PERSONAL DATA PROTECTION POLICY
When you use the website https://www.the-hill-club.com/, The Hill Club restaurant may collect and manage your personal data, either by itself or in collaboration with other establishments that are members of the Honotel hotel network or of the service program called Happyculture, allowing Our Users to benefit from Our services and Our privileged offers.
The purpose of this Personal Data Protection Policy is to inform the users of the Service of the means implemented to collect and manage Your personal data, in accordance with the applicable French and European legislation, in particular Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, as amended by Law No. 2004-801 of August 6, 2004 and by Law No. 2018-493 of June 20, 2018 ("Data Processing and Freedoms Law"), 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 management of personal data and on the free movement of such data ("RGPD") and Directive 2002/58 of 12 July 2002 as amended by Directive 2009/136/EC ("Privacy and Electronic Communications Directive"), as well as all internal texts transposing these laws and any subsequent text that may replace them.
Your privacy and the protection of your personal data are important to us.
By accessing and/or using the Service, You consent to the collection and management of Your personal data under the terms and conditions set forth below. If you do not agree to this policy, you must stop using the Service altogether.
We may modify the policy, in particular to adapt it to any legislative, regulatory, jurisprudential, editorial and technical developments under the conditions described in the TOS. You should refer to the latest version of this policy before browsing.
The terms "personal data" ("Personal Data"), "manage/manage", "data manager", "processor", "recipient(s)", "consent", "file", have the same meaning as set out in clause 4 of the GDPR.
2. DATA MANAGER
The person in charge of the Personal Data of the Users collected within the framework of the Service is the company Honotel Développement SAS, 20 Rue Treilhard, 75008 PARIS, whose coordinates appear in article 10.
3. WHAT PERSONAL DATA IS COLLECTED?
When Personal Data is collected, Users will be informed whether certain Personal Data must be completed or whether it is optional. If no mandatory Personal Data is provided, access to and use of certain features of the Service, such as online room reservations, will be impossible for the User.
In particular, we may collect the following types of Personal Information
- Identity: title, last name, first name, organization, phone number, email address;
- Interest reported on a form or deducted from the use of the service ;
- Contacts and notifications to Us;
- Technical navigation and interaction data: statistics on the frequency of visits: IP address, cookies, for example, the pages consulted by the User, the date and time of their consultation (see the Policy on cookies).
4. WHY DO WE COLLECT YOUR PERSONAL DATA?
The Personal Data that You provide to Us, as well as those that are collected and/or processed in the context of Your use of the Service, are processed for the following purposes in particular:
Agreement between You and Us (TOS and this Policy)
To make the Service available to You, to ensure its proper functioning, notably to process Your requests, to facilitate Your navigation, etc.
Our legitimate interest in improving Our Service
To improve the Service, in particular to optimize or offer new functionalities to the Service, or to offer You a simplified automatic entry
Our legitimate interest in providing You with services and offers that match Your preferences and interests
To adapt and optimize the display of the contents of the Service and promotional offers, to the parameters or preferences, appetites and centers of interest, proven, supposed or deduced, of the User, which may result from Your use of the Service, from the information You have entered or from Your navigation and Your interactions with the Service
- Our legitimate interest in promoting Our Service and providing You with offers and news
- Your consent to receive offers and news from Our partners
To inform You of Our offers and news, unless You object, as well as offers and news from Our partners, if You have given Your consent
5. Who will receive your Personal Information?
The database of Personal Data constituted at the time of Your use of the Service is strictly confidential. We undertake to take all useful precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of the Personal Data, and in particular to prevent them from being distorted, damaged or accessed by unauthorized third parties.
5.1 Data transferred to public authorities and/or agencies
In accordance with the regulations in force, Personal Data may be transmitted to the competent authorities upon request and in particular to public bodies, exclusively to meet legal obligations, court officers, ministerial officers and bodies responsible for debt collection.
5.2 Data available TO third parties
Personal Data may be used by Us, Our subcontractors, Our affiliates and/or, if applicable, by Our business partners, for the purposes described in Article 4 above.
- Our staff, the services in charge of control (auditor in particular) and Our subcontractors will have access to the Personal Data collected within the framework of the use of the Service;
- Our commercial partners, such as restaurants or spas, will have access to the User's Personal Data for the purpose of managing reservations and after-sales service;
- Social Networks: If the User has an account on social network sites and accesses the Service, We may receive information from such social networks, and the social network services may receive information about the User's use of the Service. When the User uses the Service via a social network site, the User allows Us to access certain information that the User has provided to the social network site, such as, but not limited to, the User's username, first and last name, profile picture, and Personal Data related to the use of that service. By accessing the Service via a social network site, the User authorizes Us to collect, store and use all information that the User has authorized the social network site to provide to Us.
5.3 Transfers outside the European Union
User's Personal Data may be processed outside the European Union, including via remote access. We undertake not to transfer Personal Data outside the European Union without implementing appropriate safeguards in accordance with the Applicable Regulation.
6. What are your rights regarding your Personal Information?
In accordance with the Applicable Regulations, subject to an express request and proof of Your identity to Us, You have a right of access to Your Personal Data, a right of rectification, a right of opposition, as well as a right to erasure, under the conditions of the Applicable Regulations.
Your right to erasure of Your Personal Data applies subject to the necessities that We can justify to keep Personal Data, notably with respect to Our legal obligations.
In case of exercising the right to object, We will cease processing the Personal Data, except in case of legitimate and compelling reason(s) for the processing, or to ensure the establishment, exercise or defense of its legal rights, in accordance with the Applicable Regulations.
You may also, subject to the conditions of the Applicable Regulations, request a limitation of the processing of Your Personal Data.
Where the processing of Your Personal Data is based on Your consent, You have the right to withdraw Your consent at any time.
You also have a right to the portability of some of Your Personal Data, allowing You to request a computerized copy in a readable and exploitable form of Your Personal Data processed by Us as part of Your contractual relationship with Us for the provision of products or services to which You have subscribed, This excludes the Personal Data that We may have produced for purposes that are specific to Us or that enable Us to meet Our legal obligations, in particular accounting, social or fiscal obligations, as well as information relating to the history of reservations made, the amounts paid or payable, as well as all the information that We may have generated within the framework of the legitimate interests that We pursue.
You may provide Us with instructions regarding the disposition of Your Personal Information after Your death.
If applicable, We will inform You of the reasons why the rights You are exercising cannot be satisfied in whole or in part.
To exercise the rights mentioned in this Article, You can contact Us by attaching a copy of a valid ID to your request at the address indicated in Article 10 below.
7. How long we keep your Personal Information
We undertake not to keep Your Personal Data beyond the period strictly necessary for the purposes for which it was collected, and in accordance with the Applicable Regulations.
We undertake to anonymize or delete Your Personal Data as soon as the defined purpose and/or retention period expires.
Nevertheless, Personal Data may be archived beyond the periods provided for the needs of research, the establishment, and the prosecution of criminal offenses for the sole purpose of allowing, as necessary, the provision of these Personal Data to the judicial authority, or for other obligations of conservation, including accounting or tax purposes. Archiving implies that these Personal Data will be subject to access restrictions and will no longer be available online but will be extracted and stored on an autonomous and secure medium.
The maximum retention periods set forth in the table below apply, unless You request deletion or cessation of processing of Your Personal Data prior to the expiration of these periods, in accordance with Article 7 above.
Audience measurement and personalization of the Service, management of cookies and other tracers
13 months from the deposit of the cookie or other tracer
The Personal Data that we process in the context of solicitations and promotional operations, sending offers and news
3 years from the end of the relationship with the User or from the last interaction initiated by the User
Personal Data related to the management of requests for the exercise of rights and questions about Personal Data
3 years from the last interaction initiated by the User
8. Protection of Personal Data of Minors
The Service is generally not intended for minors under the age of 15. For this reason, We do not collect or maintain Personal Information from children under 15 years of age without obtaining verifiable parental consent, although parents or guardians may request to receive information about their child and may request deletion of the information.
When the adult User enters Personal Data relating to a minor under 15 years of age, he or she undertakes to have the verifiable consent of the holders of parental authority, and to provide, on request, any element enabling proof of this consent.
Taking into account the evolution of technologies, the costs of implementation, the nature of the Personal Data to be protected as well as the risks for the rights and freedoms of individuals, We implement the appropriate technical and organizational measures in order to guarantee the confidentiality of the Personal Data collected and processed and a level of security adapted to the risk, in accordance with this Policy.
The information collected during the reservation process is transmitted encrypted on the basis of the SSL (Secure Socket Layer) protocol on the Internet. All useful precautions, in accordance with the state of the art, with regard to the nature of the Personal Data and the risks presented by the processing, will be taken to preserve the security of the Personal Data and, in particular, to prevent them from being deformed, damaged, or from being accessed by unauthorized parties.
For any request concerning the processing of Your Personal Data, You may address Your request or complaint directly to us by contacting Honotel Développement SAS, 20 Rue Treilhard, 75008 PARIS or by e-mail at firstname.lastname@example.org
We will endeavour to find a satisfactory solution to ensure compliance with the Applicable Regulations.
In the absence of Our response or if the dispute persists, You may file a complaint with the CNIL or the supervisory authority of the European Union Member State in which You usually reside.
When using the Service, information relating to the browsing of Your computer, tablet, smartphones, etc. may be recorded in text files called "cookies" installed on Your Terminal, subject to the choices You may have expressed concerning "cookies" and which You may modify at any time.
1. What is a cookie?
A "cookie" is a small text, image or software file that We may store on Your Terminal's hard drive through Your Internet browser when You use the Service, subject to Your consent and unless You object.
A "cookie" allows its issuer, during its period of validity, to recognize the Terminal concerned each time this Terminal accesses digital content containing "cookies" from the same issuer.
Once installed, "cookies" allow Us to recognize You at each visit to the Service, and therefore to allow You to take advantage of all the features of the Service, to indicate Your visit to a particular page and thus to provide You with an additional service. They also allow Us to improve Your browsing comfort, to secure Your connection or to adapt the content of a page to Your interests or preferences.
The information recorded by the "cookies", for a limited period of validity, includes the pages visited, the type of browser You are using and other data that Our online services process automatically such as the identity of Your Internet access provider, Your IP address or the information You have entered on the Service (in order to avoid re-entering it).
Cookies" are not active files, and therefore cannot host viruses. For more information, please visit https://www.cnil.fr/fr/comment-ca-marche.
2. What is the purpose of the "cookies" issued on the Service?
Only the sender of a "cookie" is likely to read or modify the information contained therein.
Cookies" are used for the purposes described below, subject to Your choices that You can express and modify at any time via the settings of the browser software used during Your navigation on the Service.
2.1 Browsing "cookies
Browsing "cookies" are used to improve the performance of the Service in order to provide the User with a better use of the Service. These "cookies" do not require the User's prior information and consent to be deposited on the User's Terminal.
More specifically, these browsing "cookies" allow us to
to adapt the presentation of the Service to the display preferences of Your Terminal (language used, display resolution, operating system used, etc.) when You use the Service, according to the hardware and software for viewing or reading that Your Terminal has;
to allow access to a reserved area subject to login and password;
to memorize information relating to the forms that You have filled in when using the Service;
to remember Your usage preferences, display settings and players You use in order to facilitate Your navigation the next time You visit the Service;
to tailor the informational or promotional content of the Service to Your assumed, stated, or browsing interests and preferences on the Service, and to Your location on the Service;
to implement security measures, for example when the User is asked to reconnect to the Service after a certain period of time has elapsed.
2.2 Statistical cookies
The statistical "cookies" issued on the Service allow us to establish statistics and measures of frequentation and use of the various elements composing the Service (sections and contents visited, path, etc.), allowing us to improve the interest and the ergonomics of the Service.
The results of the statistical cookie analyses are processed anonymously and exclusively for statistical purposes.
2.3 Advertising "cookies" and third-party "cookies
Advertising "cookies" and third party "cookies" allow in particular:
to determine in real time which advertisement to display based on Your recent browsing history in order to limit the number of times an advertisement is displayed and to help measure the effectiveness of an advertising campaign;
personalize Your experience on the Service, maintain and improve the quality of Our Service and protect You from fraudulent activity. When third party sites, such as social networking sites, receive information contained in "cookies" through the use of a specific module of the Service, this information is assumed to be anonymous and is intended only to identify You on the Service.
3. Duration of validity of the "cookies
The "cookies" issued on the Service are session "cookies" (whose duration is limited to the time of a connection to the Service) and persistent "cookies" (whose duration, however limited, is longer than the duration of a connection).
Session cookies are only active for the duration of your visit and are deleted when you close your browser. Persistent cookies remain on the hard drive of Your Terminal once Your browser is closed.
In accordance with the Applicable Regulations and the recommendations of the Commission Nationale Informatique et Libertés ("CNIL"), "cookies" are kept for a maximum of 13 (thirteen) months after their initial deposit. At the end of this period, Your consent must be obtained again for the collection of cookies subject to consent.
4. Your choices regarding "cookies":
All the rights of the User recognized in Article 6 of the Personal Data Protection Policy are also applicable to the use of "cookies".
Several possibilities are offered to You to manage cookies. The User understands that "cookies" improve the comfort of navigation on the Service. Any parameter setting that the User may undertake will be likely to modify his navigation on the Service and his conditions of access to certain services requiring the use of "cookies". We shall not be held responsible for the consequences of a less efficient functioning of the Service due to the impossibility of installing or reading "cookies" necessary for their proper functioning, once the User has rejected or deleted them.
Users can configure their browser software so that cookies are saved in their Terminal or, on the contrary, rejected, either systematically or according to their sender. Users can also configure their browser software so that acceptance or rejection of cookies is offered to them from time to time, before a cookie is likely to be recorded on their Terminal.
Please note that exercising the right to opt-out will not prevent the display of advertisements. Only the advertisements using the personalization services of the Service will cease. In other words, the User will no longer be exposed to advertisements adapted to his centers of interest via the use of "cookies" on the Service but will continue to be displayed advertisements whose content will not necessarily be in line with his centers of interest, or even dubious.
The help menu or the dedicated section of Your browser will allow You to know how to express or modify Your preferences regarding "cookies":
- For Internet Explorer™:
- For Safari™:
- For Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
- For Firefox™:
- For Opera™:
- Windows Phone: