Who we are

Our website address is: http://gradvinica.com.

The owner of Vinica Castle and this website is MIRAG INVEST d.o.o. We are aware, that the right to privacy is one of the most important human rights and are committed to the secure and confidential processing of personal data of its employees, guests, contracting parties, website users and other interested persons, and furthermore ensure that the personal data is processed in a legal, fair and transparent manner – by respecting individuals’ rights. 

Personal data protection policy

To put this commitment into action, MIRAG INVEST d.o.o. adopted the Rules on the Protection of Personal Data, which is harmonized with the of the European Parliament and of the Council (General Data Protection Regulation, GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council) and other applicable legislation. The Rules, in conjunction with other internal regulations and measures, represent MIRAG NVEST’s policy with which we ensure that we will collect and process personal data for specific purposes and to the smallest extent necessary and store them only for the length of time necessary to fulfill the purpose for which they were collected.

Areas of use

Our policy applies to anyone who submits any personal data: guests of Vinica Castle, employees, job candidates, buyers, suppliers, etc.

Who is affected by this policy

Generally speaking, this policy applies to anyone we work with or who acts on our behalf and may occasionally need access to personal data. It must be followed by MIRAG INVEST d.o.o. employees and employees of its subsidiary, as well as contractors, consultants and other external personal data processors.

Parts of the policy

We obtain and process personal data to be able to perform our processes. This information includes any data that enables the identification of a person, such as names, addresses, usernames and passwords, digital footprint, photographs, ID document numbers, special types of personal data, financial data, etc.

Our company collects this information in a transparent way and only with the full cooperation and awareness of the interested party. Once we have obtained this information, the following rules apply:

Our data will be:

  • Obtained honestly and only for legal purposes,
  • Accurate and up-to-date,
  • Processed within legal and moral boundaries,
  • Protected against any unauthorized or illegal access by internal or external parties.

Our data will not be:

  • Informally forwarded,
  • Stored for more than the determined time,
  • Transferred to organizations or countries that do not have suitable rules on data protection,
  • Communicated to any party that the owner of the data has not given consent to (except for the legal requirements of law enforcement authorities).

In addition to the appropriate handling of data, MIRAG INVEST d.o.o. also have direct obligations to the people who own the data. In accordance with the General Data Protection Regulation (GDPR) and other applicable legislation relating to personal data protection, MIRAG INVEST d.o.o. will, among other things:

  • Enable any interested party to find out which pieces of their personal data we collect and for what purpose, how long we store them and whether we transfer them to anyone else, etc.;
  • Enable any interested party to correct any of their incorrect personal data;
  • Delete all personal data where the conditions for deletion are met, e.g. if you withdraw your personal consent;
  • Initiate proceedings in cases of lost or damaged data or data at risk.


We are committed to performing activities such as the following for the protection of personal data:

  • Restrict and supervise access to special types of personal data;
  • Develop and perform transparent data collection procedures;
  • Train employees to be able to perform personal and technical security precautions;
  • Set up a safe network to protect personal data against cyber-attacks;
  • Establish clear procedures for reporting privacy violations or misuse of data;
  • Include contract clauses or clear instructions on how we process personal data;
  • Establish good data protection practices (clear desk and clear screen policy, document shredding, secure locking, data encryption, regular safety backups, access authorizations, etc.).

What personal data do we collect on our website? 

You can visit our website without providing your personal data. You only have to provide personal data if you order any services.

We only collect personal data when you provide it yourself, for example, when you subscribe to our newsletter, access certain content or take part in a prize draw when you fill out a form about side effects or make hotel reservations when you order services by e-mail or make an inquiry about services and similar cases where you have decided to provide us with your personal data.

In addition to the personal data you provide us with, we also collect data using cookies. This data can contain information about: the website you used to access our website, the websites you visit from our website, the duration of your visit to our websites. We immediately anonymize the last three numbers of your IP-address, which means we cannot identify you by your IP-address. With this information, we may be able to determine your identity, however, we do not do this.

For what purposes do we process the data that you provide us with through the website? 

The data you provide us or we collect via cookies is processed for the following purposes: for internal statistical purposes and for the purposes of visitor interests, but only in such a way that does not disclose your identity; for identifying server problems and for creating the website; for other purposes that you have requested and have agreed to unless prescribed otherwise by law.

Where do we store the personal data you entrust us with through the website? 

Your personal data is stored on MIRAG INVEST’s servers which we manage ourselves. If the personal data is being stored by contractual partners, they guarantee at least the same level of security as is provided by MIRAG INVEST. We will not forward your personal data in any​ form to be used by third parties, except for the company that creates our website, or if required to do so by judicial authorities. 

The Grad Vinica website is principally intended for adults. If MIRAG INVEST will create online content for minors or products and services for minors, it shall be performed in compliance with applicable legislation and consent shall be obtained from the minor’s parents or guardians.


A cookie is a small file that is stored on your device when you visit a website and is recognized by the website that issued it. The cookies are used to enable all the functionalities of the website, to customize certain content to your preferences and to improve the website by analysing visits.

The data collected via cookies is processed solely for statistical purposes and for the purposes of visitor interests, but only in such a way that does not disclose your identity, for identifying server problems and for creating the website.

Some cookies that we use are temporary, while some cookies remain stored on your device for a specific period even after you leave our website. We use temporary cookies to measure the number of website visitors and we use the stored cookies to store contact details for future visits to our website so that you do not have to register again the next time you visit the website. We also used stored cookies that originate from other websites: these are cookies from YouTube that enable you to be able to watch certain video content on our website, advertising cookies and Google Analytics cookies that we use to see how you use our website, what content you are interested in and how long you stay on our website. On this basis, we can create content for the website and customize it to the needs of visitors.

The majority of browsers automatically accepts the use of cookies. You can decline the use of cookies at any time. If you want to decline cookies on your device, you can change the browser settings on your device. You can find out more about declining cookies here, and about Google Analytics here.

Your rights

Using a request and the instructions on how to exercise your rights published on the page “Rights of the individual”, you can request at any time to access your personal data that we process, to correct them or delete them, object to their processing or limit processing.

Furthermore, you can unsubscribe from receiving promotional e-mails by clicking “Unsubscribe” in the footer of the received e-mail.


MIRAG INVEST uses technical and organizational security measures that protect your data against tampering, loss, destruction or unauthorized access. Since we are aware of its importance, security measures are also integrated into all systems and procedures dealing with personal data databases. While working with databases, we use the most up-to-date technological solutions and approaches that, in combination, ensure a high degree of security regarding the storage and processing of personal data (data encryption, data access policy, recording data accesses, etc.). The infrastructure with continuous supervision safeguards the data from any threats, including viruses and other types of malicious codes. We use systems and procedures to detect a threat, which helps protect the services and ultimately provide a high level of security.

Changes to the MIRAG INVEST website privacy policy

MIRAG INVEST reserves the right to change its website privacy policy, therefore we advise that you regularly check it. If any significant changes will be made, we will publish a notice in advance on our website.

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