Customer Personal Data Protection Charter
GIE La Collection Hôtels 3A
10 Rue Denfert Rochereau
E-mail : firstname.lastname@example.org
- THE 3A Hotels – La Collection GROUP’S COMMITMENT TO PROTECTING PRIVACY
As part of our commitment to meeting your expectations, we have set up a customer personal data protection charter. This charter formalizes our commitments to you and describes how the 3A Hotels – La Collection Group uses your personal data.
- SCOPE OF APPLICATION
In this charter, “3A Hotels – La Collection” means:
- GIE 3A Hotels, Group parent company, with registered office at 10 Rue Denfert Rochereau 92100 Boulogne, France
- involved in the hotel businesses in Nice and Le Chesnay
- Properties operated as Hotel WestEnd, Hotel Beau Rivage, Hotel AstonLa Scala, Hotel Mercure Versailles Parly 2, and Plage privée Beau Rivage.
- 3A Hotels – La Collection will process your data because it manages a central booking engine, which allows 3A Hotels – La Collection to collect the data necessary to organise your stay in hotels under a 3A Hotels – La Collection brand and to communicate this data to the concerned hotels.
- Each property will process your data to manage its contractual relationship with you (invoicing, payment, booking management etc.), to perform marketing activities and to comply with its legal obligations.
3A Hotels – La Collection has communicated the principles set out in this Charter to all of the 3A Hotels – La Collection branded hotels and their respective owners. We will do our upmost to ensure that all hotels comply with the applicable data protection laws and this Charter in relation to the processing of your personal data.
- 3A Hotels – La Collection FOR PROTECTING YOUR PERSONAL DATA
In accordance with applicable regulations, in particular the European General Data Protection Regulation, we have instituted the following principles throughout the 3A Hotels – La Collection Group:
- Lawfulness: We use personal data only if:
- we obtain the consent of the person, OR
- it is necessary to do so for the performance of a contract to which the person is a party, OR
- it is necessary for compliance with a legal obligation, OR
- it is necessary in order to protect the vital interests of the person, OR
- we have a legitimate interest in using personal data and our usage does not adversely affect the persons’ rights
- Fairness: We can explain why we need the personal data we collect.
iii. Purpose limitation and data minimisation: We only use personal data that we really need. If the result can be achieved with less personal data, then we make sure we use the minimum data required.
- Transparency: We inform people about the way we use their personal data
- We facilitate the exercise of the people’s rights: access to their personal data, rectification and erasure of their personal data and the right to object to the use of their personal data
- Storage limitation: We retain personal data for a limited period
vii. We ensure the security of personal data, i.e. its integrity and confidentiality.
viii. If a third party uses personal data, we make sure it has the capacity to protect that personal data
- If personal data is transferred outside Europe, we ensure this transfer is covered by specific legal tools.
- If personal data is compromised (lost, stolen, damaged, unavailable…), we notify such breaches to the respective country’s responsible authority and to the person concerned, if the breach is likely to cause a high-risk in respect of the rights and freedoms of this person.
For any questions concerning the ten principles of 3A Hotels – La Collection Data Protection policies, please contact the Data Privacy department whose details appear in the clause “Your rights”.
- WHAT PERSONAL DATA IS COLLECTED?
At various times, we may collect information about you and/or the persons accompanying you, including the following:
- Contact details (for example, last name, first name, telephone number, email)
- Personal information (for example, date of birth, nationality)
- Information relating to your children (for example, first name, date of birth, age)
- Your credit card number (for transaction and reservation purposes)
- Information contained on a form of identification (such as ID card, passport or driver licence)
- Your membership number for some loyalty program or another partner program (for example, an airline loyalty programme) and information related to your activities within the context of the loyalty program
- Your arrival and departure dates
- Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests, food and beverages preferences, etc.)
- Your questions/comments, during or following a stay in one of our 3A Hotels – La Collection establishments
- Technical and location data you generate as a result of using our websites and applications.
The information collected in relation to persons under 16 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact the Data Privacy department (see clause “Your rights” below) to arrange for this information to be deleted.
We will not collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philosophical beliefs, union membership, or details of health or sexual orientation.
- WHEN PERSONAL DATA IS COLLECTED?
Personal data may be collected on a variety of occasions, including:
- Hotel activities:
- Booking a room
- Checking-in and paying
- Hotel stays and services provided during a stay
- Eating/drinking at the hotel bar or restaurant during a stay
- Requests, complaints and/or disputes.
- Participation in marketing programs or events:
- Signing up for loyalty programs
- Participation in customer surveys (for example, the Guest Satisfaction Survey)
- Online games or competitions
- Subscription to newsletters, in order to receive offers and promotions via email.
- Transmission of information from third parties:
- Tour operators, travel agencies (online or not), GDS reservation systems and others
- Internet activities:
- Connection to 3A Hotels – La Collection websites (IP address, cookies in accordance with our Policy about the use of tracers)
- Online forms (online reservation, questionnaires, 3A Hotels – La Collection pages on social networks, social networks login devices such as Facebook login, conversations with chatbot, etc.)
- WHAT PURPOSES IS YOUR DATA COLLECTED FOR AND HOW LONG DO WE RETAIN IT?
The table below sets out why we process your data
|Meeting our obligations to our customers.
Managing the reservation of rooms and accommodation requests, in particular the creation and storage of legal documents in compliance with accounting standards.
|Managing your stay at the hotel:
|Managing our relationship with customers before, during and after your stay:
|Improving our hotel service by:
|Use a trusted third party to cross-check, analyse and combine your collected data at the time of booking or at the time of your stay, in order to determine your interests and develop your customer profile and to allow us to send you personalized offers.|
|Improving 3A Hotels – La Collection services, in particular:
|Securing and enhancing your use of 3A Hotels – La Collection websites, applications and services by:
|Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive and anti-social behaviour, non-compliance with safety regulations, theft, damage and vandalism or payment incidents).|
|Securing payments by determining the associated level of fraud risk. As part of this analysis, 3A Hotels – La Collection and hotels may use their risk prevention service provider to refine their analysis.
Depending on the results of the investigations carried out, 3A Hotels – La Collection may take security measures, in particular 3A Hôtels – La Collection Group may request the use of a different booking channel or for the use of an alternative payment method. These measures will have the effect of suspending the execution of the booking or, if the result of the analysis does not guarantee the safety of the order, of cancelling it. Fraudulent use of a means of payment leading to payment default may result in the entry of data in the 3A Hotels – La Collection incident file, which may lead 3A Hotels – La Collection Group to block future payments or carry out additional checks.
|Using services to search for persons staying in 3A Hotels – La Collection hotels in the event of serious events affecting the hotel in question (natural disasters, terrorist attacks, etc.).|
|Conforming to any applicable legislation (for example, storing of accounting documents), including:
- CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATA
The 3A Hotels – La Collection operates in France Thus, we have to share your personal data with internal and external recipients subject to the following conditions:
- We share your data with a number of authorised people and departments in the 3A Hotels – La Collection. The following teams may have access to your data:
- Hotel staff
- Reservation staff using 3A Hotels – La Collection reservation tools
- IT departments
- Commercial partners and marketing services
- Medical services if applicable
- Legal services if applicable
- Generally, any appropriate person within 3A Hotels – La Collection entities for certain specific categories of personal data.
In particular, the data related to your stays, preferences, satisfaction and, if the case may be, your loyalty program membership are shared between the hotels operating under the 3A Hotels – La Collection brand. This data is used to improve the quality of service and your experience in each of these hotels. In this context, your data is processed jointly by 3A Hotels – La Collection and these hotels. In order to pursue this legitimate interest, whilst safeguarding your rights and liberties, a specific joint controllership agreement describes the obligations and responsibilities of 3A Hotels – La Collection and these hotels. You may, at any time, object to the sharing of this data between the hotels and 3A Hotels – La Collection by contacting the Data Privacy department whose details appear in the clause “Your rights“. You can also request a summary of the key points of the joint controllership agreement.
- With service providers and partners: your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay, for example:
- 1. External service providers: IT sub-contractors, international call centres, banks, credit card issuers, external lawyers, dispatchers, printers.
- 2. Social networking sites: In order to allow you to be identified on the 3A Hotels – La Collection website without the need to fill out a registration form, 3A Hotels – La Collection has put in place a social network login system. If you log in using the social network login system, you explicitly authorize 3A Hotels – La Collection to access and store the public data on your social network account (e.g. Facebook, LinkedIn, Google, Instagram…), as well as other data stated during use of such social network login system. 3A Hotels – La Collection may also communicate your email address to social networks in order to identify whether you are already a user of the concerned social network and in order to post personalized, relevant adverts on your social network account if appropriate.
- With local authorities: We may be obliged to send your information to local authorities if this is required by law or as part of an inquiry. We will ensure that any such transfer is carried out in accordance with local regulations.
- DATA SECURITY
3A Hotels – La Collection takes appropriate technical and organizational measures, in accordance with applicable legal provisions (in particular: Art. 32 GDPR), to protect your personal data against illicit or accidental destruction, alteration or loss misuse and unauthorized access, modification or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.) to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services. In relation to the submission of credit card data when making a reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction. Organizational measures ensure the security of the processing.
- YOUR RIGHTS
You have the right to obtain information about and access your personal data collected by 3A Hotels – La Collection, subject to applicable legal provisions. Also you have the right to have your personal data rectified, erased or have the processing of it restricted. Furthermore you have the right to data portability and to issue instructions on how your data is to be treated after your death You can also object to the processing of your personal data, in particular to the sharing of the data related to your stays, preferences and satisfaction between the hotels operating under the 3A Hotels – La Collection
In the event that you wish to exercise any of your above rights, please contact the Data Privacy department for the 3A Hotels – La Collection directly by sending an email to email@example.com or by writing to the address below:
3A Hôtels – La Collection
Département Protection des Données Personnelles (Data Privacy Department)
10 Rue Denfert Rochereau
92100Boulogne Billancourt – France
For the purposes of confidentiality and personal data protection, we will need to check your identity in order to respond to your request. You will be asked to include a copy of an official piece of identification, such as a driver’s license or passport, along with your request. A black and white copy of the relevant page of your identity document is sufficient.
All requests will receive a response as swiftly as possible.
You may also exercise your rights in respect of your personal data that is stored and processed by a hotel as a data controller. To do this, you must contact the hotel directly. You will find all necessary information to contact a hotel on http://hotels3alacollection.com/. If you need any assistance, please contact 3A Hotels – La Collection Data Privacy Department by writing to firstname.lastname@example.org or to the above postal address.
You also have the right to lodge a complaint with a data protection authority . For your information,You can contact 3A Hotels – La Collection data protection officer by writing to email@example.com or to the above postal address.
We may modify this Charter from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.
- QUESTIONS AND CONTACTS
For any questions concerning the 3A Hotels – La Collection’s personal data protection policy, please contact the Data Privacy department (See clause “Your rights“).