Personal data management

Contents

Article 1.  What is the purpose of the Personal Data Management Policy?

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I. PERSONAL DATA

Article 2.   What is personal data?
Article 3.   What personal data does Maisons & Hôtels Sibuet collect, and for what purposes?
Article 4.   Who has access to the User’s personal data?
Article 5.   What are Users’ rights regarding the personal data collected?
Article 6.   How long is personal data kept?
Article 7.   What measures are in place to protect Users’ personal data?


II. COOKIES

Article 10.  What is a cookie?
Article 11.  What tracking systems does Maisons & Hôtels Sibuet use, and for what purposes?
Article 12.  How can cookies be enabled or disabled?


III. CHANGES TO THE PRIVACY POLICY

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Personal data management

Article 1. What is the purpose of the Personal Data Management Policy?

The purpose of this Personal Data Management Policy is to inform the User about how Maisons & Hôtels Sibuet manages the personal data of users of its websites, whether or not they are customers (hereinafter “Users”).


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I. PERSONAL DATA

Article 2. What is personal data?

Under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, personal data means “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Article 3. What personal data does Maisons & Hôtels Sibuet collect, and for what purposes?

Maisons & Hôtels Sibuet collects personal data on the following websites (hereinafter “the Sites”):

Hotels, chalets, restaurants, spas, delicatessen, online booking site and online shop:

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- https://www.fermesdemarie.com/fr

- https://www.lodgepark.com/fr

- https://www.hotelmontblanc.com/fr

- https://www.chaletsdesfermes.com/

https://www.epiceriedesfermes.com/

https://www.gypsea-beach.com/

- https://www.labastidedemarie.com

- https://saint-tropez.villamarie.fr

- https://saint-barth.villamarie.fr

- https://booking.groupe-sibuet.com  

- https://shop.experience-sibuet.com  

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Wine estate and online shop:

- https://www.domainedemarie.com

- http://boutique.domainedemarie.com

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Skincare and online shop:

- https://www.pure-altitude.com

- https://boutique.pure-altitude.com

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Recruitment site:

- http://www.recrutement-sibuet.com

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PERSONAL DATA COLLECTED VIA THE WEBSITES OF THE MAISONS & HÔTELS SIBUET BRAND

Purpose: to enable the user to receive exclusive offers from each of our hotels.

• Data collected: email address

• Legal basis: performance of a contract. Necessary for our legitimate interests (to enable the user to receive our best offers on the site).

Purpose: to enable the user to be called back or contacted by our reservations, concierge, marketing or press departments, or by the sales department of Domaine de Marie or Pure Altitude (depending on the nature of the request).

• Data collected: surname, first name, email address, phone number (optional)

• Legal basis: performance of a contract. Necessary for our legitimate interests (to answer our customers’ questions, tailor our offers to their expectations and grow our business)

Purpose: to enable the user to make a booking and pay for it online

• Data collected: surname, first name, email address, postal address, phone number, bank card details, expiry date, CVV code

• Legal basis: performance of a contract. Necessary for our legitimate interests (to book services, promote our products and services, develop them and grow our business)

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Purpose: to enable our hotels and departments to communicate with the customer at various points during their stay.

- Personalisation of the stay, preparation for arrival

- Sending a satisfaction survey at the end of the stay

- Promotional and administrative communications, namely:

• Sending important information about our establishments

• Information on changes to our terms and conditions and our privacy policy

• Sending administrative information about travel bookings, such as booking confirmations and communications before arrival at a Maisons & Hôtels Sibuet hotel

• Measuring the effectiveness of our marketing and sales activities

• Developing our products and services by better understanding our customers’ expectations

• Data collected: surname, first name, email address, postal address, phone number

• Legal basis: performance of a contract. Necessary for our legitimate interests (to book services, promote our products and services, develop them and grow our business)

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PERSONAL DATA COLLECTED VIA THE ONLINE SHOPS OF THE MAISONS & HÔTELS SIBUET BRAND


- https://shop.experience-sibuet.com

- http://boutique.domainedemarie.com

- https://boutique.pure-altitude.com

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Purpose: to enable the user to create an account and log in to our online shops in order to:

- Manage shopping baskets, gift vouchers, etc.

- Track orders, returns, alerts, etc.

- Be contacted

- Manage personal information

- Subscribe to newsletters published by Maisons & Hôtels Sibuet

• Data collected: title, surname, first name, email address, date of birth (optional), password

• Legal basis: performance of a contract. Necessary for our legitimate interests (to purchase products or book services, promote our products and services, develop them and grow our business)

On each collection form, fields marked with an asterisk are mandatory. Otherwise, the User will not be able to access the services offered on our sites.

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PERSONAL DATA COLLECTED VIA THE WEBSITE WWW.RECRUTEMENT-SIBUET.COM

Purposes: to enable the User to submit a speculative application for a position at Maisons & Hôtels Sibuet, and to enable Maisons & Hôtels Sibuet to contact the User if their application is shortlisted.

• Data collected: CV, cover letter, title, surname, first name, email address, mobile number

• Legal basis: necessary for our legitimate interests (to contact a person whose profile matches a position within the company)

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Purpose: to enable the user to apply for a specific job offer on the website http://www.recrutement-sibuet.com/

• Data collected: CV, cover letter, title, surname, first name, email address, mobile number

• Legal basis: necessary for our legitimate interests (to contact a person whose profile matches a position within the company)

Fields marked with an asterisk are mandatory. Otherwise, the User will not be able to submit applications on the website www.recrutement-sibuet.com.

Article 4. Who has access to the User’s personal data?

The only recipients of Users’ personal data are:

- the relevant departments and employees of Maisons & Hôtels Sibuet (in particular IT, sales/marketing and operations);

- the companies that assist Maisons & Hôtels Sibuet in operating the sites, in particular the departments and employees of the company hosting the sites. These companies are:

• Amazon Web Services, Inc. P.O. Box 81226 Seattle, WA 98108-1226, http://aws.amazon.com

• Opwan, 150, Rue Pierre et Marie Curie 34430 Saint Jean de Vedas, www.opwan.com

- Our hotels’ subcontractors, for example:

• Ski schools

• Activity organisers (dog sledding, paragliding, yoga classes…)

• Partner restaurants

• Partner shuttles and taxis

• …

These organisations receive only the personal information strictly necessary to take bookings and, where applicable, contact customers.

Article 5. What are Users’ rights regarding the personal data collected?

The User has the rights set out in Chapter III of the GDPR, including the following:

- Right of access to their personal data collected on the Website and via the Application,

- Right to modify/rectify it,

- Right to erasure (“right to be forgotten”), unless there is a legal reason requiring us to retain it,

- Right to restriction of processing, i.e. the right to ask us, in certain cases, to suspend the processing of personal data,

- Right to data portability, i.e. the right to request a copy of their personal data in a common format (for example, a .csv file),

- Right to object to the processing of personal data,

- Rights relating to individual decision-making and profiling, i.e. the right to ask us to be transparent about any profiling we carry out or any automated decision-making,

All these rights may be exercised:

- for all Maisons & Hôtels sites requesting personal information (registration forms, contact requests, booking confirmations, etc.), by sending an email to privacy@mhsibuet.com.

- for the website http://www.recrutement-sibuet.com/: by sending an email to privacy@mhsibuet.com.

The User is reminded that they can:

- access and modify their contact details and login details on the sites:

• https://www.experience-sibuet.com

• https://booking.groupe-sibuet.com  

• https://shop.experience-sibuet.com

• http://boutique.domainedemarie.com

• https://boutique.pure-altitude.com

via the “My Profile” and “My personal information” sections;

The User also has the right to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the supervisory authority for data protection matters in France (www.cnil.fr). However, Maisons & Hôtels Sibuet would appreciate the opportunity to address your concerns before you contact the CNIL, so please contact us first.

Article 6. How long is personal data kept?

- Stay and consumption history: the personal data of customers who have not booked, stayed or made a purchase at one of our establishments is deleted after 3 years. Consumption data and stay history are anonymised and used solely for statistical purposes.

- Bank details: credit card numbers are automatically deleted one day after the customer’s departure.

- Information about other guests on the stay: the personal data of guests who have not booked, stayed or made a purchase again at one of our establishments is deleted after 3 years.

- Billing data: invoices are archived for 5 years.

- Satisfaction survey responses: these are kept in named form for 3 years, then used anonymously for statistical purposes.

- Recruitment data: CVs of unsuccessful candidates are kept for 3 years.

Article 7. How is personal data protected?

Maisons & Hôtels Sibuet is highly vigilant about the security of personal data and takes all reasonable precautions to prevent any unauthorised access to, or disclosure, alteration or destruction of, personal data.

The personal data collected is stored by Maisons & Hôtels Sibuet or its service providers and is protected by physical and electronic access controls, firewall technologies and other reasonable security measures.

However, such measures cannot prevent all risks of loss, access, misuse or alteration of the personal information collected. Where required by law, Maisons & Hôtels Sibuet will notify the User of any loss, access, misuse or alteration of their personal data, so that they can take the appropriate steps to enforce their rights. Maisons & Hôtels Sibuet will notify the User electronically, by post or by telephone, where permitted by law.

The User is advised not to send payment information or sensitive information by email or in sections not intended for this purpose (for example, sending a credit card number by email).

You can choose which personal data you wish to provide to us.

However, your decision not to provide certain data may affect your experience of our services. For example, we cannot make anonymous bookings and, if we are not authorised to disclose your personal data to the hotels in our group, we may be unable to provide certain booking or other services.

Similarly, if you do not authorise us to disclose your personal data to third parties, such as our hotels’ subcontractors (ski schools, car hire companies…), we may not be able to provide the full range of possible services, or the provision of these services may be delayed. We will endeavour to respond to your request as quickly as possible.

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II. COOKIES

Article 10. What is a cookie?

According to the Commission Nationale de l'Informatique et des Libertés, a cookie is a piece of information placed on the User’s device by the server of the Website or Application they are visiting.

A cookie contains several pieces of data:

- the name of the server that placed it,

- an identifier in the form of a unique number,

- possibly an expiry date.

This information is sometimes stored on a device in a simple text file, which a server accesses to read and record information.

Article 11. What tracking systems does Maisons & Hôtels Sibuet use, and for what purposes?

The User is informed that Maisons & Hôtels Sibuet uses the following tracking tools:

Maisons & Hôtels Sibuet websites, online services, interactive applications, email messages and advertisements may use “cookies” and other technologies such as pixel tags and web beacons.

These technologies help us better understand user behaviour, show us which parts of our websites have been visited, and facilitate and measure the effectiveness of advertising and web searches.

We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information under local law, we also treat these identifiers as personal information.

Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this privacy policy.

Maisons & Hôtels Sibuet also uses cookies and other technologies to remember personal information when you use our website, online services and applications.

Our aim in these cases is to make your experience more convenient and personal. For example, knowing your country and language helps us to offer a personalised and more useful marketing experience.

We use this information to understand and analyse trends, administer the site, understand user behaviour on the site, improve our products and services, and gather demographic information about our user base as a whole. Maisons & Hôtels Sibuet may use this information in its marketing and advertising services.

Pixel tags allow us to deliver targeted advertising messages in a format customers can read. We may use the information collected to reduce or eliminate the messages sent to customers.

The User is informed that they have, at any time, a right of access to data concerning them in relation to cookies, and a right to object, allowing them to choose at any time whether or not to accept cookies.

However, if the User does not accept cookies, the Services (and in particular browsing the Sites) may not work properly.

For "Facebook" cookies, Maisons & Hôtels Sibuet obtains the User’s prior consent.

Article 12. How can cookies be enabled or disabled?

The User can manage, disable and enable cookies at any time by configuring their web browser. For example:

- on an Apple smartphone or tablet: via Settings, then select the browser concerned / Accept cookies / Never / or From visited sites / or Always.

- on an Android smartphone: after launching the browser, press the menu button (bottom left of the Mobile Device) / More / Settings / Accept cookies or not.

- on a computer:

• Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

• Safari: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html

• Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

• Firefox: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

• Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

For more information on managing and disabling cookies, the User can refer to their browser’s help section.

If the User has any difficulty exercising their right of access or objection regarding cookies, they may contact Maisons & Hôtels Sibuet at: privacy@mhsibuet.com

The maximum lifespan of a cookie is thirteen months.

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III. CHANGES TO THE PRIVACY POLICY

Maisons & Hôtels Sibuet reserves the right to change, modify or revise this policy at any time.

This document was last updated on 12 February 2019.

In the event of a significant change to this policy, we will indicate on the Sites that our privacy policy has been amended.

If we make material changes to the way we use your personal data, we will notify you by email at the address in your account (where applicable) or by means of a notice on the home page of our Sites, while giving you the option to refuse this new use.

Any change to this privacy policy will take effect when it is published on the Sites.

Your use of our Sites after these changes come into effect constitutes acceptance of this privacy policy under the new published terms.

Les Chalets des Fermes, Megève