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PRIVACY POLICY

The SAS SUNELIA Company, registered under the number 572 185 684 RCS Paris, (hereinafter “Sunêlia”) attaches great importance to the protection of your personal data and attentively complies with the protective measures relating to your private life and the processing of your personal data, in particular the European Regulation on the protection of individuals with regards to the processing of personal data and the free movement of such data (EU Regulation 2016/679 of April 26, 2016), the law of January 6, 1978, known as "Information Technology and Civil Liberties", amended in 2004, as well as the recommendations issued by the CNIL (hereinafter the "Legislation in force"). 

The purpose of this Privacy Policy (hereinafter the “Charter”) is to describe how and when Sunêlia, as data controller, collects, uses and discloses certain personal data (hereinafter the “Data), which are addressed to it in order to meet the needs of its customers but also in order to optimise and improve the quality of the services offered by Sunêlia and each of its Licensees.

1.     Under what circumstances does this policy apply?

2.     What Data does Sunêlia collect?

3.     How do we use the Data we collect?

4.     Which cookies are used by Sunêlia?

5.     How long do we keep your Data?

6.     What are the categories of recipients of your Data?

7.     On what legal basis are your Data processed?

8.     What are your rights?

9.     Are your Data being transferred outside the European Union?

10.  The protection of your Data by Sunêlia.

11.  Revision of the Policy

1. UNDER WHAT CIRCUMSTANCES DOES THIS POLICY APPLY?

This Policy informs you about how your Data is collected, processed and used when:

·       you reserve a holiday or services with Sunêlia;

·       you visit the Sunêlia website or our mobile application (hereinafter the “Website");

·       you subscribe to our Sunêlia news (product information & promotional offers) and personalised content;

·       you contact our Customer Service Department;

·       you meet us at a trade show or in the context of commercial visits;

·       you participate in our contests.

2. WHAT DATA DOES SUNÊLIA COLLECT?

2.1 The information that you send us directly

You transmit Data to us, in particular:

 when you register on the Website by completing different forms relating to your account or by loading Data;

 when you subscribe for a holiday or service;

• when you participate in a contest;

 when completing a Sunêlia questionnaire;

 when you contact our Customer Service Department.

This information may include, for example:

 your last name(s) and first name(s),

 your date of birth,

 your gender,

 your postal address,

 your e-mail address,

 your telephone number(s),

• your means of payment,

 your reservation history.

The same goes for all the information you give us about the people for whom you reserve a holiday or service. You shall agree in this case to obtain their prior consent to communicate their Data.

You can choose not to give us certain information; however, this decision may deprive you of some of the services and features we offer. Information that is essential to the provision of our services and operations is identified by an asterisk on our collection forms.

2.2 Data collected automatically

When you are browsing the Website, Sunêlia may collect, in strict compliance with the Applicable Legislation and your rights, Data relating to:

·       the characteristics of the operating system, browser or devices (computer, tablet, smartphone) that you use to access our services;

·       your location such as your IP address;

·       your browsing history and your interactions with the content of the Website, such as the pages visited, the search keywords used, the frequency of your visits to the website, the advertisements you click on.

3. HOW DO WE USE THE DATA WE COLLECT?

The browsing Data in particular is collected by means of cookies. For more information about these cookies, please see Article 4.

3.1 Data from other sources

We may also collect Data via third parties, including social networks, when you use the account you hold with these third parties to register or connect to our services. During this use, you will be informed of the Data that the third party transmits to us.

We use, store and process your Data to process your inquiries, manage our business relationships, optimise our services and tools to create and maintain a more secure trust environment, and to comply with our legal obligations as we specify hereinafter.

3.2 Execute the contracts concluded between us

We use your Data to enable the management of your subscription for a package-holiday and the execution of the various services related thereto.

Your Data will be used especially to collect your payments, inform you by SMS, email or any other means of communication on the terms of execution of the contract that binds us (information on your trip, on any changes to the terms of your holiday, for emergency notifications, proposal of additional services for your holiday or services, etc.).

As part of our business, it is possible, although exceptional, for us to use commercial partners who are mandated to provide certain services on our behalf, such as, for example, for certain services which we delegate to a third party.

However, our business partners may not use your Data for purposes other than those necessary to carry out the services you have requested. Lastly, they are obliged to process them in strict compliance with the Legislation in force. This is the case, for example, with data that is transmitted to our establishments that are beneficiaries of the Trademark License Agreement or the Sunêlia Partnership Agreement.

3.3 Provide you with access to the Website and certain services

The Data that you communicate allows us to identify you in order to access your Customer Area which is restricted to authenticated persons.

3.4 To send you our Sunêlia news and personalised content

If, at the time of the reservation of a holiday-package, the creation of your account on the Website or later, you ticked the box or filled the form which allows you to receive the Sunêlia news (information products and promotional offers Sunêlia) and personalised content, then we are likely to use your Data to communicate with you, according to your preferences (notably by email, SMS, telephone or postal mail):

 information relating to the Website;

 invitations to Sunêlia events that may interest you;

 information about our offers;

 information on Policy updates or security measures.

You may, at any time, reject the Sunêlia Group's commercial communications by (i) clicking on the unsubscribe link or following the opposition procedure indicated on those communications, or (ii) contacting us as described in Article 6 below. You may also block telephone canvassing by registering on Bloctel.

We may also use your Data to send you advertising messages that may be of interest to you on third-party sites or social media platforms. For more information on this subject, we invite you to read the conditions relating to the use of your Data directly on these websites and/or third-party platforms.

3.5 For profiling purposes

We may also have to process your Data as part of profiling operations.

Profiling consists of operations of automated processing of your Data with the aim of analysing, anticipating and evaluating your interests and preferences in order to send you personalised content and commercial offers tailored to your specific needs.

Sunêlia will share your Data only with third-party providers to determine your profile and preferences with greater accuracy and thus send you more relevant Sunêlia content. In no event will Sunêlia provide your Data to any business partners.

You may, at any time, object to the use of your Data for profiling purposes by accessing your Customer Area or by contacting us as described in Article 6 below.

3.6 Optimise the Website and our services

We use your Data to conduct studies, technical tests (including the anonymisation of your Data) and deduplications, which allow us to improve and optimise the Website and customise our tools and services. For example, it will ensure that the display of our various contents is adapted to the terminal that you use, or allows us to host your Data to even more secure servers, etc.

3.7 Address your complaints

When you contact our customer service by telephone, via the contact form available on the Website or by any other means made available to you by Sunêlia (social networks, chat, etc.), we use your Data (including records of your calls with your prior agreement) to:

·       answer you and provide a solution to your complaint;

·       ensure and manage the follow-up for your complaint;

·       improve the customer relationship service.

3.8 For the purposes of internal statistics and surveys

We may use your Data to perform various statistical studies and/or to request you to participate in our own surveys.

3.9 Ensuring compliance with the law and court decisions

Your Data may be used to:

·       respond to a request from an administrative or judicial authority, a representative of the law, an auxiliary of justice or to comply with a court order;

·       ensure compliance with our general terms and conditions of sale and our Policy;

·       protect our rights and/or obtain compensation for any damage we may suffer or limit its consequences;

·       prevent any act contrary to the laws in force, in particular to prevent the risks of fraud.

3.10 Manage your participation in our contests

When you enter a contest, you provide us with a certain amount of Data. They are essential to take into account your participation, and if necessary, the delivery of your prize.

In addition, with your prior and express consent, we may use this Data to send you Sunêlia news (product information and promotional offers Sunêlia) and customised content.

4. WHICH COOKIES ARE USED BY SUNÊLIA?

4.1 What is a cookie?

When you use the Website, Sunêlia may deposit on your device (computer, tablet for example), through your browser, a file called a "cookie". During its recording period, it enables the identification of your computer for your next visits. Thus, every time you visit the Website, the Data from your previous visit can be kept.

4.2 Which cookies are used by Sunêlia?

Sunêlia uses, in particular, the cookies listed in the appendix of this document.

a) Cookies that are required to provide the requested services

Sunêlia may use cookies that are strictly necessary to provide the services or information you have requested, in particular:

 “session IDs in your Customer Area" cookies;

 "shopping cart" cookies;

 authentication cookies;

 load balancing session cookies;

 persistent cookies for customising the user interface;;

 audience measurement analysis cookies ("statistical cookies").

Data collected by statistical cookies are not cross-checked with other processed data (or previously anonymised) and are used only for the production of anonymous statistics.

These cookies do not make it possible to track your browser to other sites, nor to geolocate you precisely.

You can simply disable cookies, including statistical cookies (see below "Disabling cookies").

b) Tracking and customisation cookies

Certain cookies make it possible to analyse, optimise and personalise your browsing on the Website. They can also make it possible to carry out automated processing operations of your Data according to the terms and conditions specified in Article 3.4. These are installed only with your prior and express consent.

c) Monitoring and customisation cookies

During your browsing on the Website, cookies issued by third parties (communication agency, audience measurement company, targeted advertising provider, etc...) may allow them, during the period of validity of these cookies, (i) to collect browsing information about the terminals viewing the Webite and (ii) to determine the advertising content that may be relevant to your interests. The issue and use of cookies by third parties are subject to the cookie management policies of these third parties.

 

 

5. HOW LONG DO WE KEEP YOUR DATA?

In general, your Data is kept only for the time necessary to complete the operations for which it was collected.

Here are the different retention periods for the data collected by Sunêlia:

•the Data that have been sent to us directly as detailed in Article 2.1 are kept for the period necessary to process them;

 the browsing Data are retained for a maximum of 13 months;

 the prospection Data are kept for up to 3 years from the last contact you initiated with Sunêlia;

 the Data relating to the identity documents that you transmit to us when you exercise your right of access or rectification are kept for a maximum period of 12 months;

 the information enabling us to take into account the rights of opposition of the persons concerned to receive commercial prospection are kept for a maximum period of 3 years from the exercise of this right.

We may also delete your Data on your request.

However, at the end of the aforementioned periods, including your request for deletion, your Data may be stored in order to meet our legal, accounting and tax obligations (e.g. obligation to keep invoices for 10 years), in accordance with Article L.123-22 of the French Commercial Code) and/or during the applicable limitation period and/or in the event of contentious proceedings for the period of the aforesaid procedure.

6. WHAT ARE THE CATEGORIES OF RECIPIENTS OF YOUR DATA?

We may share your Data with different third parties, including:

our affiliates, in order to provide you with the services requested or those acting as subcontractors in accordance with the applicable Legislation;

our business partners, our suppliers and/or subcontractors who process your Data on our behalf, according to our instructions, for the purposes detailed in Article 2 (in particular transport companies, insurance companies, customs authorities, receptive service providers, financial institutions, technical subcontractors, etc.). We take special care to ensure that these third parties provide sufficient guarantees to ensure the protection and security of your Data;

the duly authorised French or foreign authorities, in particular in the context of a legal action or a request for communication of information.

7. ON WHAT LEGAL BASIS ARE YOUR DATA PROCESSED?

In accordance with the Legislation in force, to process your Data, we rely on different legal bases, and in particular:

 your prior and express consent for the processing of your Data for one of the purposes referred to in Article 3;

 the execution of the contract that binds us;

 the need to comply with a legal obligation or to defend ourselves in the event of legal proceedings;

 the pursuit of Sunêlia’s legitimate interests;

 safeguarding your vital interests.

8. WHAT ARE YOUR RIGHTS?

8.1 Your rights of access, rectification, deletion and opposition

You may ask us for access, to correct, update or delete personal information about you.

You also have the right to object to the processing of your Data.

8.2 The right to the portability of your Data

The right to portability gives you the opportunity to recover some of the Data that concerns you, namely:

• the Data you have provided directly to us as detailed in Article 2.1;

 the Data generated by your activities on the Website as detailed in Article 2.

We will endeavour to respond to your request within a reasonable time and, in any event, within the deadlines set by the Legislation in force.

8.3 Set guidelines on what should be done with your Data

You have the right to set general or specific guidelines for the storage, deletion and communication of your post-mortem Data.

8.4 Contact

To exercise all these rights, you must send a letter by regular mail to the following address: Sunêlia, Service Relation Client, Le Grand Angle, Avenue Périé, 33525 Bruges Cedex, France, and enclose with your request a copy of your identity document.

At any time, if you feel that your rights have not been respected, you have the option to make a complaint to the Sunêlia Data Protection Officer (DPO).

You may, at any time, file a complaint with the competent supervisory authority.

9. ARE YOUR DATA BEING TRANSFERRED OUTSIDE THE EUROPEAN UNION?

We undertake not to transfer your Data to countries outside the European Union for the purposes described in this Policy.

10. THE PROTECTION OF YOUR DATA BY SUNÊLIA

Sunêlia undertakes to guarantee the integrity and reliability of the Data entrusted to it, in particular by taking all the physical, organisational and logistical measures necessary to prevent any alteration or destruction of such Data, in particular by ensuring secure access only to authorised persons to process them.

11. REVISION OF THE POLICY

Sunêlia may have to amend this Policy, in particular if the Legislation in force is changed. Any changes will be posted on this page.

LIST OF COOKIES USED BY SUNÊLIA

This list is updated regularly by Sunêlia; last update: June 12, 2018

   Google Analytics:

  • _ga
  • _gat_UA-1515429-2
  • _gid

=> cookies for the use of statistics (Google Analytics)

   Family composition:

  • acc_nb_adults
  • acc_nb_babies
  • acc_nb_children4to5
  • person

=> memorisation of the family composition, in order to offer adapted reservations

   Holiday selection:

  • arrivalDate
  • departureDate
  • selectCampsite
  • type

=> memorisation of holiday choices, in order to propose adapted reservations

   Technical:

  • cookiesDirective
  • PHPSESSID

=> technical variables necessary for the operation of the website

HOW DO YOU BLOCK COOKIES?

You can set your browser to change your consent or express your refusal of cookies.

You may thus accept all cookies, be notified when a cookie is placed, or refuse all cookies. If you refuse all or some cookies, certain features of the Website may be compromised or some pages may be inaccessible.

To disable cookies:

If you are using Internet Explorer 8 or more recent versions:

1. Go to "Tools" in the menu bar and click on "Internet Options"

2. Click on the "Privacy" tab at the top

3. Drag the cursor up to the "Block all cookies" setting to block all cookies, or down to the "Accept all cookies" setting to accept all cookies.

For more information, visit http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies

If you are using Firefox 30.0 or more recent versions:

1. Click on the "menu" button and select "Options"

2. Select the "Privacy" panel.

3. In the History box, for the “Retention rules” option, select “Use custom settings for history”.

4. Check the "Accept cookies" box to enable cookies, or uncheck them to disable them.

If you have problems with cookies, make sure the "Accept third-party cookies" option is not set to “Never”.

5. Choose how long cookies can be kept.

Keep them until:  "Their expiry": Each cookie will be deleted on its expiry date, a date set by the website issuing the cookie.

Keep them until: “Firefox Shutdown”: cookies saved on your computer will be deleted when you close Firefox.

Keep them until: “Ask me every time”: a warning appears each time a website wants to send a cookie, asking you whether you agree to save the cookie or not.

6. Click OK to close the "Options" window

For more information, visit: https://support.mozilla.org/fr/products/firefox/privacy-and-security/cookies

If you are using Google Chrome:

1. Go to the "Tools" menu

2. Click on "Settings"

3. Click on "Advanced Settings"

4. Click on "Privacy/Content Settings"

5. "Cookies" must be selected. Then select “Block cookies and data from third-party sites”.

For more information, visit: https://support.google.com/chrome/answer/95647?hl=fr

If you are using Safari 5.0:

1. Choose Safari> Preferences and click on "Security".

2. In the "Accept cookies" section, indicate if and when Safari should accept cookies from websites. To see an explanation of the options, click on the help button (looks like a question mark). If you have set Safari to block cookies, you may need to temporarily accept cookies to open a page. Repeat the above steps, selecting "Always". When you have finished with the page, turn off cookies again and delete cookies from the page.

For more information, visit: http://support.apple.com/kb/ht1677?viewlocale=fr_FR

If you have a different browser type or version, we invite you to consult the "Help" menu of your browser.