Personal Data Protection Policy
The personal data relating to users of the website hoteltourismeavenue.com and to Tourisme Avenue’s customers are collected, processed and retained by Tourisme Avenue in accordance with the laws and regulations governing personal data protection, in particular the French Data Protection Act of 6 January 1978, as currently in force, and Regulation (EU) 2016/679 of 27 April 2016 (General Data Protection Regulation, hereinafter the “GDPR”).
For the purposes of this Personal Data Protection Policy, the term “personal data” (hereinafter the “Personal Data”) shall be understood as corresponding to “personal data” as defined by the GDPR.
The controller responsible for the processing of the Personal Data is Tourisme Avenue.
I. Nature of personal datas collected et processing purpose
| Type of Processing | Personal Data Concerned | Purpose and Legal Basis of Processing |
| Personal Data relating to reservations | Data relating to bookings made, in particular: concerning the person making the booking: title, surname, first name, email address, telephone number, payment card details; concerning occupants (persons staying at the hotel): title, surname, first name; company name (if the booking is made by a company), details of the booked stay, customer requests/preferences, booking source through which the customer made the reservation, payments made in connection with the booking; reservation data (services requested, arrival and departure dates, specific requests made at the time of booking, etc.); transaction data | Administrative management of accommodation bookings and any ancillary services that may be provided. Processing of Personal Data is carried out on the contractual basis referred to in Article 6(1)(b) of the GDPR. In addition, certain data are also processed for the purpose of preventing payment fraud (processing carried out on the basis of the legitimate interest referred to in Article 6(1)(f) of the GDPR). |
| Newsletter Personal Data | These data include in particular: surname, first name, email address, IP address at the time of receipt, date and time of newsletter opening, country, newsletter opened/not opened, operating system used, email client, number of clicks on the newsletter, date of booking made after a click, revenue generated following a click, number of days between the booking date and the newsletter sending date, unsubscribe requests | Management of newsletter distribution and analysis of campaign performance. Processing of Personal Data is carried out on the basis of the legitimate interest referred to in Article 6(1)(f) of the GDPR (namely Tourisme Avenue’s legitimate interest in promoting its offers and news to its customers), where communications relate to services similar to those already purchased by the customer or where they aim to inform about Tourisme Avenue’s news (in particular opening dates), provided that the customer has not objected to receiving such communications. |
| Check-in Registration Form | Surname, first name, nationality, email address, details of the stay, copy of passport (for foreign occupants only) | Administrative management of the guest’s stay. Processing of Personal Data is carried out on the contractual basis referred to in Article 6(1)(b) of the GDPR. |
| Customer Satisfaction Survey Personal Data | These data include in particular: surname, first name, email address, telephone number, company name where the booking was made by a company, details of past and future stays at the establishment, customer requests | Management of satisfaction survey distribution and analysis of responses. Processing of Personal Data is carried out on the basis of the legitimate interest referred to in Article 6(1)(f) of the GDPR (namely Tourisme Avenue’s legitimate interest in assessing customer satisfaction in order to improve its services, provided that the customer has not objected to receiving such communications). |
| Personal Data relating to the exercise of data subjects’ rights | Data communicated by the data subject in the context of exercising their rights, in particular surname, first name, address, etc. | Management of data subject rights requests. Processing of Personal Data is carried out on the basis of the legal obligation referred to in Article 6(1)(c) of the GDPR. |
| CCTV Data | Images from CCTV cameras installed inside Hotel Tourisme Avenue | Ensuring the safety of persons and property within Hotel Tourisme Avenue. Processing is carried out on the basis of the legitimate interest referred to in Article 6(1)(f) of the GDPR. For full information on CCTV, please refer to section 7 of this Privacy Policy below. |
| Personal Data relating to disputes | Any Personal Data collected in the context of the processing activities mentioned above | Management of customer disputes for the defence of Tourisme Avenue’s interests in legal proceedings. Processing is carried out on the basis of the legitimate interest referred to in Article 6(1)(f) of the GDPR. |
| Cookies | Audience measurement per page; list of pages from which a link was followed to access the current page (referrer), internal or external, per page and aggregated daily; device type, browser and screen size, per page and aggregated daily; page loading time statistics, per page and aggregated hourly; time spent on each page, bounce rate, scroll depth, per page and aggregated daily; user interaction statistics (clicks, selections), per page and aggregated daily; geographical origin of requests, per page and aggregated daily | Necessary for the provision of the service. Processing of Personal Data is carried out on the contractual basis referred to in Article 6(1)(b) of the GDPR. |
II. Recipients of Personal Data for Processing Operations Carried Out under the Responsibility of Société Hôtelière du Home ModernePersonal Data are intended for the authorised departments and personnel of Tourisme Avenue for the performance of the processing purposes defined above (customer service, accounting department, legal department, security department, etc.).
They may be disclosed, for certain of the aforementioned purposes and only where such disclosure is necessary, to our service providers who may intervene in the processing of Personal Data.
These recipients act solely on behalf of and under the instructions of Tourisme Avenue and receive only the Personal Data strictly necessary for the purpose requiring such disclosure. These include the following service providers:
technical service providers (hosting providers, IT service providers managing reservations – MEDAILOG – E-EDGE – EXPERIENCE – secure payment provider, etc.);
lawyers, judicial officers, debt collection service providers.
Personal Data may also be disclosed to other recipients:
where Tourisme Avenue is legally required to do so (for example, pursuant to a request from judicial, police or administrative authorities) or directly to such authorities;
where a third party has a legitimate interest (for example, fraud prevention).
Personal Data collected by Tourisme Avenue are under no circumstances sold to third parties and are not subject to any transfer outside the European Union. In any event, should Personal Data be processed outside the European Union, Tourisme Avenue shall ensure that the transfer of Personal Data to the relevant country is subject to one of the following safeguards:
the country concerned benefits from an adequacy decision issued by the European Commission recognising an adequate level of protection;
the transfer contract complies with the standard contractual clauses adopted by the European Commission or any other document or mechanism approved by the competent data protection authorities.
III. Retention of Personal Data
| Data Category | Maximum Retention Period |
| Reservation Data | · Bank card data: Until the card’s expiry date, or 15 days after deletion of the reservation, or the night following the guest’s departure where all invoices relating to the reservation have been settled and archived. · Other reservation data: Up to 5 years after departure or cancellation of a stay. |
| Personal Data from Satisfaction Surveys | · Other reservation data: Up to 5 years after departure or cancellation of a stay. |
| Guest Information Form | · Up to 5 years from departure from the hotel |
| CCTV / Video Surveillance | · 1 month |
| Newsletter Data | 3 years from the booking of the stay or from the guest’s last contact · |
| Cookies | Cookie lifespan: 13 months Data retention period: 25 months maximum |
| Personal Data relating to the Exercise of Data Subjects’ Rights | · For the duration of the processing of the request, then 5 years from the closure of the file. |
| Personal Data relating to Disputes/Litigation | Data processed to manage a pre-litigation matter is deleted upon amicable settlement of the dispute or upon expiry of the limitation period for the corresponding legal action. Data processed to manage litigation is deleted once no further appeal is possible against the judgment rendered for its enforcement, following execution of the judgment. |
The periods referred to in this Article may be superseded by any other mandatory maximum period prescribed by law or regulation.
IV. Rights of Individuals with Regard to Their Personal Data
Individuals whose Personal Data are collected by Tourisme Avenue may, at any time, exercise their individual rights of access to their Personal Data, rectification, erasure of their data, restriction of processing, data portability, objection to the processing of their Personal Data, and the right to define instructions regarding the fate of their Personal Data after their death. These rights may be exercised at any time and by any means by contacting Tourisme Avenue, in particular:
By post: Tourisme Avenue, 66 Avenue de la Motte-Picquet, 75015 Paris, France
By email: assistant@tourismeavenue.com
In accordance with applicable law, requests are processed within a maximum period of one (1) month from receipt (which may be extended by two (2) months in the case of complex requests). It is reminded that abusive requests are punishable by law.
In certain cases, you may also exercise your rights directly:
- you may unsubscribe from the newsletter or request not to receive any further commercial offers from Tourisme Avenue at any time by clicking the unsubscribe link at the bottom of each email received;
- regarding SMS communications, you may object by registering on the “Bloctel” telephone marketing opt-out list;
- if, after contacting Tourisme Avenue, you consider that your rights are not respected, you may lodge a complaint with the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés – CNIL).
V. Security of Personal Data
Tourisme Avenue makes every effort to ensure the security of Personal Data.
Accordingly, Tourisme Avenue implements organisational, procedural and technical measures to ensure control of both physical and logical access to Personal Data. These measures aim, among other things, to prevent any unauthorised loss, use, alteration or disclosure of Personal Data.
When Tourisme Avenue engages a service provider, Personal Data are only disclosed after obtaining from the latter commitments and guarantees regarding its ability to comply with these security and confidentiality requirements.
Tourisme Avenue concludes contracts with its processors defining precisely the conditions and terms under which Personal Data are processed, in accordance with applicable personal data protection regulations.
VI. Specific Information Regarding Cookies
A cookie is a text file used for browsing websites, stored in a dedicated space on the user’s device (computer, tablet, mobile phone, or any other internet-enabled device) when accessing online content.
Tourisme Avenue uses only cookies that are strictly necessary for the provision of the service (use of the website hoteltourismeavenue.com). Consequently, Tourisme Avenue is not required to obtain your consent for the use of these cookies (consent exemption pursuant to Article 82 of the French Data Protection Act).
The cookies used by Tourisme Avenue are strictly limited to audience measurement of the website hoteltourismeavenue.com (performance measurement, detection of navigation issues, optimisation of technical performance and usability, estimation of required server capacity, analysis of content viewed), exclusively for Tourisme Avenue, and are used solely to produce anonymous statistical data.
If you wish, you may refuse or delete cookies via your browser settings.
You may at any time choose to disable all or part of the cookies and/or configure your browser to notify you whenever cookies are stored on your device and request your acceptance (case by case or globally).
Below are links to browser support pages explaining how to manage cookie settings:
Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
Firefox: https://support.mozilla.org/fr/kb/protection-renforcee-contre-pistage-firefox-ordinateur?redirectslug=Activer+et+d%C3%A9sactiver+les+cookies&redirectlocale=fr
Safari: https://support.apple.com/fr-fr/guide/safari/sfri11471/16.1/mac/13.0
Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
The CNIL (Commission Nationale de l’Informatique et des Libertés) provides extensive information on cookies on its website and guides users on how to limit online tracking:
https://www.cnil.fr/fr/cookies-et-autres-traceurs/comment-se-proteger
It also explains how to configure browsers regarding cookies:
https://www.cnil.fr/fr/cookies-et-autres-traceurs/comment-se-proteger/maitriser-votre-navigateur
VII. Specific Information Regarding Video Surveillance
INFORMATION NOTICE ON PERSONAL DATA PROTECTION IN THE CONTEXT OF VIDEO SURVEILLANCE WITHIN HOTEL TOURISME AVENUE
Purpose of Processing (Purpose and Legal Basis)
Hotel TOURISME AVENUE, whose registered office is located at 66 Avenue de la Motte-Picquet, 75015 Paris, France, has installed a video surveillance system within its premises to ensure the safety of its staff and property. Images recorded by this system are not used for employee monitoring or working time control.
The legal basis for this processing is TOURISME AVENUE’s legitimate interest in ensuring security within its establishment (Article 6(1)(f) of the General Data Protection Regulation (GDPR)).
Data and Categories of Data Subjects
Visitors (customers, service providers, etc.) and employees of TOURISME AVENUE are recorded by the system.
Recipients
Images may be viewed, in the event of an incident, by authorised staff of TOURISME AVENUE and by law enforcement authorities.
Retention Period
Images are stored for a maximum period of one month.
In the event of an incident relating to the safety of persons or property, video surveillance footage may be extracted from the system. It is then stored on a separate medium for the duration necessary for the handling of procedures relating to the incident and accessible only to authorised persons for that purpose.
Data Subjects’ Rights
You may access your personal data or request its deletion. You also have the right to object and the right to restriction of processing (see cnil.fr for more information on your rights).
To exercise these rights or for any questions regarding the processing of your data in this system, you may contact us by email at assistant@tourismeavenue.com or by post at: Hotel TOURISME AVENUE, 66 Avenue de la Motte-Picquet, 75015 Paris, France.
If, after contacting us, you believe that your rights regarding your personal data have not been respected or that the video surveillance system does not comply with data protection rules, you may lodge a complaint online with the CNIL (www.cnil.fr/plaintes) or by post at: CNIL – Complaints Department – 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07, France.