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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. That's why we are committed to respecting the confidentiality of the personal information we collect.


DEFINITIONS

Capitalized 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 elements specific to his or her identity.

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

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

"We" or "HOLIDAYS AND CO": refers to 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 1,000 euros.

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

The "Data Controller" is 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, service or any other organization that receives communication of 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 prospecting 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 MANAGER

The Data Manager mentioned 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 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 us with 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:

  • Last name, 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 (for example: Messenger, WhatsApp, Telegram...), you are informed that this exchange will be handled in accordance with the privacy policy of the network in question, which you are responsible for reading prior to use.

  • Any exchanges with our customer service department (date, time and content of exchange, telephone number, identifier or e-mail 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 transmitted in order to justify the identity of the person requesting the exercise of rights) 
  • Data relating to reviews of our products or services posted 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 review, content, date and time of the review, product or service covered by the review, 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 with public information (such as reviews and contributions) from other sources such as social networks (in particular: Facebook, Google, Youtube, Instagram...) when these contributions are freely accessible to the public. This includes information to which we may have access as administrator of a page or group.

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

When you browse the website, 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:

  • Management and monitoring of contracts and service performance: 
  • Order payment processing and invoicing ;
  • Keeping an up-to-date customer file ;
  • Exchanges with customer service and assistance;
  • Rental payment and billing management

The legal basis of the Processing is then the execution 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 HOLIDAYS AND CO's compliance with its legal obligation to retain this data.
  • Keeping a prospect file: the legal basis for Processing is HOLIDAYS AND CO's legitimate interest in keeping up-to-date information on people 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 to improve its Site 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 Site 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 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 for which previous orders have been placed, 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 the respect of a legal obligation of HOLIDAYS AND CO to allow the exercise of the rights of its customers with regard to Data protection.


 OUR COOKIES POLICY

During your browsing on the Website, we use several types of cookies and tracers in order to optimize your browsing and enable us to improve our offers.

In addition to cookies whose sole purpose is to enable communication via our Website 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 our site, i.e. the number of unique visitors, the number of page views, logged-in users, actions taken on the site by visitors, and to protect the site against hacking attempts. These cookies enable us to improve the speed and security of our website and to optimize our editorial choices as well as your browsing experience.

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

  • Advertising and marketing cookies: we use cookies to offer you personalized advertising content based on your browsing habits 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 social networks Facebook, Telegram or Instagram appearing on the Site and if the User has accepted the deposit of cookies, these networks may deposit cookies on your terminal (computer, tablet, cell phone), in accordance with their own policy on the deposit of cookies. 

INTERNET TAGS. The Company may occasionally 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 beacons are placed both in online advertisements enabling Internet users to access the Website, and on its various pages.

This technology enables the company to evaluate visitors' responses to the Website 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 the Website by the User.

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

Consent to the deposit of cookies and tracers: Except for strictly necessary cookies, in the absence of your express consent to the deposit of these cookies and tracers (particularly in the case of your continued browsing on the Website), 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 cookie deletion ; Chrome ;  Safari ; Opera ; Microsoft Edge).

You can also configure your terminal's browser to activate the "Do Not Track" option, which will indicate to visited Websites, advertising agencies or applications that you do not wish to be "tracked". This feature 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 Website :

Some Website functionalities, such as video players or interactive content, use services provided by third parties and deposit cookies enabling them to identify your consultation of the content. If you refuse to accept these cookies, the personalization features may not function. Browsing on the Site may not run as smoothly, and the content offered to you (particularly suggested videos or advertisements) will still be present, but will not be related to your centers of interest.


RECIPIENTS

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 applicable regulations, within the limits of strictly necessary data and with due regard for 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 Website will have access to the Data generated during your browsing if you have consented to the placement of these cookies.
  • Our hosting service provider (see legal notice) ;
  • Our mailing service providers: are recipients of your identity, your billing address, your e-mail address and information on the device and applications you use to access e-mails sent by these providers (IP address, your operating system, your browser identifier).
  • Upon request, the police, administrative or judicial authorities whose right to access personal Data is recognized by law will receive your Data in the event of a request on their part 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 secure such a transfer by framing it through the European Commission standard contractual clauses.

You can obtain more detailed information on 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 RGPD). 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 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.

In addition, with regard to commercial prospecting, you can unsubscribe from our mailing lists at any time by clicking on the unsubscribe link in our communications or by contacting us to stop receiving solicitation messages.

  • Right to object (Article 21 RGPD) to the Processing of your Data where such Processing has as its legal basis our legitimate interest.
  • Right to erasure of your Personal Data (Article 17 of the RGPD) 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 that has as its legal basis the legitimate interest of HOLIDAYS AND CO or to Processing carried out for canvassing purposes or for profiling purposes linked to canvassing.
  • Right to the limitation of the Processing of your Personal Data, which, except for compelling reasons, may no longer be implemented except with your consent (Article 18 RGPD) 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 opt instead for the limitation of 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 when 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 the fate of your Data after your death (article 40-1 of law 78-17 of January 6, 1978) and to choose a trusted third party to whom we should entrust them (more information on this subject on the CNIL).

If you wish to exercise any of the aforementioned rights or require further information, please contact us at info@divine-villas.com or by post at the Company's registered office address shown at the top of this page. You may also obtain the following information 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 controlling and protecting your personal data (in France, the CNIL).

 

IT SECURITY

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

Please be careful about what you decide to make public on the Internet. With regard to Personal Data, including those relating to your private or sensitive life, made public at your initiative or deduced from your contributions, comments and statements of any kind whatsoever on the Website, or on social networks in groups and/or conversations with other users of the Website.

SSL protocol. The URL address of the site begins with "https" and is accompanied by a closed padlock or a key 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 credit card number. The high security standards of the Https protocol are applied to Data storage.

Data breach. In the event of an event leading to the realization of the risks of modification, disappearance or unauthorized 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 when required by law.

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