Personal Data Management

Prior information

Maisons & Hôtels Sibuet is a commercial brand that groups together all the hotels owned and managed by the Sibuet family, Le Domaine de Marie (wine production and sales) and Pure Altitude (cosmetics line). Our establishments are located in France and in Saint Barthelemy. Our vocation is to offer unique and personalised lifestyle experiences by constantly adapting our services and products to the sensibilities of our clients.

This Maisons & Hôtels Sibuet personal data management policy is an appendix to the General Terms and Conditions ("GTC") and therefore has contractual value. In the event of a contradiction between the GTC and this policy, the GTC shall take precedence, which the user of our sites acknowledges and accepts.

This personal data management policy reflects Maisons & Hôtels Sibuet's desire to be completely transparent with users about how it manages their personal data and incorporates the latest requirements of the European regulation on the protection of personal data.

The person responsible for processing personal data for Maisons & Hôtels Sibuet is :

Mr FRUITIER - 144 chemin du petit Darbon - 74120 MEGEVE, Email: privacy@mhsibuet.com

The personal data protection officer of Maisons et Hôtels Sibuet is :

Mr Frédéric MOUNIER, Email : dpo@mhsibuet.com

If you have any questions about this privacy policy, please send a message to privacy@mhsibuet.com

Contents

Article 1. What is the purpose of the Personal Data Management Policy?

I.PERSONAL DATA

Article 2. What is personal data?

Article 3. What personal data is collected by Maisons & Hôtels Sibuet and for what purposes?

Article 4. Who has access to the User's personal data?

Article 5. What rights do Users have regarding the personal data collected?

Article 6. For what period of time is personal data collected?

Article 7. What measures are put in place to protect Users' personal data?

II.COOKIES

Article 8. What is a cookie?

Article 9. What tracking systems are used by Maisons & Hôtels Sibuet and for what purpose?

Article 10. How to enable/disable cookies?

III. CHANGES TO THE PRIVACY POLICY

Personal data management

Article 1. What is the purpose of the Personal Data Management Policy?

The purpose of this Personal Data Management Policy is to inform the User of the manner in which Maisons & Hôtels Sibuet manages the personal data of the users of its websites, whether or not they are customers (hereinafter referred to as "Users").

I. PERSONAL DATA

Article 2. What is personal data?

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, personal data is "any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject") ; An 'identifiable natural person' is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity."

Article 3. What personal data is collected by Maisons & Hôtels Sibuet and for what purposes?

Maisons & Hôtels Sibuet collects personal data on the following websites (hereinafter "the Sites"):

Hotels, online booking site and online shop:

- https://www.fermesdemarie.com/fr

- https://www.lodgepark.com/fr

- https://www.hotelmontblanc.com/fr

-https://www.chaletsdesfermes.com/

-https://www.gypsea-beach.com/

- https://www.epiceriedesfermes.com/

- https://www.labastidedemarie.com

- https://saint-tropez.villamarie.fr

- https://saint-barth.villamarie.fr

- https://booking.groupe-sibuet.com  

- https://shop.experience-sibuet.com  

Wine estate and online shop:

- https://www.domainedemarie.com

- http://boutique.domainedemarie.com

Cosmetics and online shop :

- https://www.pure-altitude.com

- https://boutique.pure-altitude.com

Recruitment website:

- http://www.recrutement-sibuet.com

PERSONAL DATA COLLECTED VIA THE WEBSITES OF THE COMMERCIAL BRAND MAISONS & HÔTELS SIBUET :

Purpose: To allow the user to receive exclusive offers from each of our hotels.

- Data collected : E-mail address

- Legal basis: Performance of a contract. Necessary for our legitimate interests (to enable the user to receive our best offers, on the site).

Purpose: To allow the user to be called back or recontacted by our reservation/concierge/marketing/press services, by the sales department of Domaine de Marie or Pure Altitude (depending on the nature of the need).

- Data collected: Name, first name, e-mail address, telephone number (optional)

- Legal basis: Performance of a contract. Necessary for our legitimate interests (to answer our customers' questions, to tailor our offers to their needs, and to expand our business)

Purpose: To allow the user to make a reservation and pay for the reservation online

- Data collected: Name, first name, e-mail address, postal address, telephone number, credit card identifiers, validity date, CVV code

- Legal basis: Performance of a contract. Necessary for our legitimate interests (to book services, promote our products and services, develop them and expand our business)

Purpose: To enable our hotels and services to communicate with the customer at different times during their stay.

- Personalization of the stay, preparation of the arrival

- Sending of a satisfaction questionnaire at the end of the stay

- Promotional and administrative communication, namely :

- Sending important information about our establishments

- Information on changes to our terms and conditions, privacy policy

- Sending administrative information concerning travel reservations, such as reservation confirmations and communications prior to arrival at a Maisons & Hôtels Sibuet hotel

- Measuring the effectiveness of our marketing or sales actions

- Evolution of our products and services by better measuring our customers' expectations

- Data collected: Name, first name, e-mail address, postal address, telephone

- Legal basis: Performance of a contract. Necessary for our legitimate interests (to book services, promote our products and services, develop them and expand our business)

PERSONAL DATA COLLECTED VIA THE SALES SITES OF THE COMMERCIAL BRAND MAISONS & HÔTELS SIBUET :

- https://shop.experience-sibuet.com

- http://boutique.domainedemarie.com

- https://boutique.pure-altitude.com

Purpose: To allow the user to create an account and log in to our online product sales sites in order to :

- Manage order baskets, gift vouchers, etc.

- Track orders, returns, alerts,...

- Get in touch with us

- Managing personal information

- Subscribe to newsletters published by Maison & Hôtels Sibuet

- Collected data: Civility, surname, first name, e-mail address, birthday (optional), password

- Legal basis: Performance of a contract. Necessary for our legitimate interests (to purchase products or book services, to promote our products and services, to develop them and to expand our business)

On each of the collection forms, the data marked with an asterisk is essential. Otherwise, the User will not be able to access the services offered on our sites.

PERSONAL DATA COLLECTED VIA WWW.RECRUTEMENT-SIBUET.COM

Purposes: To enable the User to apply spontaneously for a position with Maisons & Hôtels Sibuet. To enable Maisons & Hôtels Sibuet to contact the User again if his/her unsolicited application is accepted.

- Data collected: CV, cover letter, civility, surname, first name, email address, mobile phone

- Legal basis: Necessary for our legitimate interests (in order to recontact a person whose profile would correspond to a position within the company)

Purpose: To allow the user to apply for a specific job offer on the site http://www.recrutement-sibuet.com/

- Data collected: CV, cover letter, civility, surname, first name, email address, mobile phone

- Legal basis: Necessary for our legitimate interests (in order to recontact a person whose profile would correspond to a position within the company)

The data marked with an asterisk are essential. Otherwise, the User will not be able to submit applications on the www.recrutement-sibuet.com website.

Article 4. Who has access to the User's personal data?

The only recipients of Users' personal data are :

- the relevant departments and employees of Maisons & Hôtels Sibuet (in particular: IT, sales/marketing and operational departments);

- the companies that assist Maisons & Hôtels Sibuet in the operation and/or exploitation of the sites, and in particular the services and employees of the company that hosts the sites. These companies are :

- Amazon Web Services, Inc. P.O. Box 81226 Seattle, WA 98108-1226, http://aws.amazon.com

- Opwan, 150, Rue Pierre et Marie Curie 34430 Saint Jean de Vedas, www.opwan.com

- The subcontractors of our hotels, for example:

- Ski schools

- Organisers of activities (dog sledding, paragliding, yoga classes...)

- Partner restaurants

- Shuttles, partner taxis

- • …

These structures only receive personal information that is strictly necessary to make a reservation and to call back clients if necessary.

Article 5. What rights do Users have regarding the personal data collected?

The User has access to the rights detailed in Chapter III of the GDPR, including the following rights

- Right of access to personal data collected on the Website and via the Application,

- Right to modify/correct,

- Right to erasure ("right to be forgotten"), unless there is a legal reason for us to keep it,

- Right to restrict processing, i.e. the right to ask us in certain cases to suspend the processing of personal data,

- Right to data portability, i.e. the right to request a copy of one's personal data in a common format (e.g. a .csv file),

- Right to object to the processing of personal data,

- Rights relating to individual decision making and profiling, i.e. the right to ask us to be transparent about any profiling we carry out or any automated decisions,

All these rights are exercised

- for all Maisons & Hôtels websites requesting personal information (registration forms, contact requests, booking confirmations, etc.), by sending an email to privacy@mhsibuet.com.

- For the http://www.recrutement-sibuet.com/ website: by sending an email to privacy@mhsibuet.com.

Users are reminded that they may :

- access and modify their contact details and login details on the sites:

- https://shop.experience-sibuet.com

- http://boutique.domainedemarie.com

- https://boutique.pure-altitude.com

via the "My Profile" and "my personal information" sections;

The User also has the right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL), the supervisory authority for data protection issues in France (www.cnil.fr). However, Maisons & Hôtels Sibuet would like to have a chance to address your concerns before we contact the CNIL. So please contact us first.

Article 6. For how long are personal data collected?

- History of stays and consumption: The personal data of customers who have not booked, stayed or consumed in one of our establishments are deleted after a period of 3 years. The consumption data and stay history are anonymised and used only for statistical purposes.

- Bank details: Credit card numbers are automatically deleted one day after the customer has left.

- Information about the participants of the stay : The personal data of participants who have not booked, stayed or consumed in one of our establishments will be deleted after a period of 3 years.

- Invoice data: Invoices are archived for a period of 5 years.

- Return of satisfaction questionnaires: They are kept nominally for a period of 3 years and then used anonymously for statistical purposes.

- Recruitment data: CVs of non-recruited candidates are kept for 3 years.

Article 7. How is personal data protected?

Maisons & Hôtels Sibuet is very vigilant about the security of personal data and takes all reasonable precautions to prevent any unauthorised access, disclosure, alteration or destruction of personal data.

The personal data collected is stored by Maisons & Hôtels Sibuet or its service providers, and is protected by physical and electronic access controls, firewall technologies and other reasonable security measures.

However, such measures cannot prevent all risks of loss, access, misuse or alteration of the personal information collected. Where required by law, Maisons & Hôtels Sibuet will notify the User of any loss, access, misuse or alteration of his or her personal data, so that he or she can take the appropriate steps to have his or her rights respected. Maisons & Hôtels Sibuet shall notify the User by e-mail or post or by telephone, if authorised by law.

The User is advised not to transmit payment or sensitive information by e-mail or in sections not intended for this purpose (e.g. sending a credit card number by e-mail).

You have the opportunity to choose which personal data you wish to provide to us.

However, your decision not to provide certain data may affect your experience of our services. For example, we cannot make anonymous reservations and, if we are not permitted to disclose your personal data to our group hotels, we may not be able to provide you with certain reservation or other services.

Similarly, if you do not allow us to disclose your personal data to third parties, such as our hotels' subcontractors (ski school, car rental companies, etc.), we may not be able to provide you with the full range of possible services or the provision of those services may be delayed. We will endeavour to respond to your request as soon as possible.

Maisons & Hôtels Sibuet is very vigilant about the security of personal data and takes all reasonable precautions to prevent any unauthorised access, disclosure, alteration or destruction of personal data.

The personal data collected is stored by Maisons & Hôtels Sibuet or its service providers, and is protected by physical and electronic access controls, firewall technologies and other reasonable security measures.

However, such measures cannot prevent all risks of loss, access, misuse or alteration of the personal information collected. Where required by law, Maisons & Hôtels Sibuet will notify the User of any loss, access, misuse or alteration of his or her personal data, so that he or she can take the appropriate steps to have his or her rights respected. Maisons & Hôtels Sibuet shall notify the User by e-mail or post or by telephone, if authorised by law.

The User is advised not to transmit payment or sensitive information by e-mail or in sections not intended for this purpose (e.g. sending a credit card number by e-mail).

You have the opportunity to choose which personal data you wish to provide to us.

However, your decision not to provide certain data may affect your experience of our services. For example, we cannot make anonymous reservations and, if we are not permitted to disclose your personal data to our group hotels, we may not be able to provide you with certain reservation or other services.

Similarly, if you do not allow us to disclose your personal data to third parties, such as our hotels' subcontractors (ski school, car rental companies, etc.), we may not be able to provide you with the full range of possible services or the provision of those services may be delayed. We will endeavour to respond to your request as soon as possible.

II. COOKIES

Article 8. What is a cookie?

According to the Commission Nationale de l'Informatique et des Libertés, a cookie is a piece of information deposited on the User's means of access by the server of the Website or Application that he/she visits.

A cookie contains several pieces of data:

- the name of the server that filed it,

- an identifier in the form of a unique number,

- possibly an expiry date.

This information is sometimes stored on a medium in a simple text file that a server accesses to read and record information.

Article 9. What tracking systems are used by Maisons & Hôtels Sibuet and for what purposes?

The User is informed that Maisons & Hôtels Sibuet uses the following tracking tools:

Maisons & Hôtels Sibuet's websites, online services, interactive applications, e-mail messages and advertisements may use "cookies" and other technologies such as web beacons and web beacons.

These technologies help us to better understand user behaviour, tell us which parts of our websites are visited, and facilitate and measure the effectiveness of web advertising and searches.

We treat the information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information.

Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Maisons & hôtels Sibuet also uses cookies and other technologies to remember personal information when you use our website, online services and applications.

Our goal in these cases is to make your experience more convenient and personal. For example, knowing your country and language helps us deliver a more useful and personalised marketing experience.

We use this information to understand and analyze trends, administer the site, learn about user behavior on the site, improve our products and services, and gather demographic information about our user base as a whole. Maisons & Hôtels Sibuet may use this information in its marketing and advertising services.

Pixel tags allow us to deliver targeted advertising messages in a format that customers can read. We may use this information to reduce or eliminate messages sent to customers.

The User is informed that he/she has, at any time, the right to access his/her data concerning cookies and to oppose them, allowing him/her to choose whether or not to accept cookies.

However, if the User does not accept cookies, the use of the Services (and in particular the navigation on the Sites) may not be carried out correctly.

With regard to "Facebook" cookies, Maisons & Hôtels Sibuet obtains the prior consent of the User.

Article 10. How to enable/disable cookies?

The User may at any time manage, deactivate and authorise cookies by configuring his or her internet browser. For example :

- for Mac smartphones or tablets: via Settings/select the relevant browser/accept cookies/never/or From sites visited/always.

- for Android smartphones: by pressing, after launching the browser, the menu button (bottom left of the Mobile Device)/More/Settings/Accept cookies or do not accept.

- for computer :

- under Internet Explorer: http: //windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

- under Safari: http: //docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html

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

- under Firefox: http: //support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

- under Opera: http: //help.opera.com/Windows/10.20/fr/cookies.html

For more information on how to manage and deactivate cookies, the User can use the help section of his browser.

In the event of difficulty in exercising their right of access or opposition to cookies, Users may contact Maisons et Hôtels Sibuet via the following e-mail address: privacy@mhsibuet.com

The maximum duration of a cookie is thirteen months.

III. CHANGES TO THE PRIVACY POLICY

Maisons & Hôtels Sibuet reserves the right to change, modify or revise this policy at any time.

The document was last updated on 12 February 2019.

If there is a material change to this policy, we will post on the Sites that our privacy policy has changed.

If we make any material changes to the way we use your personal data, we will notify you by email to the address in your account (if any) or by means of a notice on the home page of our Sites, giving you the opportunity to opt out of the new use.

Any changes to this Privacy Policy will be effective upon posting on the Sites.

Your use of our Sites after these changes become effective constitutes acceptance of this Privacy Policy on the new terms as made public.

Le Domaine de Marieproperties