Privacy and personal data protection

1. What is personal data?

Personal data is any information that relates to an identified or identifiable natural person, directly or indirectly, especially by reference to an identifier. The types of personal data covered by this notification include, for example: personal information, approximate location data, data on communication with the user, etc.

Personal information: name and surname, address, email address, sex and date of birth.

Approximate location data is automatically generated information within a public mobile communications network. The data shows which base station the user’s device is connected to. In view of the layout of mobile base stations, as well as the approximate area of mobile signal coverage provided by one base station, this data indirectly represents the approximate geographical location of the user’s mobile device.

Data on communication with the user is information generated during communication between the National Tourism Organisation of Montenegro and our users, in the form of user inquiries, complaints, requests (written or electronic communication), data generated as a result of answering calls/messages relating t services used or other requests.

2. Purpose of and lawfulness of data processing

The National Tourism Organisation of Montenegro collects and processes your personal data solely on the basis of your consent and in line with applicable legislation and the General Data Protection Regulation (GDPR).

Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Data is collected for the following:

• sending electronic communication, news, stories and newsletters
• cooperation in business events organised or co-organised by the National Tourism Organisation of Montenegro and keeping records of participants of such business events
• keeping records of media interested in a study visit to Montenegro
• enabling access to the media library
• enabling the submission of tourist offers
• participation in prize games
• segmentation of visitors to www.montenegro.travel and recipients of electronic communication, news, stories and newsletters to provide content of interest to individual online users,
• showing ads on topics that online users have previously expressed interest in
• using cookies for browsing www.montenegro.travel in order to provide website visitors with a better user experience
• data automatically collected by website analysts
• sending electronic communication, news, newsletters, press releases, media advisories, etc. to the media.

3. Contractual personal data processing

The National Tourism Organisation of Montenegro may entrust individual tasks relating to your data to other persons (contractual processors). Contractual processors may process confidential data only on behalf of the National Tourism Organisation of Montenegro, within its powers and in accordance with purposes defined in this Privacy Policy.

Personal data processors are natural or legal persons who process personal data on behalf of the National Tourism Organisation of Montenegro, and who have been certified by the National Tourism Organisation of Montenegro as processors on the basis of mutual business cooperation. They do not have the right to process personal data submitted to them for purposes other than those intended for the performance duties assigned to them by the National Tourism Organisation of Montenegro, on the basis of mutual business cooperation. Processors are required to adhere to all instructions given by the National Tourism Organisation of Montenegro.

Contractual processors that the National Tourism Organisation of Montenegro cooperates with include:

• hotel and transport service providers, tour guides, organisers and co-organisers of business events;
• data processing and analytics service providers;
• IT system administrators;
• email marketing automation providers;
• customer relationship management software providers;
• digital advertising solution providers;
• law firms and other legal advice providers.

The National Tourism Organisation of Montenegro will not share collected personal data with unauthorised third parties.

Contractual processors may process personal data only in accordance with instructions provided by the National Tourism Organisation of Montenegro and may not use personal data to pursue any of their own interests.

4. Transborder flows of personal data

As a rule, the National Tourism Organisation of Montenegro does not transfer users’ personal data to countries that are outside the list of countries having an adequate level of personal data protection. It is considered that an adequate level of protection is provided in EU member states, as well as in those countries that the EU has deemed to provide an adequate level of protection of personal data.

5. Security

The National Tourism Organisation of Montenegro takes data security very seriously. It uses an appropriate level of protection and has adopted electronic and administrative measures to protect collected data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

The priority of the National Tourism Organisation of Montenegro is to build and maintain trust with our users. Protecting our systems and personal data is therefore of paramount importance for both our customers and us. In accordance with the requirements of the applicable Law on Personal Data Protection and based on best practices, the National Tourism Organisation of Montenegro takes necessary measures to ensure the security of users’ personal data.

6. Your legal rights

As an individual to whom personal data is attached, you have certain rights in respect of personal data collected about you by the National Tourism Organisation of Montenegro. The following list contains information about your rights arising from applicable data protection legislation:

• You have the right to ask National Tourism Organisation of Montenegro about whether we are processing your personal data.
• If your personal data is incorrect, you have the right to ask for it to be corrected.

Examples:

• you have changed your residential address and you want the information to be updated in the National Tourism Organisation’s database;
• you have established that an error was made when entering your name after signing the contract, so you have the right to request a correction of this information.
• Right to restriction: You have the right to request the National Tourism Organisation of Montenegro to restrict the processing of your personal data if your data has been unlawfully processed and you wish to request the restriction of processing rather than erasure of your personal data.
• Right to withdraw consent: You have the right to withdraw consent at any time in the same way it was given.
• Right to erasure: You can request the erasure of your personal data from the National Tourism Organisation’s database if:
  • the user has withdrawn the consent on which the processing is based and there are no other legal grounds for the processing of such data;
  • the user has objected to the processing of personal data performed for the purpose of direct marketing, and there are no other legal grounds for the processing of such data;
  • if personal data relating to the user concerned has been processed unlawfully;
  • personal data is no longer necessary for the purposes for which it is collected or otherwise processed;
  • personal data must be deleted by the National Tourism Organisation of Montenegro with a view to complying with legal obligations arising from the laws of Montenegro.

7. Retention of personal data

The National Tourism Organisation of Montenegro retains users’ personal data for as long as justified, for the purposes stated in this Privacy Notice or for as long as necessary to comply with obligations arising from relevant legislation.

The National Tourism Organisation of Montenegro may retain your personal information in line with the following principles:

• in accordance with law, an agreement or our legal obligations; or
• for as long as necessary for the purposes for which the data was collected or processed, or longer if required by any agreement or applicable law, or for statistical purposes, taking into account appropriate security measures,
• until the consent to the processing of personal data for a particular purpose has been revoked.

The Privacy Notice may be amended to reflect changes in the applicable law, at the initiative of the National Tourism Organisation of Montenegro, users or competent authorities.

It is recommended that users regularly check the latest version of the Privacy Notice on our website.

8. Amendments

All amendments to the personal data policy will be published on www.montenegro.travel.