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External data protection policy

Identity of the data controller

Européenne d’Hôtellerie, société anonyme coopérative de commerçants détaillants [a cooperative limited company of retail traders] with variable capital, whose registered office is at 22 Rue Maurice Grimaud, 75018 Paris, identified in the SIRENE directory under number 328 179 726 and entered in the Paris Trade and Companies Register, is the controller of the data processed via the website www.theoriginalshotels.com/

Collection of personal data 

Within the context of browsing the Website, Européenne d’Hôtellerie collects personal data of Site Users that is strictly necessary for the provision of Services, namely the following categories of data: 

• Identification data and address details: title, surname, first name, postal address (with postcode, city, country), email, telephone number, date of birth, billing address, and, if applicable, age of children, as well as certain information that can prove the identity of the user if necessary).
• Data on usage history: Loyalty Scheme membership, key dates, previous User stays or interaction, products and/or services used, requests for services and/or special arrangements:
- data relating to membership or the loyalty scheme;
- key dates;
- previous stays or interaction as a customer, products and services purchased, requests for services and special arrangements;
- customer’s personalised data and preferences;
- social media account identifiers, profile photo and other data that is already public, or information made available by linking to social media and loyalty accounts.
• Data relating to the agreement to or refusal of direct marketing (text or email);
- data relating to building loyalty and marketing, in particular data on the use of emails and texts (sending date, email opening, clicks, etc.). 
• Data relating to exchanges with customer service and/or the seminar service. 
• Internet browsing data (cookies, browsing data, audience measurement, etc.).
• Data relating to applications. 

The personal data is collected: 
- using online forms that Users fill in as part of various requests for information made of them (Bookings, Questionnaires, Customer account preferences, etc.);
- by integrating data from Users' Social Media account(s). To be implemented, this data integration must be expressly authorised by Users by accepting the proposal made in this respect;

Purposes of processing the personal data

Personal data is collected and processed by Européenne d’Hôtellerie in order to: 
- allow Users to book Services;
- facilitate the Hotelier’s performance of the Services booked by Users;
- optimise the management of User satisfaction questions: 
       - provision and collection of pre- and post-stay questionnaires;
       - access to contact forms; 
- adapt the offer to Users' preferences: 
      - account set-up;
      - request for quotations and other points of contact of the customer experience;
      - customer service;
- facilitate the management of the loyalty scheme and Guest Management System (customer knowledge management tool);
- ensure that the site content is presented in the most efficient way (display, browsing, etc.);
- enable Users to participate interactively in the Website’s services, subject to their express prior consent;
- inform Users of any changes in the Website’s offer;
- enable Users to submit their requests; 
- organise marketing campaigns, subject to Users' express prior consent.

Depending on the purpose of the processing, it will be based either on the fulfilment of a contractual obligation or legal obligation, or on consent or legitimate interest.

Recipients of the data collected

The personal data processed by Européenne d’Hôtellerie is intended for the services authorised by Européenne d’Hôtellerie.

In addition, other recipients may have access to all or part of the personal data depending on their authorisation level and the purpose, i.e.:
- the authorised services of Européenne d’Hôtellerie’s providers;
- government bodies, police services and judicial authorities, particularly in the case of a court order, within the framework of their mission.

Information and rights of holders

In accordance with the applicable legislation on the protection of personal data, any person concerned by the processing has a right of access to, a right to question, and a right to rectification and erasure of their data, as well as a right to object for legitimate reasons and a right to object to direct marketing, in particular regarding sales.

Pursuant to Regulation 2016/679 of 27 April 2016 on data protection and the amended French Data Protection Act of 6 January 1978, data subjects have a right to restrict the processing concerning them, a right of access to, a right to question, and a right to rectification, erasure and portability of their data. 

Data subjects also have a right to object for legitimate reasons and a right to object to direct marketing. 

Data subjects also have the right to set out specific and general guidelines regarding the storage, erasure and disclosure of their personal data after their death. 

In addition, data subjects have the right to lodge complaints with CNIL [the French Data Protection Authority]. 

Rights may be exercised: 
-  by email to dpo@theoriginalshotels.com; 
- by sending a letter to the following address: SA EUROPEENNE D’HÔTELLERIE, 22 Rue Maurice Grimaud, 75018. 

Within the framework of exercising their rights, data subjects must provide proof of their identity by any means. In case of doubt as to the identity of data subjects, SA Européenne d’Hôtellerie reserves the right to request additional information that seems necessary for their identification and in particular a photocopy of their identity document. 

Retention period

The personal data processed is stored according to its purpose in accordance with applicable legislation and archived according to the statutory limitation and retention periods and in particular those regarding taxation, sales and accounting.

Location of data

Personal data is hosted on servers of Iguane Solutions located in the United States.