Security and confidentiality policy

In the framework of use of its services and notably services available on its internet website, its mobile website and mobile applications, the company COLLECTION BAGATEL, as processing controller, is likely to collect and process personal data concerning you, either directly or via its subsidiaries.

COLLECTION BAGATEL, simplified French law limited liability company (SAS) with capital of  6 610 000 euros, registered in the Paris trade register under the number 794 053 264, with head office at 8 rue Christophe Colomb 75008 Paris, is a COLLECTION BAGATEL GROUP company, whose business is managed under the trading name COMPAGNIE HÔTELIERE DE BAGATELLE.

As at 25 May 2018, the COLLECTION BAGATEL GROUP is composed of the following companies:

• HOTEL PLATINE, SAS, registered in the Paris trade register under the number 522 056 597 with head office at 8 rue Christophe Colomb 75008 Paris
• HOTEL VICE-VERSA, simplified French law single person limited liability company (SASU), registered in the Paris trade register under the number 301 292 603 with head office at 213 rue de la Croix Nivert 75015 Paris
• HOTEL LES PLUMES, SASU, registered in the Paris trade register under the number 522 057 876 with head office at 8 rue Christophe Colomb 75008 Paris
• HOTEL LES THEATRES, SASU, registered in the Paris trade register under the number 398 754 010 with head office at 8 rue Christophe Colomb 75008 Paris
• THE CHESS HOTEL, SASU, registered in the Paris trade register under the number 552 103 764 with head office at 6 rue du Helder 75009 Paris
• LE ROCH HOTEL ET SPA, SASU, registered in the Paris trade register under the number 794 046 144 with head office at 8 rue Christophe Colomb 75008 Paris.

The COLLECTION BAGATEL GROUP attaches great importance to the respect of the rules governing the protection of the privacy of its customers, members of its loyalty programme, prospects and users of its internet websites, mobile websites and mobile applications. All the processing of personal data carried out in the framework of the available services respects the local regulations applicable to the protection of personal data and notably the provisions of the amended French data protection law of 6 January 1978 and EU Regulation 2016/679 on Data Protection (GDPR).

COLLECTION BAGATEL has also implemented adequate internal procedures to raise its employees’ awareness of these rules and ensure their respect within its organisation.

Undertakings of the Collection Bagatel Group relating to Data Protection

The COLLECTION BAGATEL GROUP undertakes to guarantee a high level of protection of the personal data of its customers, prospects, users of its internet websites, mobile websites and its mobile applications and of any other person whose personal data it processes.

The COLLECTION BAGATEL GROUP undertakes to respect the regulations applicable to all the personal data processing which it carries out. In particular, the COLLECTION BAGATEL GROUP undertakes to respect the following principles notably:

• Your personal data are processed in a lawful, fair and transparent manner (lawfulness, fairness, transparency).
• Your personal data are collected for specified, explicit and legitimate purposes, and are not further processed in a way which is incompatible with these purposes (purpose limitation).
• Your personal data are conserved in an adequate and pertinent manner and are limited to what is necessary in relation to the purposes for which they are processed (data minimisation).
• Your personal data are exact, kept up to date and all reasonable steps are taken to ensure that data which are inexact, regarding the purposes for which they are processed, are erased or rectified without delay (accuracy).

The COLLECTION BAGATEL GROUP has implemented the appropriate technical and organisational measures to ensure a level of security adapted to the risks inherent in its processing operations, satisfy regulatory requirements and protect the rights and data of the persons concerned, and this from the conception of the processing operations.

Moreover, the COLLECTION BAGATEL GROUP imposes contractually the same level of personal data protection on its sub-contractors (providers, suppliers, etc.).

Finally, the COLLECTION BAGATEL GROUP undertakes to respect any other principle imposed by the regulations applicable to personal data protection, and more specifically concerning the rights conferred on the persons concerned, the conservation duration of personal data and the obligations relating to cross-border transfers of personal data.

Use of the data collected

Collection tools

In the context of our relations, you are likely to communicate to us your personal data by various means, and notably on our internet websites, mobile websites and applications, when you browse on the internet, make purchases or reservations, by filling in the various forms, when you subscribe to the e-newsletter, create an account on one of our applications, when you apply for a job, when you post comments on our social network pages, when you make any contact with the COLLECTION BAGATEL GROUP or when you transmit your personal data to us by any other means.

Purpose of the processing and legal basis

Your data are mainly used for the purposes of reservation and the provision of specific services: accommodation, prospection, creating loyalty, sales promotion and information, customer satisfaction surveys, organisation of competitive games, new services and products intended to improve your customer experience in our hotels, statistics, recruitment, after sales service, processing your requests and/or complaints, but also to ensure the security of the stays and fight against fraud.
Apart from the cases where your consent has been obtained (notably to communicate personalised offers to you), the processing of your data for the various above-mentioned purposes is necessary notably:

• to fulfil the accommodation contract,
• to respect legal obligations (notably for the arrival card transmitted to the police …),
• for the legitimate interests pursued by the COLLECTION BAGATEL GROUP (notably the development of new services and offers, improvement of the loyalty programme and customer service…).

More specifically, your data are used:

• to enable you to benefit from all the services available on the COLLECTION BAGATEL GROUP internet websites and its mobile websites and applications: creating a user account, e-newsletter, managing reservations, assistance and complaints, administration of the loyalty programme, etc.,
• to enable you to browse on our internet websites,
• to improve the matching of our information, notifications, offers and other forms of service with your interests,
• to be enhanced by sharing some information with privileged commercial partners with the aim of improving our knowledge of your centres of interest and to enable us to send you offers and other forms of personalised services (subject to your prior consent when required and to the respect of your right to object, in compliance with the rules applicable in the field of sales canvassing),

Conservation durations

The COLLECTION BAGATEL GROUP undertakes not to keep your personal data for a duration longer than that necessary for the purposes for which they are processed.  Moreover, the COLLECTION BAGATEL GROUP conserves your personal data in compliance with the conservation durations imposed by the applicable laws in force.

These conservation durations are defined in function of the processing purposes implemented by the COLLECTION BAGATEL GROUP and take account notably of the applicable legal provisions imposing a specified conservation duration for certain data categories and the possible limitation periods applicable.

Access to personal data

Communication of your data

The data collected on the COLLECTION BAGATEL GROUP internet websites and its mobile websites and applications, are likely to be communicated to the authorised personnel of the COLLECTION BAGATEL GROUP, its partners or providers of ancillary services, in the context of providing all or part of the above-mentioned services. We remind you that in this context, the COLLECTION BAGATEL GROUP requires its providers to implement strict confidentiality measures and to protect these data. Moreover, and as for any company providing hotel services, in compliance with the laws and regulations applicable in France, the COLLECTION BAGATEL GROUP may be obliged to provide personal information to the French public authorities (police etc…). This is the case for example with the filling in of the arrival card in our hotels for transmission to the police.

Transfer of data outside the European Union

Some of the addressees mentioned above may be situated outside the European Union and have access to all or part of the personal information collected by the COLLECTION BAGATEL GROUP and this for the purpose of performing the accommodation contract.

In this context, the COLLECTION BAGATEL GROUP undertakes to guarantee the protection of your data in compliance with the strictest rules notably via the signature, case by case, of contractual clauses based on the European Commission models, or any other mechanism in compliance with the GDPR, whenever your personal data are processed by a provider outside the European Economic Area and whose country is not considered by the European Commission as having an adequate level of protection.

Exercising your rights

In compliance with the regulations applicable to the protection of personal data, you may, at any time, exercise your rights of access, rectification or erasure of data concerning you and your rights to restriction of and objection to the processing and to the portability of your personal data.

Also, you have the legal right to define how your personal data should be administered after your death.

Moreover, any person under-age when their personal data were collected may have them erased without delay.

These rights may be exercised by post sent to the following address:

COLLECTION BAGATEL
Protection des Données
8, rue Christophe Colomb
75008 Paris
France

E-mail : protection.donnees@cie-bagatelle.com

In this context, please specify your identity in your request (surname, forename, e-mail) as well as providing proof of your identity.

For some specific services, these rights are to be exercised directly on line (administration of your user account, reservations, loyalty programme etc.).

You also have a right of appeal to the French National Data Protection Supervisory Authority (CNIL) in the event of a breach of the regulations applicable to personal data protection and notably the GDPR.

In the framework of the loyalty programme, you may exercise your rights, withdraw your consent, or send any question or complaint, by contacting the COLLECTION BAGATEL GROUP at the address mentioned above.

The COLLECTION BAGATEL GROUP will cooperate whenever it appears necessary to guarantee the exercise of your rights, or to answer your questions or complaints.

You have a right to object to the processing of your personal data being used for sales canvassing. When the law so requires, your personal data will only be used for canvassing by electronic communications after obtaining your explicit agreement.

Moreover, if you do not wish to receive the COLLECTION BAGATEL GROUP’s electronic newsletter any more by e-mail, you may click on the unsubscribe button at the foot of each communication.

If you do not wish to receive offers from the COLLECTION BAGATEL GROUP and our partners, you may update your communication preferences in your profile by connecting to your account.
In compliance with French and international laws and regulations, the absence of communication or inaccuracy of some data may lead to a decision to refuse accommodation.

User-friendliness of the tools

The COLLECTION BAGATEL GROUP permanently endeavours to improve its electronic services to facilitate access for its customers, potential customers and visitors. The COLLECTION BAGATEL GROUP’s internet websites and its mobile websites and applications provide you, for example, with permanent access (24/24) to online reservations and services.

Cookies

To constantly improve the quality of services proposed on the websites and their adequation with your expectations, the COLLECTION BAGATEL GROUP uses “cookies”, text files which identify your terminal when you connect to one of our services.

The placing of cookies or tracers in your terminal (computer, tablet, smartphone, etc.) enables the COLLECTION BAGATEL GROUP to collect personal information and data. Depending on your configuration choices for your terminal, cookies enable us notably to:

• provide use of the principal functionalities of the COLLECTION BAGATEL GROUP’s websites,
• optimise our internet websites and detect possible technical problems,
• memorise your choices and preferences and personalise your user interface,
• compile statistics for the purposes of managing the traffic and use of the diverse elements composing the COLLECTION BAGATEL GROUP websites (rubrics visited, route taken by the user) enabling us to improve the ergonomics of the websites and the interest of the services offered,
• assess the efficiency of our advertising campaigns by recording and valuing the number of sales and clicks in relation to our advertising expenses,
• know the content of the pages you consult, the availability searches you carry out, the information you choose to share when registering on other websites and the pages and websites you may have consulted,
• share information with other internet websites in order to send you pertinent advertisements and announcements,
• share information on the social networks.

Depending on the configuration choices concerning the use of cookies, some tracers may be issued or read by third parties (advertising or communication agencies etc.) who are not part of the COLLECTION BAGATEL GROUP.

At any time, you may adjust your configuration relating to cookies. For further information on the use of cookies by the COLLECTION BAGATEL GROUP, please consult our cookies administration policy.

Security

It is a priority for the COLLECTION BAGATEL GROUP to look after the security and confidentiality of the personal data you entrust to us. Thus, we implement all the necessary technical and organisational measures, with regard to the nature, scope and context of the personal data you communicate to us and the risks presented by their processing, to preserve the security of your personal data and, notably, prevent any destruction, loss, alteration, divulgation, intrusion or non-authorised access to these data, accidentally or illicitly. You are thus assured of paying for your reservations confidentially and safely.

We provide an on line secured payment system thanks to the latest technology in use.

The COLLECTION BAGATEL GROUP endeavours to fight against identity theft on the internet. This is why, for example, we use a system for the detection of fraudulent payments made by bank cards. This system is designed to protect you in the event of theft or loss of your bank card.

The security and confidentiality of personal data rely on everybody’s good practice. This is why we encourage you not to communicate your passwords to third parties, and we encourage you to disconnect systematically from your profile and your social network account (notably in the case of linked accounts) and to close your internet connection at the end of your work session, especially if you connect to internet from a terminal shared with other persons. You will thus avoid other users having access to your personal information.

We strongly advise you not to communicate to third parties or post on social networks any document issued by the COLLECTION BAGATEL GROUP containing your personal data (your reservation number, etc…)

Finally, the COLLECTION BAGATEL GROUP has implemented a procedure for the management of security breaches enabling it to spot possible violations of personal data, notify the competent authorities of these violations without delay and warn you when this violation is likely to harm your personal data.

Minors

The COLLECTION BAGATEL GROUP neither collects nor processes personal data relating to children under 16 years of age without the prior agreement of the parents or persons with parental responsibility for the child.

If personal data concerning children are collected via the COLLECTION BAGATEL GROUP internet websites, or mobile websites or applications, the parents or persons with parental responsibility may express their objection by contacting us at the address shown at the foot of this page.

Moreover, as stated above, a child who is under-age when his or her personal data are collected may have them erased without delay.

Other links

On several pages of the COLLECTION BAGATEL GROUP internet websites you have the possibility of clicking to arrive on other internet websites of other companies. We advise you to read the policies of these websites, for which the COLLECTION BAGATEL GROUP is not liable, relating to the processing and protection of personal data, because the terms and conditions of these websites may differ from those of the COLLECTION BAGATEL GROUP. The COLLECTION BAGATEL GROUP may in no case be held liable for the processing of the personal data by these other internet websites.

Contact

For any further question relating to this policy or the way in which the COLLECTION BAGATEL GROUP processes your personal data, you may contact us at the following address: protection.donnees@cie-bagatelle.com

Modifications

The COLLECTION BAGATEL GROUP reserves the right to adapt the personal data protection policy and undertakes to inform you via its internet website of any changes or additions.