Privacy Policy – Les espaces Rocroy

Introduction

Les Espaces Rocroy operates a Hotel which provides Clients with Accommodation(s) and related services, namely through the Website(s) www.lesespacesrocroy.fr. The ultimate objective of our teams is your satisfaction and the trust you place in us. In this spirit and in compliance with your expectations, we have adopted a rigorous personal data protection policy, aligned with the requirements of the General Data Protection Regulation (GDPR). This policy illustrates our commitment to you and is intended to provide a general overview of our privacy practices.

The processing of personal data, as detailed below, is carried out regarding Accommodation(s) booking offered via its Website(s) www.lesespacesrocroy.fr. The processing operations mentioned in this privacy policy do not systematically involve personal data in the strict sense of the legislation relating to the protection of privacy (law of January 6, 1978 or European regulation GDPR).

In order to allow the Customer to make a Reservation(s) directly with the establishment, Les Espaces Rocroy provides a Booking Engine which allows Users to check availability according to multiple criteria (dates, price , room categories, etc.) and book a stay and other optional services.

The Booking Engine is a crucial tool regarding the relationship between the Client and Les Espaces Rocroy,it is therefore important to first specify that Les Espaces Rocroy does not own the Booking Engine, it is a solution operated by an independent service provider, namely the company D-edge. By clicking on the “Book now” or “Search” button highlighted on the Website(s), the Client is redirected to a page of the Booking Engine (sometimes integrated into the Website(s) as “iframe”). When you use the Booking Engine your data is collected and used by the company D-edge, we strongly invite you to first consult their confidentiality policy available at the following link https://www.d-edge.com/fr/mentions-legales/.

Les Espaces Rocroy organizes its activity in compliance with the principle of data minimization which consists of collecting only necessary personal data (data minimization), we inform you when a collection is not strictly necessary.

Definitions

The terms defined in this Privacy Policy supplement or clarify the terms defined in the General Conditions.

Booking Engine : Software solution allowing customers to make a Reservation(s) online, directly with the establishment, based on room availability (checked in real time) and a multitude of criteria (example: price, dates, types of bedroom).

Website(s) : Websites whose domain name belongs to Les Espaces Rocroy and offering Accommodation(s) booking of the establishment.

Accommodation(s) and related services : rooms, meeting rooms and various main and related services and products that the User(s) can order, purchase, rent, reserve or consume from Les Espaces Rocroy.

Accommodation(s) booking : Online order, purchase, payment or booking services for different products and services on the Booking Engine.

Reservation(s) : The order of a Service or Product available and completed via the Booking Engine.

User(s) : Anyone using a Website(s) or the Booking Engine.

Recipient(s) : Any natural or legal person who receives personal data from Les Espaces Rocroy, this may include Les Espaces Rocroy employees or external entities (for example: partners, banking establishments, etc.).

Personal data : 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 a reference to an identifier, such as name, identification number, location data, online identifier, or one or more factors that are specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Purpose(s) : The main objectives assigned to the processing and the substantial functions implemented.

Data subject : User(s) or Customers whose Personal Data is collected and integrated into the Processing of the Personal Data of Les Espaces Rocroy.

Controller : The company Les Espaces Rocroy is the entity responsible for processing personal data for the processing activities listed in this privacy policy and carried out as part of the Accommodation(s) booking offered via the Booking Engine and its Website(s), unless otherwise indicated or explicitly stated.

Processor : Any natural or legal person who processes Personal Data on behalf of Les Espaces Rocroy.

Personal data processing: Any operation or set of operations relating to Personal Data, regardless of the process used, such as collection, recording, organization, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, broadcast or any other form of making available, reconciliation or interconnection, as well as blocking, erasure or destruction.

Transparency and detailed information

First of all, transparency is expressed by reminding you what information you are entitled to access regarding the processing activities. Therefore, in case you consider that information is missing or is not sufficiently clear in this Privacy Policy, we invite you to contact our DPO who will endeavor to answer your questions.

The information relating to the processing activities of your personal data that we share with you:

The identity and contact details of the data controller.
Contact details of the data protection officer.
Recipients or categories of recipients.
Where applicable, the legitimate interests pursued by the data controller or by a third party.
Where applicable, the fact that the controller intends to transfer personal data to a third country or to an international organization.
The duration of data retention.
The existence of the right to request from the controller access to your personal data, rectification or erasure thereof, or the restriction of processing relating to the data subject, or the right to object processing and the right to data portability.
Where applicable, the existence of the right to withdraw consent at any time.
The right to lodge a complaint with a supervisory authority.
The information on whether the requirement to provide personal data is of a regulatory or contractual nature or whether it conditions the conclusion of a contract and whether the data subject is obliged to provide the personal data, as well as the possible consequences of non-provision of this data.
The existence of automated decision-making, including profiling.
The information about any further processing of personal data for a purpose.
The data controller and the objectives of collecting this data (purposes).
The legal basis for data processing.
The mandatory or optional nature of the data collection in order to manage your request and the reminder of the categories of the processed data.
The source of the data (when other data than those provided via the online service are used to process your request).
The categories of data subjects.
The recipients of the data (in principle, only our company, unless otherwise specified when transmission to a third party is necessary).
The duration of data retention.
Security measures (general description).
The possible existence of data transfers outside the European Union or automated decision-making.
Your rights and how to exercise them.

Data sources

Data subjects

The Accommodation(s) booking offered by Les Espaces Rocroy requires you to communicate certain information to enable you to make a Reservation(s). All personal data is then provided to us in general by you, the data subject concerned by the processing. You can also share certain information of your own volition in order to benefit from a better quality of service during the Accommodation(s) and related services (ex : special diet). In this case, be sure to only communicate the strictly necessary information, including in free text fields (for example the “message” field in a form). Likewise during your communication with our Customer Service, via our contact form, our messaging or any other solutions that we use, social networks or specialized service providers.

Other User(s)

In order to respect the principle of minimizing the processing of personal data, the email of the people accompanying you is not required during the Reservation(s), consequently, Les Espaces Rocroy cannot enter directly into contact with the accompanying persons. Therefore, we ask you to ensure the accuracy of the data that you may share with us concerning them, and then to share with them, as soon as possible, the link to this Privacy Policy page, in order to inform them about the processing of their data and their rights.

Automatically

When browsing our Website(s) or using the Booking Engine, certain information about you is automatically collected.

Accessible to the public

For Professional Clients or Partners, certain publicly accessible legal data, concerning the legal entity for which they act, may be provided by specialized partners.

Partners

Commercial partners.

Service Provider(s)

Accommodation(s) booking involves using external service providers such as the Booking Engine. In certain situations, these service providers may be required to send us certain information about you, mainly in order to finalize a Reservation(s).

Processing activities

The purposes of the processing activities are based on the following legal bases described in the General Data Protection Regulation (GDPR): your consent (which you can withdraw at any time), performance of a contractual or pre-contractual obligation, legal duty, legitimate interest.

Reservation(s) via the Booking Engine

Purpose

Allow the User(s) to search for and, then,complete and manage their Reservation(s) online as smoothly and comfortably as possible. To clarify, this involves any communication relating to your Reservation(s) (confirmations, reminders, invoicing, modifications).

Subsequent Purpose(s): Proposals for services closely linked to the Reservation(s) of Accommodation(s) and related services (e.g.: additional proposals, anniversary date offers).

Legal basis

6.1.b – the processing is necessary for the performance of a contract to which the data subject is a party or for the execution of pre-contractual measures taken at the request of the data subject.

Data provision requirement

The Reservation(s) cannot be finalized if the required data is not communicated by the User(s).

Categories of data likely to be processed

Reservation – Customer information: Title, First name, Last name, Email, Nationality, Telephone number, Country of residence, Postal address (optional), Age (for children)
Reservation – Accompanying person information (optional): Title, First name, Last name, Age (for children)
Reservation – Contact information: Email, Telephone number

Payment is made by the User(s) directly to our Booking Engine partner offering the payment gateway D-edge, Les Espaces Rocroy does not intervene in the processing of your data related to payment (Payment – Credit Card: Name of holder, Card number, Expiry date, CVC/CVV), we invite you to consult the privacy policy on the following page (https://www.d-edge.com/fr/mentions-legales/).

Storage duration

5 years from the date of the last Reservation(s).

Customer service

Purpose

The aim of Customer Service is to assist you during your Reservation(s) and each time you contact us for any other reason relating to your Reservation(s) (modifications, complaints, special requests, etc.).

Legal basis

6.1.a – the data subject has consented to the processing of his or her personal data for one or more specific purposes.

Data provision requirement

Les Espaces Rocroy cannot provide customer support if the required data is not provided.

Categories of data likely to be processed

Reservation – Customer information: Title, First name, Last name, Email, Nationality, Telephone number, Country of residence, Postal address (optional), Age (for children)
Reservation – Contact information: Email, Telephone number

Storage duration

5 years from the date of your last request for assistance.

Communication

Purpose

The Les Espaces Rocroy teams may use the contact details you provide to contact you (via email, text message, chat, telephone, courier, etc.) on their own initiative or in response to actions or requests from you or of the Accommodation provider(s). For example, if you have started your Reservation(s) online but not completed it, our teams can offer you their help to finalize it, to invite you to leave a comment on Les Espaces Rocroy, to send you information relating to your Reservation(s), or to check inappropriate behavior.

Legal basis

6.1.f – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless overridden by the interests or fundamental rights and freedoms of the data subject which require protection.

Storage duration

5 years from the date of our last communication.

Accounting and taxation

Purpose

We keep invoices and other mandatory documents as part of your Reservation(s), which may include your personal data, in order to meet our general accounting and taxation obligations.

Legal basis

6.1.c – the processing is necessary for compliance with a legal obligation to which the data controller is subject.

Categories of data likely to be processed

Reservation – Customer information: Title, First name, Last name, Email, Nationality, Telephone number, Country of residence, Postal address (optional), Age (for children)

Storage duration

10 years from the end of the current accounting year.

Safety and prevention

Purpose

Ensuring the security of User(s) data is a priority concern for Les Espaces Rocroy, Specifically, this involves detecting and preventing any suspicious events on the Website(s).

Legal basis

Categories of data likely to be processed

Browsing: Media type (computer, mobile, tablet, etc.), Display format, IP address, Browser, Language, Connection timestamp, Conversion tunnel, referring URL
Logging: User Activities, Identifiers, Connection Timestamps, IP Address

Storage duration

6 months from the date of the last activity.

Data sharing

Les Espaces Rocroy shares your data with third parties, within the limits of what is necessary in order to achieve the purposes of each processing.

With our advisors

In certain cases, we may share certain strictly necessary personal data about you with our advisors (internal or external). This may involve, for example, law firms (themselves subject to an obligation of confidentiality) in the case of litigation management or to simply respond to a complaint.

With the authorities

In certain cases, when the law or any other legal obligation requires it from us, or in order to defend our rights, we are required to share certain strictly necessary personal data concerning you with certain authorities.

Data retention and transfer

We have chosen to store the majority of data with providers whose servers are located in France and Switzerland and which ensure one of the highest levels of data security on the market.

The hosting of the Website(s) as well as the optimization and security of the databases are provided by our subcontractor Planethoster (head office: 4416 Louis-B. Mayer Laval, Quebec Canada H7P 0G1, (+1 ) 855 774 4678), we control the main parameters of the platform including the choice of data location in France and Switzerland:

We invite you to consult Planethoster data protection policy (https://www.planethoster.com/fr/Politique-Vie-Privee) for further details on the security measures implemented and the documentation relating to compliance.

We may transfer data outside the European Union, either on the basis of a so-called adequacy decision of the recipient’s country, or on the basis of appropriate guarantees implemented by the recipient.

For each processing the data is kept for the period necessary for the specific purpose of the processing (according to the form provided in the register of “processing activities”). Additional retention period may be added to this initial period according to the legal requirement applicable to the processing in question, during which the data is kept in intermediate archives with restricted access. At the end of the established retention periods, we delete the personal data from our databases.

Security measures

We pay particular attention to the confidentiality and security of your personal data. Les Espaces Rocroy has established an authorization management policy, this is an organizational security measure aimed at regulating access to the information system by all of our teams (employees and service providers). This measure helps to strengthen the protection of your personal data against any illegitimate access, in order to preserve their confidentiality and integrity.

We have put in place a whole series of technical measures (example: pseudonymization, anonymization, firewall, database backups) to ensure the availability of your data.

Personal data relating to children

Les Espaces Rocroy does not offer any Accommodation(s) booking to people under the age of 18 ans, these young people cannot make any Reservation(s). the User(s) must be at least 18 years old to access the Accommodation(s) booking of Les Espaces Rocroy. Les Espaces Rocroy may only process children’s personal data when it has been transmitted by, or with the consent of, one of the parents (or legal guardians).

Exercise your rights

Data subjects have the right to request from the controller access to personal data, rectification (completed, clarified, updated) or erasure thereof, or restriction of processing personal data relating to the concerned person, or the right to object to the processing and the right to data portability (within the conditions set by the regulation).

The protection of your personal data is a priority, In order to facilitate the exercise of your rights, we have made several means of communication available to you, so you can:

Write us a message at the following email address: dpo@dfc.com.
Send us a letter to the following postal address: Les Espaces Rocroy, 13, rue de Rocroy – 75010 Paris.
Contact us via the form available on the website: https://www.lesespacesrocroy.fr/exercise-your-rights/.

We will tell you if it is necessary to attach documents to your request in order to confirm your identity (your identity document, for example).

Submit a complaint

You have the right to lodge a complaint with a supervisory authority, the supervisory authority in France is the CNIL.

Postal address: CNIL – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, France
Telephone: +33 (0)1 53 73 22 22
Submit a complaint online at the following link: CNIL (service des plaintes)

General

The French language version of this privacy policy shall be controlling in all respects and shall prevail in case of any inconsistencies with translated versions, if any. Any other language versions of this privacy policy are provided for convenience only.