Personal data management

Prior information

Maisons & Hôtels Sibuet is a commercial brand which brings together all the hotels concluded and managed by the Sibuet family, Le Domaine de Marie (production and sale of wine and Pure Altitude (cosmetic line). Our establishments are located in mainland France and in Saint Barthélémy. Our vocation is to offer unique and personalized lifestyle experiences by constantly adapting our services and products to the sensitivities of our customers.

This Maisons & Hôtels Sibuet personal data management policy is an appendix to the General Conditions (“General Conditions”) and therefore has contractual value. In the event of a contradiction between the T&Cs and this policy, the T&Cs will take precedence, which the user of our sites acknowledges and accepts.

This personal data management policy demonstrates the desire of the company Maisons & Hôtels Sibuet to be completely transparent with the user on the way they manage their personal data and incorporates the latest requirements from the European regulation on protection of personal data.

The person responsible for processing personal data of the company Maisons & Hôtels Sibuet is:

Mr. FRUITIER – 144 chemin du petit Darbon – 74120 MEGEVE, Email: privacy@mhsibuet.com

The personal data protection delegate for Maisons et Hôtels Sibuet is:

Mr. Frédéric MOUNIER, Email: dpo@mhsibuet.com

For any questions from the user regarding this personal data management policy, they are invited to ask their question by sending a message to privacy@mhsibuet.com

Summary

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

I.PERSONAL DATA

Article 2. What is personal data?

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

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

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

Article 6. For what duration are personal data collected?

Article 7. What measures are put in place to protect Users’ personal data?

II.FACEBOOK

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

Article 9. What data is transmitted by the company Maisons & Hôtels Sibuet to Facebook?

III.COOKIES

Article 10. What is a cookie?

Article 11. What tracking systems are used by Maisons & Hôtels Sibuet and for what purpose?

Article 12. How to authorize/deactivate cookies?

  1. CHANGES TO THE PRIVACY POLICY

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 on the way in which the company Maisons & Hôtels Sibuet manages the personal data of users of its websites, whether or not they are customers (hereinafter “ the users ").

  1. PERSONAL DATA

Article 2. What is personal data?

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, personal data is “any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); is deemed to be an “identifiable natural person” a natural person 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 specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity.”

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

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

Hotels, online reservation site and online store:

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

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

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

- https://montenvers.terminal-neige.com/fr

- https://www.altapura.fr

- https://totem.terminal-neige.com/fr

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

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

- https://www.labastidemarie.com

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

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

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

- https://booking.groupe-sibuet.com

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

Winery and online store:

- https://www.domainedemarie.com

- http://boutique.domainedemarie.com

Cosmetics and online store:

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

Recruitment site:

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

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

Purpose: To allow the user to create an account and connect to the site https://www.experience-sibuet.com

  • Data collected: Title, last name, first name, email address, postal address, telephone number
  • 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 allow 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 allow the user to be called back or recontacted by our reservation/concierge/marketing/press services, by the sales department of Domaine de Marie or Pure Altitude (depending on the nature of the need).

  • Data collected: Name, first name, email address, telephone number (optional)
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (in order to answer our customers' questions, adapt our offers to their expectations, and increase our activity)

Purpose: Allow the user to make a reservation and pay for their reservation online

  • Data collected: Name, first name, email address, postal address, telephone number, bank card identifiers, validity date, CVV code
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to book services, promote and develop our products and services and increase our business)

Purpose: To allow our hotels and our services to communicate with the customer, at different times of their stay.

- Personalization of the stay, preparation of arrival

- Sending a satisfaction questionnaire at the end of the stay

- Promotional and administrative communication, namely:

  • Sending important information about our establishments
  • Information on the evolution of our general conditions and our confidentiality policy
  • Sending administrative information regarding travel reservations, such as reservation confirmations and communications prior to arrival at a Maisons & Hôtels Sibuet hotel
  • Measuring the effectiveness of our marketing or commercial actions
  • Evolution of our products and services by better measuring the expectations of our customers
  • Data collected: Name, first name, email address, postal address, telephone number
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to book services, promote and develop our products and services and increase our business)

PERSONAL DATA COLLECTED VIA MAISONS & HÔTELS SIBUET PRODUCT SALES SITES:

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

- http://boutique.domainedemarie.com

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

Purpose: To allow the user to create an account and connect to our online product sales sites in order to:

- Manage order baskets, gift vouchers, etc.

- Track orders, returns, alerts, etc.

- Be contacted again

- Manage personal information

- Subscribe to newsletters published by Maison & Hôtels Sibuet

  • Data collected: Title, last name, first name, email address, birthday (optional), password
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to purchase products or book services, to promote our products and services, to develop them and to increase our business)

On each of the collection forms, data marked with an asterisk is essential. Otherwise, the User will not be able to access the services offered on our sites.

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

Purposes: To allow the User to spontaneously apply for a position within the company Maisons & Hôtels Sibuet. Allow the Maisons & Hôtels Sibuet company to recontact the User if their spontaneous application is accepted.

  • Data collected: CV, cover letter, Title, Name, First name, email address, mobile
  • Legal basis: Necessary for our legitimate interests (in order to recontact a person whose profile corresponds to a position within the company)

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

  • Data collected: CV, cover letter, Title, Name, First name, email address, mobile
  • Legal basis: Necessary for our legitimate interests (in order to recontact a person whose profile corresponds to a position within the company)

Data marked with an asterisk is essential. Otherwise, the User will not be able to submit applications on the site 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 services and employees of the company Maisons & Hôtels Sibuet (in particular: IT, sales/marketing, operational departments);

- companies which assist Maisons & Hôtels Sibuet in the operation and/or exploitation of the sites, and in particular the services and employees of the company which hosts the sites. These companies are:

- Subcontractors of our hotels, for example:

  • Ski schools
  • Activity organizers (sled dog outings, paragliding, yoga classes, etc.)
  • Partner restaurants
  • Shuttles, partner taxis

These structures only receive the personal information strictly necessary for making reservations and possibly calling back customers.

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

The User has access to the rights detailed in Chapter III of the GDPR, including the following rights:

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

- Right to modify/rectify them,

- Right to erasure (“right to be forgotten”), unless there is a legal reason which requires us to keep them,

- 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 one's 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 and profiling, i.e. the right to ask us to be transparent regarding any profiling we carry out or any automated decision,

All of these rights are exercised

- for all Houses & Hotels sites requesting personal information (registration forms, contact requests, reservation confirmation, etc.), by sending an email to privacy@mhsibuet.com.

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

The User is reminded that he can:

- access and modify your contact details and identifiers on the sites:

via the “My Profile” and “my personal information” section;

The User also has the right to file a complaint with the Commission Nationale Informatique et Libertés (CNIL), the supervisory authority for data protection issues in France (www.cnil.fr). Maisons & Hôtels Sibuet would, however, like to have a chance to address your concerns before we contact the CNIL. Also, contact us first.

Article 6. For what duration are personal data collected?

- History of stays and consumption: The personal data of customers who have not reserved, stayed or consumed in one of our establishments are deleted after a period of 3 years. Consumption data and stay history are anonymized and used only for statistical purposes.

- Banking data: Credit card numbers are automatically deleted one day after the customer's departure.

- Information on stay participants: The personal data of stay participants who have not re-booked, stayed or consumed in one of our establishments are deleted after a period of 3 years.

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

- Return of satisfaction questionnaires: They are kept by name for a period of 3 years, then used anonymously for statistical purposes.

- Recruitment data: The CVs of candidates not recruited are kept for 3 years.

Article 7. How are personal data protected?

Maisons & Hôtels Sibuet is very vigilant about the security of personal data and takes all reasonable precautions to prevent any unauthorized access and 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 by means of 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. In cases where the law requires it, the company Maisons & Hôtels Sibuet will notify the User of any case of loss, access, abusive use or alteration of their personal data, so as to allow them to take appropriate steps to ensure that your rights are respected. The Maisons & Hôtels Sibuet company will notify the User by electronic or postal means or by telephone, if authorized by law.

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

You have the possibility to choose the personal data you wish to provide to us.

However, your decision not to transmit certain data could alter your experience of our services. For example, we cannot make anonymous reservations and, if we are not allowed to disclose your personal data to hotels in our group, we may be unable to provide you with certain reservation or other services.

Likewise, if you do not authorize us to disclose your personal data to third parties, such as subcontractors of our hotels (ski school, car rental companies, etc.), we may not be able to provide you with all possible services or the provision of these services could be delayed. We will endeavor to respond to your request as quickly as possible.

  1. FACEBOOK

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

The company Maisons & Hôtels Sibuet only accesses the following data:

- Facebook ID

- Facebook password.

The purpose of collecting this data is to allow the User to connect to the site https://www.experience-sibuet.com/#!experiences/ete/voyages-luxe .

Article 9. What data is transmitted by the company Maisons & Hôtels Sibuet to Facebook?

No personal data of the User is transmitted to Facebook.

III. COOKIES

Article 10. What is a cookie?

According to the National Commission for Information Technology and Liberties, a cookie corresponds to information deposited on the User's means of Access by the server of the Website or Application that he is visiting.

A cookie contains several pieces of data:

- the name of the server which submitted it,

- an identifier in the form of a unique number,

- possibly an expiration date.

This information is sometimes stored on an access medium in a simple text file that a server accesses to read and record information.

Article 11. What tracking systems are used by Maisons & Hôtels Sibuet and for what purposes?

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

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

These technologies help us better understand user behavior, tell us which parts of our websites are visited, and facilitate and measure the effectiveness of advertisements 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 such identifiers as personal information.

Likewise, to the extent non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

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

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

We use this information to understand and analyze trends, administer the Site, learn user behavior 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 that customers can read. We may use this collected information to reduce or eliminate messages sent to customers.

The User is informed that he has, at any time, a right of access to data concerning him regarding cookies and of opposition allowing him at any time to choose whether or not to accept cookies.

However, if the User does not accept cookies, the use of the Services (and in particular navigation on the Sites) may not be carried out correctly.

Regarding “Facebook” cookies, the company Maisons & Hôtels Sibuet obtains the prior consent of the User.

Article 12. How to authorize/deactivate cookies?

The User can manage, deactivate and authorize cookies at any time by configuring their internet browser. For example :

- for Mac smartphone or tablet: via the Settings section/then select the browser concerned/Accept cookies/Never/or Sites visited/or Always.

- for Android smartphone: by pressing, after launching the browser, the menu button (bottom left of the Mobile Device)/More/Settings/Accept cookies or do not accept.

- for computer:

For more information on managing and deactivating cookies, the User can use the help section of their browser.

In the event of difficulty exercising their right of access or opposition to cookies, the User can contact the company Maisons et Hôtels Sibuet via the email address: privacy@mhsibuet.com

The maximum duration of a cookie is thirteen months.

  1. CHANGES TO THE PRIVACY POLICY

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

The document was last updated on February 12, 2019.

If there is a significant change to this policy, we will post on the Sites that our privacy policy has changed.

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

Any changes to this privacy policy will be effective upon posting on the Sites.

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