PERSONAL DATA PROTECTION POLICY
APPLICABLE FROM 25 MAY 2018
GOELIA builds strong and lasting relationships with its users, based on mutual trust: ensuring the security and confidentiality of its customers’ personal data is an absolute priority for our services.
GOELIA complies with all French and European regulatory and legislative provisions concerning personal data protection. GOELIA applies an effective policy to ensure the protection of its users’ personal data:
- Each user of GOELIA retains control of their data. GOELIA does not make it freely available.
- The data are processed in a transparent, confidential and secure way using its tools RESALYS (SOFTBOOKING) and ADMIN (PLANET BOURGOGNE) and secure servers (ITDG).
- GOELIA is committed to an ongoing process of protecting its users’ data, in compliance with the [French] Data Protection Act of 6 January 1978 amended (hereinafter “LIL”) and the (EU) General Data Protection Regulation of 27 April 2016 (hereinafter “GDPR”).
- GOELIA has a team dedicated to personal data protection, composed of the CEO, the Development Director (Data Protection Officer DPO), the Director of Human Resources, the Marketing Manager and specialist IT developers.
- Users’ personal data are hosted by three service providers (Resalys, Planet Bourgogne and GIDT)
PURPOSE OF THIS POLICY
GOELIA wishes to inform you by means of this policy of how we protect your personal data processed via the website https://www.goelia.com, via bookings with our booking office or our websites, via oral requests for brochures or via our satisfaction questionnaires or competitions.
This policy describes how GOELIA processes the personal data of visitors and users (hereinafter the “User/s”) while browsing the website www.goelia.com or on the websites called related stations (searchable lists on request) (hereinafter the “Website”) and when using GOELIA’s services.
This policy may be amended, supplemented or updated in particular to comply with any legal, regulatory, case-law and technical developments. However, the User’s Personal Data will always be processed in accordance with the policy in force at the time of their collection, unless an imperative legal prescription provides otherwise and is applied retroactively. This policy is an integral part of the general terms and conditions of use of the Website. (Amend the general terms and conditions of use + put in the brochure)
DATA COLLECTION & ORIGIN
All the data concerning Users are collected directly from the latter or via a partner (which will indicate their forwarding to GOELIA in their own terms and conditions).
GOELIA undertakes to collect the consent of its Users and/or to permit them to object to the use of their data for certain purposes, as soon as necessary, via information on its website.
PURPOSE OF THE COLLECTED DATA 1. Need for the collection.
When making a booking online or by phone with our teams, the User communicates certain Personal Data. If the User does not wish to disclose the information that is requested, they may be unable to make a booking. 2. Purposes
The legal basis for collecting Personal Data is as follows:
- GOELIA’s legitimate interest in ensuring the best quality of its services, to provide its Users with the best possible follow-up of their booking and of their stays on site, and to improve the operation of its website
- GOELIA’s legitimate interest is to conduct optional satisfaction surveys on its services in order to improve them
- the consent of Users when required by the regulations in force, in particular with regard to business prospecting and cookies.
GOELIA’s Users’ data are primarily processed to:
- allow them to browse the website (book, online payment, catalogue request, get their opinion, subscribe to the newsletter), and the improvement of these services,
- allow follow-up by GOELIA of the booking option until the end of the stay and then ask their opinion to improve our services if necessary
- allow the collection of their opinion and the improvement of GOELIA’s services - facilitate their future bookings
- allow the sending of catalogues and newsletters specific to GOELIA
TYPES OF DATA PROCESSED
GOELIA is likely to process, to enable bookings to be made and managed: all or part of the following information:
- Last name (and birth name),
- First name,
- Date of birth,
- Height, weight, shoe size (only if pre-booking ski equipment),
- Telephone numbers,
- Email address,
- Postal address,
- Choice of destination,
- Trip start and end dates,
- Number of occupants in the accommodation,
- History of stays and services used,
- Special wishes,
- Origin (Works Council, partners),
- Promotion codes used,
- Loyalty account,
- And this for all occupants of the accommodation.
GOELIA is likely to process via its subcontractor:
- website login and use data, to prevent and combat computer fraud (spamming, hacking, etc.) and to establish visitation and purchase statistics to improve its commercial actions.
NON-COMMUNICATION OF PERSONAL DATA
The User’s Personal Data will not be forwarded to commercial or advertising companies without their express agreement. The User’s Personal Data can only be processed by GOELIA and its identified service providers (PLANET BOURGOGNE, GIDT and SOFTBOOKING), in full compliance with the above principle, solely to achieve the purposes of this policy.
Within the limits of their respective powers and for the purposes referred to above, the people who are likely to have access to the data of GOELIA’s Users are mainly our customer service agents, the marketing department and our operational teams.
GOELIA also uses the services provided by several specialist companies (mailing, audience analysis), the list of which can be communicated to the persons concerned following a request sent to firstname.lastname@example.org
When organising competitions via a partner, GOELIA indicates to Users that the partner will have access to the following data: Last name, First name, Post code and Email.
In the case of a booking for a partner residence (i.e. a residence not locally managed by the GOELIA group), GOELIA shall forward the personal data necessary for the booking to the establishment.
In the case of booking additional services (ski equipment, ski lift passes, activities pass, etc.), GOELIA shall forward the personal data necessary to provide the services.
DATA RETENTION PERIOD
We only keep your data for the time necessary for the purposes pursued and in accordance with the legal requirements.
In accordance with the European regulations in force, Users of GOELIA have the following rights:
- right to access (Article 15 GDPR) and rectify (Article 16 GDPR), update and completeness of the Users’ data
- right to lock or to erase Users’ data of a personal nature (Article 17 of the GDPR), when inaccurate, incomplete, misleading, outdated, or whose collection, use, communication or retention is prohibited
- the right to withdraw consent (at any time Article 13-2C GDPR)
- right to limited processing of Users’ data (Article 18 GDPR)
- right to object to the processing of Users’ data (Article 21 GDPR)
- right to the portability of the data that Users have provided, when the data are the subject of automated processing based on their consent or on a contract (Article 20 GDPR)
If the User wishes to find out how GOELIA uses their Personal Data, requests to rectify them or objects to their processing, the User can contact the Data Protection Officer in writing at the following address: Goelia, Data Protection Officer, 114 allée des Champs Elysées, 91042 EVRY CEDEX, France or by email to email@example.com or by telephone: 01.60.76.59.00 Requests to delete Personal Data will be subject to the obligations which are imposed on GOELIA by the law, particularly in the field of the storing or archiving of documents.
“COOKIES” AND INTERNET TAGS 1. “COOKIES”
A “cookie” is a small information file sent to the User’s browser and saved on the User’s device (e.g. computer, smartphone), (hereinafter “Cookies”). This file includes information such as the User’s domain name, the User’s Internet service provider, the User’s operating system, as well as the access date and time. Cookies cannot in any case damage the User’s device.
GOELIA is likely to process the User’s information concerning their visit to the Website, such as pages viewed, the searches performed. This information allows GOELIA to improve the content of the Website, promotions, and the User’s browsing via its PLANET BOURGOGNE.
If the User refuses the saving of Cookies to their device or browser, or if the User deletes those saved there, the User is informed that their browsing and experience on the Website may be limited. This may also be the case when GOELIA, via its provider PLANET BOURGOGNE cannot recognise, for the purposes of technical compatibility, the type of browser used by the device, the language and display settings or the country from which the device seems to be connected to the Internet.
If applicable, GOELIA waives all liability for the consequences related to the degraded operation of the Website and the services that may be offered by GOELIA, resulting from the refusal of Cookies by the User making it impossible for GOELIA to save or consult the Cookies necessary for their operation because of the User’s choice. Each User’s browser is configured differently for managing and choosing Cookies. This is described in the browser’s help menu, which will allow the User to find out how to amend their wishes concerning Cookies.
The User can choose to express and amend their wishes regarding Cookies at any time. GOELIA may also call on the services of external service providers to help collect and process the information described in this section.
Finally, by clicking on the icons for the social networks Twitter, Facebook, LinkedIn, Instagram, Pinterest and Google Plus that appear on GOELIA’s Website and if the User has accepted the storing of the Cookies by continuing to browse GOELIA’s Website, Twitter, Instagram, Facebook, LinkedIn and Google Plus can also store cookies to your devices (computer, tablet, mobile phone).
These types of cookies are only stored on your devices on condition that you consent, by continuing to browse the Website www.goelia.com. The User can nevertheless withdraw their consent to GOELIA storing these types of cookies at any time. 2. INTERNET TAGS
may occasionally use Internet tags (also called “tags”, or action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs), created by its partner PLANET BOURGOGNE and deploy them by the intermediary of a specialist Web analyses partner likely to be located (and therefore store the corresponding information, including the User’s IP address) in a foreign country.
These tags are placed both in online advertisements that allows Internet users to access the Website, and on the various pages of the latter. This technology allows GOELIA to assess the responses of visitors to the website and the effectiveness of its actions (for example, the number of times a page is opened and the information viewed), as well as the use of this website by the User. The external service provider may collect information on visitors to the website and other websites using these tags, compile reports on the website’s activity for the attention of GOELIA and provide other services relating to the use of the latter and of the Internet.
A GOELIA User can click on the icons for the social networks Twitter, Instagram, Pinterest, Facebook, LinkedIn and Google Plus that appear on GOELIA’s Website.
Social networks improve the usability of the Website and aid its promotion via shares. Video sharing services enrich GOELIA’s Website with video content and increase its visibility.
When the User clicks on these buttons, GOELIA can access personal information that the User will have indicated as public and accessible from their Twitter, Facebook, LinkedIn, Pinterest, Instagram and Google Plus profiles. However, GOELIA does not create or uses any database independent of Twitter, Instagram, Pinterest, Facebook, LinkedIn and Google Plus from the personal information that the User may publish there and GOELIA will not process any data falling under their private life via these means.
If the User does not want GOELIA to have access to personal information published on the public space of their profiles or social accounts, the User will need to use the means made available to them by Twitter, Facebook, Pinterest, Instagram, LinkedIn and Google Plus to limit access to their data.
For any booking with our services, to create a customer account, request to subscribe to the newsletter or for a brochure request, you will be automatically subscribed to our newsletter. This free of charge service offered to Internet users, allows GOELIA to provide information on holiday homes and to announce anything new about the Website and the Group.
To better meet users’ needs, GOELIA measures the rate of clicks through links embedded in newsletters. To stop subscribing, GOELIA includes a link in each of its emails for this purpose at the bottom of the page.
REVIEWS ON THE WEBSITE WWW.GOELIA.COM
Each holidaymaker who has stayed at our residences can share a review of their stay on the website goelia.com. Once posted, their review will be verified by GOELIA’s Quality Department at head office before being activated (between 48 hrs and 15 days depending on the season). All reviews are published under the following conditions: check by our staff that the customer has actually stayed on the dates specified in the review (in order to avoid fake reviews by fake customers); any review with discriminating, offensive or defamatory content will be rejected; any review posted without indicating a name will be refused (impossible to verify the stay). Taking into account the seasonal nature of Goélia’s business, any review must be published by its author no later than 3 months following their stay. Goélia also reserves the right to contact the consumer who wrote the review to check their authenticity. All reviews are published and kept for a maximum of 5 years and have not been the subject of any payment in exchange for their provision. The information collected on this form are stored in an electronic file by GOELIA’s Marketing Department to enable monitoring of the quality of its services and to update its customers file. All reviews are displayed in chronological order of creation.
GOELIA implements all the technical and organisational measures to ensure the security of the processing of personal data and the confidentiality of Personal Data.
Accordingly, GOELIA takes all the necessary precautions, in relation to the nature of the data and the risks presented by the processing, in order to preserve the security of the data and, in particular, to prevent that them from being distorted, corrupted, or unauthorised access by third parties (physical protection of premises, CCTV, authentication processes with staff access and secured via confidential usernames and passwords, etc.).
PERSONAL INFORMATION AND MINORS
In principle, the website is aimed at adults capable of contracting obligations in accordance with the legislation of the country in which the User is located.
Minor Users under 16 years of age or incapable must obtain the prior consent of their legal guardian prior to entering their data on the Website. Unless there is a statutory confidentiality obligation, GOELIA will directly inform this legal guardian of the specific categories of Personal Data collected from the minor of the possibility of objecting to their collection, use or storage.
The age of 16 years may be lowered to 13 years according to the local regulations of the User’s usual residence, under article 8 of GDPR.
CONTACT US - CONTACT INFORMATION FOR THE DPO
If the User has any questions or complaints concerning the observance of this Policy by GOELIA, or if the User would like to share recommendations or comments with us to improve the quality of this policy, the User can contact GOELIA by writing to the following address:
GOELIA – 114 allée des Champs Elysées – 91042 EVRY CEDEX, France
GOELIA undertakes to comply with the legislative provisions set out in French law.