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Privacy policy

INTRODUCTION

With the development of new communication tools, it is necessary to pay particular attention to the protection of privacy. This is why we are committed to respecting the confidentiality of the personal information we collect.

DEFINITIONS

Capitalised terms refer to the following definitions:

Policy« means this privacy policy.

Data« means any information about an identified or identifiable natural person (the »data subject«) 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 identity.

Processing« means any operation applied to Data (collection, recording, organisation, storage, adaptation, communication by transmission, dissemination, deletion, etc.).

«You» or the «data subject» refers to users of the Website and persons who are the subject of Data Processing carried out by HOLIDAYS AND CO (prospects, customers, etc.).

«We» or «HOLIDAYS AND CO»: means the company HOLIDAYS AND CO, whose registered office is located at 43 Avenue Albert Calmette - 59910 BONDUES - FRANCE, registered in the Lille Métropole Trade and Companies Register under number 914 078 811, with a share capital of 1000 euros.

The «Site» refers to the Internet Site accessible from the address : https://divine-villas.com/ and any sub-Sites providing access to a content consultation area, an area reserved for customers, etc., which are provided by the Company.

The «Controller» means the person who, alone or jointly with others, determines the purposes and means of the Processing.

A «Recipient» refers to the natural or legal person, public authority, department or any other body that receives Personal Data, whether or not it is a third party.

The «Regulations» means 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 Processing of Personal Data and on the free movement of such Data (known as the «RGPD»); Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms; the rules applicable to commercial canvassing set out in the French Post and Telecommunications Code and, more generally, the laws and regulations applicable to the Data Processing that we carry out.

 

DATA CONTROLLER

The Data Controller referred to in this Policy is the company HOLIDAYS AND CO, whose registered office is located at: 43 Avenue Albert Calmette - 59910 BONDUES - FRANCE, registered with the Lille Métropole Trade and Companies Register under number: 914 078 811, with a share capital of 1000 euros.

 

DATA CONCERNED

The Data we collect is used for precisely defined purposes and has a legal basis, in accordance with the applicable regulations.

Unless otherwise specified, the collection of the Data indicated below is compulsory and necessary for the performance of the contract concluded with HOLIDAYS AND CO. When subscribing to a service, the Data whose provision is compulsory are indicated by an asterisk or any other appropriate wording.

If you do not provide this Data, we will not be able to provide you with the service you have subscribed to.

In order to Process your order placed via our Site, we collect the following Data directly from you by means of a form:

  • Surname, first name, title, date of birth
  • Email address

As part of our commercial relationship, we collect the following Data:

If you contact us via a social network (e.g. Messenger, WhatsApp, Telegram, etc.), you are informed that this exchange will be handled in accordance with the privacy policy of the network in question, which you should read before using it.

  • Any exchanges with our customer service department (date, time and content of the exchange, telephone number, identifier or email address used to contact us)
  • Exchanges relating to the exercise of your rights with regard to the protection of personal data (nature of the exchange and any identity documents sent to prove the identity of the person requesting the exercise of rights)
  • Data relating to opinions published about our products or services on our Site or on third-party Sites (in particular social networks or reservation sites): name, pseudonym or identifier, photo of the author of the opinion, content, date and time of the opinion, product or service that is the subject of the opinion, any rating given to the product or service.

The collection of the Data listed above is optional and will only take place if you contact our customer service department or leave a review of our products or services.

This information may be enriched by public information (such as opinions and contributions) from other sources such as social networks (in particular: Facebook, Google, Youtube, Instagram, etc.) where these contributions are freely accessible to the public. This includes information to which we may have access as the administrator of a page or group.

  • Consent to or refusal of the receipt of commercial offers concerning other products marketed by HOLIDAYS AND CO,

When you browse the Site, we also collect Navigational Data, details of which are set out in our Cookie Policy.

 

PURPOSES AND LEGAL BASIS OF DATA PROCESSING

We collect the Data identified in point 2 above for the purposes and in accordance with the legal bases set out below:

  • Managing and monitoring contracts and service performance:
  • Processing payment for your order and invoicing ;
  • Keeping an up-to-date customer file; ;
  • Discussions with customer service and assistance;;
  • Management of payment and invoicing for rentals

The legal basis for the Processing is therefore the performance of the contract concluded between you and HOLIDAYS AND CO.

  • Bookkeeping (accounting and tax obligations and protection of transactions and means of payment against fraud): the legal basis for Processing is therefore compliance by HOLIDAYS AND CO with its legal obligation to retain this data.
  • Keeping a prospect file: the legal basis for Processing is the legitimate interest of HOLIDAYS AND CO in keeping up-to-date information on persons likely to be interested in its offers.
  • Carrying out audience analyses and compiling statistics in order to improve our services: the legal basis for Processing is the legitimate interest of HOLIDAYS AND CO in using Customer Data in order to improve its Website and its offers.
  • The publication of customer reviews: the legal basis is then the legitimate interest of HOLIDAYS AND CO to provide its prospects and other users of the Website with fair and transparent information on the reviews issued by its customers on the services.
  • The sending of commercial solicitations (loyalty offers and actions, canvassing, surveys, competitions) by email on products similar to those you have ordered: the legal basis for the processing is our legitimate interest in promoting our products to our customers.
  • Sending newsletters or commercial e-mail solicitations to our customers about other services that are not similar to those that have been the subject of previous orders or sending commercial solicitations to prospective customers: the legal basis for Processing is the consent of customers and prospective customers to receive commercial solicitations.

You always have the option of objecting to receiving commercial communications from us.

The management of requests relating to Personal Data (right of access, rectification, opposition, and more generally the rights described in the Policy): the legal basis of the Processing is then compliance with a legal obligation of HOLIDAYS AND CO to allow the exercise of the rights of its customers in terms of Data protection.

 

 OUR COOKIES POLICY

When you browse the Site, we use several types of cookies and tracers to optimise your browsing experience and enable us to improve our offers.

In addition to cookies whose sole purpose is to enable communication via our Site or cookies strictly necessary for the provision of the Service, we use cookies and trackers for the following purposes:

  • Cookies for audience measurement and statistics: we use cookies to collect information about the number of visitors to the Site, i.e. the number of unique visitors, the number of times the Site's pages are viewed, the users logged on, the actions carried out on the Site by visitors, and to protect the Site against attempts at piracy. These cookies enable us to improve the speed and security of our Site and to optimise our editorial choices and your browsing experience.

These cookies are set by HOLIDAYS AND CO, and Google.

  • Advertising and marketing cookies: we use cookies to offer you personalised advertising content based on your browsing and profile. The purpose of these cookies is to collect browsing data across several websites and to record information for remarketing purposes.
    These cookies are set by HOLIDAYS AND CO and Google.

Finally, by clicking on the icons dedicated to the Facebook, Telegram or Instagram social networks appearing on the Site and if the User has accepted the deposit of cookies, these networks will be able to deposit cookies on your terminal (computer, tablet, mobile phone), in accordance with their own policy on the deposit of cookies.

INTERNET TAGS. The Company may from time to time employ Internet tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs, and one-to-one GIFs) and deploy them through a web analytics partner that may be located (and therefore store related information, including the User's IP address) in a foreign country.

These tags are placed both in the online advertisements enabling Internet users to access the Site, and on the various pages of the Site.

This technology enables the company to evaluate visitors' responses to the Site and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the use of this Site by the User.

The external service provider may collect information on visitors to the Site and other websites using these tags, compile reports on Site activity for the company and provide other services relating to the use of the Site and the Internet.

Consent to the deposit of cookies and tracers: Except for strictly necessary cookies, if you do not expressly consent to the deposit of cookies and tracers (in particular if you continue to browse the Site), they will not be deposited on your terminal. You may be asked periodically to reiterate your consent, to ensure that it is still valid.

Setting cookies and trackers: Once you have given your consent or refused the deposit of certain cookies and trackers, you always have the option of modifying your preferences directly via the HOLIDAYS AND CO website using the dedicated settings tool or via your browser settings (Firefox with enhanced protection against tracking ; Firefox with cookies deleted ; Chrome ;  Safari ; Opera ; Microsoft Edge).

You can also configure your terminal's browser to activate the «Do Not Track» option, which will indicate to the Sites visited, advertising agencies or applications that you do not wish to be «tracked». This function is available for the following browsers in particular: Firefox ; Chrome ; Internet Explorer ; Safari ; Opera ; Microsoft Edge.

If you refuse cookies that are not essential to the operation of the Site :

Certain functions on the Site, such as video players or interactive content, use services offered by third parties and deposit cookies enabling them to identify your consultation of the content. If you refuse to accept these cookies, the personalisation functions will not work. Browsing the Site may not run as smoothly and the content offered to you (in particular suggested videos or advertisements) will still be present but will not be related to your areas of interest.

 

MAILING ADDRESSES

In the course of our business, your personal data may be transferred to the third parties listed below. Data transfers are carried out in compliance with the applicable Regulations, within the limit of the Data strictly necessary and while ensuring their security.

  • The owners of HOLIDAYS AND CO and mainly those responsible for managing reservations, customer relations, marketing and website management will have access to all your Data.
  • Third parties who place cookies and other tracers on our Site will have access to the Data generated during your browsing if you have consented to the placing of these cookies.
  • Our hosting service provider (see legal notice) ;
  • Our mailing service providers: are recipients of your identity, your billing address, your email address and information about the device and applications you use to access emails sent by these providers (IP address, your operating system, your browser identifier).
  • Upon request, the police, administrative or judicial authorities whose right of access to Personal Data is recognised by law will receive your Data in the event of a request from them or in order to enforce our rights.

TRANSFER TO THIRD COUNTRIES

The HOLIDAYS AND CO website and your personal data are hosted in France and in the European Union. However, as part of the provision of our services, your Data may be transmitted for the purposes defined above to companies located in countries outside the European Union, and more specifically in the United States.

In this case, and before any transfer, HOLIDAYS AND CO makes sure to respect the guarantees necessary to the security of such a transfer by framing this one by the means of the European Commission standard contractual clauses.

You can obtain more detailed information about this transfer by contacting us at: info@divine-villas.com

 

 

EXERCISING YOUR RIGHTS

In accordance with the Regulations, you have the following rights with regard to your Personal Data:

  • Right of access to your Data being Processed (including the right to request a copy) and to the information provided in this privacy policy (Article 15 GDPR). Where the legal basis for the Processing of Data is our legitimate interest, you have the opportunity to request from our services information relating to the balancing we have carried out between the interests of our customers and those of HOLIDAYS AND CO prior to such Processing.
  • Right to rectify (article 16 RGPD) and update your Data held by us.
  • Right to withdraw your consent at any time (article 13-2c RGPD) for all Data Processing based on the legal basis of your consent.

Furthermore, with regard to commercial prospecting, you have the option of unsubscribing from our mailing lists at any time by clicking on the unsubscribe link in our communications or by contacting us if you no longer wish to receive solicitation messages.

  • Right to object (Article 21 GDPR) to the Processing of your Data where such Processing is lawfully based on our legitimate interests.
  • Right to erasure of your Personal Data (Article 17 of the GDPR) in the following cases:
  • When the Data is no longer required.
  • When you have withdrawn your consent to their Processing (if the Processing was based on the legal basis of consent).
  • When you object to Processing whose legal basis is the legitimate interest of HOLIDAYS AND CO or to Processing carried out for canvassing purposes or for profiling purposes linked to canvassing.
  • Right to limit the Processing of your Personal Data, which, unless there are compelling reasons, may only be carried out with your consent (Article 18 GDPR) when:
    • you dispute the accuracy of the Data, for the time necessary to verify it.
    • If the Data Processing is unlawful but you object to the deletion of the Data and choose instead to limit the Processing,
    • When we no longer need the Data but it is still necessary for you to establish, exercise or defend your legal rights.
    • Where you have objected to Processing based on our legitimate interest, for the time necessary to balance our respective interests.
  • Right to portability of the Personal Data you have provided where it is subject to automated Processing based on your consent or on a contract (Article 20 RGPD). This right means that you have the possibility of requesting the communication of this Data in a structured, commonly used and machine-readable format so that it can be communicated to another Data Controller.
  • The right to define what happens to your Data after your death (article 40-1 of law 78-17 of 6 January 1978) and to choose a trusted third party to whom we should entrust it (more information on this subject on the CNIL).

If you wish to exercise any of the above rights or require further information, please contact us at info@divine-villas.com or by post at the Company's registered office address given at the top of this page. more information on the CNIL website.

We reserve the right to ask you to specify your request and to provide us with proof of identity (which will be kept for one year in the event of exercising the right of access or rectification and three years in the event of exercising the right of opposition).

If you are not completely satisfied with our response, you always have the right to lodge a complaint with the authority responsible for monitoring and protecting your personal data (in France, the CNIL).

 

COMPUTER SECURITY

Commitments. We undertake to implement all appropriate technical and organisational measures using physical and logistical security measures in order to guarantee a level of security appropriate to the risks of accidental, unauthorised or illegal access, disclosure, alteration, loss or destruction of your Personal Data.

We invite you to remain cautious about what you decide to make public on the Internet. With regard to Personal Data, including data relating to your private life or sensitive data made public at your initiative or deduced from your contributions, comments and opinions of any kind whatsoever on the Site, or on social networks in groups and/or conversations with other users of the Site.

SSL protocol. The URL address of the Site begins with «https» and a closed padlock or a key appears in the bottom right-hand corner of your browser. This enables you to check that you are in a secure browsing zone, particularly when you are asked for your bank card number. The high security standards of the Https protocol are applied to the storage of Data.

Data breach. In the event of an event leading to the realisation of the risks of modification, disappearance or unauthorised access to Data, we undertake to:

  • Examine the causes of the incident; ;
  • Take the necessary measures to limit the negative effects and damage that may result from the incident; ;
  • Notify the competent authority and/or the persons concerned of the incident as soon as possible if this is required by law.

Under no circumstances may the undertakings set out in the point above be assimilated to any acknowledgement of fault or responsibility for the occurrence of this incident.