The Adova Group collects, uses and shares various information that users of our Products provide to us via our website (the ‘Website’) accessible from the website https://www.hotelys.com/fr/
In order to preserve the confidentiality of your Personal Data and in a desire for transparency, we have drawn up this document so that you can be aware of and understand the processing that we carry out on the data that you provide to us.
The Adova Group is committed to ensuring the highest level of protection and security for your personal data in compliance with applicable European and French regulations.
Therefore, the Confidentiality Policy, formalised herein, aims to describe :
- what data we collect and why we collect it;
- how we use this data;
- your rights regarding the use of your personal data.
You will note that this Policy illustrates our contractual commitments, and in particular the general conditions of use of the Website.
This Privacy Policy does not apply to mobile applications and third-party websites, whether or not they are partners of our company, to which our Website may redirect you.
For further information on the protection of personal data, please consult the CNIL website: https://www.cnil.fr/
I. Data collected
In order to provide better services to all users of our products, we may collect and process various data collected in the following ways:
(i) data collected directly from the user: When using our Website, you may provide us with information that enables us to identify you (‘Personal Data’). By way of illustration, you provide us with Personal Data when you fill in the registration forms for our services, when you take part in one of our games, competitions, promotional offers, studies or surveys, or when you contact us by any means whatsoever.
This information contains, in particular, the following data:
- your surname, first name, address, title, telephone number and e-mail address;
- data relating to your location where you have agreed to us collecting and processing this data;
(ii) data collected automatically: In the course of using our products and services, we collect various information on a systematic and automated basis. This information mainly falls into the following categories:
- data relating to the device used for connection or to the methods of consulting and using our services: we may collect information relating to the devices on which you use our services or to the networks from which you access them, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of your browser's plugins, operating systems and platforms, or data relating to your browsing habits;
In any event, we only collect and process data that is strictly necessary to achieve the purpose for which it was collected. Finally, when we request information from you, we inform you of the optional or compulsory nature of providing this information, and of the consequences of failing to reply. For example, only the data fields marked with an asterisk are mandatory in order for us to offer you a service, such as placing an order.
Children
Our Site is not designed for children under the age of 16, and we ask minors not to communicate any Personal Information to the Adova Group. If we become aware that we have collected Personal Information from a minor under the age of 16, we will take all necessary steps to delete such information as soon as possible.
II. Retention period of collected data
As a matter of principle, the data collected is kept for a maximum period of 24 months following the last visit to the Website.
This retention period may be reduced if your account is closed at your initiative or if you request the deletion of your Data.
However, the retention period for certain data may exceed the five 24-month period referred to above, in order to comply with our accounting and tax obligations and, more generally, with our legal obligations. This refers in particular to all transactions that have taken place, as well as the associated financial data.
III. Use of data collected
The Data collected is used to:
(i) send you information about our services by any means of communication, such as important warnings about security or any significant changes to this Privacy Policy, and to provide you with a high-quality customer support service;
(ii) to enable you to personalise our services, correct and improve them in order to always offer you the best service; for example, your purchase history may enable us to provide you with better information when you visit our Site;
(iii) geolocation functions; we collect location data only if you authorise us to do so and for the sole purpose of providing you with the Services based on the location you request (use of the store locator to locate points of sale). This data is stored on your terminal and is not stored or processed by us.
(iv) allow you to create an Account which may give you access to certain services which require prior registration, for example, when you create an Account we ask for your email address and name to ensure the security of your Account;
(v) allow you to log in to your Account using the login details used on a social network; if you choose to do this, when you first log in you will be asked to give your consent to the social network provider to provide us with certain information to the ADOVA Group, including your name, email address, profile picture, posts, comments and other information associated with your account on that social network. All this information will be transmitted to the ADOVA Group by the social network provider because of the way the connection via a social network works. However, we only store and process your e-mail address. If you do not wish to do so, you can simply connect to your Account using your connection information, without using the identifiers associated with your social network account;
(vi) to provide you with product and customer support and to monitor the quality and nature of that service; when you contact a customer support advisor by email or telephone, we collect Personal Information such as your name, postal address, telephone number, email address and contact preferences, as well as information about the Products you own, such as date of purchase. We may also create event logs that we use to diagnose product or application performance problems and to collect information about a support or service issue. Subject to applicable law, we may also record and listen to your conversations with our customer support advisers and analyse any feedback voluntarily provided via a customer survey, all in order to improve our customer service. With your consent, which you may withdraw at any time, our customer support advisers may connect to your Account if required to resolve problems.
IV. Communication of data collected
In order to provide you with the best possible service, we may share information about you, in particular your Personal Data, with third-party companies which process it on our behalf, according to our instructions and in compliance with the legislation in force and with these terms and conditions. Your Data will only be shared with partners who provide sufficient guarantees that appropriate technical and organisational measures have been implemented to ensure the protection of your rights and your Data.
We may also share certain data, including your Personal Data, pursuant to a legal obligation to do so or if we believe in good faith that it is necessary to (i) respond to any claim made against the ADOVA Group, (ii) comply with any legally enforceable demand, (iii) enforce any contract entered into with our users (iv) in an emergency involving public health or the physical safety of any person, (v) in connection with investigations and enquiries, or (vi) in order to protect the rights, property and safety of the ADOVA Group, its users and, more generally, any third party.
More generally, we may communicate to third parties all the information that you have authorised us to communicate to them. We also reserve the right to disclose some or all of the Data we collect in connection with the transfer of ownership or restructuring of our business or its assets, provided that the entity to which we transfer the Personal Data will only process your Personal Data in accordance with this Privacy Policy and applicable law.
V. Data location
We store your Personal Data on our secure servers located within the European Union. However, it is possible that the data we collect when you use our services may be transferred to other countries.
In such cases, we ensure that the processing is carried out securely and in accordance with this Policy and that it is governed by the European Commission's standard contractual clauses, which guarantee an adequate level of protection.
VI. Data security
We implement appropriate and customary security measures to protect your data from unauthorised access, modification, disclosure or destruction.
VII. Vos droits
The ADOVA Group has put in place appropriate Personal Data protection measures to ensure that Personal Data is used in accordance with the purposes set out above and to ensure that it is accurate and kept up to date and that you can exercise your rights.
Right of access: You have the right to access the Personal Data we hold through your account (accessible via the Website or via the Application).
Right of rectification: You have the right to request the rectification and immediate updating of your Data.
Right to erasure (‘right to be forgotten’): Unless otherwise provided by law, we will delete your Data in order to comply with our legal obligations, in particular when your Data is no longer necessary or when you request us to do so.
Right to limit processing: You also have the right to limit the processing of your Personal Data if you consider that your Data is inaccurate or if you object to its use.
Right to portability of your Data: You may ask us for a copy, in a structured, commonly used and machine-readable format, of the Data you have communicated to us as long as its processing is carried out using automated processes. Where technically possible, you may request that this Data be transmitted directly to another data controller.
Right to object: In certain circumstances and for reasons relating to your particular situation, you may object to us processing your Personal Data. Where you make such a request and it complies with the applicable law, we will no longer process your Data unless we demonstrate the legitimacy and imperative nature of the processing of personal data and that this overrides your rights, interests and freedoms. We may also process your Data if this is necessary for the establishment, exercise or defence of legal claims.
In order to respond to your request, we may (i) verify your identity and (ii) ask you to provide us with the type of information you wish to be disclosed.
Please note that we may retain certain information where we are required to do so by law or where we have a legitimate reason to do so notwithstanding your deletion of such information.
Right to lodge a complaint with a supervisory authority: If you believe that the ADOVA Group is not complying with this Privacy Policy or that your rights under applicable law are not being adequately protected by the ADOVA Group, you have the right to lodge a complaint with a supervisory authority. In any event, we invite you to contact us directly at the following address: donneespersonnelles@adova-group.com
Finally, we will take all reasonable steps to notify each user to whom personal data has been communicated of any rectification or erasure of personal data or any restriction on the processing carried out, unless such communication proves impossible or would require disproportionate effort.
VIII. Cookies and similar technologies
Cookies’ are data stored in the terminal equipment of an Internet user and likely to be used by the Website to send information to the User's or Member's browser, enabling this browser to send information back to the site of origin (for example a session identifier, choice of language or date, etc.). Cookies also make it possible to store status information when a browser accesses the various pages of a website or when the browser returns to the website at a later date, thereby optimising browsing.
Users are informed that, during their visits to the Website, information relating to their browsing is likely to be collected and stored by means of ‘cookie’ files which may be installed automatically on their terminal.
When browsing the Website, you may encounter different types of cookies:
The Publisher's cookies
The main purposes of the Publisher's ‘cookies’ are:
- to store variable and personalised data about a visitor to the Website ;
- to memorise the various entries made in order to optimise the services of interest to the User or Member and make it easier to fill in the various forms.
Third-party cookies
- tracking cookies ;
- audience cookies ;
- technical and operating cookies.
The main purposes of third-party cookies are to:
- to distinguish Users, sessions and new visits;
- to compile statistics for analysing traffic and anonymous browsing;
- recording the source of traffic or a campaign;
- memorising the login and password in order to facilitate the connection of a Member who has already registered;
- personalising potential commercial offers;
- securing a User/Member's connection to the Website, storing his/her user preferences and optimising browsing;
- collecting the display parameters of a site to facilitate browsing.
This list is not exhaustive and may change as the Website evolves.
Users may refuse the installation of cookies on their computer terminal by configuring their browser according to the procedure indicated on the browser.
In this case, use of the Website and access to the Services may be impaired.
IX. Changes to the data collection and processing policy
We may amend this Privacy Policy from time to time. In the event of substantial modification, we will inform you and/or seek your agreement as soon as possible and using reasonable means. We advise you to consult our current Policy regularly to take note of any changes or updates made to it.
X. Contact and data controller
If you have any requests or questions relating to this Policy and the way in which we use your Personal Data, please contact us at the following address: donneespersonnelles@adova-group.com
You can also contact us by post at the following address:
ADOVA GROUP
For the attention of the Data Processing Manager
30 rue Proudhon, bâtiment 106, 93210 Saint Denis, FRANCE - Email : donneespersonnelles@adova-group.com