Personal data management

Preliminary information

Maisons & Hôtels Sibuet is a commercial brand that encompasses all the hotels owned and managed by the Sibuet family, Le Domaine de Marie (wine production and sales), and Pure Altitude (cosmetic line). Our establishments are located in metropolitan France and Saint Barthélemy. Our mission is to offer unique and personalized art-de-vivre experiences by constantly adapting our services and products to our customers' sensibilities.

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

This personal data management policy demonstrates the Maisons & Hôtels Sibuet company's desire to be completely transparent with the user regarding how it manages their personal data and incorporates the latest requirements from the European General Data Protection Regulation.

The data controller for the Maisons & Hôtels Sibuet company is:

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

The data protection officer for the Maisons et Hôtels Sibuet company is:

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

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

Table of Contents

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 the Maisons & Hôtels Sibuet company and for what purposes?

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

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

Article 6. For how long is personal data collected?

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

II. FACEBOOK

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

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

III. COOKIES

Article 10. What is a cookie?

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

Article 12. How can I authorize/disable cookies?

  1. MODIFICATION OF 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 about how the Maisons & Hôtels Sibuet company manages the personal data of users of its websites, whether they are customers or not (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 27 April 2016, personal data is "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 is collected by the Maisons & Hôtels Sibuet company and for what purposes?

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

Hotels, online booking site and online store:

- https://www.fermesdemarie.com/

- https://www.hotelmontblanc.com/

- https://www.lodgepark.com/

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

- https://www.labastidedemarie.com/

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

- https://www.chaletsdesfermes.com/

- https://www.relais-desfermes.com/

- https://www.relais-montblanc.com/

- https://www.levieuxmegeve.fr/

Wine estate and online store:

- https://www.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 log in to the https://www.experience-sibuet.com site

  • Data collected: Title, last name, first name, email address, postal address, phone number
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to allow 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 allow 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 departments, or by the commercial department of Le Domaine de Marie or Pure Altitude (depending on the nature of the need).

  • Data collected: Last name, first name, email address, phone number (optional)
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to answer our customers' questions, adapt our offers to their expectations, and grow our business)

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

  • Data collected: Last name, first name, email address, postal address, phone, bank card identifiers, expiration date, CVV code
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to reserve services, promote our products and services, develop them, and grow our business)

Purpose: To allow our hotels and our departments to communicate with the customer at different stages of their stay.

- Personalization of the stay, preparation of arrival

- Sending a satisfaction questionnaire after the stay

- Promotional and administrative communication, namely:

  • Sending important information about our establishments
  • Information on changes to our general terms and conditions, our privacy policy
  • Sending administrative information regarding travel reservations, such as reservation confirmations and communications before arrival at a Maisons & Hôtels Sibuet company hotel
  • Measuring the effectiveness of our marketing or commercial actions
  • Developing our products and services by better measuring our customers' expectations
  • Data collected: Last name, first name, email address, postal address, phone
  • Legal basis: Performance of a contract. Necessary for our legitimate interests (to reserve services, promote our products and services, develop them, and grow our business)

PERSONAL DATA COLLECTED VIA THE PRODUCT SALES SITES OF THE MAISONS & HÔTELS SIBUET COMMERCIAL BRAND:

- http://domainedemarie.com

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

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

- Manage order baskets, gift vouchers, etc.

- Track orders, returns, alerts, etc.

- Be recontacted

- Manage personal information

- Subscribe to newsletters published by Maison & Hôtels Sibuet

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

On each of the collection forms, data marked with an asterisk is mandatory. 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 submit a spontaneous application for a position within the Maisons & Hôtels Sibuet company. To allow the Maisons & Hôtels Sibuet company to recontact the User if their spontaneous application is accepted.

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

Data marked with an asterisk is mandatory. Otherwise, the User will not be able to submit applications on the www.recrutement-sibuet.com site.

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

The only recipients of the Users' personal data are:

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

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

- Our hotels' subcontractors, for example:

  • Ski schools
  • Activity organizers (dog sledding trips, paragliding, yoga classes, etc.)
  • Partner restaurants
  • Partner shuttles, taxis
  • ...

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

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

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

- Right to access their 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 ground obliging 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 their personal data in a standard 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 regarding any profiling we perform or any automated decision,

All of these rights can be exercised

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

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

The User is reminded that they can:

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

via the "My Profile" and "my personal information" section;

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

Article 6. For how long is personal data collected?

- History of stays and consumption: The personal data of customers who have not booked, 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 booked, stayed, or consumed again 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 in nominative form for a period of 3 years, then used anonymously for statistical purposes.

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

Article 7. How is personal data protected?

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

The personal data collected is stored by the Maisons & Hôtels Sibuet company 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 Maisons & Hôtels Sibuet company will notify the User of any case of loss, access, misuse, or alteration of their personal data, so as to allow them to take the appropriate steps to enforce their rights. The Maisons & Hôtels Sibuet company will notify the User by electronic or postal means or by phone, if the law authorizes it.

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

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

Nevertheless, your decision not to transmit certain data could alter your experience of our services. For example, we cannot process anonymous bookings and, if we are not authorized to disclose your personal data to the hotels in our group, we may be unable to provide you with certain services, whether booking-related or otherwise.

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

  1. FACEBOOK

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

Maisons & Hôtels Sibuet only accesses the following data:

- Facebook ID

- Facebook password.

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

Article 9. What data is transmitted by 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 French Data Protection Authority (CNIL), a cookie is information placed on the User’s access 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 expiration date.

This information is sometimes stored on an access device in a simple text file that a server accesses to read and save 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 behavior, tell us which parts of our websites have been 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 by 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 goal in these cases is to make your experience more convenient and personal. For example, knowing your country and language helps us offer a personalized and more useful marketing experience.

We use this information to understand and analyze trends, administer the site, learn about 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 send 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 they have, at all times, a right of access to their data regarding cookies and a right of objection allowing them to choose whether or not to accept cookies at any time.

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

Regarding "Facebook" cookies, Maisons & Hôtels Sibuet obtains the User's prior consent.

Article 12. How can cookies be authorized/disabled?

The User can manage, disable, 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 relevant browser / Accept cookies / Never / or From visited sites / or Always.

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

- for computer:

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

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

The maximum lifespan of a cookie is thirteen months.

  1. MODIFICATION OF THE PRIVACY POLICY

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

The date of the last update to this document is February 12, 2019.

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

If we make material changes to how we use your personal data, we will notify you by email at the address provided in your account (if applicable) or by means of a notification on the homepage of our Sites, while giving you the opportunity to refuse this new use.

Any change made to this Privacy Policy will take effect at the time of its publication on the Sites.

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