1. Definition and nature of personal data
When using our software, we may ask you to provide us with personal data about you.
The term “personal data” refers to all data that identifies an individual, including their surname, first names, photograph, postal and email addresses, telephone numbers, sex, date of birth, interests, bank card number, data relating to your transactions, details of your purchases, reservations, queries and browsing history, as well as any other information you choose to provide to us about you.
3. Who collects your personal data
The body tasked with collecting your personal data is Experience Hotel, with its registered office at 128 rue la Boétie, 75008 Paris, France.
4. The collection of personal data
The legal basis for our collection of your personal data is as follows:
- There is legitimate interest insofar as you voluntarily provide us with personal data during your visit to our website, and we collect this personal data to enable us to better respond to your requests for information on our services;
- Your consent regarding social networking cookies, advertising cookies and Google Analytics cookies referred to in Article 10;
- This collection is necessary for the performance of the contract you enter into when you use our services in the software.
Your personal data is collected for one or more of the following purposes:
- Manage your access to certain services available on the software and its usage;
- Perform guest management operations for contracts, orders, deliveries, invoices, loyalty programs, guest relationship monitoring;
- Create a file for users, guests, and prospects;
- Send newsletters, requests, and promotional messages. In case you do not want this, we give you the chance to opt out when collecting and processing your data;
- Develop business and usage statistics for our services;
- Organize contests, raffles, and any promotional activities, excluding online gambling, subject to the approval of the Online Games Regulatory Authority;
- Manage feedback on products, services, or contents;
- Manage unpaid bills and potential litigation regarding the use of our products and services;
- Customize responses to your requests for information, as well as our discussions and communications;
- Fulfill our legal and regulatory obligations.
When collecting your personal data, we will inform you whether supplying certain data is compulsory or optional. Compulsory data is necessary for the services to run smoothly. Regarding optional data, it is entirely your choice whether to supply them or not. We will also inform you of the possible consequences of not providing certain data.
5. Recipients of collected data
Only our company’s staff, the departments responsible for audits (the auditor in particular), and some of our subcontractors will have access to your personal data.
Solely for the purposes of fulfilling our legal obligations, your personal data may also be sent to public bodies, as well as court officials, members of the legal or allied professions, and debt collection agencies.
6. The sale of personal data
We will not sell, lease to third parties, nor trade with them your personal data.
7. The storage period of personal data
(i) Regarding data on guest and prospects management:
Your personal data will not be stored for a time longer than is strictly necessary for managing our business relationship with you. However, data which acts as proof of a right or a contract, which we must retain to fulfill our legal obligations, will be stored within the time frame set by the law in force.
Regarding possible prospecting operations for customers, their data may be stored for three years from the end of the business relationship.
Personal data on a prospect who is not a client may be stored for three years from their collection or the last contact from the prospect.
At the end of this three-year period, we will be able to contact you again to find out if you wish to continue receiving business communications.
(ii) Concerning the management of lists of contacts who do not consent to prospection:
The information which acts as a record of your right to deny consent is stored for at least three years from when you exercised this right.
(iii) Concerning cookies:
The length of time cookies referred to in Article 10 are stored is 13 (thirteen) months.
We take all necessary precautions, organizational and technical measures to maintain the security, integrity, confidentiality of your personal data and to ensure they are not distorted, damaged, and unauthorized third parties cannot access it.
Your data is retained and stored on servers located in France (European Union), for the duration of their storage.
Cookies are text files, often encrypted, which are stored in your browser. They are created when a user’s browser loads a given website: the site sends information to the browser, which creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website’s server.
There are various types of cookies, which have different purposes:
Technical cookies are used throughout your navigation to facilitate and perform certain functions. A technical cookie can, for example, be used to memorize the answers filled in a form or the user’s language or website presentation preferences when such options are available. We use technical cookies.
Social network cookies can be created by social platforms to enable website editors to share the content of their site on these platforms. These cookies may be used by social platforms to track users’ browsing habits on the website concerned, whether or not they use these cookies. We do not use social network cookies. If we decide to do so later, we will inform you in advance and ask for your consent before using them. You will then be given the chance to find out about and accept or refuse them.
Advertising cookies can be created not only by the website the user is browsing but also by other websites which have advertisements, promotional messages, widgets, or other items on the page displayed. These cookies may be used to carry out targeted advertising, in other words, advertising based on the user’s browsing habits. We do not use advertising cookies. If we decide to do so later, we will inform you in advance and ask for your consent before using them. You will then be given the chance to find out about and accept or refuse them.
11. Accessing your personal data
In accordance with the French “Information Technology and Civil Liberties Act” and the GDPR, you have the right to access, and where appropriate, correct or delete your data by accessing your file online. You may request this by contacting:
Email address: firstname.lastname@example.org
Postal address: 128 rue la Boétie, 75008 Paris, France
Persons whose data are collected on the basis of our legitimate interest, as mentioned in Article 4, are reminded that they may at any time refuse consent to the processing of their data. We may, however, be required to continue processing data if there are legitimate grounds for it that prevails over your rights and freedoms or if processing the data is necessary to ascertain, exercise or defend our rights in court.
12. Right to issue instructions for processing data after your death
You have the right to issue instructions for the storage, deletion, and disclosure of your personal data after your death.
These instructions can be general, in that they relate to all your personal data. In this case, they must be registered with a trusted third party, certified by the CNIL (the French Data Protection Authority).
The instructions may also be specific to the data processed by our company. Please, therefore, send these to the following:
Email address: email@example.com
Postal address: 128 rue la Boétie, 75008 Paris, France
You may, in your instructions, nominate a person tasked with carrying them out. Upon your death, the nominated person will then be tasked with taking note of your instructions and asking us to carry them out. In the absence of a nominated person, your heirs will be tasked with taking note of your instructions and asking us to carry them out.
You may amend or revoke your instructions at any time by writing to us, using the above contact details.
13. The right to data portability
You have a right to receive the personal data you have provided us with, which is understood as the data you have actively and consciously declared in connection with the access and use of services, as well as data generated by your activity while using the services. Please remember that this right does not relate to data collected and processed on any other legal basis other than the consent or performance of the contract which binds us.
This right may be exercised free of charge, at any time, and when closing your account on the software so your personal data can be recovered and stored.
In this context, we will send your personal data, by any means deemed convenient, in a standard, commonly used, open and machine-readable format, in accordance with the best current practice.
14. Lodging a complaint with a supervisory authority
15. Processing restrictions
You have the right to set restrictions on the processing of your personal data in the following cases:
- During our verification period, should you dispute the accuracy of your personal data.
- If processing such data is illegal, and you want to set restrictions on this processing rather than delete your data.
- If we no longer need your personal data, but you would like to have it stored to exercise your rights.
- During the period set for verifying legitimate reasons, if you objected to the processing of your personal data.
17. User Data Usage Policy for Google API services: (The use of the application) and the transfer of information received from Google APIs to any other application will adhere to the User Data Usage Policy for Google API services, including Usage Limits requirements.
18. Entry into force