Posted on 29/04/2024




Your personal privacy is of crucial importance to us. Your trust in us is our top priority and that is why we apply this Privacy Policy to our website www.hotel-des-elmes.com (hereinafter the "Website") and to all relationships existing or not between SOC EXPLOIT DE L HOTEL DES ELMES and its customers as well as its partners. We take the protection and the privacy of the users of our website seriously and take the necessary steps to ensure they benefit from such protection. SOC EXPLOIT DE L HOTEL DES ELMES protects users' personal data in accordance with the provisions of the General Data Protection Regulation (GDPR: 2016/679).

What is a Privacy Policy? This document informs users of our Website about their personal data we collect when they visit our Website. We, therefore, undertake to comply with the confidential nature of the personal data we collect as described below. This Privacy Policy sets out the personal data we collect about users, the reason why we collect such data, the means used to collect the data, the recourse available to users to prevent the collection and the security measures taken to protect users’ personal data. Personal Data refers to any information that identifies a user, such as last names, first names, postal and email addresses, telephone numbers, etc.

SOC EXPLOIT DE L HOTEL DES ELMES may collect the personal data of any person visiting the Website who submits a question to SOC EXPLOIT DE L HOTEL DES ELMES via the Contact section of the Website or who makes a booking online or who signs up to the Website newsletter. The collection and processing of personal data submitted by users to SOC EXPLOIT DE L HOTEL DES ELMES are subject to the provisions of the General Data Protection Regulation (GDPR: 2016/679).

The Website makes a form available to users enabling them to exercise their rights to privacy protection. Click on the following link to access this form:
www.hotel-des-elmes.com/en/gdpr-form.

Please read this « Privacy Policy » in conjunction with the « Cookie Policy » of SOC EXPLOIT DE L HOTEL DES ELMES.

1 - Collection of personal data

SOC EXPLOIT DE L HOTEL DES ELMES can collect and process personal data (see personal data types below), when filling out a contact form, or other forms, on our www.hotel-des-elmes.com Website.

• Last name
• First name
• Civility
• Professional category
• Company name
• Job position
• Address
• E-mail address
• Landline/mobile number
• Curriculum Vitae
• Information about your use of the Website such as the browser type, software, hardware, location data and the web page you visited when you access the website.

In addition, SOC EXPLOIT DE L HOTEL DES ELMES automatically collects anonymous information about the use you make of our Site and its services. For example, SOC EXPLOIT DE L HOTEL DES ELMES will automatically record which parts of the Website you visit, which web browser you are using and which website you visited when you received access to the website. We cannot identify you based on these data, but they allow SOC EXPLOIT DE L HOTEL DES ELMES to compile statistics about the use of the website, website traffic and enables more targeted communication with users. The personal data we collect is gathered using the means described below in section « 2 - How we collect your personal data ».

2 - How we collect your personal data

Your personal data is collected by the following means:

• A collaboration with SOC EXPLOIT DE L HOTEL DES ELMES
• Website visit to www.hotel-des-elmes.com
• When a user creates a customer account
• The contact form(s)
• The request forms
• The use you make of SOC EXPLOIT DE L HOTEL DES ELMES
• Identity checks
• Registration for communications and newsletter (on the Website)
• Correspondence exchanged with and from SOC EXPLOIT DE L HOTEL DES ELMES
• The exchange of business cards
• Reception and exchanges with the staff of the establishment
• Opinion polls
• Cookies (for more information: « Cookie Policy »)
• Contests

The personal data collected by SOC EXPLOIT DE L HOTEL DES ELMES are therefore specifically and voluntarily provided by you.

3 - Use of personal data

www.hotel-des-elmes.com may process all or part of the data collected in order to:

• Allow Website navigation, management and traceability of services and services ordered by users.
• Optimize the user experience, quality, management, navigation and content of the SOC EXPLOIT DE L HOTEL DES ELMES Website.
• Set up a customer account and confirm this.
• Track customer/prospect relationships when booking.
• Provide SOC EXPLOIT DE L HOTEL DES ELMES goods and services.
• Improve customer service and your support needs.
• Contact you by email and/or by telephone.
• Conduct satisfaction surveys, studies, and optional surveys on the Website.
• Send targeted marketing campaigns and advertisements from SOC EXPLOIT DE L HOTEL DES ELMES, updates and promotional offers based on your preferences and your communication consent.
• Provide personalised ad content.
• Send you quotes, receipts and invoices.
• Collect statistical elements.
• Develop an offer.
• Administer a contest.
• Perform a contract entered into with SOC EXPLOIT DE L HOTEL DES ELMES.
• Prevent and fight against computer fraud (spamming, hacking,...).

4 - Confidentiality of personal data

SOC EXPLOIT DE L HOTEL DES ELMES is the only owner of the information collected on the Website. Your personal data will not be sold, exchanged, transferred, or given to third parties for any reason, without your consent, apart from that required to respond to a request and / or transaction in the framework of our customer relationship management, the provisions of SOC EXPLOIT DE L HOTEL DES ELMES services and the optimisation of such services.

5 - The data protection officer

The data protection officer in charge of collecting and processing users personal data upon setting up their account and when they browse on the Website is Brice SANNAC.

As a data controller responsible for the processing of the personal data it collects, www.hotel-des-elmes.com undertakes to respect the framework of the current legal requirements. It is incumbent on it to establish the purposes of the data processing, to provide prospects and customers, from the time they provide their consent, with full information on the processing of their personal data and to maintain a record of processing that is consistent with the reality.

Whenever the Website processes personal data, SOC EXPLOIT DE L HOTEL DES ELMES takes all reasonable measures to ensure the personal data is accurate and relevant with regard to the purposes for which the Site processes such data.

6 - Disclosure of personal data to third parties

www.hotel-des-elmes.com shall refrain from processing, hosting or transferring the data collected about its customers to a country located outside the European Union or recognised as unsuitable by the European Commission without first informing the customer. However, the Site remains free to choose its technical and commercial data processors on condition it presents sufficient guarantees with regard to the requirements of the General Data Protection Regulation (GDPR: 2016/679).

The Website doesn't sell your personal data which are therefore only used when required or for statistical purposes and analyses. We will not sell, trade, or transfer your personally identifiable information to third parties. If it is necessary for SOC EXPLOIT DE L HOTEL DES ELMES to disclose your personal data to third parties, the third party concerned will be required to use your personal data in accordance with the provisions of this « Privacy Policy ». We believe that it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, alleged fraud, situations involving potential threats to the physical security of any person, violations of our Terms and Conditions, or when the law compels us to do so.

Notwithstanding the foregoing, however, it is possible that SOC EXPLOIT DE L HOTEL DES ELMES may disclose your personal data:

• To the competent authorities when SOC EXPLOIT DE L HOTEL DES ELMES is bound to do so by law or in the context of legal proceedings or future legal proceedings and to protect and defend our rights.
• When SOC EXPLOIT DE L HOTEL DES ELMES or most of its assets are taken over by a third party, in which case your personal data, which SOC EXPLOIT DE L HOTEL DES ELMES has collected, will be among the transferred assets.

The Website undertakes to take all necessary precautions to secure your data and in particular to ensure they are not communicated to unauthorised persons. However, if an incident affecting the integrity or confidentiality of the customer's data is brought to the attention of www.hotel-des-elmes.com, it will promptly inform the customer and indicate the corrective measures taken. In addition, the Website does not collect any « sensitive data ».

The User's personal data may be processed by the Website’s subsidiaries and data processors (service providers), exclusively for the purposes of this « Privacy Policy » such as:

• The service provider in charge of the booking and payment system(s) in order to manage and validate your request.
• The service provider who develops and maintains the Website, Diadao Productive, a digital agency.

Within the limits of their respective attributions and for the purposes mentioned above, the principal persons likely to have access to data of www.hotel-des-elmes.com users are mainly the agents in our customer service.

In all other cases SOC EXPLOIT DE L HOTEL DES ELMES will not sell, rent or transmit your personal data to third parties, except when it has obtained your authorisation to do so and has entered into a contract with the third party concerned, data processing, which contains the necessary guarantees regarding the confidentiality and compliance of your personal data with the protection of your private and professional life. If you do not wish your personal data to be shared with third parties, you may object to it when this data is collected or at any time thereafter, as mentioned in section « 8 - Rights relating to the protection of your privacy ».

7 - Storage of personal data

Except when a longer retention period is required or justified by law or by compliance with another legal obligation such as the 10 year period required to retain accounting documents, SOC EXPLOIT DE L HOTEL DES ELMES will retain your personal data for a period of 18 months from the time of the last contact with the hotel for a prospect and for a period of 24 months from the date of check-out for SOC EXPLOIT DE L HOTEL DES ELMES's customers in order to achieve the objectives set out in the « Privacy Policy », under the heading « 3 - Use of personal data ».

8 - Rights relating to the protection of your privacy

In accordance with the provisions of the General Data Protection Regulation (GDPR: 2016/679), users of the Website may exercise their rights relating to the protection of privacy, as stipulated below:

• Right to access (Article 15 GDPR) and rectify (Article 16 GDPR), update, complete user data, right to lock or delete users personal data (Article 17 GDPR) when such data are inaccurate, incomplete, equivocal, out of date, or whose collection, use, communication or retention is prohibited.
• Right to withdraw consent at any time (Article 13-2c GDPR).
• Right to restrict the processing of user data (Article 18 GDPR).
• Right to object to the processing of user data (Article 21 GDPR).
• Right to the portability of the data that the users have provided, when this data is the subject of automated processing based on their consent or on a contract (Article 20 GDPR).
• Right to define the fate of the user’s data after their death and to choose to whom www.hotel-des-elmes.com will have to communicate (or not) its data to the third party it will have first designated.

As soon as the Website becomes aware of the death of a user and in the absence of instructions from the said user, SOC EXPLOIT DE L HOTEL DES ELMES undertakes to destroy this person’s data, unless these data must be retained for probative purposes or to comply with a legal obligation.

If a user wishes to exercise their rights on the Website, they can send us a notice telling us which rights they wish to exercise with respect to their personal data. This is free of charge and is performed by contacting Brice SANNAC, as Owner, by e-mail at contact@leselmes.com, or by post SOC EXPLOIT DE L HOTEL DES ELMES, Plage des Elmes 66650 Banyuls sur Mer, specifying in the subject of the email or letter « Rights relating to the protection of your privacy » or by completing the application form located at the following address: www.hotel-des-elmes.com/en/gdpr-form

In this case, the user must indicate the personal data he/she would like to correct, update or delete on www.hotel-des-elmes.com. The user must provide proof of their identity by providing a copy of their identity papers (identity card or passport). Requests to delete personal data will be subject to the obligations imposed on SOC EXPLOIT DE L HOTEL DES ELMES by law, particularly as regards the preservation or archiving of documents.

In addition, you can always update, modify and/or check, through your account, the personal data you had to submit when you set up your account. If you no longer wish to receive newsletters about our services or advertisements, you can unsubscribe at any time by clicking on the « unsubscribe » button provided in the lower part of any email from SOC EXPLOIT DE L HOTEL DES ELMES.

9 - Protection of personal data

SOC EXPLOIT DE L HOTEL DES ELMES undertakes to take reasonable, physical, technological and organisational precautions to prevent unauthorised access to your personal data, as well as the loss, misuse or alteration of your personal data. We use state-of-the-art encryption to protect sensitive information transmitted online. We also protect your offline information. Only employees who need to perform specific work (for example, billing or customer service) have access to personally identifiable information.

The data collected and stored via the Website is hosted by an external company, EHR SOFT, which provides a PMS (Property Management System) software, named VEGA, for customer relationship management. EHR Soft is a subsidiary of the QuatuHoRe group which is a specialist in hotel IT.

The VEGA software allows the definition of technical and organizational measures within the hotel to protect user data in an appropriate manner according to its nature, the extent of processing and its accessibility. The respect of your data is binding for all partners and service providers of the hotel.

Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot, therefore, guarantee absolute security.

If we become aware of a security breach, we will notify the affected users so that they can take appropriate action. Our incident reporting procedures take into account our legal obligations, whether at the national or European level. We are committed to fully informing our customers on all matters relating to the security of their account and providing them with all the information they need to help them meet their own regulatory reporting requirements.

No personal data belonging to users of the Website are published without the knowledge of the user, nor are they exchanged, transferred, assigned or sold on any media whatsoever to third parties.

10 - Update to the « Privacy Policy » statement

SOC EXPLOIT DE L HOTEL DES ELMES reserves the right to make changes to this « Privacy Policy » statement by placing a new version on the Website. Therefore, users are advised to regularly check the relevant page on the Website on which the « Privacy Policy » is published so they are fully aware of the new terms.

11 - Hyperlinks to other websites

The Site may contain hyperlinks that lead to other websites. In any case, SOC EXPLOIT DE L HOTEL DES ELMES cannot be held liable for any third party’s « Privacy Policy » or any third party’s practices relating to privacy.

12 - Consent

When using our Website, you are obliged to accept this « Privacy Policy » and the « Terms & Conditions » by checking the checkboxes present when we collect information if you wish to benefit from SOC EXPLOIT DE L HOTEL DES ELMES.

13 - Claims

If you have any complaints about the manner in which SOC EXPLOIT DE L HOTEL DES ELMES collects, uses and/or processes your personal data, you can contact us, in the first place, to resolve the issue(s). If this is not sufficient, Website users may file a complaint with the supervisory authorities at the following link: https://edps.europa.eu

14 - Contact SOC EXPLOIT DE L HOTEL DES ELMES

If you have any questions about the « Privacy Policy » or how SOC EXPLOIT DE L HOTEL DES ELMES collects, uses or processes your personal data, please contact us by e-mail at contact@leselmes.com, or by post to SOC EXPLOIT DE L HOTEL DES ELMES, Plage des Elmes 66650 Banyuls sur Mer.