1) What's the point of this policy?
1.1 As part of the services offered by Groupe Lucien Barrière, and in particular accessing, consulting, browsing and using the www.groupebarriere.com website and the services it offers, you may be asked to provide Groupe Lucien Barrière with personal information about yourself.
1.2 Groupe Lucien Barrière processes your personal data in accordance with applicable data protection regulations, and in particular in accordance with the General Data Protection Regulation (GDPR).
1.3 The purpose of this policy is to provide you with information about the processing of your personal data by Groupe Lucien Barrière.
1.4 Please read the following carefully to understand our policy and practices regarding your personal data and how we process it. This policy supplements any documents or information referring to the policy.
2) Who processes your data?
2.1 The data controller is Groupe Lucien Barrière. In this capacity, Groupe Lucien Barrière determines the purposes of the processing carried out on its website and the manner in which your data is processed.
2.2 If you have any questions, please send an e-mail to dpo@groupebarriere.com or a letter to the following address :
Société Anonyme Groupe Lucien Barrière
33 rue d'Artois
75008
Paris
3) What personal data may be processed?
3.1 Groupe Lucien Barrière collects and processes the following categories of personal data:
4) Why is your data collected?
4.1 Groupe Lucien Barrière may collect data from site users for the following purposes:
5) How long do we keep your personal data?
5.1 We will retain your personal data in accordance with a retention policy set so that data is retained for a period proportionate to the purpose for which it was collected, except where laws and regulations require a different retention period.
5.2 Accordingly, we organize ourdata retention policy as follows:
5.3 We draw your attention to the fact that in the event of pre-litigation or litigation between you and Groupe Lucien Barrière, your personal data will be kept until the dispute has been settled out of court or, failing that, until the legal statute of limitations has expired (5 years in civil and commercial matters).
6) With whom do we share your personal data?
6.1 We share your personal data with persons who are strictly authorized to do so by virtue of their functions within Groupe Lucien Barrière.
6.2 Your data will also be sent to third parties of the Lucien Barrière Group, listed in the following table:
6.3 When we use a service provider, we will only disclose your personal data to them once we have obtained a commitment and guarantees from them regarding their ability to meet these security and confidentiality requirements.
6.4 In compliance with data protection regulations, we enter into contracts with our subcontractors that precisely define the terms and conditions of personal data processing.
7) Is your data transferred outside the European Union?
7.1 We may transfer your personal data outside the European Union as part of the IT tools used for our activities.
7.2 In the event that the recipient country does not ensure a level of protection of personal data equivalent to the European Union, Groupe Lucien Barrière undertakes, in the absence of an adequacy decision and after having assessed the level of protection of your rights on the territory of the third country where the recipient of your personal data is established, to take all necessary measures to ensure the protection of your personal data on the basis of appropriate guarantees (in particular the standard contractual clauses defined by the European Commission), which may be obtained directly from the company Groupe Lucien Barrière at the following address dpo@groupebarriere.com.
8) How do we protect your data?
8.1 We attach particular importance to the security of your personal data.
8.2 Groupe Lucien Barrière has implemented technical and organizational measures adapted to the degree of sensitivity of personal data, in order to ensure the integrity and confidentiality of data and to protect them against any malicious intrusion, loss, alteration or disclosure to unauthorized third parties.
9) What are your rights?
9.1 Groupe Lucien Barrière, as the data controller, is particularly concerned about respecting the rights granted to you in the context of the data processing it implements, in order to guarantee fair and transparent processing given the particular circumstances and context in which your personal data is processed.
9.2 Your right of access: under this heading, you have confirmation that your personal data is or is not being processed, and when it is, you have the right to request a copy of your data and information concerning :
- the purposes of the processing ;
- the categories of personal data concerned;
- the recipients or categories of recipients and, where appropriate, if such
- communications are to be made, the international organizations to which the personal data have been or will be communicated, in particular recipients established in third countries;
- where possible, the intended retention period for personal data or, where this is not possible, the criteria used to determine this period ;
- the existence of the right to ask the data controller to rectify or erase your personal data, the right to request a restriction on the processing of your personal data, the right to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- information on the source of the data when it is not collected directly
- from the data subjects;
- the existence of automated decision-making, including profiling, and in
- the latter case, useful information concerning the underlying logic, as well as the importance and expected consequences of this processing for the data subjects.
9.3 Your right to rectify your data: you can ask us to rectify or complete your personal data if it is inaccurate, incomplete, ambiguous or out of date.
9.4 Your right to erasure: you may ask us to erase your personal data in the cases provided for by legislation and regulations. Please note that the right to erasure of data is not a general right and can only be exercised if one of the grounds provided for in the applicable regulations is present.
9.5 Your right to restrict the processing of your data: you may request that we restrict the processing of your personal data in the cases provided for by legislation and regulations.
9.6 Your right to object: you have the right to object at anytime, for reasons relating to your particular situation, to the processing of your personal data for which the legal basis is the legitimate interest pursued by the data controller.
9.7 Your right to portability: you have the right to port your personal data. Please note that this is not a general right. In fact, not all data from all processing operations is portable, and this right only applies to automated processing operations, to the exclusion of manual or paper processing. This right is limited to processing for which the legal basis is your consent or the performance of pre-contractual measures or a contract.
9.8 Your right to withdraw your consent: when the data processing we carry out is based on your consent, you may withdraw it at any time. We will then cease to process your personal data, without affecting any previous operations for which you have given your consent.
9.9 You have the possibility of formulating directives relating to the conservation, deletion and communication of your personal data after your death and of designating a person to carry out these directives. This person is then entitled to be aware of the directives and request their implementation from the data controller.
9.1.0 You may inform us of your instructions concerning your personal data processed by Groupe Lucien Barrière by writing to the e-mail address or postal address indicated in article 12 of this data protection policy.
9.1.1 You can change or revoke your instructions at any time.
10) How can you exercise your rights?
10.1 All the rights listed above can be exercised by providing proof of your identity by any means:
- to the following e-mail address: dpo@groupebarriere.com; or
- by post sent to the following address:
SA Groupe Lucien Barrière
33 rue d'Artois 75008
Paris
10.2 If necessary, you can lodge a complaint with Cnil via its website or by post at the following address: 3, place de Fontenoy - TSA 80715 - 75334 Paris Cedex 07. This right may be exercised at any time free of charge, apart from the cost of postage where applicable, and any costs of assistance or representation if you choose to be assisted in this procedure by a third party.
11) Who should I contact if I have questions or comments about this Data Protection Policy?
11.1 Any questions relating to this Data Protection Policy may be asked on the Groupe Lucien Barrière website at the dpo@groupebarriere.com.
11.2 Alternatively, you can contact Groupe Lucien Barrière at the following postal address:
Société Anonyme Groupe Lucien Barrière
33 rue d'Artois
75008
Paris
BARRIÈRE PRIVACY POLICY