Data Protection Policy

Summary

I. Personal data

II. Facebook

III. Cookies

IV.Changes to the privacy policy

1. What is the role of the Data Protection Policy?

This Data Protection Policy explains how Maisons & Hôtels Sibuet manages the personal data of its website users, whether they are customers or not (hereafter referred to as “Users”.)

I. Personal data

2. What is personal data?

According to regulation (EU) 2016/679 from the European Parliament and 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.”

3. What personal data is collected by Maisons & Hôtels Sibuet and for what purpose?

Maison & Hôtels Sibuet collects personal data on the following websites (hereafter referred to as “Websites”)

Personal data collected via the websites of the commercial brand Maisons & Hôtels Sibuet

Purpose : Enable the User to create an account on the website https://www.experience-sibuet.com

• Type of data and how it is collected : last name, first name, email, address, phone number

• Legal basis for processing the data : Performance of a contract. Required for our legitimate interests (to enable the User to create an account on the website).

Purpose : Make a booking/provide information on proposed services to someone who contacts Maisons & Hôtels Sibuet via the contact email available on the website

• Type of data and how it is collected : Last name, first name, email, phone number 

• Legal basis for processing the data : Performance of a contract Required for our legitimate interests (to develop our products or services and grow our activity)

Purpose : Book and pay a stay on the website 

• Type of data and how it is collected : last name, first name, email, address, phone number, credit card number, expiration date, CVV code

• Legal basis for processing the data : Performance of a contract Required for our legitimate interests (to book services, study how our customers use our products and services, develop our products and grow our activities)

Purpose : Allow the hotel and its services to communicate with the guest to :

- Prepare and organise the stay, provide a bespoke service

- Send out customer satisfaction surveys following a stay

- Provide communications on special offers or administrative matters, namely:

• Send important information about our establishments

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

• Send administrative information about holiday bookings, such as booking confirmations and information prior to arrival at one of Maison & Hôtels Sibuet’s hotels.

• Measure the impact of our marketing and sales actions

• Improve our products and services by having a better understanding of our customers’ expectations.

• Type of data and how it is collected : last name, first name, email, address, phone number

• Legal basis for processing the data : Performance of a contract Required for our legitimate interests (to book services, study how our customers use our products and services, develop our products and grow our activities)

Personal data collected via the online stores of the commercial brand Maisons & Hotels Sibuet :

- https://shop.experience-sibuet.com 

- http://boutique.domainedemarie.com 

- https://boutique.pure-altitude.com

Purpose : Enable the User to create an account on the online shop to :

- Order products on the online shop

- Sign up to the newsletter

- Get information on products available to purchase

- Be recontacted

• Type of data and how it is collected : Title, last name, first name, email, date of birth (optional), password

• Legal basis for processing the data : Performance of a contract (when the User places an order). Required for our legitimate interests (to develop our products or services and grow our activity)

Personal data collected via the website www.recrutement-sibuet.com

Purpose : Enable the User to make an unsolicited application for a position at Maisons & Hôtels Sibuet and enable Maisons & Hôtels Sibuet to contact the User should their unsolicited application be successful.

• Type of data and how it is collected : CV, covering letter, title, last name, first name, email and phone number

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

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

• Type of data and how it is collected : CV, covering letter, title, last name, first name, email and phone number

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

Information marked with an asterisk is required. Otherwise the User will be unable to access to our the offered services on our websites.

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

Users’ personal data is only intended for:

- Maisons & Hôtels Sibuet's departments and employees (in particular: the IT department, sales/marketing);

- Companies that assist Maisons & Hôtels Sibuet in operating and/or running the websites, in particular the departments and employees of the web hosting company :

• 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

- The subcontractors of our hotels, for instance :

• Ski school

• Activities organizers (paragliding, yoga class...)

• Taxis

• ...

These organizations only received the personal informations they need for a booking or a call back.

5. What rights do Users have regarding the personal data that is collected?

The User benefits from the rights detailed in Chapter III of the GDPR including the following rights:

- The right to access their personal data collected on the website and via the application,

- The right to change/correct their personal data,

- The right to deletion (“right to be forgotten”) of their personal data, unless we are required by law to retain it,

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

- The right to data portability, i.e. the right to request a copy of one’s personal data in a commonly-used format (a csv. file for example),

- The right to object to personal data processing,

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

To exercise any of these rights, the User can:

- with regards to all the websites of Maisons & Hotels Sibuet : send an email to the following address privacy@mhsibuet.com.

- with regards to the website http://www.recrutement-sibuet.com/: send an email to the following address privacy@mhsibuet.com.

We remind Users that they can:

- Access and modify their contact details and logins on the website :

• 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” section;

- Access and modify their contact details and logins on the website https://shop.experience-sibuet.com/index.php via the “My Account” and “My Personal Details” section.

Users also have the right to make a complaint to the CNIL (Commission Nationale Informatique et Libertés), France’s data protection body(www.cnil.fr).

However Maisons & Hôtels Sibuet would like to be given a chance to respond to your concerns before you contact the CNIL. Therefore please contact us in the first instance.

6. How long is personal data kept for?

Hotel stay and purchase records: the personal data of customers who have not reserved, stayed or purchased at one of our establishments is deleted after a period of 3 years. Data on purchases and hotel stay records is made anonymous and used exclusively for statistical purposes.

Credit card payment details: credit card numbers are automatically deleted one day after the client’s departure.

Information on hotel guests: personal data on hotel guests who do not book, stay or purchase again in one of our establishments is deleted after a period of 3 years.

Invoicing data: Invoices are archived for a period of 5 years.

Completed customer satisfaction surveys: kept with name details for a period of 3 years, then used anonymously for statistical purposes.

Recruitment data: 3 years from the most-recent date of contact

7. How is personal data protected?

Maisons & Hôtels Sibuet is extremely vigilant about the secure storage of personal data and takes all reasonable precautions aimed at preventing any unauthorised access, disclosure, alteration or destruction of personal data.

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

However these measures cannot prevent all risks of loss, access, abusive use or alteration of the personal information that is collected. When required by law, in the event of loss, access, abusive use or alteration of personal data, Maisons & Hôtels Sibuet will advise the User so the latter can take the appropriate measures to enforce their rights. Maisons & Hôtels Sibuet will advise the User by electronic means or by post or by telephone, when permitted by law.

Users are invited to not provide payment information or sensitive information by electronic means or in sections not designed for this (for example, sending a credit card number by email).

You are able to choose which personal data you provide us with.

However, your decision to not provide certain data could impair your experience of our services. For example, we are unable to take anonymous reservations and if we are not authorised to impart your personal data to the hotels in our group, we will be unable to provide you with certain services, among others booking services.

Likewise, if you do not authorise us to impart your personal data to third parties, such as our hotel subcontractors (ski school, hire car companies...), we will be unable to provide you with all of the available services or the realisation of these services could be delayed. We endeavour to respond to your request at the earliest opportunity.

II. Facebook

8. What Facebook account data does Maisons & Hôtels Sibuet have access to?

Maisons & Hôtels Sibuet only has access to the following data:

• Facebook login

• Facebook password

This data is collected to enable the User to sign into the folllowing website https://www.experience-sibuet.com.

9. What data does Maisons & Hôtels Sibuet supply Facebook with?

None of the User’s personal data is supplied to Facebook.

III. Cookies

10. What is a cookie?

According to the CNIL (the French Data Protection Commission), a cookie is a piece of information placed on the User’s means of access by the Website server or the Application they are visiting.

A cookie contains various data:

- the name of the server which placed the cookie,

- a unique ID number,

- sometimes an expiry date.

This information is sometimes stored on a means of access in a simple text file to which the server has access in order to read and save the information.

11. Which cookies does Maisons & Hôtels Sibuet use and for what purpose?

We inform Users that Maisons & Hôtels Sibuet uses cookies for the following purposes :

- record information from a form filled in by the User on the Websites (e.g. sign-up to a user account).

- enable the User to access reserved areas such as their User area, using logins or data previously provided to Maisons & Hôtels Sibuet

- log in to content or a service after a certain period of time

- Improve the security of User services/sections/areas (e.g. log in to the User Area,)

The use of cookies on the Websites is justified either because it is exclusively to enable or facilitate communicating by electronic means, or because it is required to provide an online communication service which is expressly requested by the User.

We inform Users that they have the right, at any time, to access data relating to them with regards to cookies and a right of opposition enabling them at any time to choose to enable or disable cookies.

However, should the User not accept cookies, the use of the Services (and in particular Website browsing cannot be performed correctly).

With regards to “Facebook” cookies, Maisons & Hôtels Sibuet obtains the User's prior consent/has set up a “Social Share Privacy” system

With regards to “audience measurement” cookies, please note that:

- data collected using audience measurement cookies is not cross-referenced with other data processing (customer files or statistics on visits to other websites for example),

- the data collected is only used to produce anonymous statistics,

- the data collected does not enable Maisons & Hôtels Sibuet to track the Web user's browsing on other websites,

- the IP address which can track the geographical location of the User can only identity the town/city. Cookies that can track Web users and IP addresses must not be kept beyond the 13th month after the first visit.

12. How to enable / disable cookies

At any time, Users can configure their web browser to manage, disable and enable cookies. For example:

- On a Mac smartphone or tablet: settings/select the right browser/enable cookies/never/or visited websites/or always.

- On an Android smartphone: after launching the browser, press on the menu button (left hand corner of the Mobile device)/More/Settings/Enable or disable cookies.

- On a computer:

• for Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

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

• for Chrome:https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en

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

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

or further information on managing and disabling cookies, Users can consult their browser’s help section.

If Users encounter a problem in exercising their right to access or object in relation to cookies, they can contact Maisons et Hôtels Sibuet by sending an email to the following address: privacy@mhsibuet.com

The maximum lifetime of a cookie is thirteen months.