Le Cloître and its website www.lecloitre.com take special care to ensure the protection its customers’ personal data.
We are committed to respecting European Regulation 2016/679 of 27 April 2016 regarding the protection of personal data, as well as Law No. 2018-493 of 20 June 2018 regarding the protection of personal data.
This Policy applies to all data processing carried out by Le Cloître and its website www.lecloitre.com.
This Policy is an integral part of the Terms and Conditions. Capitalized terms in this Policy have the same definition as in the General Conditions. By using the services of Le Cloître and/or the website www.lecloitre.com, you agree to the collection and use of your personal data as described in this Policy.
This Policy may be updated. In this case, we will indicate the date of the last update at the bottom of this Policy. Your consent will be systematically required if the update of this privacy statement affects in any way our rights to use your personal data, as defined in the provisions of this Policy, at the time data collection.
Table of Contents
- What data is being processed?
- When is your personal data collected?
- Who is responsible for collecting and processing data?
- For what purposes is your personal data processed?
- Who are the recipients of personal data?
- How long is personal data retained?
- How is the data secured?
- The transfer of data outside the European Union
- What are your rights and how can you exercise them?
1. What data is being processed?
Le Cloître ensures it only collects data that is strictly necessary in view of the reason for which it is processed.
When your data is collected through a questionnaire, information that is obligatory to provide is indicated by an asterisk or by an equivalent means. Failure to provide this data will make it impossible for Le Cloître to process your request.
We may collect and process the following types of data:
- Data that you transmit directly, including:
- Contact information (e.g. last name, first name, phone number, email address);
- Personal information (e.g. date of birth, nationality);
- Information about your children (e.g. first name, date of birth, age);
- Your credit card number (for transaction and reservation purposes);
- Your dates of arrival and departure;
- Your preferences and interests (e.g. smoking or non-smoking room, preferred floor, type of bedding, type of periodicals, sports, cultural interests);
- Your questions, comments and/or opinions during or following a stay in one of our institutions.
Data collection for persons under 18 years is limited to their name, nationality and date of birth, which can only be provided by an adult. Please make sure that your children do not send us any personal data without your authorization (especially via the Internet). In the event that this type of data sharing happens, you can contact the Personal Data Officer (see Article 10 “What are your rights and how do you exercise them?”) in order for this information to be deleted.
We do not deliberately collect sensitive data, such as information regarding racial or ethnic origins, political opinions, religious and philosophical beliefs, membership to unions, health details, or sexual orientation.
In addition, depending on applicable local laws, other information may be considered sensitive, including: your credit card number, your personal activities and your hobbies, whether you are a smoker or not, etc. We may collect this type of information to satisfy your requests or to provide you with appropriate services, such as a specific diet.
In this case, and in accordance with the laws in effect in certain countries, your prior agreement may be required for the collection of sensitive data.
Data collected automatically
We may record data usage when you access our website www.lecloitre.com (or use it in any way).
During each of your visits, and in accordance with the applicable legislation and with your consent, we may, if necessary, collect information about the devices you use to access our services or about the networks through which you access our services, such as your IP address, connection data, types and versions of Internet browsers used, types and versions of browser plugins, operating systems and platforms, clickstream data, including the URL of the page from which you access our platform, and the content you access or view.
Among the technologies used to collect this information, we use the cookies described in detail in Article 8 below.
2. When is your personal data collected?
Personal data may be collected on various occasions, including:
- Hotel activities:
- Room reservation;
- Registration and payment;
- Consumption at the hotel bar or hotel restaurant during your stay;
- Requests, claims and/or litigation;
- Participation in marketing programs or events:
- Registration in customer loyalty programs;
- Participation in satisfaction surveys;
- Contests or online games;
- Subscription to newsletters, in order to receive offers and promotions by email;
- Transmission of information from third parties:
- Tour operators, Travel agencies, Booking systems by GDS and others;
- Internet activities:
- Connection to www.lecloitre.com sites (IP address, cookies);
- Online data collection forms (online booking, questionnaires, Le Cloître pages on social networks, connecting devices such as Facebook Login).
3. Who is responsible for collecting and processing data?
The subscription, access and/or use of certain services involve the processing of personal data.
The person in charge of the processing of users’ personal data is SNC Hôtel du Cloître, a general partnership with a capital of 25,000 euros. Its head office is located at 7-9-11 rue de la République, 13200 Arles, and it is registered on the Tarascon Trade and Companies Registy under number 532 699 063.
SNC Hôtel du Cloître, the person responsible for data processing, is conscientious of the trust you place in it by giving it your personal information for the use of its services. SNC Hôtel du Cloître attaches the greatest importance to the confidentiality and security of this information.
As such, SNC Hôtel du Cloître agrees to comply with this Policy, which you accept when you subscribe to its products or use its services.
4. For what purposes is your personal data processed?
The data processing carried out by Le Cloître is done according to an explicit, legitimate and determined purpose, which is based on the execution of our services, on the respect of legal or regulatory obligations, and on the legitimate interest in business development.
Depending on how you interact with us or with our platform, your personal data will be processed for the following purposes:
We collect your personal data in order to:
- Provide products and services
Processing personal data enables us to provide you with the services you have ordered.
The processing of this data is strictly necessary for the proper execution of our services and allows us to fulfil our obligations towards our customers.
This data allow us to:
- Manage room reservations and accommodation requests;
- Manage your stay at the hotel, including:
- Follow your consumption (phone use, bar purchases);
- Ensure the management of room access;
- Know and manage our customers’ preferences and requirements;
- Manage our relationship with our customers before, during and after your stay;
- Manage our customer loyalty program;
- Ensure the internal management of the list of customers who have behaved inappropriately during their stay at the hotel (e.g. assault and incivility, non-compliance with the hotel contract, non-compliance with security rules, theft, damage and vandalism or payment disputes);
- Improve our services, such as:
- Adapt our products and services to better respond to your requests;
- Personalize our offers and relational messages;o Predict and anticipate future behaviors;
- Conduct segmentation operations based on your booking history and on your travel habits, in order to send you targeted marketing offers;
- Conduct cross-checks, analyses and combinations, via a trusted third party, of your data collected during your booking or your stay, in order to determine your interests and your customer profile, and to enable us to send you personalized offers;
- Secure and improve your use of the site website www.lecloitre.com (including the improvement of site navigation, the implementation of security and the prevention of fraud);
- Comply with legal and regulatory requirements:
Le Cloître may be required to collect certain personal data necessary to comply with all the legal and regulatory obligations to which it is subject, as the case may be.
Your data is necessary in particular for the pursuit of legitimate interests by Le Cloître, such as:
- To establish and retain legal documents in accordance with applicable laws and regulations;
- To detect and prevent potential threats to the security of our customers;
- To prevent fraud or any other unlawful action and to comply with our legal obligations;
Le Cloître may process your data for marketing purposes.
Le Cloître is committed to offering you products and services that are constantly adapted to your wishes, chiefly by email or SMS.
Insofar as you have given us your prior consent, we will be able to use your personal data, under the conditions explained herein, to keep you informed of developments regarding our products and services and to offer you products and services.
However, when collecting information that may be used to keep you informed about our products and services, you will always be given the opportunity to accept or refuse that this information be used for marketing purposes. In addition, each email that we send contains an unsubscribe link allowing you to automatically discontinue this type of communication. If you choose to unsubscribe, you will be removed from the corresponding mailing list within a reasonable period time.
5. Who are the recipients of personal data?
Le Cloître is aware of the sensitivity of your data and treats it with the greatest care. Data will only be communicated to third parties if strictly necessary for processing.
Le Cloître only shares your data with the third parties mentioned in this article in the following cases:
- In order to provide you with the best service, we may share your personal data with and give access to authorized staff members of Le Cloître, such as:
- Hotel staff;
- Reservation staff;
- IT services;
- Medical services, if necessary;
- Legal services, if necessary;
- Generally, any appropriate staff member of Le Cloître, for certain types of personal data;
- Le Cloître may communicate information to persons with whom it negotiates, fulfils or concludes contracts, service contracts concluded with a third party to whom important operational functions are entrusted, or at the time of the review or development of any type of contract or transaction between its affiliates, on the condition that this information is necessary for the operations concerned. Third-party recipients of this information are also subject to an obligation of confidentiality and to the provisions of the General Data Protection Regulation;
- Le Cloître may also communicate your personal data to external service providers (such as IT sub-contractors, international call centers, banks, credit card issuers, external lawyers, routers, printers), whose operations are strictly necessary to achieve one of the aforementioned purposes. Le Cloître ensures that these third parties guarantee the integrity, confidentiality and security of your data when it is processed;
- When you have expressed consent to the business partners of Le Cloître, to receive promotional offers from them;
- To local authorities if required by law or as part of an investigation, in accordance with local regulations;
- When Le Cloître has the legal obligation to do so or if Le Cloître believes in good faith that it is necessary to respond to any claim against it, to comply with any legal request, or to guarantee the rights, property and security of Le Cloître and/or its website www.lecloitre.com, its members and more generally any third party.
Le Cloître cannot be held responsible for the content of websites linked to its websites, their level of security or their applied privacy practices.
In accordance with applicable laws and with your consent when required, Le Cloître may aggregate data concerning you and that Le Cloître receives from or sends to its business partners, such as all or part of your personal data and information collected through cookies. This aggregated information will only be used for the purposes described above.
Your data will not be transferred for purposes other than those described in Article 4 of this Policy, except with your express permission, which may be withdrawn at any time.
6. How long is personal data retained?
As regards data concerning the management of our business relationship:
- Your personal data will not be stored beyond the time strictly necessary to manage our business relationship;
- Regarding possible survey operations, your data may be kept for a period of up to three years from the end of the business relationship. At the end of this three-year period, we will be able to contact you again to determine whether you wish to continue receiving commercial solicitations. You retain the option to withdraw your consent at any time, as specified in Article 9 of this Policy.
As regards data concerning your credit cards:
- Financial transactions concerning the payment of purchases and fees via our platform are entrusted to an external payment service provider that ensures their security and smooth functioning. This provider collects and retains the time of your registration on our platform and, at least until you carry out your last transaction, and in our name and on our behalf, your personal data concerning your credit card numbers. We do not have access to this data. By ticking the box specifically provided for this purpose on our platform, you give us your express consent for the preservation of this data.
- Data concerning the visual cryptogram or CVV2 registered on your credit card is not stored.
Generally, your data is conserved for the time necessary to fulfil the purpose for which it was collected, as defined in this Policy. It will be deleted subsequently. By way of exception, this data may be archived to manage current claims and litigations, and to meet our legal and/or regulatory obligations and/or to respond to requests from authorities authorized to make such a request.
7. How is the data secured?
Le Cloître ensures the security of your data by implementing data protection enhanced by the use of physical and logical security measures to ensure the integrity of your data as well as their confidential and secure processing. More specifically, Le Cloître systematically encrypts your personal data as they travelling over networks to ensure their confidentiality and prevent them from being intercepted by unauthorized third parties.
The servers on which your data is stored are located in closed computer rooms and access to which is restricted to the necessary persons. This access is strictly controlled to prevent any data theft. Logical access control is granted only to automatic processes and to employees who need to access the data to process it.
We use different cookies on the site to improve its interactivity and that of our services.· What is a “cookie”?
- Different sources of cookies
Cookies for the site www.lecloitre.com
These cookies are stored by the site website www.lecloitre.com on your device for the navigation on our site and for the optimization and customization of our services on the site. These cookies do not identify you, and if they do, they are deleted when you leave the webpage without ever being uploaded on a server.
These cookies are used to obtain information about your use of the website www.lecloitre.com. These cookies are necessary for the proper functioning of the site. They can at times identify the user.
These are cookies deposited by third-party companies (for example, advertising agencies or partners) in order to measure our site traffic, to identify your centers of interest through the products consulted or purchased, and to personalize our advertising offers for you on our sites or outside them.
These features use third-party cookies that are stored directly by these services. On your first visit on www.lecloitre.com, a banner informs you of the presence of these cookies and invites you to indicate your preferences. They are only stored if you accept them or continue browsing the site by visiting another webpage of www.lecloitre.com.
- Accepting or refusing cookies
There are different ways to manage cookies.
Your Internet browser settings
You can disable cookies through your Internet browser settings, by following the instructions below:
- If you use Internet Explorer: http://windows.microsoft.com/en/windows7/how-to-manage-internet-cookies-explorer-9
- If you use Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- If you use Safari: https://support.apple.com/guide/safari/privacy-sfri35610/mac
- If you use Google Chrome: https://support.google.com/chrome/answer/95647?hl=f
Platform settings for managing cookies
You can manage certain third-party cookies by using cookie management platforms offered by advertising professionals.
9. The transfer of data outside the European Union
As a general rule, Le Cloître retains personal data within the European Union.
Nevertheless, the site website www.lecloitre.com may transfer certain personal data to countries outside the European Union (“Third Countries”), for example in cases where our service providers are located in Third Countries. This may be the case with Third Countries for which the European Commission has not taken a decision of “adequate protection,” for example. In this case, Le Cloître ensures that the transfer is carried out in accordance with the applicable regulations, and guarantees a sufficient level of protection for the privacy and fundamental rights of the persons concerned (as defined specifically by the standard contractual clauses of the European Commission).
Le Cloître can provide you with more information about these transfers (including the standard contractual clauses of the European Commission) upon request by sending an email to the following address: [email protected]
10. What are your rights and how can you exercise them?
In accordance with European Regulation 2016/679 of 27 April 2016 regarding the protection of personal data, as well as Law No. 2018-493 of 20 June 2018 regarding the protection of personal data, you have:
- The right to access: the right to receive a copy of your personal data in our possession;
- The right to rectification: the right to modify personal data in our possession that concerns you, which is erroneous or obsolete;
- The right to erasure and the right to be forgotten: the right to the erasure of personal data concerning you, which is in our possession (except when the law requires that this data be stored, or when we have legitimate reason for doing so);
- The right of objection: you may oppose, at any time and for reasons relating to your particular situation, the processing of your personal data for direct marketing purposes, except when legitimate and compelling reasons for the processing prevail over the interests, rights and freedoms of the person concerned, or for the establishment, exercise or defence of legal claims;
- The right to limitation: you have the right to limit the processing of your personal data in the following cases:o If you exercise your right to rectification, it may be required to limit processing for the period necessary for us to verify its accuracy;
- If you exercise your right to objection, data processing is limited for the period necessary to verify whether the legitimate grounds claimed by Le Cloître prevail over yours;
- In case of unlawful processing of your personal data, you may demand that their use be limited rather than erased;
- For personal data processing whose erasure is requested but is still necessary for the establishment, exercise or defence of legal claims.
- The right to portability: you have the right to receive the personal data you have provided. These must be communicated in a structured format, commonly used and readable by the machine. This right also includes the right to transmit this data to another controller.
Lastly, you have the right to set guidelines regarding the fate of your personal data after your death.
These rights may be exercised under the conditions and limitations defined by current legislation. It is specified that the exercise of some of these rights may, on a case-by-case basis, make it impossible for Le Cloître to provide products or services.
You can at any time, without charge and without having to justify your request, exercise these rights by contacting us at the following address: [email protected].
It is specified that these rights can only be exercised upon proof of identity. Incomplete requests cannot be processed.
In the event of a dispute with Le Cloître regarding data processing, you may address your claim to Le Cloître.
To do so, you can write to the company’s Data Protection Officer at the following address: [email protected].
If no satisfactory solution can be reached or if the dispute persists, you can lodge a claim with the French Data Protection Authority (CNIL) or with the supervisory authority of the Member State of the European Union in which you usually reside.
If you have any questions about this Policy or any request regarding your personal data, you can contact us by sending an email to the following address: [email protected].
Date of application of this Policy: June 20, 2018.