1 – Purpose of the policy
The Tourist Office of Haute Maurienne Vanoise attaches great importance to respecting your privacy. This is one of the reasons why we have a specific policy relating to privacy and personal data protection.
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 and explains how we process and protect such data in relation to the services we offer. The data we collect includes information obtained offline or through our Customer Service, and online via our websites, applications (including mobile applications) and third-party platforms (“Websites”). The Policy also serves as a reminder of your rights and the procedure for exercising those rights in relation to our services.
We maintain adequate technical and organisational measures to protect your personal data from destruction, loss, alteration, disclosure or unauthorised access, be it accidental or unlawful.
This external Policy relating to privacy and the protection of personal data is published by the company SPL Haute Maurienne Vanoise Tourisme (Haute Maurienne Vanoise Tourist Office) whose head office is located at the following address: Mont-Cenis – 6 rue Napoléon – 73480 Val-Cenis – France
2 – Exercising your rights
The Data Protection Act No. 78-17 of 6th January 1978, and the European General Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th 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 the following specific rights:
• A right to access: the right to query whether we hold Personal Data concerning you and to know the nature of any such data;
• A right to rectify: the right to ask us to rectify information concerning you in the event of errors or inaccuracies;
• A right to oppose: when the data is processed on a legitimate basis, the right to object, for legitimate reasons, to the processing of your Personal Data, other than for the purpose of commercial prospection in which case no justification is required.
• A right to restrict processing: the right to ask us not to store certain items of your Personal Data for future processing, in the event that:
- You dispute the accuracy of such Personal Data;
- You consider and can establish that the Processing of such Personal Data is unlawful and that you oppose its deletion and instead demand that its Processing be restricted;
- We no longer need your Personal Data but it is still needed for the purpose of exercising or defending legal rights in court;
- You oppose the processing of your data based on our legitimate interest, during the audit as to whether the legitimate grounds prevail over your own;
• A right to delete: subject to the exceptions provided for in the Regulation, the right to have your Personal Data deleted, when one of the following reasons applies:
- Your Personal Data is no longer needed for the purpose for which it was collected or otherwise processed;
- You wish to withdraw your consent to the Processing of your Personal Data and there is no other justification for its processing;
- You oppose the Processing and there are no compelling legitimate reasons for such Processing, or you do not wish to receive commercial solicitations;
- You consider and can establish that your Personal Data has been unlawfully processed;
- Your Personal Data must be deleted in order to comply with a legal obligation;
• A right to the portability of your data: where the Processing is based on your consent or a contract, the right to receive from us the Personal Data concerning you in a structured, commonly-used format, and to send such Personal Data to another processing manager without hindrance;
• A right to withdraw your consent: when the Processing is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of the Processing performed prior to such withdrawal;
• A right to decide what happens to your Personal Data after your death: You have the right to organise the fate of your Personal Data post-mortem by adopting general or specific provisions, which we commit to follow. In the absence of such provisions, we acknowledge the right of heirs to exercise certain rights, in particular the right of access, if this is necessary for the settlement of the estate of the deceased; and the right to oppose in order to proceed with closure of the user accounts of the deceased and to oppose the Processing of their data;
You can exercise any of the above rights by writing with proof of identity:
• By e-mail to our data protection officer at: firstname.lastname@example.org
• By postal mail to the following address: 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 help identify you directly or indirectly (“Personal Data”). It usually includes information such as your name, your postal address, e-mail address and phone number, as well as other information such as your IP address, shopping habits, lifestyle or preferences. including your hobbies and interests. Health-related information falls into a “special Personal Data category” and requires specific protection because of its degree of sensitivity.
We collect your personal data directly in a variety of ways, for example when:
• You browse our Site or use the 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 pass an order or make a payment on our Site;
• You write a review or comment on our social media pages or on our Site;
• You contact us through different channels including our contact forms, by post or by phone;
• You participate in a game or contest, a product test, a satisfaction survey or an opinion poll;
• You visit one of our tourist offices;
• You share content on social media using one of the following hashtags: #instanthmv #hautemaurienne #hautemauriennevanoise or other hashtags suggested by us;
• You have given consent to third parties to send us personal data concerning you;
• You share your content with us via our UGC (User Generated Content);
When you provide us with your personal data, we process it in compliance 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 deduce in a transparent manner that you want us to process your personal data for marketing purposes. You can ask to stop receiving our marketing communications at any time, 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 beforehand, and only for a specific purpose. We will also ask you to give us an additional consent if we are to use your personal data for purposes not covered by this Policy.
Please see the following section for details of the different types of personal data we may collect, the purposes for which it is to be used and the legal basis for its processing.
4 – Personal data processing
The Haute Maurienne Vanoise Tourist Office follows the need-to-know principle, and the principle of data protection by design and by default. As a result, the Personal Data we collect is relevant, appropriate and limited to the strict necessities of the purposes for which it is processed.
In particular, this Personal Data is collected 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, or when you fill out one of our forms.
When you fill out a form, mandatory input fields are 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 your request from being processed.
When you choose to spontaneously send us your Personal Data, without having been asked to do so, you agree to take full responsibility for such Personal Data.
You are hereby informed of the existence of a “Bloctel” ex-directory list to which you can sign up in order to avoid being contacted by cold callers: https://conso.bloctel.fr/
4.1 – Nature of the personal data
Among other information, we may collect and process your full name, title, delivery address, telephone number and e-mail address, as well as information concerning your order or complaint, or the payment of invoices.
We may also collect information such as your IP address, shopping habits, lifestyle information, or preferences.
Such data is collected fairly; no data is collected without your knowledge or without your having been informed.
4.2 – Purposes
The Tourist Office of Haute Maurienne Vanoise processes your Personal Data only for specific purposes and in the appropriate manner to fulfil such purposes.
The processing of your personal data for any other purpose than those described below will require your consent if it is not a case of legitimate interest.
Among other reasons, we process your Personal Data for the following purposes:
• To respond to your queries, questions or comments, satisfy your needs and provide you with efficient support;
• To provide you with more pertinent information;
• To manage your customer account;
• To establish, maintain, manage and monitor our relationship with customers;
• To process and deliver your orders;
• For accounting purposes;
• To manage invoicing and receipts;
• To handle payment and debt collection issues;
• To send commercial or promotional material relating to similar products or services to those provided. You may oppose the use of your Personal Data for prospecting purposes, free of charge, at any time, and without justification, by following the instructions in the “Exercising your rights” section. We draw your attention to the fact that when you exercise your right to oppose, this does not prevent us from continuing to contact you for other purposes, especially when we do so by virtue of a legal obligation or for the fulfilment of the contract;
• To manage the operation and optimisation of our website; help speed up your future browsing experience on our website; evaluate user behaviour vis-à-vis our website, products and services; analyse the effectiveness of our advertising campaigns and promotions; customise your experience on our site and other platforms; make an anonymous and global assessment of the activity on our site and other platforms (in particular, we take note of the time of day when you visit, whether or not you have visited previously, and which through which site you connected to ours); make our site more user-friendly, and better adapt our site, products and services to your interests and needs;
• To manage our relationship with customers via our CRM in order to get to know you better, to customise our products and services, and to contact you about products and services that may interest you (promotional offers and events, PR events, VIP gatherings, announcements / events, etc. .), provided that you have given your consent (or that you have not expressly refused) or that you have previously requested a product or service from us and that the communication is relevant or related to such prior request and made within the time limits set by the applicable laws;
• To provide a customer service that is accessible by phone or by email;
• To make sharing tools available on our Site and/or social media;
• To proceed with the verification, identification and authentication of the personal data you have provided us with;
• To prevent and detect fraud and malware (malicious software) and handle security incidents;
• To handle any claims or disputes;
• To manage your requests for Personal Data access, rectification, opposition, deletion, restriction or portability;
• To send you satisfaction surveys or to conduct internal analyses;
• To invite you to events;
• To manage registrations for newsletters and proposed events;
• To generate analytical studies and sales statistics;
• To certify, exercise or defend a right in court, in the context of judicial, administrative or extrajudicial proceedings, whatever their nature;
• For archiving purposes;
• To ensure the conformity of our activities;
• And for all other purposes imposed by law or by the authorities.
4.3 – Legal grounds for processing data
The Haute Maurienne Vanoise Tourist Office collects and processes Personal Data only if:
• We have obtained your prior consent;
• Such processing is necessary for the fulfilment of a contract to which you are a party or the fulfilment of pre-contractual measures taken at your request;
• Such processing is necessary in order for us to meet our legal or regulatory obligations;
• Such processing is necessary for the purposes of our legitimate interests and does not unduly affect your own interests or fundamental rights and freedoms.
4.4 – Shelf life
The Tourist Office of Haute Maurienne Vanoise stores your Personal Data for the time necessary for the fulfilment of its purpose and in compliance with legal provisions for archiving, and obligations relating to the storage and/or anonymity of certain items of Personal Data.
Clients’ Personal Data unrelated to any specific contract is stored for a period of three years after the last contact. Personal Data relating to a specific contract is stored for the duration of that contract.
Once the aforementioned deadlines are reached, the Personal Data is stored in an Intermediate Archive for the appropriate legal or regulatory period. At the end of such legal or regulatory period, we undertake to delete the Personal Data from the databases or to render it anonymous.
The Personal Data of prospective clients is stored for a period of three years after the last contact and is then deleted or rendered anonymous.
4.5 – Data transfer and recipients
All items of personal information are confidential and can be accessed only by our services. They are neither transferred nor sold to third parties.
We may share your personal data with those service providers who help us with its processing, namely:
• Our advertising, marketing and promotional agencies who help us deliver and analyse 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,
• Providers of third-party services, such as web hosting,
• Web analytics providers, such as Google,
• Our service providers and/or economic partners when sharing is necessary to fulfil the above-mentioned purposes.
We require these service providers to comply with strict requirements in accordance with current data protection legislation, under which they may only process your personal data on our behalf and must comply with stringent data protection standards.
Please note that we never share your personal data with social media platforms. When we develop our audience or conduct customer correlation research via social media platforms such as Facebook or Google, your personal data is rendered anonymous before it is transferred.
If any future changes mean that we need to share your personal data with a social media platform, we will ask for your prior consent.
Please note that we may share your personal data with law enforcement agencies or other bodies when we have a legal obligation to do so or in the context of judicial assistance, a court summons, or a court order compelling us to disclose your personal data.
5 – Personal data security
The Tourist Office of Haute Maurienne Vanoise undertakes, within the framework of its activities and in accordance with the Regulations, to ensure the protection, confidentiality and security of Personal Data.
We take all necessary precautions in the light of current knowledge, taking into account implementation costs and the nature, scope, context and purpose of the Processing as well as the likelihood of each risk in order to ensure the protection and confidentiality of your Personal Data, in particular to prevent it from being distorted, deteriorated or communicated to third parties without your consent.
Consequently, we implement all the technical, logical, physical and organisational measures possible to guarantee a level of security adapted to the risk and to prevent the loss, alteration or disclosure of Personal Data or access to Personal Data by unauthorised third parties.
However, given the intrinsic nature of the Internet, no transmission of information via the Internet is entirely secure. The measures taken to protect Personal Data transmitted via the Internet do not safeguard against all risks of data misappropriation and/or breach. Therefore, when you send Personal Data, you do so at your own risk.
In accordance with the Regulation, we undertake to notify the CNIL in the event of violation of Personal Data.
6 – Transfer of personal data to countries outside the European Union
The Haute Maurienne Vanoise Tourist Office currently transfers beyond the European Union only the Personal Data of Relevant Persons located outside the European Union, under the terms and conditions provided for in the Regulation.
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 complying with the Regulation are implemented by the Importer and that you have enforceable rights and effective legal means to ensure that your Personal Data is adequately protected.
Personal Data may, for the aforementioned purposes, be transferred to countries within the European Union, to countries outside the European Union that are deemed by the European Commission to implement adequate data protection measures, and to countries outside the European Union that are not deemed by the European Commission to implement adequate data protection measures but which have provided the appropriate guarantees in compliance with the GDPR.
7 – Child privacy protection
Our products and services are not intended for children and do not target children under the age of fifteen. If you under fifteen years of age, you are prohibited from ordering products or services and sending us information about yourself.
8 – Social Media / Hypertext links
The Tourist Office of Haute Maurienne Vanoise is present on Social Media, including Facebook, YouTube and Instagram.
Consequently, you will be able to access many features, for example to sign up for our events and newsletters, add comments or share content published on your personal pages within those Social Media, etc.
For these purposes, we will process certain items of your Personal Data, including your full name and any information that is accessible to the 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 monitored by us.
The Tourist Office of Haute Maurienne Vanoise will therefore not be held responsible for the content of such websites or for the data protection practices of the third parties who operate 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 entrusting them with your personal data.
9 – Policy updates and advertising
This policy comes into effecton 25th May 2018.