal data where the legal requirements are met;
request restriction of processing;
exercise the right to data portability where the applicable requirements are met;
object to processing based on legitimate interests;
object at any time to the processing of personal data for direct marketing purposes;
withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before consent was withdrawn.
To exercise your rights, you may contact us by e-mail at:
or in writing at:
Avangardni Servis d.o.o.
Dolska 4
20000 Dubrovnik
Croatia
Before acting upon a request, we may request additional information necessary to verify the identity of the person submitting the request.
The rights to erasure, restriction, portability and other data protection rights are not absolute and may be restricted where continued processing is necessary to comply with a legal obligation, perform a contract, protect the rights of others or establish, exercise or defend legal claims.
13. Right to Lodge a Complaint with a Supervisory Authority
If you believe that your personal data is being processed contrary to applicable data protection legislation, you may first contact us so that we can attempt to resolve your concern.
You also have the right to lodge a complaint with the competent supervisory authority:
Croatian Personal Data Protection Agency (AZOP)
Selska cesta 136
10000 Zagreb
Croatia
www.azop.hr
14. Requirement to Provide Personal Data
Certain personal data is necessary in order for us to respond to your enquiry, prepare and contract the requested service, make a reservation, provide travel arrangements or comply with a legal obligation.
If you are unwilling or unable to provide information that is necessary for these purposes, we may not be able to make a particular reservation or provide the requested service.
Information that is not necessary for entering into or performing a contract is provided voluntarily.
15. Automated Decision-Making
Avangardni Servis d.o.o. does not make decisions that produce legal effects or similarly significantly affect clients or travellers solely through automated processing of personal data, including profiling.
16. Changes to this Privacy Policy
We may amend this Policy from time to time in order to reflect changes in legislation, business processes, technology or the services we provide.
The current version will always be available at www.avantgardeservice.com together with the date of the latest update.
In the event of significant changes affecting the manner in which personal data is processed, we will take appropriate measures to inform the individuals concerned in a timely manner.
Ovo je engleski ekvivalent hrvatske verzije, tako da ih možeš objaviti paralelno bez sadržajnih razlika.
