Privacy Policy
Privacy Policy:
1. Purpose
This Privacy Policy (here in after the "Privacy Policy") illustrates the commitment of SELA - SOCIÉTÉ D'EXPLOITATION LUNE D'ARGENT, a simplified joint-stock company with a sole shareholder (SASU) with a share capital of €10,000, registered with the Montpellier Trade and Companies Register under number 902 018 332, with its registered office at Le Néos II, 130 rue de la Jasse de Maurin, 34070 - Montpellier (here in after the "Company"), with regard to respecting your privacy and protecting your personal data when browsing the following website: https://www.leschaletsdelobservatoire.com (here in after the "Site") published by the Company.
The Company is committed to processing the data you entrust to us in a transparent, confidential and secure manner.
In the context of processing your personal data, the Company recognises the importance of ensuring the protection and security of your privacy and personal data, and has established this Privacy Policy in accordance with the strictest personal data protection standards, as well as all applicable regulations, in particular French Law No. 2018-493 of 20 June 2018 and the General Data Protection Regulation (hereinafter "GDPR"), which came into force on 25 May 2018.
This privacy policy applies to personal information we collect through:
1. our online services: websites owned or controlled by any of us, social media pages, HTML-formatted emails, Wi-Fi connectivity and other digital channels; and
2. offline interaction: when you visit or stay as a guest at one of our establishments, attend events and activities organised by us, contact our call centre or engage in other offline interactions.
We invite you to read its contents carefully. If you disagree with the process put in place by the Company, please do not provide any personal information about yourself and stop using the Site. By continuing to provide such information, you acknowledge that you have been informed of the processing of your personal data and accept it.
We may also collect, generate, use and disclose aggregated, anonymous and other non-identifiable data related to our services, which are not considered personal information and are therefore not subject to this privacy policy.
We only collect information that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed ("data minimisation").
2. Processing of your personal data
2.1. Description of the processing of your personal data
In accordance with applicable laws and regulations, the Company, acting as data controller, collects certain personal data when you visit the Site.
When you browse our Site, information may be recorded or read on your device. We use Google Analytics audience analysis service. The information collected via Google Analytics (including IP address) enables us to track the volume, type and configuration of traffic using our Site in order to develop its design and layout. The information collected also allows us to improve your customer experience by sending personalised offers tailored to your needs.
In order to respond to your contact requests, the Company, acting as data controller, collects the following personal data:
Your first name;
Your last name;
Your email address;
Your phone number;
The content of your request.
When you subscribe to the newsletter, the Company collects the following personal data: your email address.
When you log in to the Site, the Company also collects the following personal data:
Your connection logs;
Your connection data;
Your IP address.
When you visit our establishments, we may collect information about you through closed-circuit television systems, electronic key cards and other security systems in those establishments.
The Company uses your personal data for the following purposes:
Purpose:
- Receiving and managing contact requests
- Managing and confirming your reservations including any modifications and cancellations, performing cart recovery, sending a reminder for an ongoing reservation or searches made on the Site, sending a transaction confirmation, managing payment or prepayment
- Managing newsletter subscriptions
- Managing requests for rights of access, portability, erasure, restriction of processing, rectification and objection
- Managing requests for the right to object to commercial prospecting
Legal basis:
- Processing is based on your consent
- Processing is based on the performance of the contract concluded with you when booking your room
- Processing is based on your consent
- Processing is necessary to respond to your requests to exercise your rights and is based on your consent
- Processing is necessary to respond to the request to exercise the right to object
Retention period for personal data:
- Until withdrawal of your consent or three years from the last contact with you
- Your personal data is retained for a period of 5 years from the end of your stay or the last contact with you
- Until withdrawal of your consent or three years from the last contact with you
- Up to one year from your request to exercise right(s)
- Up to three years from the exercise of your right to object
2.2. Recipients / transfers of your personal data
Access to your personal data is restricted to those persons who need your personal data to fulfil the purpose specific to the processing and to the subcontractors who support the Company's activities.
We share your personal data with the internal hotel system where you will be staying in order to process and finalise your reservation.
We disclose personal data and other data to business partners who provide goods, services and offers that enhance your experience at our establishments. By sharing certain data, we are able to provide you with personalised services and unique travel experiences. For example, this sharing enables restaurants and other points of sale in our establishments to provide you with services.
Your personal data may also be disclosed by the Company to third parties:
- if the law or legal proceedings require the Company to share your personal data;
- in response to a request from a public or judicial authority (in particular in the event of a judicial requisition);
- when the Company considers that the transmission of your personal data is necessary or appropriate to ensure the safety of persons or protect the public.
We disclose personal data to third-party service providers for the purposes described in this privacy policy. Examples of service providers include companies that provide website hosting, data analytics, payment processing, order fulfilment, information technology and related infrastructure, customer service, email and marketing.
Your personal data is therefore not transferred outside the European Economic Area.
You may access social media pages by clicking on sharing buttons provided for this purpose. The collection of information by social media sharing buttons is subject to the privacy policies of these third parties. We invite you to read the policies of these social networks to find out how your personal data is used.
We require all third parties to protect your personal data and process it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.
2.3. Security of your personal data
The Company ensures the security of your personal data by implementing appropriate technical and organisational measures to guarantee a level of security appropriate to the risk:
- pseudonymisation and encryption of your personal data;
- any means to guarantee the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- any means to restore the availability and access to personal data;
- a procedure for regularly testing, analysing and evaluating the effectiveness of the technical and organisational measures implemented.
2.4. Retention of your personal data
Your personal data is retained only for as long as necessary to fulfil the purpose for which the Company holds your personal data.
The Company may retain your personal data for a period not exceeding the statutory limitation period to fulfil its legal or regulatory obligations, in order to enable it to exercise its rights and/or for statistical or historical purposes.
At the end of the periods mentioned above, your personal data will be deleted or the Company will proceed with their anonymisation.
2.5. Your rights over your personal data
You have the following rights over your personal data:
Rights of access and rectification:
You may request access to your personal data.
You may also request the rectification of your personal data that may be inaccurate or that your incomplete personal data be completed.
You also have the right to know the origin of your personal data.
Right to erasure:
You may request the erasure of your personal data when:
1. Your personal data is no longer necessary for the purposes for which it was processed;
2. You have chosen to withdraw your consent (in cases where consent is the legal basis for processing), such withdrawal not affecting the lawfulness of processing carried out by the Company on the basis of your consent prior to its withdrawal or the lawfulness of processing based on another legal basis such as the performance of a contract between you and the Company;
3. You have objected to the processing of your personal data;
4. Your personal data has been processed unlawfully;
5. Your personal data must be erased to comply with a legal obligation; or
6. The deletion of your personal data is required to ensure compliance with applicable legislation, in particular with regard to applicable retention periods.
Right to object:
You may object to the processing of your personal data in compliance with the legal obligations imposed on the Company.
Right to restriction:
You may also request restriction of the processing of your personal data if:
1. You contest the accuracy of your personal data;
2. The Company no longer needs your personal data for the purposes of the processing; and
3. You have objected to the processing of your personal data.
Right not to be subject to a decision based solely on automated processing:
You have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, in particular based on profiling.
Right to data portability:
You may ask the Company to provide you with your personal data in a structured, commonly used, machine-readable format, or request that it be "ported" directly to another data controller under the following conditions: that the processing is based on your consent; and that the processing is carried out by automated means.
Right to withdraw your consent:
You may withdraw your consent to the processing of your personal data at any time. The withdrawal of your consent only applies to the future and does not affect the lawfulness of processing carried out by the Company on the basis of your consent prior to its withdrawal or the lawfulness of processing based on another legal basis such as the performance of a contract between you and the Company.
Right to issue advance directives regarding the processing of personal data after your death:
Pursuant to Article 85, I of the French Data Protection Act of 6 January 1978 as amended, you may define directives regarding the exercise of your rights provided for in this section after your death (in particular regarding the retention period of your personal data, their deletion and/or the communication of your personal data), and designate a person responsible for exercising these rights.
In the absence of such directives, the Company will comply with requests from your heirs, as exhaustively set out in Article 85, II of the French Data Protection Act.
Right to lodge a complaint with a supervisory authority:
If you have concerns or complaints regarding the protection of your personal data, you have the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) via the following link: Online complaints | CNIL.
The CNIL can also be reached at the following address: 3 Place de Fontenoy, 75007 Paris - phone: 01 53 73 22 22.
You are invited to inform the Company's Data Protection Officer beforehand so that they can process the request and attempt to find an amicable solution.
You may exercise the aforementioned rights and/or ask any questions relating to the processing of your personal data by contacting the Company by email at: dpo@369degree.com or by post at: Le Néos II, 130 rue de la Jasse de Maurin, 34070 – Montpellier.
To enable the Data Protection Officer to process your request as quickly as possible, you may indicate in your request its subject matter and the context in which your personal data was processed by the Company.
In case of reasonable doubt as to your identity, the Company may ask you to provide a copy (front and back) of a valid identity document. This will be deleted by the Company once your request has been fulfilled.
The Company may retain a copy of your identity document solely for the purpose of establishing proof, in the event of a dispute with you.
2.6. Links to third-party websites
In order to improve the quality of the Site, the Company may include links on the Site to third-party websites. These sites have a privacy policy that is different from and independent of that of the Company.
You are invited to consult the privacy policy of any third-party websites you visit.
2.7. Language of the Site
This Privacy Policy is written in French. In the event that it is translated into one or more foreign languages, only the French version shall prevail in the event of a dispute.
2.8. Cookies
The provisions relating to the placement of cookies on the Site are set out in the cookie policy available on the Site.
2.9. Amendments to the Privacy Policy
The Company reserves the right to make changes to this Privacy Policy at any time.
The Company recommends regularly consulting this page by referring to the date of its last modification.
In the event of significant changes to the Privacy Policy, the Company will notify you of these changes.
