Privacy
policy

This privacy policy aims to outline the rules surrounding the various processing of personal data that may be implemented when you use our website accessible at the URL: www.hoteldeleurope.fr

As the data controller for your personal data, we make every effort to protect your privacy during your visits to the site.

This policy provides you with more information about the origin and use of your personal data as well as your browsing information processed when you access our website.

In the context of this Policy, the term “Personal Data” refers to any data that relates to you alone and allows you to be identified directly or indirectly, regardless of the device you are using.

The term “Device” refers to the hardware equipment (computer, tablet, smartphone, phone, etc.) that you use to access and browse the Site.

The term “Regulation” refers to the regulations relating to personal data, including Regulation (EU) 2016/679 known as the General Data Protection Regulation (GDPR), French Data Protection Act No. 78-17 of January 6, 1978, as well as French Data Protection Act No. 2018-493 on personal data protection.

By using our Site, you declare that you accept the terms of this Policy in their entirety.

If you disagree with any of these terms, you are free to stop using our Site.

This Privacy Policy is regularly updated. To ensure that you are properly informed of any significant changes in advance, we will notify you through notifications on the relevant services or by email as appropriate.

The Site will always display the most recent version of this privacy policy.

1. Protection of Your Personal Data

In accordance with the Regulation, we record all processing activities in a register of processing activities, which we make available to the relevant authorities.

All the information you may have provided to us during your visits to the Site is strictly confidential. This information is necessary for the purposes of its processing.

1.1. What Personal Data is Collected and Processed?

The information that may be collected and processed includes:

• Identification and contact details: your first name, last name, address, phone number, email address, language, and the country from which you interact with us;
• Financial and payment data: your bank details (in this regard, we inform you that all payment transactions are encrypted by the receiving bank or accredited storage center, and we do not retain any credit card numbers), information about your reservations, etc.;
• Connection, geolocation (only with your consent), and browsing data; and
• Personal preferences: this includes your cookie preferences.

When we ask you to enter your personal data to access a feature, some data are mandatory since they are necessary for you to access that feature (for example, to make a reservation, we need your first name and last name).

It is important that the personal information shared about you is correct and up to date.

We do not process any personal data that could be classified as “sensitive” (information concerning racial or ethnic origin, political, philosophical, or religious opinions, trade union membership, health, or sex life) within the meaning of the Regulation on personal data.

In this regard, please note that our Site is not intended for children, and therefore, we do not process any data related to them.

We commit not to transfer your personal data to third parties except for exceptions listed in Article 1.3.

1.2. For What Purposes are Your Personal Data Collected and Processed?

The Personal Data listed above may be collected and processed for the following purposes:

Reservation management

The processing of your data is necessary to keep you informed about the status of your reservation, the summary of your reservation, accepting your payment, etc.

Access to customer service

We process your Personal Data as part of our customer service to respond to your requests, including through the contact form.

Improvement of our services

We process your browsing and reservation data for analysis and statistics purposes. Indeed, this data allows us to analyze how you use our Site and improve its usability and quality.

Marketing

As part of your subscription to our newsletter, we process your data to manage your subscription and send you targeted information by email or SMS according to your preferences. We may also contact you via push notifications if you subscribe to this service.

Processing for marketing purposes requires your consent. Thus, you can unsubscribe from our communications at any time.

If you have given us your consent to receive our communications, whether through our newsletter or push notifications, we may use the information you have provided us for the following purposes:

• Sharing information about our events, products, current offers;
• Recommendations on certain products or services that may interest you; and
• Customer surveys to better understand your expectations regarding the products and services offered by our Site.

1.3. Who are the Recipients of Your Personal Data?

In the use of our Site, you may receive information from third parties with whom we collaborate to offer you certain services. These may include:

• Financial institutions and accredited storage centers;
• Entities for fraud detection and prevention; and
• Marketing, communication, and advertising service providers.

Personal data collected from the Site are mainly processed by the internal services of the Data Controller.

However, we may share your information with the third parties listed above for the following reasons:

• Process payments regarding financial institutions and accredited storage centers;
• Verify your credit and identity with entities for fraud detection and prevention; and
• Optimize your experience on our Site and improve our services with marketing, communication, and advertising service providers.

We ask third-party recipients of your personal data to commit to complying with the Regulation on personal data. The third parties listed above can only use your personal information according to our instructions and not for their own use.

Your connection and browsing data may also be transferred to Google Analytics.

We may also disclose your Personal Data to respond to a legal order.

1.4. How Long is Your Personal Data Retained?

We will retain your data for a period of ten (10) years following your last reservation to answer any questions, complaints, or to maintain all the necessary data to meet legal, accounting, or analytical requirements (Article L.123-22 of the French Commercial Code).

We may also retain your data for research or statistical analysis purposes; these will be anonymized.

In the case of a subscription to our newsletter, we will not contact you further if you have not opened our newsletters for more than twelve (12) months.

Any changes to this Policy will be made on this page and will be notified to you by email in the case of substantial changes.

The Data Controller may also retain your data for research or statistical analysis. These being anonymized, no retention period is imposed by the Regulation since it will no longer be possible to “re-identify” you later.

1.6. What are Your Rights?

1.6.1. Consent

Your consent must be given clearly and unequivocally. Therefore, when you agree to fill out the Site’s contact form:

• The use that will be made of your Personal Data is explained to you;
• You must check a box validating your consent; and
• Children under 13 cannot give their consent.

1.6.2. Other Rights

In accordance with the Regulation, you have the following rights over your Personal Data:

• Right to access data: This right allows you to receive a copy of the Personal Data we hold about you;
• Right to rectification: This right allows you to request the correction of inaccurate or incomplete Personal Data about you;
• Right to erasure (right to be forgotten): This right allows you to request the deletion of your Personal Data when we no longer need it for the purposes for which it was collected, or when you have withdrawn your consent and there is no other legal basis for processing it;
• Right to restriction of processing: This right allows you to limit the processing of your Personal Data in certain cases, for example, if you contest the accuracy of the data, or if you have objected to its processing, and we are verifying whether our legitimate grounds override yours;
• Right to data portability: This right allows you to receive your Personal Data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller when the processing is based on consent or contract;
• Right to object: This right allows you to object to the processing of your Personal Data for certain purposes, such as direct marketing or processing based on legitimate interests;
• Right to withdraw consent: If we process your Personal Data based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You can exercise your rights by sending a written request to the Data Controller using the contact details indicated in Article 1.5. Your request must be accompanied by a photocopy of your identity card bearing your signature in order to verify your identity. You will receive a response within one (1) month of your request.

1.7. Protection of Your Personal Data

We make every effort to implement all necessary precautions to preserve the security and confidentiality of your personal data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties.

We take the necessary steps to ensure the protection and confidentiality of your Personal Data when transferring them.

We use secure payment systems that comply with the current state of technology and the Regulation. The processing operations carried out via these payment systems are entrusted to our bank.

In accordance with the Regulation, we have put in place procedures to deal with any potential breaches of Personal Data. In the event of such a breach, we will notify you and the relevant authorities as required by law.

1.8. Cookies and Tracking

We use cookies and similar tracking technologies on our website to collect and use personal information about you. For more information about the cookies we use and how you can control them, please see our Cookie Policy.

1.9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons.

Please review this Privacy Policy regularly to stay informed about our information practices. The date at the beginning of this Privacy Policy indicates when it was last updated.

2. Internet Browsing Security

2.1. Integrity of Your Data on the Internet

The Site has appropriate security measures in place to prevent any loss, unauthorized use or access, modification, or disclosure of your Personal Data.

All personal data collected are stored on secure servers. The Data Controller has also established procedures to manage any breaches of personal data.

2.2. Malicious Activities

It is recommended that you connect only to secure networks, preferably private networks. Stay aware of the risks associated with public Wi-Fi networks.

Regardless of the Data Controller to whom you voluntarily provided your Personal Data and given the nature of the Internet network, other operators, with no connection to the Data Controller, may capture this data without your consent, especially during your internet browsing. Therefore, we recommend that you install antivirus and anti-spyware software on your computer and keep them updated regularly.

2.3. Impersonation/Phishing

The Data Controller will never solicit you via email to obtain personal information.

If you receive an email on behalf of the Data Controller requesting sensitive personal information (such as banking data or information about your private life), please do not respond to it and forward the email to us so that we can take the necessary actions.

You should only provide information related to your account after directly logging into the Site through your browser.

3. Cookie Policy

A cookie is a connection token, which is a text file that can be stored in a dedicated area of your terminal’s hard drive when you visit a website. A cookie allows its issuer to identify the terminal in which it is stored for the duration of the cookie’s validity or recording.

When you visit the Site, information about the browsing of your terminal (computer, tablet, smartphone, etc.) may be recorded through cookies installed on your terminal, subject to the choices you make regarding cookies, which you can modify at any time.

What Are the Cookies Issued on Our Site Used For?

Only the issuer of a cookie is able to read or modify the information contained in it.

When you connect to the Site, the Data Controller may, subject to your choices, install various cookies on your terminal to recognize your terminal’s browser for the duration of the relevant cookie’s validity. The cookies we issue are used for the following purposes:

• Conducting studies and establishing statistics and traffic and usage volumes for various elements of our Site (sections and content visited, user journeys), allowing the Data Controller to improve the interest and usability of its services.
• Adapting the presentation of the Site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the Site, based on the hardware and software for viewing or reading that your terminal uses.
• Implementing security measures, such as when you are asked to log in again to content or a service after a certain period of time.

3.2 Your Choices Regarding Cookies

Several options are available to you to manage cookies. Any settings you undertake may affect your internet browsing and your access conditions to certain services that require the use of cookies.

You can choose at any time to express and modify your cookie preferences using the methods described below.

You can configure your browsing software to allow cookies to be stored on your terminal or, on the contrary, to reject them, either systematically or depending on the issuer.

You can also configure your browsing software to prompt you to accept or reject cookies on a case-by-case basis before a cookie is likely to be stored on your terminal.

3.2.1. Acceptance of Cookies

The storage of a cookie on a terminal is essentially subject to the user’s will, which can be expressed and modified at any time and free of charge through the choices offered by their browsing software.

If you have accepted the storage of cookies in your browsing software, the cookies integrated into the pages and content you have viewed may be temporarily stored in a dedicated area of your terminal. They will only be readable by their issuer.

3.2.2. Refusal of Cookies

If you refuse to store cookies on your terminal or if you delete those already stored, the quality of the operation of the services offered by the Site will not be degraded.

However, you will no longer be able to benefit from certain features that may be necessary for browsing in certain areas of the Site. This would be the case if you attempted to access content or services for which the installation of cookies is strictly necessary (e.g., booking a stay). This would also be the case when the Data Controller, or its service providers, could not recognize, for technical compatibility purposes, the type of browser used by your terminal, your language and display settings, or the country from which your terminal appears to be connected to the Internet.

In such cases, the Data Controller cannot be held responsible for the consequences related to the reduced functionality of its services resulting from the inability to store or consult cookies necessary for their operation, which you have refused or deleted.

We inform you that some cookies cannot be deleted since they are strictly necessary for the technical operation of the Site.

3.2.3. How to Exercise Your Choices, Depending on the Browser You Use?

For cookie management and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your cookie preferences.

For Internet Explorer:

http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies

For Safari:

https://support.apple.com/en-gb/guide/safari/sfri11471/mac

For Google Chrome:

http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer=95647

For Firefox:

http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies

3.2.4. Deleting Your Cookies

You can delete all of your cookies or only those you want. Deleting cookies does not prevent navigation or their reinstallation during navigation. This allows you to control the cookie library of your browser at a given time. Technical cookies necessary for navigation will be reinstalled if you visit the Site.

Below, we explain the process to follow depending on your browser.

Chrome:

1. In Chrome’s menu, select “Settings.”
2. Display advanced settings.
3. Go to the “Privacy” section.
4. Click on “Content settings.”
5. In the “Cookies” section (the first section), click on “Cookies and site data.”
6. Find the cookies you want to delete and click “OK.” You can also choose to delete all your cookies.

Firefox:

1. In Firefox’s menu, go to “Tools” and then “Options.”
2. On the “Privacy” tab, click on “Show Cookies.”
3. Find the cookies you want to delete and click “Remove Cookies.”

Internet Explorer:

Internet Explorer does not allow for individual cookie management. To delete all your cookies:

1. Click on “Tools” and then “Internet Options.”
2. In the “General” tab, under “Browsing history,” click on “Delete.”
3. Check the box for “Cookies” and then click “Delete.”

Safari:

1. In Safari’s menu, select “Preferences.”
2. In the window that opens, go to the “Privacy” tab.
3. Click on “Manage Website Data.”
4. Find and select the cookies you want to delete, then click “Remove.”

3.2.5. Private Browsing

The “Private Browsing” mode, now offered by all browsers, mainly allows you to browse the Internet without keeping a history of visited pages or downloads. Regarding cookies, all those stored during your browsing will be erased when you close your browser. This is not a solution for rejecting cookies; however, their lifespan is limited to the duration of your browsing.

3.2.6. Disabling Third-Party Cookies

Disabling third-party cookies allows you to accept only cookies placed by the Site, which you also have the option to disable, delete, or limit. Here is the procedure to follow, depending on your browser, if you wish to reject third-party cookies:

Chrome:

1. In Chrome’s menu, select “Settings.”
2. Display advanced settings.
3. Go to the “Privacy” section.
4. Click on “Content settings.”
5. In the “Cookies” section (the first section), check the box for “Block third-party cookies and site data.”
6. Save the changes by clicking “OK.”

Firefox:

1. In Firefox’s menu, go to “Tools” and then “Options.”
2. On the “Privacy” tab, check the box for “Accept cookies from sites” and, for the “Accept third-party cookies” setting, select “Never.”
3. Save the changes by clicking “OK.”

Internet Explorer:

1. In Internet Explorer’s menu, go to “Internet options.”
2. In the “Privacy” tab, click on the “Advanced” button.
3. Accept first-party cookies, block third-party cookies.
4. Save the changes by clicking “OK.”

Safari:

1. In Safari’s menu, select “Preferences.”
2. In the window that opens, go to the “Privacy” tab.
3. Choose “Accept cookies” and select “Only from sites I visit.”

3.2.7. Your Choices Expressed Online Directly with Us

If you do not wish:

• for us to collect data about your browsing,
• for us, in the context of registration via a special operation, to be able to identify the original special operation,

you can choose to disable all non-essential third-party cookies for navigation on the Site.

We will then record on your terminal a cookie whose sole purpose is to disable the deposit of these cookies on your computer. This cookie will have a validity period of twelve (12) months.

Please note that the consideration of your preference is based on a cookie. If you delete all cookies stored on your terminal (via your browser), the Data Controller, or its service providers, will no longer know that you have chosen this option.

Please note that this translation is provided for informational purposes and may not be legally binding. For any legal or specific questions regarding this policy, it’s advisable to seek legal counsel or consult the original privacy policy in its official language.