1 – Purpose of the policy
The Tourist Office of Haute Maurienne Vanoise attaches great importance to respect for privacy. This is one of the reasons why we have a policy of confidentiality and the protection of personal data.
We are committed to protecting your privacy rights and to ensuring that your personal data is protected.
This personal data management policy (the “Policy”) details the types of personal data we collect, how we treat and protect them in relation to the services we offer. These include information collected offline or through our Customer Service and online through our websites, applications (including mobile applications) and third-party platforms (“Sites”). It also reminds you of your rights and how to exercise them with our services.
We maintain adequate technical and organizational measures to protect the personal data you provide against the destruction, loss, alteration, disclosure or unauthorized access to your personal data, whether accidentally or unlawfully.
This external policy relating to privacy and the protection of personal data is published by the company SPL Haute Maurienne Vanoise Tourism (named Tourist Office of Haute Maurienne Vanoise) whose seat is located at the following address: Mont-Cenis – 6 rue Napoléon – 73480 Val-Cenis – France
2 – Your rights and how to exercise them?
Law No. 78-17 of 6 January 1978 relating to data, files and freedoms, and the European General Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46 / EC (General Data Protection Regulation) supplementing Law No 78-17, grants you specific rights:
• A right of access: right to question us to know if we hold Personal Data about you and to ask to know them;
• Right of rectification: right to ask us to rectify information about you in case of errors or inaccuracies;
• A right of objection: when the Treatment is based on our legitimate interests right to oppose, for legitimate reasons, to a Personal Data Processing, except the commercial prospection where the motivation is not required.
• A right to the limitation of the treatment: right to ask us that some of your Personal Data are not preserved during future treatments when:
- You dispute the accuracy of your Personal Data;
- You consider and can establish that the Processing of Personal Data is unlawful and you oppose the deletion of Personal Data and instead require the limitation of the Processing;
- We no longer need your Personal Data but that it is still necessary for you to find, exercise or defend the rights in court;
- You oppose the treatment that would be based on our legitimate interest, during the audit as to whether the legitimate grounds for your claim prevail over your own;
• A right to erasure: subject to the exceptions provided by the Regulations, the right to obtain the erasure of your Personal Data, when one of the following reasons applies:
- Your Personal Data is no longer necessary for the purpose for which it was collected or otherwise processed;
- You wish to withdraw your consent on which the Processing of your Personal Data was based and there is no other basis for this treatment;
- You oppose the Treatment and there are no compelling legitimate reasons for the Treatment or you oppose the sending of commercial solicitations;
- You consider and can establish that your Personal Data has been the subject of unlawful processing;
- Your Personal Data must be erased under a legal obligation;
• A right to the portability of your data: where the Processing is based on your consent or a contract, right to receive from us the Personal Data about you in a structured, commonly used format, and to transmit such Personal Data to another treatment manager without hindrance;
• A right to withdraw your consent: when the Treatment is based on your consent, you have the right to withdraw your consent at any time, without this withdrawal affecting the lawfulness of the Processing performed prior to such withdrawal;
• Right to decide the fate of your Personal Data after your death: You have the right to organize the fate of your Personal Data post-mortem by adopting general or specific guidelines. We are committed to following these guidelines. In the absence of directives, we recognize the heirs the possibility of exercising certain rights, in particular the right of access, if it is necessary for the settlement of the estate of the deceased; and the right to object to close the user accounts of the deceased and oppose the processing of their data;
You can exercise each of these rights by justifying your identity:
• By sending an e-mail to our data protection officer at: firstname.lastname@example.org
• By sending a postal mail to the following address: the Tourist Office of Haute Maurienne Vanoise – Lanslebourg Mont Cenis – 6 rue Napoléon – 73480 Val-Cenis – France
• By following the instructions on the CNIL website at this address: https://www.cnil.fr/agir
If, despite our efforts to preserve the confidentiality of your Personal Data, you consider yourself a victim of a violation of the Regulations, you can submit a complaint to the CNIL.
3 – Personal data
Personal data refers to information that may identify you directly or indirectly (“Personal Data”). They usually include information such as your name, your mailing address and e-mail, your phone number, but also other information such as IP address, shopping habits, lifestyle information or your preferences. like your hobbies and interests. Health information is called “special categories of Personal Data” and requires special protection because of its level of sensitivity.
We collect your personal data directly in a variety of ways, for example when:
• You browse our Site or use our Services on our Site;
• You create an account, log in to your account or use your account on our Site,
• You subscribe to our newsletter;
• You make and pay an order on our Site;
• You write an opinion or comment on our social networks or on our Site;
• You contact us through different channels including contact forms, by post or by phone;
• You participate in a game or contest, product tests, satisfaction surveys, surveys;
• You visit us at one of our tourist offices;
• You share content on social networks using a hashtag #instanthmv #hautemaurienne #hautemauriennevanoise or hashtags we offer you;
• You have given consent to third parties to send us personal data about you;
• You share us your content on our UGC (User Generated Consent);
When you provide us with your personal data, we process it in accordance with this Policy. If you do not want us to process your personal data in this way, please do not provide us with personal information.
If you become a customer, we could transparently deduce that you want us to process your personal data for marketing purposes. You can always give up marketing communications without affecting your benefits as a customer.
When we process your personal data on the basis of your consent, we will explicitly ask for your consent, and only for a specific purpose. We will also ask you to provide us with additional consent if we are to use your personal data for purposes not covered by this Policy.
Please see the following section for details on the different types of personal data we may collect, the purposes for which it is to be used and the legal basis for this processing.
4 – Personal data processing
The Haute Maurienne Vanoise Tourist Office takes into account the principles of minimizing data, protecting data from the outset and protecting data by default. As a result, Relevant Personal Data is collected, adequate and limited to what is necessary for the purposes for which it is processed.
This Personal Data is collected especially when you place an order or make a reservation, when you create or modify your account, when you browse one of our Sites, when you contact us, when you participate in an event, when you fill out forms.
When you fill out input fields on a form, the mandatory nature of a response is indicated by the use of an asterisk (*) at the end of the question. The absence of an answer to a question marked with an asterisk prevents the processing of your request.
When you choose to spontaneously send us your Personal Data, without having been asked to do so, you agree to assume full responsibility for the Personal Data transmitted.
You are informed of the existence of the list of opposition to soliciting phone “Bloctel”, on which you can register here: https://conso.bloctel.fr/
4.1 – Nature of the personal data
We are required to collect and process the surname, first name, title of civility, delivery address, telephone number, e-mail, information concerning your order or any complaints and information concerning the payment of invoices.
It may also include other information such as your IP address, shopping habits, lifestyle information, or preferences.
These data are collected fairly; no collection is carried out without the knowledge of the people and without them being informed.
4.2 – Purposes
The Tourist Office of Haute Maurienne Vanoise always treats your Personal Data for specific purposes and implements only relevant treatments to achieve these purposes.
Any processing of your personal data that has a purpose other than those described below will require your consent if it is not justified by a legitimate interest.
In particular, we treat your Personal Data for the following purposes:
• Respond to your requests for information, questions, comments, satisfy your requests and provide you with effective help;
• Improve the relevance of the information addressed;
• Manage your customer account;
• Establish, maintain and manage the customer relationship and ensure its follow-up;
• Process and deliver your orders;
• Provide accounting;
• Manage billing and receipts;
• Manage payment or unpaid incidents and debt collection;
• Send commercial or promotional solicitations for products or services similar to those provided. At any time, you may object, free of charge, that your Personal Data be used for prospecting purposes, without having to justify this request by following the instructions in the section “Your rights and how to exercise them”. We draw your attention to the fact that the exercise of the right of opposition does not prevent us from continuing to contact you for other purposes, in particular by virtue of a legal obligation or for the performance of the contract;
• Manage the operation and optimization of our website, help speed up your future activities and experiences on our website, evaluate the use of our website, our products and services and analyze the effectiveness of our communication campaigns and promotions, personalize your experience on our site and other platforms and anonymously and globally evaluate the activity on our site and other platforms (we take into account the time you visited it, if you have it already visited and which site you referred to), make our site easier to use and better adapt our site, our products and services to your interests and needs;
• Manage our customer relationship via our CRM, to know you better, to personalize our products and services and to contact you concerning products and services that may interest you (promotional offers, promotional events, PR events, VIP gatherings, announcements / events, etc. .), provided that you have given your consent, (or that you have not expressed your refusal) or that you have previously requested a product or service from us and that the communication is relevant or related to this prior request and made within the time limits set by the applicable laws;
• Provide customer service accessible by phone or by courier;
• Make sharing tools available on our Site and / or social networks;
• Perform the verification, identification and authentication of the personal data you have transmitted to us;
• Prevent and detect fraud, malware or malicious software and manage security incidents;
• Manage any litigation and litigation.
• Manage your requests for access, rectification, opposition, deletion, limitation and portability on Personal Data;
• Send you satisfaction surveys or conduct internal analyzes;
• invite you to events;
• Manage registrations to newsletters and proposed events;
• Conduct analytical studies and commercial statistics;
• Find, exercise or defend a right in court, whether in the context of judicial, administrative or extrajudicial proceedings of any kind;
• Manage the archives;
• Ensure the conformity of our activities;
• And all other purposes imposed by law and the authorities.
4.3 – Treatment Lice
The Haute Maurienne Vanoise Tourist Office collects and processes Personal Data if:
• We have obtained your prior consent;
• The processing is necessary for the performance of a contract to which you are a party or the performance of pre-contractual measures taken at your request;
• Processing is necessary to comply with our legal or regulatory obligations;
• Treatment is necessary for the purposes of our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms.
4.4 – Shelf life
The Tourist Office of Haute Maurienne Vanoise keeps your Personal Data for the time necessary for the accomplishment of the purposes pursued, subject to the legal possibilities of archiving, obligations of conservation of certain Personal Data and / or anonymisation.
Personal Data of clients that are not related to a specific contract are retained for a period of three years from your last interaction. Personal Data relating to a specific contract is kept for the duration of the contract.
At the end of the aforementioned deadlines, the Personal Data are the subject of an Intermediate Archiving for the periods of legal or regulatory prescription.
At the end of the legal or regulatory prescription period, we undertake to erase the Personal Data from its databases or to anonymize them.
The Personal Data of prospects are kept for a period of three years from your last interaction and then deleted or anonymized.
4.5 – Recipients and transfer of your data
All this personal information is confidential and only accessible by our services. They are not intended to be sold or sold.
We share your personal data with the service providers who help us carry out the above treatments and in particular:
• Our advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions,
• Third parties required to deliver to you a product or service, such as a delivery or postal service delivering a product you have ordered,
• Third-party service providers, such as web hosting service providers,
• Web analytics providers, such as Google,
• Our service providers and / or economic partners when sharing is necessary to fulfill the purposes mentioned above,
We require these service providers to comply with strict requirements in accordance with the applicable data protection legislation, under which they may only process your personal data on our behalf and must comply with high standards of data protection. computer security.
Please note that we never share your personal data with social media platforms. When we develop our audience or conduct customer correspondence research activities on social media platforms such as Facebook or Google, your personal data is anonymous before the transfer.
If there are changes in the future and we need to share your personal data with a social media platform, we will ask for your consent.
Please note that we may share your personal data with law enforcement agencies or other agencies when we have a legal obligation to do so or in the case of letters rogatory, citation or a court order telling us to disclose your personal data.
5 – Security of personal data
The Tourist Office of Haute Maurienne Vanoise undertakes, within the framework of its activities and in accordance with the Regulations, to ensure the protection, the confidentiality and the security of the Personal Data.
We take the necessary precautions considering the state of knowledge, the costs of implementation and the nature, scope, context and purpose of the Treatment and the likelihood of each risk in order to maintain the safety and security of the confidentiality of the Personal Data that you communicate to him and in particular to prevent that they are distorted, damaged or communicated to thirds (except agreement on your part).
Therefore, we implement all the technical, logical, physical and organizational measures to guarantee a level of security adapted to the risk and to prevent any loss, alteration, disclosure of Personal Data or access to unauthorized third parties.
However, given the intrinsic characteristics of the Internet, any transmission of information over the Internet is not completely secure. The Personal Data transmitted are the subject of measures that can not protect against all risks of diversion and / or piracy. The transmission of your Personal Data is therefore at your own risk.
In case of violation of Personal Data and in accordance with the Regulations, we undertake to notify the CNIL.
6 – Transfers of personal data to a country outside the European Union
To date, the Haute Maurienne Vanoise Tourist Office only transfers Personal Data of Concerned Persons outside the European Union, in the terms and conditions provided for in the Regulations.
In the event that we would have to transfer Personal Data relating to Relevant Persons located within the European Union, we undertake, from this day, to verify that appropriate guarantees in accordance with the Regulations will be implemented. by the Importer and that you have enforceable rights and effective remedies to ensure that your Personal Data has an adequate level of protection.
Personal Data may, for the aforementioned purposes, be transferred to a country within the European Union, to a country outside the European Union that has been the subject of a decision of adequacy of the European Commission, as well as to countries outside the European Union that have not been the subject of a decision of adequacy by the European Commission, provided that appropriate guarantees have been at RGPD
7 – Protection of the confidentiality of children
Our products and services are not intended for children and do not target children under the age of fifteen. If you are under the age of fifteen, you are prohibited from ordering products or services and sending us information about yourself.
8 – Social Networks / Hypertext links
The Tourist Office of Haute Maurienne Vanoise is present on Social Networks, including Facebook, YouTube and Instagram.
Depending on the Social Network used, you will be able to access many features such as registration for events we offer, follow our news, comment or share content published on your personal page within the Social Network, etc. .
For these purposes, we will treat some of your Personal Data, including your last name, first name and any information made public on your personal page.
As a service to our visitors, our Site may contain hypertext links to other websites that are not operated or controlled by us.
The Tourist Office of Haute Maurienne Vanoise will therefore not be held responsible for the content of such websites or the data protection practices of third parties who exploit them. We draw your attention to the fact that third-party data protection practices may differ from those presented in this Policy. We urge you to check and understand their practices in this area before giving them your personal data.
9 – Advertising and updating the policy
This policy is effective May 25, 2018