Confidentiality policy
I. General Information
The policy below sets out the personal data protection practices of CAP ESTEL HOTEL, operated by SAS CAP ESTEL HOTEL (hereinafter the “Hotel”), including its restaurants and spa, acting as data controller.
SAS CAP ESTEL HOTEL reserves the right to amend this personal data protection policy at any time and invites you to check the date of the latest update.
This Policy applies to all information and personal data provided directly by you or collected during your stay at the Hotel or while browsing the website www.capestel.com (hereinafter the “Website”), including when using the Services offered, such as our online boutique.
Through the Website, the Hotel may collect personal data from any individual submitting an enquiry to the Hotel via the “Contact” section or through an information request form available on the Website or making an online reservation at the Hotel or at one of its restaurants.
Any personal information that you may transmit to the Hotel is subject to the provisions of French Law No. 78-17 of January 6, 1978 relating to Information Technology, Data Files and Civil Liberties (as amended), the applicable European regulations, as well as any other applicable legislation relating to the protection of personal data.
II. For What Purposes and on What Legal Bases are Your Data Processed ?
The personal data that we collect and process concerning you enable us to:
- Respond to messages you send us by email and provide you with information relating to the Hotel’s accommodation, restaurant, spa, event organization and other services. This processing is based on the Hotel’s legitimate interest in responding to your requests;
- Allow you to make reservations online, by email, by telephone or on-site for stays at the Hotel and reservations at the restaurants. This processing is necessary for the performance of a contract to which you are a party;
- Enable you to manage your online account on our online boutique website. This processing is based on your consent;
- Manage your stay at the Hotel and your visits to the restaurant, spa and other services provided by the Hotel. This processing is necessary for the performance of a contract to which you are a party, as well as for the pursuit of the Hotel’s legitimate interest in managing its activities, gaining a better understanding of its customers and providing the requested services;
- Manage our online boutique, allowing you to offer gifts to third parties. This processing is necessary for the performance of the contract to which you are a party, as well as for the pursuit of the Hotel’s legitimate interest in providing the requested products and services;
- Offer you the best possible experience and guarantee a personalized service during your stay at the Hotel. This processing is necessary for the performance of a contract to which you are a party, as well as for the pursuit of the Hotel’s legitimate interest in providing its services;
- Manage payment incidents or inappropriate behaviour in breach of our Etiquette Code, as well as any resulting access restrictions applicable to the person concerned. This processing is necessary for the pursuit of the Hotel’s legitimate interest in carrying out its services;
- Carry out the formalities necessary for check-in and check-out upon your arrival at the Hotel. This processing is necessary for compliance with a legal obligation;
- Manage security within the establishment. The processing of photographs and CCTV footage is necessary for the pursuit of the Hotel’s legitimate interest in ensuring the protection of individuals and property. This enables us not only to recognize Hotel guests, but also to detect any abnormal or reprehensible behaviour and to provide you with personalized services without systematically requiring proof of identity during your stay at the Hotel;
- Subject to your prior consent, collect data relating to your minor children and, should you wish to inform us thereof, sensitive data concerning you;
- Manage newsletter subscriptions and unsubscriptions and send you information and marketing communications relating to the Hotel. This processing is based on our legitimate interest where you are already a customer, or on your consent in all other cases;
- Secure and improve your use of the Website. This processing is based on the Hotel’s legitimate interest in managing the administration and security of the Website in order to prevent fraud and hacking;
- Manage accounting and financial matters, as well as potential disputes. This processing is necessary for the performance of a contract to which you are a party and enables us to comply with a legal obligation;
- Manage your applications when you apply for one of our job offers. This processing is based on the implementation of pre-contractual measures;
- Process your messages on social media, on the basis of our legitimate interest;
- Produce statistics relating to traffic sources on our Website and the geographical origin of Website visitors. This processing is based on our legitimate interest.
Where consent has been provided, it may be withdrawn at any time. Such withdrawal shall not affect the lawfulness of processing based on consent carried out prior to such withdrawal. However, where you withdraw your consent to the processing of data necessary for the provision of a service, you may no longer benefit from that service.
III. Personal Data Relating to Minors
SAS CAP ESTEL HOTEL does not collect or process personal data relating to children under the age of 18 without the prior consent of the parents or holders of parental responsibility for the child.
If personal data relating to children are collected through our Website or online boutique, parents or holders of parental authority may object thereto by contacting us at the address indicated at the bottom of this page.
IV. IP Adress
An IP address is a series of numbers automatically assigned to your computer by your Internet Service Provider each time you connect to the Internet. Whenever you submit a request on the Website, our servers record your visit. We collect IP addresses for the purpose of analysing trends on the Website.
We do not transmit any information capable of identifying you, which means that your session will be logged but will remain anonymous to us. We may use your IP address in cooperation with your Internet Service Provider in order to identify you where necessary to enforce the terms of use, protect our services and customers, or comply with applicable laws.
V. Our « Shopping Assistant » Chatbot
We provide you with an assistant based on an artificial intelligence solution published and operated by API & You. This Chatbot is intended to facilitate your navigation on our online boutique.
The solution used is not capable of identifying or detecting the profile of the individual interacting with it.
VI. Are you Required to Provide Your Personal Data ?
The data required by the Hotel to achieve the purposes described above are identified by an asterisk on the collection forms. If you do not complete these mandatory fields, we will not be able to provide the requested services or, where applicable, process your request.
Data not marked with an asterisk are optional and enable the Hotel to better understand your preferences and improve the services we offer.
VII. How Long Are Your Data Retained ?
Your personal data are retained for a period that does not exceed the time necessary to achieve the following purposes:
| Purposes | Retention Period |
|---|---|
| Customer data management | Your data will be retained for the entire duration of your stay at the Hotel and for a period of 5 years following the end of your stay. |
| Passport data |
|
| Online account management | For as long as you interact with us through your account, or for 3 years following your last login. |
| Management of sensitive data | Subject to your consent, your sensitive data may be retained for the duration of your stay or for a period of 24 months where necessary for the protection of human life during your future stays (e.g. allergies). |
| Payment management | Your payment data will be retained for the duration of the transaction and for up to 10 days following the end of your stay in the event of additional charges. |
| Financial and accounting management | Your data will be retained until the closing of the financial year and approval of the accounts. |
| Newsletter management | Your data will be retained for as long as your subscription remains active and we remain in contact with you, i.e. as long as you open our newsletter or otherwise interact with us. |
| Commercial prospecting management | Your data will be retained for 3 years following our last contact with you or in the absence of any response from you after two successive communications from us. |
| Recruitment management | For the duration of the recruitment process and up to 3 months following the end of the recruitment process. |
VIII. To Whom Are Your Data Disclosed ?
Your data are disclosed or transmitted only to persons who need to know them for the purposes described above.
Recipients of your data include, in particular:
| Recipients |
|---|
|
The Hotel does not disclose your data to third parties except in the following cases:
- Where the Hotel is required to share such data with a third party in order to provide the requested service or respond to your request;
- Where the Hotel is required by any competent authority (including judicial or administrative authorities) to disclose the relevant data.
IX. Are Your Data Transferred Outside the European Economic Area ?
Your Data are hosted within the European Union. Should your Data be transferred outside the European Economic Area, such transfer shall be carried out subject to appropriate safeguards, in particular contractual safeguards, in compliance with the applicable personal data protection regulations.
You may obtain a copy of the appropriate safeguards by sending a request to the following address: SAS CAP ESTEL, 1312 Avenue Raymond Poincaré, 06360 Èze-Bord-de-Mer, France, or by email at: contact@capestel.com.
X. Security and Confidentiality of Personal Data
The Hotel endeavours to implement all appropriate measures to preserve the confidentiality and security of your processed personal data and to prevent them from being altered, damaged, destroyed or accessed by unauthorized third parties.
XI. Payment Security
Payments made by credit card are processed through a secure system compliant with applicable standards, so that the information transmitted is encrypted by software and cannot be accessed by any third party during transmission over the network.
XII. What Are Your Rights ?
You have the right to access your personal data, request their rectification, erasure or portability, as well as the right to request restriction of the processing of your data, withdraw your consent and provide instructions regarding the fate of your data after your death.
You also have the right to object, at any time:
- To processing carried out by the Hotel for commercial prospecting purposes;
- For reasons relating to your particular situation, to processing based on the Hotel’s legitimate interests.
COOKIE POLICY
I. What Is a Cookie ?
A cookie is a small text file downloaded onto your device (computer, tablet, smartphone, etc.) which collects and stores certain personal data relating to your browsing activity (e.g. your preferences, actions, time and number of visits, login information, etc.), thereby enabling the website to recognize your device.
Not all cookies are identical; they may differ depending on their source or their duration.
- Cookies may originate from two sources:
- First-party cookies (or internal cookies): these are created by the website you are visiting and are associated with its domain name.
- Third-party cookies: these are created by third-party providers and placed by the publisher of the website you are visiting. They are therefore associated with a domain name different from that of the website on which they are implemented.
With regard to our third-party partners, they may place cookies when you are connected to their pages.
These cookies are governed by the privacy policies of such third parties, which may be consulted on their respective websites.
You may find the list of our partners using cookies on our Website in the Privacy Preference Centre, accessible by clicking on the link allowing you to manage cookies, available at the bottom of the Website pages.
- Cookies may have two types of duration:
- Session cookies: these are temporary and are automatically deleted when you close your browser.
- Persistent cookies: these are not deleted when you close your browser, but only once their expiration date has been reached, which may vary depending on the purpose of the cookie. You may also manually delete these cookies.
There are also other tracking technologies commonly referred to as web beacons, which likewise collect information about you. Such information does not necessarily constitute personal data but is also related to your browsing activity and may be combined with information collected through cookies, such as digital fingerprints, tags, logs, HTTP variables, local storage, advertising identifiers, etc.
These other tracking technologies are subject to the same rules as cookies and are therefore governed by this Policy. For the sake of simplicity, only the term “cookies” will be used herein, regardless of the type of tracking technology concerned.
Further information is available at :
https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs and https://www.youronlinechoices.com/fr/
II. Cookies Used on Our Website
When you connect to our Website, cookies are placed on the device you are using, enabling us to recognize your browser for the duration of validity of the relevant cookie. Through our cookie banner and this section, we inform you about the cookies placed on your device.
The various cookies we use have different retention periods, after which they are deleted unless your consent is renewed.
You will find the names and functionalities of each cookie, as well as their retention periods, in the Privacy Preference Centre accessible at the bottom of the Website pages.
a. Strictly Necessary Cookies
These cookies are generally set in response to actions carried out by you which constitute a request for services, such as setting your privacy preferences, logging in or completing forms.
These cookies cannot be disabled using our settings system, as they are based on our legitimate interest.
You may nevertheless configure your browser to block such cookies; however, in this case, we cannot guarantee full access to or proper functioning of our Website.
b. Functionality Cookies
These cookies enable the enhancement and personalization of the functionalities of our Website. They may be activated by our teams or by third parties whose services are used on the pages of our Website.
The use of these cookies is based on your consent. If you refuse their placement, some or all of these services may not function properly.
c. Performance Cookies
These cookies allow us to determine the number of visits and traffic sources in order to measure and improve the performance of our Website. They also help identify the most and least visited pages and assess how visitors navigate through our Website. They may be placed either by the Hotel or by our partners. In the latter case, we invite you to consult the relevant third party’s cookie policy.
The use of these cookies is based on your consent. If you refuse their placement, this will not affect your browsing experience on our Website; however, we will not be able to monitor or analyse your navigation and interaction with our Website.
d. Targeted Advertising Cookies
We do not use cookies for this purpose. Such cookies may nevertheless be placed on our Website by Google (Google Analytics and reCAPTCHA) or by our partners whose websites are accessible through redirect links. They may be used by these companies to build a profile of your interests and display relevant advertisements to you on other websites.
The use of these cookies is based on your consent.
For further information, please consult the information provided by such third-party websites and social media platforms regarding their own cookies.
- SAS CAP ESTEL HOTEL does not associate your cookies with any information enabling your direct personal identification. Cookies do not under any circumstances allow us to know your address, date of birth, telephone number or any other information enabling your identification.
- The Hotel does not provide any personal information to advertisers or third-party websites displaying advertisements based on your interests.
III. For What Purposes Do We Use Cookies ?
Cookies are used on our Website in order to:
- Produce statistics and traffic volumes relating to the use of the various sections and content of our Website, enabling us to improve the relevance and ergonomics of our services;
- Adapt the presentation of our Website to your device’s display preferences (language used, display resolution, operating system used, etc.) during your visits to our Website, depending on the hardware and software used by your device;
- Store information relating to forms you have completed on our Website (such as registration or access to your account) or to products, services or information you have selected on our Website (subscribed service, reservation details, etc.);
- Implement security measures, for example where you are requested to log in again to access content or a service after a certain period of time.
IV. Your Choices Regarding Cookies
The placement of cookies on your device is subject to your consent, except where such cookies are strictly necessary, in which case their use is based on our legitimate interest.
Accordingly, you may choose to accept or refuse most of the cookies used on our Website at any time.
IV.1 Choices Available on Our Website
Upon your first visit to our Website, a cookie banner is displayed containing information relating to the use of cookies.
This banner allows you to accept or refuse all or part of the cookies we use. Your consent or refusal applies only to the cookies used on our Website.
Your choices regarding cookies subject to consent (whether acceptance or refusal) are retained for a maximum period of 6 months.
The choices you expressed during your first visit to the Website may be modified at any time in the Privacy Preference Centre accessible by clicking on the link located at the bottom of the Website pages.
IV.2 Choices Available Through Your Browser Software
You may also configure your browser software so that cookies are stored on your device or, conversely, rejected, either systematically or depending on the issuer.
You may also configure your browser software so that acceptance or refusal of cookies is offered to you on a case-by-case basis before a cookie is likely to be stored on your device.
The management of cookies and your preferences differs depending on each browser. Such configuration is described in your browser’s help menu, which will enable you to understand how to modify your cookie preferences.
Please note that your browser settings may affect your Internet browsing experience and your access conditions to certain services requiring the use of cookies.
Where applicable, we disclaim all liability for any consequences linked to the degraded functioning of our services resulting from the impossibility for the Hotel to store or access cookies necessary for their operation and which you may have refused or deleted.
V. If You Share the Use of Your Device With Other Persons
Where your device is used by several persons, or where a single device has multiple browser software applications installed, we cannot ensure with certainty that the services and advertisements intended for your device correspond to your own use of that device and not to the use of another user of the same device.
Where applicable, sharing the use of your device with other persons and configuring your browser settings with regard to cookies are matters of your own free choice and responsibility.