Introduction

We respect your right to privacy and treat any information you give to us with care. Sarl 4H, in France (“Company,” “we,” “our” and “us”) is the data controller when you provide information to any of our brands, like: Private & Comfortable Apartments.

This Privacy Policy (“Policy”) describes how we processes, collects, uses and shares personal data when using the website https://privatecomfortableapartments.com (the “Website”). We are committed to ensuring the personal data you provide is used for the purpose it was collected and is kept secure.

Your personal information allows us to provide the products and services you have asked for, as well as enabling us to improve those products and services by understanding your interests and preferences. By understanding what you like (and what you don’t) we are able to personalize your experience, show relevant adverts and improve your stay.

Please read the following information carefully to understand our practices regarding your personal data and how we will process data.

EU Personal Data

If you are located in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data. You can find out more information about the EU General Data Protection Regulation (the “GDPR”) here:

https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en

Purposes of Processing

What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation, this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual, including, for example, your name, email address, telephone number and personal address.

Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with some of our services. If you book a room or an apartment with us, you will have been asked to tick to agree to provide this information in order to purchase our services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our website.

What Information do we Collect?

When you interact with our products and services, for example when browsing our website or booking a room or apartment, we collect information about you and that particular interaction. Generally, this may include your personal data which means personal details from which you can be identified or are identifiable, for example:

• · Contact information, and preferences;
• · Information about your use of our rooms and apartments, and other services when you stay with us;
• · Images of you in areas of our properties covered by CCTV;
• · Conversations you have when you call our reservations or sales teams;
• · Information about anyone you’re travelling with or meeting, if that information is provided to us;
• · Information about the devices you use to interact with us; and
• · More sensitive information, for example when you tell us about dietary requirements, disabilities, and religious beliefs.

Where you provide us with sensitive details, for example in relation to requirements you may have regarding accessibility to our properties, we will only hold this information with your express permission. This information is stored securely with restricted access and handled the greatest respect for your privacy.

Where you provide information to us about other people, you need to make sure you have their permission to do so or that you can speak on their behalf, for example, in the case of children.

When and How we Collect your Information?

We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us. This may include when you:

• · Book a room or apartment online, over email or on the phone;
• · Visit our website;
• · Fill out our online forms;
• · Visit our properties or use our properties services, like room service;
• · Access the internet by WIFI on our properties;
• · Interact with us in online forums, by email, text, telephone, or on social media;
• · Post reviews of your stay or interaction with us; and
• · Complete our market research/customer surveys.

Legal Basis for Using your Information

All organizations need a legal reason to use your personal information, if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated but below are the most relevant grounds you should be aware of.

With your Consent

There are some activities where we process personal information with your consent, for example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time by clicking on the unsubscribe link on the email. We will indicate in the Policy where we rely on consent.

To Fulfil a Contract

We also process your personal information in order to fulfil a contract we have with you. For example, when you book a stay with us, we will process your information to administer that stay.

For a Legitimate Interest

Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyze occupancy rates of our properties and adjust room rates or to send you details of special offers or other information about our properties. You can object to us relying on our legitimate interest to use your personal data in these ways at any time by getting in touch with us using the contact details below.

To Comply with Legal Obligations

There may be situations where we need to use your information to comply with legal obligations. For example, we are required by law to keep records of who is in our properties in case there is an emergency, so we can make sure you’re safe.

How we use your Personal Information

The reason we use your information will often be obvious from the way you interact with us. For example, if you book a room or apartment at one of our properties, we would use that information to administer your stay with us. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it to:

Cookies

We may collect information using “cookies” to help improve our websites in a variety of different ways. Including collecting contextual information about your visit to the site to enhance functionality and user experience.

What are cookies?

Cookies are small text files placed on your devices when you visit websites via internet browsers. Our use of cookies is to primarily help enhance your user experience and improve the efficiency of our website. In order to make purchases on our website and for an optimal user experience, you will need to enable cookies.

What cookies do we use?

Our website uses the following types of cookies for the purposes set out below:

Essential cookies – These cookies are essential to provide you with services available through our website and to enable you to use some of its features. These make our website work. For example, they help the content of the pages you request load quickly, they remember what dates you want to stay with us and what sort of room you want. They also allow us to collect information about your use of our website, enabling us to improve the way they work.

Analytics and Performance Cookies – Performance cookies also allow us to see if there are any technical issues on our website and if you are experiencing any issues using our website. These cookies are used to collect information about traffic to our website and how users use our website. The information gathered does not identify any individual visitor. It includes the number of visitors to our website, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: https://policies.google.com/privacy

You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Functional cookies – These cookies collect information about the language you have requested the site display content in, text size, location you are in and generally allow us to customize your experience. Nobody likes having to repeat themselves and these cookies help with that.

Tracking and advertising cookies and similar technologies – We may use these types of cookies and similar technologies to provide adverts that we think may be more relevant to your interests. This can be based on your browsing activity and is known as Online Behavioral Advertising or OBA. Cookies are placed on your browser, which remembers what websites you’ve been to. Advertising based on what you have been viewing is then displayed.

Web beacons and tracking pixels – These technologies help us to count users on a web page, and see if a cookie has been activated. They allow us to see how popular content is and if an email has been delivered to a recipient, opened and links clicked on. We use this information to track how successful campaigns have been.

Flash cookies – Sometimes we may use flash players to deliver special content, such as video clips. This uses Local Shared Objects or flash cookies to remember settings. Device Fingerprinting – Sometimes we may use a device’s browser information to identify that device, conduct analysis, help detect and prevent fraud and present content correctly. We also use cookies and similar technologies to :

• Allow you access to our website;
• Permit your internet connection to our website;
• Allow our servers to record information about your device (such as IP address, browser type, location, hardware and software information;
• Collect unique device identifier (UDID), geo-location and other transactional data to validate free trials when you use a mobile device;
• Assess content usage;
• Provide relevant content;
• Sell third party advertising and enable frequency capping;

Social Media Cookies – These cookies are used when you share information using a social media sharing button or “like” button on our website or engage with our content on or through a social networking website such as Facebook, Twitter or Instagram. The social network will record that you have done this.

Managing and Disabling cookies

You can typically remove or reject cookies very easily via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

However, you need to be careful about restricting the use of cookies, as they may prevent the websites you visit from working as they were intended.

For information about cookies, please visit https://www.allaboutcookies.org/

More information available also on the website of the CNIL

Advertising

We may use other companies to serve third-party advertisements when you visit and use the website. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the website and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.

Sharing with Advertising Partners

When you visit our website, we may pass information about you and any devices you are using to our advertising network partners to enable them to deliver relevant adverts and tell advertisers that adverts have been delivered and seen.

Technical and Organizational Measures

We have secure systems and processes in place to ensure the personal information you provide us is kept safe. We store personal information on our secure electronic systems. Your information may be transferred to one of our reputable cloud-based service providers who may store and process this information outside the European Economic Area (EEA). We can assure you that we take all reasonable steps to ensure your data is handled securely under appropriate agreements with our suppliers.

How we Store your Personal Information and how Long we Keep it for

We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.

Our Processors

There may be situations where we use data processors – companies who act on our behalf – to collect your information for us or to use the personal data we pass to them to provide your service. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.

Identity Verification

If we provide a service that is dependent on age or residency, we have an obligation to verify relevant information. Where relevant we may pass your information to a third party for this purpose.

Our websites and partner websites

We also receive information about you indirectly when you interact with us. For example, when you visit our website, the devices you use may provide us with your general location (like which country or region you’re in). They also tell us if you are using ad-blockers and your IP address. We may also receive information from cookies and other technologies that are on your device or browser. For more information on our use of cookies, please see our cookie policy below.

Travel Agents and Partners

We collect information about you when it is provided to us by third parties. This might include online travel agents, travel websites, and other partners. This could be when you make bookings, review your stay online, or where you interact with anyone who promotes our brands. You should always read the privacy policies of travel companies or other third parties you use, as they will use your information in accordance with their own privacy policies.

When you, or someone on your behalf, make a booking using travel agent, booking platform or other third party to use our services, they may pass us information about your booking, including information about anyone else on that booking. The same would be true where you use a third party to make enquiries about our products or services.

Where you interact with third parties who promote our services for us, these third parties may pass us your information.

When you post comments, reviews, or engage in discussions and polls about our products and services, we may receive this information from the platform you interacted with or from our partners who monitor how our brands are performing.

We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline, like insight providers.

Sometimes we may want to improve our products and services by getting a better understanding about our customers and their preferences. In these situations, we may ask reputable insight providers to provide us information that may identify you. However, this would only be where you have specifically consented to that third party providing your information to us. Where we do receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy. We may receive updated information about you from organizations that provide services to you. For example, we might be updated if you move home so that we can keep our records up to date or receive updated bank details to ensure that you can continue to use our products and services. Alternatively, we may be updated if your flight is late, so that we can anticipate your arrival more accurately. Where we engage with credit reference agencies (for example if you were using our properties for a business event) we would only do this with your explicit consent.

Further Information on how we use your Information

We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below.

Profiling and Preferences

We sometimes make decisions about what your interests are based on the way that you interact with us and the information we hold about you, this is called profiling. For example, if you regularly choose a specific room or apartment type, then we might use this information improve your experience by pre-selecting certain features of your stay for you, so you don’t need to. Understanding your preferences and personalizing your experience in this way allows us to deliver the very best service possible.

Do not track signals or browser/device settings Our website is not designed to respond to “do not track” signals or browser/device settings.

Direct Marketing

In addition to sending you information about the products and services you use and in-life communications while you stay with us, where we have your permission or where we are relying on our legitimate interest, we may send you direct marketing communications about our products, services, events and offers.

Direct marketing communications may be sent by post, email, telephone, SMS and MMS, through social media (such as WhatsApp, Instagram, Twitter, and Facebook), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our website. This may also include any websites and apps of our partners who are in our advertising networks.

We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our products or services where we feel we have a legitimate interest.

You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.

Product Related Communications and “in-life” Updates

We may use your information to send you newsletters, bulletins, and other “in-life” communications (about your stay).

For example, we may send you email or text messages about an upcoming stay with us in order to help you plan your visit and give you the best experience possible. You’ll be able to opt-out of these.

Service communications will be sent to you regarding products and services you interact with. These are important messages relating to the products and services we provide to you.

Data Matching and Audience Insights

Sometimes we may compare our customer database with our commercial customers or partners databases either directly with each other or by using an independent third party. This helps us understand if customers are on both databases, and allows us to plan joint marketing activities, and promotions. Additionally, we may match databases for business planning/continuity purposes.

We may use marketing permissions we hold to contact those customers for promotions that relate to data matching exercises.

We will only share personal information for data matching purposes where we have an agreement in place with the commercial customer or partner. This ensures that they comply with their data protection obligations, protect the information we share and limit the use of any shared information.

We may provide commercial customers and partners with information about the effectiveness of campaigns they run and well as the potential reach of future campaigns by providing aggregated reports of customer segments. This is called audience insights and helps us plan promotions and other marketing campaigns. Your personal information is not shared for this activity. You have the right to object to us processing your information this way, known as profiling. If you would like to opt-out of profiling, you can do this by contacting us using the details below, where this feature is available.

Analysis and Product Development

We may use your information to improve the products and services we offer. For example, we may look at the preferences our guests have when they stay with us to offer more relevant personalization to customers.

Detecting Ad Blockers

When you visit our website, we may check (by using script, code, cookies or other technical means) if you are using ad-blocker or other privacy tools. If we do detect one of these tools, we may ask you or ask your browser to ask you, if you would give us permission to ignore those settings and continue to serve adverts and/or collect your information using cookies and similar technologies.

Information about your device and use of ad blockers may be stored or associated with your device and used to reinsert adverts and to understand how ad blockers and other privacy tools are being used by our visitors.

Linked Services, Third Party Sites and Content

Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. We do not accept any responsibility or liability for other sites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.

Payment and Credit Checks

Your information may be used to take payment for products and services and may be used to verify credit details related to payments.

Disclosures Required by Law

Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.

Acceptable Usage

If you post or send offensive or inappropriate content anywhere on or to our website, or otherwise engage in disruptive behavior on our website, we may use the information that is available to us about you to stop such behavior. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behavior.

International Data Transfer

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. When you give us information about other individuals, you confirm that you have authority to act for them and have made them aware of the potential transfer of their information outside the EEA. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Security

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.

Our Policy on Children

Our website is/are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.

Your Rights

• Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the website may be ineffective upon opt-out.
• Access. You may access the information we hold about you at any time by contacting us directly.
• Amend. You can also contact us to update or correct any inaccuracies in your personal data.
• Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Sales of our Business

If we restructure or sell all or part of our business or business operations, we may transfer your information as part of that activity, including, but not limited to, where we transfer or cease to manage (or license the use of a brand at) a hotel. Where this is the case, your information will be used in accordance with this Policy unless you are notified otherwise.

Withdrawing Consent

Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time by contacting us by email, opting-out in any marketing or product communication you have received from us or emailing us using the contact details below. However, we may have the right to rely on an alternative legal basis for the processing activity so that we are able to provide you with the product or service you have requested and, in that case, will inform you of that.

Other Rights

You may have the right to object, erase, or restrict our processing of your information – for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.

Complaints

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us through the information listed on our website. We will reply to your complaint as soon as we can and in any event, within 30 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority

Changes to our Privacy Policy

From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.

Contact Information

We welcome your comments or questions about this Policy.

If you would like to get in touch with us, please contact

By Email: contact@privatecomfortableapartments.com

By Post: The Data Protection Officer,

Sarl 4H,

22 Rue Lothaire, 57000 Metz -FRANCE