Personal Data Protection Policy
Dated May 20, 2024
IN SUMMARY ABOUT THE PROTECTION OF YOUR PERSONAL DATA
This personal data protection policy of the Hotel Le Pigalle is an annex to the General Terms and Conditions (“GTC”) and thus has contractual value. In case of contradiction between the GTC and this policy, the GTC will prevail, which the user of our sites acknowledges and accepts.
This personal data protection policy reflects the Hotel Le Pigalle’s commitment to being completely transparent with the site user about how their personal data is managed and incorporates the latest requirements from applicable legislation and regulations, notably the European Regulation on the protection of personal data (GDPR). The Data Protection Officer for Hotel Le Pigalle is: Mr. Thomas FULLANA – Email: privacy@biografygroup.com. For any questions from the user regarding this personal data protection policy, they are invited to send a message to privacy@biografygroup.com.
SUMMARY
Article 1. What is the purpose of the Personal Data Protection Policy?
I. PERSONAL DATA
Article 2. What is personal data?
Article 3. What personal data is collected by the Hotel Le Pigalle and for what purposes?
Article 4. Who has access to the user’s personal data?
Article 5. What are the Users’ rights regarding the collected personal data?
Article 6. For how long is the personal data collected?
Article 7. What measures are taken to protect users’ personal data?
II. COOKIES
Article 8. What is a cookie?
Article 9. What tracking systems are used by Le Pigalle and for what purposes?
Article 10. How to authorize/disable cookies?
III. MODIFICATION OF THE DATA PROTECTION POLICY
Article 11. What is the purpose of the Personal Data Protection Policy?
PROTECTION OF PERSONAL DATA
Article 1. What is the purpose of the Personal Data Protection Policy?
The purpose of this Personal Data Protection Policy is to inform the User about how the Hotel Le Pigalle manages the personal data of users of its websites, whether they are clients or not (hereinafter “the Users”).
I. PERSONAL DATA
Article 2. What is personal data?
According to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, personal data is “any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.”
Article 3. What personal data is collected by the Hotel Le Pigalle and for what purposes?
The Hotel Le Pigalle collects personal data on the following website: https://lepigalle.paris/
Data processing involved: Sending exclusive offers and communication
Personal data processed: Email address
Purpose: Commercial
Legal basis: Legitimate interest / contract (following a stay)
Retention period: 3 years from the date you were last active with us in any way
Data processing involved: Newsletter
Personal data processed: Email address
Purpose: Commercial
Legal basis: Consent
Retention period: The duration of the subscription
Data processing involved: Contact before the stay
Personal data processed: Name, first name, email, phone
Purpose: Commercial
Legal basis: Contract
Retention period: 3 years
Data processing involved: Contact and service follow-up during the stay – satisfaction follow-up
Personal data processed: Name, first name, email, phone
Purpose: Commercial
Legal basis: Contract
Retention period: 3 years
Data processing involved: Booking, follow-up, and payment
Personal data processed: Name, first name, email, bank details, credit card, ID card
Purpose: Commercial
Legal basis: Contract
Retention period: 5 years (deletion of bank data after one day)
Data processing involved: Recruitment of new employees
Personal data processed: Name, first name, email, phone, CV data (mandatory data)
Purpose: Recruitment
Legal basis: Pre-contractual measures
Retention period: 2 years after the last contact (unless recruited)
Article 4. Who has access to the user’s personal data?
The only recipients of Users’ personal data are:
– The relevant services and employees of Hotel Le Pigalle and the Biografy group (notably: IT, sales/marketing, operational), bound by specific data protection obligations;
– Companies that assist Hotel Le Pigalle in the operation and/or exploitation of the sites;
– Subcontractors of our hotels.
These entities receive only the personal information strictly necessary for booking and possibly reminding customers. Personal data processing by these entities is carried out under conditions compliant with applicable legislation and regulations.
Article 5. What are the Users’ rights regarding the collected personal data?
The User has access to the detailed rights in Chapter III of the GDPR, including the following rights:
– Right of access to their personal data collected on the Website
– Right to modify/rectify them
– Right to erasure (“right to be forgotten”) unless there is a legal reason that obliges us to retain them
– Right to restrict processing, meaning the right to ask us in some cases to suspend the processing of personal data
– Right to data portability, i.e., the right to request a copy of their personal data in a commonly used format (e.g., a .csv file)
– Right to object to the processing of personal data
– Rights related to automated decision-making and profiling, i.e., the right to ask us to be transparent about any profiling we perform or any automated decisions.
All these rights apply to data processing carried out via the Hotel Le Pigalle website and requesting personal information (registration forms, contact requests, booking confirmations, etc.). Any user can contact Hotel Le Pigalle by sending an email to privacy@biografygroup.com or by mail to 9 rue Frochot 75009 Paris.
The User also has the right to lodge a complaint with the Commission Nationale Informatique et Libertés (CNIL), the supervisory authority for data protection in France (www.cnil.fr).
However, Hotel Le Pigalle would like a chance to address your concerns before you contact the CNIL. So, please contact us first.
Article 6. For how long is personal data collected?
Users’ personal data is retained under conditions compliant with applicable legislation and regulations. For more information, any user can contact Hotel Le Pigalle by sending a message to privacy@biografygroup.com.
Article 7. How is personal data protected?
Hotel Le Pigalle is very vigilant about data security and takes all reasonable precautions to prevent unauthorized access, disclosure, alteration, or destruction of personal data. The personal data collected is stored by Hotel Le Pigalle or its service providers and protected by physical and electronic access controls, firewall technologies, and other reasonable security measures.
However, these measures cannot prevent all risks of loss, misuse, or alteration of personal information. Where required by law, Hotel Le Pigalle will notify the User of any loss, misuse, or alteration of their personal data, so they can take appropriate steps to enforce their rights. Hotel Le Pigalle will notify the User by email, mail, or phone if permitted by law.
Users are advised not to transmit payment information or sensitive data by email or in non-designated sections (e.g., sending a credit card number by email). Users are also informed that they can always choose the personal data they wish to provide. However, their decision not to transmit certain data may affect their experience of the services. For example, we cannot make anonymous reservations, and if we are not authorized to disclose your personal data to our group hotels, we may be unable to provide certain reservation or other services.
Similarly, if the User does not allow us to disclose their personal data to third parties such as Hotel Le Pigalle subcontractors (transfer service, concierge service, etc.), we may not be able to provide all possible services or the provision of these services may be delayed. We will strive to respond to your request as soon as possible.
II. COOKIES
Article 8. What is a cookie?
According to the Commission Nationale de l’Informatique et des Libertés, a cookie is information placed on the User’s access device by the server of the Website or Application they visit. A cookie contains several data:
– The name of the server that placed it
– A unique identifier number
– Possibly an expiration date.
This information is sometimes stored on a device in a simple text file to which a server accesses to read and record information.
Article 9. What tracking systems are used by Hotel Le Pigalle and for what purposes?
The User is informed that Hotel Le Pigalle uses the following tracking tools:
– Google Analytics
– Google Tag Manager
– Google Search Console
– Experience
– Bowo
The Hotel Le Pigalle website, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons.
These technologies help us better understand user behavior, tell us which parts of our websites users have visited, facilitate and measure the effectiveness of advertisements and web searches.
We treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses (Internet Protocol) or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information.
Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this privacy policy.
Hotel Le Pigalle also uses
cookies and other technologies to remember personal information when using our website, online services, and applications. Our goal is to make your experience with Hotel Le Pigalle more convenient and personal. For example, knowing your first name allows us to welcome you the next time you visit the Hotel Le Pigalle. Knowing your country and language helps us provide a customized and more useful browsing experience.
As is true of most Internet services, we automatically collect some information and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit pages, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, administer the site, learn about user behavior on the site, and gather demographic information about our user base as a whole. Hotel Le Pigalle may use this information in its marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to the content on the Hotel Le Pigalle website. When customers click on one of these URLs, they pass through a separate web server before arriving at the landing page on our site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click on text or graphic links in the email messages.
Pixel tags allow us to send email messages in a format that customers can read and let us know whether the email has been opened. We may use this information to reduce or eliminate messages sent to customers.
Article 10. How to authorize/disable cookies?
Most browsers automatically accept cookies, but the user can usually modify their browser setting to refuse cookies if they prefer. The User can also delete cookies from their device.
The settings for each browser are different. They are described in the help menu of the User’s browser, which will allow them to know how to modify their wishes regarding cookies.
Disabling cookies may alter or make it impossible to access certain features of the Website.
III. MODIFICATION OF THE PERSONAL DATA PROTECTION POLICY
Hotel Le Pigalle reserves the right to update this personal data protection policy at any time, and the User will be informed of any substantial change via the Site or by any other appropriate means.
The new privacy policy will be available on the Site, and the User is advised to refer to it regularly. The User can also send an email to privacy@biografygroup.com for any question or request for clarification about changes in this policy.