The company Compagnie Culture & Développement (hereafter “CCD”) respects the privacy of its customers, website users and business partners, and treats personally identifiable information provided by them as confidential. This personal information is collected with due diligence, in accordance with all applicable laws in the countries in which CCD operates. CCD acts as a data controller for the data it collects and processes.
1. Identity of the Controller
CCD is the data controller of Personal Data.
Mailing address: Place Saint Louis, 41250 Chambord
Contact email address: firstname.lastname@example.org
2. What personal data is collected?
CCD only collects information that is adequate, relevant and limited to what is necessary for the purposes for which it is processed. CCD, therefore, collects information only to function effectively and to provide the User with the best experiences with his Website and / or Service.
The specific type of collected Personal Data depends on the context of the User’s interactions with the Site and / or its Service. Here are some examples of Personal Data that can be collected:
– Contact details (name, email address, address, phone number, fax number) ;
– Payment information (payment card, number and expiration date on PCI DSS rules, billing address and bank account information);
– Demographic data (age, sex, country, and preferred language);
– Information related to the User’s reservation (dates of arrival and departure, purchased goods and services);
– Information needed to respond to special requests and / or specific accommodations of the User (preferences, leisure activities, guest name, number of children and ages);
– Information collected through security systems (closed-circuit television systems and electronic key);
Automatic Information: When the User uses or interacts with the Site and / or uses the Service, CCD receives and stores the information generated by this activity and the information collected automatically from the browser or mobile device. For example, like many websites, CCD gets certain information when the browser accesses the Site, including your IP address, browser type, operating system, mobile network data, viewed pages, and hours of access. This information helps CCD communicate with the user and understand them better.
3. On what occasions are personal data collected?
CCD may collect Personal Data as part of the information provided directly by the User. This Personal Data is thus collected and processed on the following occasions:
– Access to the Site;
– Use of the Service;
– Subscription to newsletters and requests for brochures;
– Inquiries and other forms;
– Correspondence with CCD;
– Answers to surveys, promotions and other communications;
– Responses to job applications;
CCD takes into account the principles of minimization of Personal Data, protection from the design and protection of Personal Data by default. As a result,is collected relevant, adequate and limited information that is necessary for the purpose for which it is processed.
4. On what basis are personal data collected?
Personal Data is processed by CCD in the cases permitted by the applicable regulations, and in particular under the following conditions:
– When the concerned person has expressed free, specific, informed and unambiguous consent regarding the processing of his / her Personal Data (eg when filling out online forms on the Website or at the hotel, etc.);
– When necessary for the execution of a contract or pre-contractual measures taken at the request of the User (online hotel reservation, etc.);
– For the respect of the legal or regulatory obligations of CCD ;
– When the legitimate interests of CCD may be of a nature to warrant treatment by it (eg computer security measures).
5. Why are personal data collected?
Personal Data is collected for specific, explicit and legitimate purposes. Depending on the case, Personal Data may be used for the purpose of:
– Completion of the reservation when using the Service;
– Relationship with the User;
– Reply to requests for information;
– Internal business objectives (customer files, marketing, promotion);
– Objectives of administrative communication (management of the reservation);
CCD may also use Personal Data for any other purpose imposed by applicable law.
6. Who are the recipients of the personal data?
Personal Data is never sold.
The Personal Data that CCD collects will be strictly communicated only in these hypotheses:
– To subcontractors or third-party providers acting for CCD as part of a specific treatment in accordance with the purposes for which they were initially collected, in the context of activities such as the provision of services, the evaluation of the use of the Site, marketing, and product marketing, data management or the Service;
– Bodies responsible for control or inspection missions in accordance with the applicable regulations.
7. How is the security of personal data ensured?
CCD protects and secures Personal Data to ensure that it is secure and prevent it from being distorted, damaged, destroyed or disclosed to unauthorized third parties. All persons having access to the Personal Data are bound by a confidentiality obligation.
In particular, CCD providers and subcontractors are bound by security and confidentiality obligations prohibiting them from using Personal Data for purposes other than those for which CCD shares information with them; more specifically, they are not allowed to use the personal information of the members and/or delegates to disclose it to other third parties.
No transfer of Personal Data outside the European Union is operated by CCD.
Where the disclosure of Personal Data to third parties is necessary and/or authorized, CCD shall ensure that such third parties guarantee to the Personal Data concerned the same level of protection as that offered to them by CCD, and require contractual guarantees so that, in particular, Personal Data is exclusively processed for the purposes that you have previously accepted, with the necessary confidentiality and security.
CCD implements technical and organizational measures to ensure that Personal Data is securely stored for the time necessary to fulfill the purposes pursued in accordance with applicable law.
In accordance with the applicable French and European regulations, in the event of proven violation of the Personal Data that may create a risk for the rights and freedoms of the persons concerned, CCD undertakes to communicate this violation to the competent supervisory authority and, where required by those rules, to the persons concerned (individually or in general as the case may be).
8. How long are the personal data kept?
CCD retains the Personal Data for the time necessary to fulfill the pursued purposes, subject to the legal possibilities of archiving, obligations of retention of certain Personal Data, and / or anonymization.
CCD applies, in particular, the following retention periods for these few major categories of Personal Data:
– Personal data of customers/prospects/ business partners: as long as the User is active, member, delegate and, at the latest, three (3) years after the last contact with the latter;
– Personal data to access databases: 1 year after last login;
9. What are the rights to personal data and how to exercise them?
Right of access, rectification and erasure (or “right to forget”) of Personal Data
The right of access allows obtaining from CCD the confirmation that the Personal Data is or are not processed, and the conditions of this treatment, as well as to receive an electronic copy (for any additional copy, CCD is entitled to require the payment of reasonable fees based on administrative costs). The concerned person also has the right to obtain from CCD, as soon as possible, the correction of his Personal Data. Finally, subject to the exceptions provided for by the applicable law (eg retention necessary to fulfill a legal obligation), the person has the right to ask CCD to delete, as soon as possible, his Personal Data, when one the following reasons apply:
– Personal Data is no longer necessary for the purpose for which it was collected or otherwise processed;
– The person wishes to withdraw his consent on which the processing of his Personal Data was based and there is no other basis for this treatment;
– The person considers and can establish that his Personal Data has been the subject of unlawful processing;
– Personal Data must be erased under a legal obligation.
Right to limit the processing of Personal Data
The applicable regulations provide that this right may be invoked in certain cases, in particular, the following:
– When the accuracy of the Personal Data is disputed;
– When it is established that the processing of Personal Data is unlawful and that the limitation of the processing is requested instead of the deletion;
– When CCD no longer needs Personal Data but that it is still concerned;
– When the data subject objects to the treatment based on the legitimate interest of the controller.
Right to portability of Personal Data
Right to lodge a complaint with a supervisory authority
If despite CCD’s efforts to preserve the confidentiality of the Personal Data, the User considers that the latter is not insured, a complaint to a supervisory authority may be lodged. A list of supervisory authorities is available on the website of the European Commission.
Right to decide the fate of Personal Data after the death of the User
Finally, the User has the right to organize the fate of his Personal Data post-mortem by adopting general or specific guidelines. CCD is committed to following these guidelines. In the absence of guidelines, CCD recognizes that heirs may exercise certain rights, in particular, the right of access, if it is necessary for the settlement of the estate of the deceased; and the right to object to close the User Accounts of the deceased and oppose the processing of their Personal Data.
9.2. Procedures for exercising rights
If the application is submitted electronically, the information will also be provided electronically where possible, unless the User specifically requests otherwise.
If CCD does not respond to the request of the User, it will inform you of the reasons for its inaction and the User has the possibility to lodge a complaint with a supervisory authority and / or to form a judicial appeal. In particular, the person may file a complaint via the online complaint service on the CNIL website, or by post by writing to: CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.
To improve the user experience on the Site and the Service, CCD uses “cookies”. These do not indicate, in themselves, the User’s Personal Data, unless the User chooses to provide them (by registering for the Service for example).
11. Governing Law and Jurisdiction