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Privacy policy

Stublina Hotel Group d.o.o., with its registered seat at Bečićka plaža b.b. Budva, Montenegro, TIN: 03358704 (hereinafter: Stublina Hotel Group), respects and protects privacy of every person whose private data it collects. Privacy policy defines which personal data Stublina Hotel Group collects, for which purpose it uses them, how it protects them, and what your rights are.

Stublina Hotel Group holds all copyrights for usage of photos, texts, and other published material, within the meaning of statutory legal regulations in the Republic of Montenegro. Photographs, texts, and other material can’t be published, sold, publicly or privately published, or in any other manner used without consent of Stublina Hotel Group. Non-compliance with the above stated terms entails responsibility and obligation of remuneration of non-material damage to Stublina Hotel Group per violation of each material.

General provisions

Scope of application

This Policy applies to every Stublina Hotel Group’s personal data handling.

Data handler and legal framework

Stublina Hotel Group,  as handler of your data, respects your privacy and undertakes to protect your personal data.

Collection and safekeeping of data is conducted in accordance with the Law on personal data protection of the Republic of Montenegro (PDPL), other rules governing area concerned, applicable in Republic of Montenegro, as well as with General Data Protection Regulation of EU (GDPR).

Implementation of data protection principles 

Stublina Hotel Group within implementation of this Policy, especially takes care of data procession principles, therefore these data are processed:

  • Legally – processing will be possible if the Law allows it and within the boundaries set by the Law.

  • Fairly – with respect of uniqueness of every relationship, applying all adequate measures for protection of personal data and privacy in general, and without preventing examinee to exercise their rights.

  • Transparent - by informing examinees on personal data procession. All the way from the collection of data, when the examinees are informed on every aspect of data procession, till the end of data procession, examinees will have simple and fast access to their own data which includes possibility of inquiry and obtaining of copy in accordance with the provisions of the Law. Certain information can be limited only when it is obligatory by Law or if necessary for protection of third persons.

  • With limitation of safekeeping – by safekeeping of data in the form that provides identification of the examinee only for the period of time necessary for the purpose for which personal data are handled, and longer only if allowed by the Law.

  • With reduction of the data amount – by handling data only if they are appropriate, relevant, and limited to what’s necessary. Care will be taken not to collect data for which there is no justified need for handling. 

  • By taking care of accuracy – by taking care of accuracy and up-to-datedness of the data, and by deleting incorrect data within capacity.

  • By taking care of completeness and confidentiality – by giving technical and organizational measures necessary safety of personal data, including protection from unauthorized or illegal handle, and from accidental loss, destruction, or damage by applying necessary technical and organizational measures. Relevant measures are applied regarding the risk during every type of data handling.

Purpose of the collection

Stublina Hotel Group is obliged to collect some of your personal data to fulfil Accommodation Agreement and due to rules regulating hospitality industry, but Stublina Hotel Group can collect some other or same data for other purposes, primarily for contact, i.e.:

  • realization of Accommodation Agreement
  • provision of information and services (accommodation, event organization, seminars, celebrations, and other)
  • security of payment
  • fulfilment of legal requests and other statutory legal regulations regulating hospitality industry
  • for the purpose of direct marketing
  • sending the offers
  • for the purpose of improvement and personalization of services for you as a guest
  • for the purpose of property protection and safety of individuals by usage of video surveillance

Stublina Hotel Group warrants to use collected data only for the purposes above stated.
Stublina Hotel Group can use depersonalized data for statistics.

Legal basis for collections

Legal basis for stated collections are:

  • lawful
  • contracting
  • key interest of examinee
  • legitimate interest which prevails over the interests of the examinee, or
  • consent or explicit consent of the examinee, depending on the purpose of handling and type of personal data

Places for collection of data

Stublina Hotel Group collects your data in the event of:

  • reservation of accommodation (reservation via internet or via phone by calling call center)
  • in the event of filling agreements on accommodation, event organization, seminars, celebrations and other
  • application to newsletter on internet pages of Stublina Hotel Group
  • filling survey during and after staying of guests in facilities of Stublina Hotel Group
  • during visit to our stand at fairs and similar events
  • accession into loyalty program membership
  • in places covered by video surveillance
  • we can obtain personal data from third parties that we have close collaboration with (e.g. including travel agency, event and congress organization agency, business partners, associates, suppliers, etc.)

Period of data safekeeping

Stublina Hotel Group is obliged to keep safe the data collected based on the Law for as long as requested by certain law or other statutory legal regulation.

Data collected by Stublina Hotel Group on the basis of contractual relations, will be kept only as long as necessary for the purpose of fulfilment of contract i.e. for the providing of service.

Data on name, surname and e-mail address collected by Stublina Hotel Group based on legitimate interest for the purpose of direct marketing will be kept in its guest database for 10 years.

Other data collected by Stublina Hotel Group based on explicit consent of the guest (mobile telephone number, number of children, marital status, interests, meanings of travelling, accommodation preferences) will be kept in its guest database for 5 years.

Rights of examinee

Regardless of the basis of data collection, you can ask at any time, free of charge, for the:

  • access, you have right to know if your personal data are handled or not
  • amendment of data in all personal databases, after which Stublina Hotel Group will amend your data in all its bases depending on your request,
  • erasure (“right to be forgotten”) of personal data in all personal databases, after which Stublina Hotel Group will erase you from all its bases, except from the bases which Stublina Hotel Group is obliged to hold and keep in accordance with statutory legal regulations, or in the event of more powerful legitimate reasons for handling or if handling is not necessary for submission, exercise, or defense of legal requests,
  • limitation of handling of your data or file complaint on handling of such data
  • transfer of data on you collected by us to you or to third parties (“right to data portability”), in accordance with statutory legal regulations,
  • if data are given based on consent, you can withdraw this consent at any time without any negative consequences,
  • right to file complaint to competent supervisor authority, the Agency for Personal Data Protection and Free Access to Information, with registered seat in Podgorica, Montenegro.

If you have any questions regarding our Privacy Policy, or described handling of your data, or doubt or complaint regarding implementation of this Policy, or if you wish to send a request for access to your personal data that we have about you or for their erasure, you can send us your written request to the contact address: This email address is being protected from spambots. You need JavaScript enabled to view it. or via postal service to address:

Stublina Hotel Group d.o.o., hotel Katamare

Bečićka plaza bb, 85310 Budva


Personal data collected from the persons booking the accommodation

Your personal data, which you have to provide in order to receive accommodation services, Stublina Hotel Group, as data handler, keeps in its database only for the purpose of fulfilment of Accommodation Agreement, and for fulfilment of its legal obligations, and for collecting of personal data related to hospitality industry, and is allowed to use them for other purposes in accordance with statutory legal regulations. If you fail to provide to Stublina Hotel Group necessary minimum of data required for the guest registration with all competent authorities, Stublina Hotel Group will not be able to provide you with accommodation in accordance with the Agreement and the Law.

Personal data, which Stublina Hotel Group registers upon the reservation and arrival to facilities, are collected based on the Law regulating hospitality industry and for the purpose of service provision to guests. Those are following data (that can be changed in accordance with statutory legal regulations):

  • name and surname
  • residence address (Montenegrin citizens)
  • date of birth
  • number, type of ID and issuing place
  • citizenship
  • number of accommodation unit
  • date of arrival and departure of the guest
  • gender
    Stublina Hotel Group keeps the data in its guest database and sends them to a system (electronic system for guest registration) to competent authorities of the Republic of Montenegro, and those data must be kept in the system for 10 years. Also, Stublina Hotel Group is obliged to keep all invoices issued to guests with personal data of the guest in accordance with law regulations. Moreover, for the purpose of fulfilling of its contractual obligation, upon reservation and arrival to facilities, Stublina Hotel Group collect following information:
  • e-mail
  • telephone number

Other data connected to your staying, such as: means of traveling, marital status, number of children, other interests, also can be collected if they have direct connection with providing accommodation.
Based on the legitimate interest, data handler has rights to collect your personal data (name, surname, e-mail address) to its personal guest database and to use them for the purpose of direct marketing, exclusively for the purpose of notification on offers and Stublina Hotel Group ' news via e-mail. In such event, at any time and free of charge, you can ask for the erasure (“right to be forgotten”) from personal database for that purpose.

During and after your staying, Stublina Hotel Group will send you to your mail address satisfaction survey. Survey is filled out only with your consent.
The primary purpose of the satisfaction survey is collection of data on service for Stublina Hotel Group’ improvement of service, and Stublina Hotel Group depersonalizes and handles data from the survey for statistics purposes.

Additionally, person booking the accommodation, that is, a guest can give special permit, consent, to Stublina Hotel Group, to all his data, such as:

  • name
  • surname
  • e-mail
  • date of birth
  • country

other personal data collected during staying (such as telephone number, mobile telephone number, gender, marital status, number of children, other interests and activities during staying, means of traveling, accommodation preferences, etc.)

collects and uses for further profiling of examinees for the purpose of contacting and notifying on special and personalized offers, news and events organized by Stublina Hotel Group via on-line channel (e-mail, web, internet promotion). In this event, the examinee has right to withdraw given consent at any time, which includes handling for the purpose of profiling to the extent to which it is connected to such direct marketing, regarding initial or further handling, at any time and free of charge, as well as the right to change the data at any time, and right to be forgotten.

Data are kept in Stublina Hotel Group’ guest database for 10 years.

Personal data collected via subscription to newsletter

In the event of subscription to newsletter, the examinee will have a possibility to give, with a consent, the following additional data (not including name, and surname, and e-mail address which Stublina Hotel Group collects based on legitimate interest):

  • gender
  • date of birth
  • country, language

In the event of newsletter subscription update, the examinee will have possibility to give, with a consent, the following additional data:

  • street, home number, postal code, city
  • telephone number
  • mobile telephone number
  • interests
  • means of traveling
  • accommodation preferences

Collected data are collected based on explicit consent for the purpose of notifying about special and personalized offers, news, and events organized by Stublina Hotel Group via on-line channel (e-mail, web, internet promotion).

Data are kept in Stublina Hotel Group’  guest database for 10 years.
As the Examinee, you have right to change data and right to be forgotten. You have possibility to unsubscribe from mailing list if you no longer wish to receive our newsletter.

Cookies and internet technologies

As well as other web pages, our also uses cookies (small files we place on your computer or device when accessing our web pages, in order to provide basic or additional functionality of those pages).
Cookies help us to present to you the contents depending on your interests, so that we could provide you better user experience. 

Cookies themselves cannot reveal your identity, your name or address. Also, cookies cannot be carriers of viruses and other malicious programs. 

We use different types of cookies:

Necessary cookies– they are necessary for functioning of web page, which could not function without them. That means that web page cannot be opened or seen without them. For this type of cookies your consent is not required and therefore we don’t ask for it.

  • Functional cookies – we use them to conduct advanced analyses of web page functioning. These cookies are used for analyses of user’s behavior and based on received anonymous data, we can establish what visitors of web page most want and look, so that we are able to adapt web page and make its contents and functionality as simple as possible for usage. For this type of cookies, we ask for your consent.

  • Advertisement cookies – we use them to analyze your interests and pleasures, and they help us to present to you information that would be interesting to you and to create offer adapted to your usage of Stublina Hotel Group’ web page. For this type of cookies, we ask for your consent.

Stublina Hotel Group stores cookies in the database and saves them for 5 years at most, for the purpose of notification on special and personalized offers, news, and events that we organize via on-line channel (e-mail, web, internet promotions).

If you changed your mind regarding settings of cookies on Stublina Hotel Group’ web pages, you could always erase or block cookies by changing settings on your web browser and disable further handling of your personal data, accordingly. These setting depends on your browser.

If you block cookies, it is possible that some options on web page will not be available.

Further information on cookies and other similar technologies and how they work can be found at the following address: And at:

Social networks

Our web page can use certain elements of social networks such as Facebook, Google+, Instagram, and others, which have their own privacy policy, therefore we draw attention to getting familiar with their terms and conditions of use and privacy policy, before you give them any personal data, because Stublina Hotel Group doesn’t take responsibility for those web pages or their managing organizations.


Stublina Hotel Group  pays special attention to personal data protection of children. Personal data of minor person are handled in accordance with the Law, in a manner that is in the best interest of a minor. Every data handling of children up till age of 18 is allowed with previous exclusive consent of a parent or guardian.


You can contact us at any time for review of your personal data, as well as for update, correction, or deletion of data. Up till that moment we will use your previously recorded data for the above stated purposes.


When giving information to Stublina Hotel Group, in any form (booking, contract, etc.), you guarantee that the information you provided is accurate, that you are legally competent and authorized to dispose of such information, and that you agree completely that Stublina Hotel Group can use your data and collect them in accordance with the Law and terms and conditions of this Privacy Policy.


Stublina Hotel Group, as data handler takes care on highest organizational and technical standards of data protection and conducts appropriate measures for application of data protection principles.
Likewise, Stublina Hotel Group conducts appropriate technical and organizational measures to ensure that only personal data requested for every possible purpose of handling are handled in integrated manner. Stublina Hotel Group applies this measure to the quantity of collected personal data, range of their handling, timeframe of their keeping and their availability. More specific, with those measures it is ensured that personal data are not automatically, without individual interference, available to unlimited number of individuals.


Stublina Hotel Group, as a data handler, keeps record of personal data collection in accordance with provisions of the Law, with the following data:

  • Name and contact information of data handler
  • Purpose of handling and legal basis for handling
  • Description of category of examinees and category of personal data
  • Category of receivers that personal data are revealed or will be revealed to, including receivers in third countries or international organizations
  • Envisaged timeframe for deletion of different data categories, if possible.


In the event of personal data violation, Stublina Hotel Group, as data handler, is obliged to inform competent authority on the violation of personal data, without necessary delay and, if possible, within 72 hours of learning about that violation, unless it’s unlikely that personal data violation will cause risk for rights and freedoms of individuals. Notification delivered to competent authority holds all the information in accordance with the Law. In the event of personal data violation that probably will cause high risk for rights and freedoms of individuals, Stublina Hotel Group, as a data handler, will inform examinee on personal data violation without necessary delay. In cases when it is not legally obligatory, it will not inform examinees.


This Privacy Policy is available on web pages as well as at reception desk of our hotel. If we decide to change our Privacy Policy, changes will be set and published on web page  as well as at reception desk of our hotel.

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