Personal data management

Advance information

Maisons & Hôtels Sibuet is a commercial brand that includes all the hotels concluded and managed by the Sibuet family, Le Domaine de Marie (production and sale of wine) and Pure Altitude (cosmetics line). Our establishments are located in mainland France and Saint Barthélémy. Our vocation is to offer unique and personalized lifestyle experiences by constantly adapting our services and products to the sensitivities of our customers.

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This personal data management policy of Maisons & Hôtels Sibuet is an annex to the GTC (“General Conditions”) and therefore has contractual value. In the event of a contradiction between the GTC and this policy, the GTC will prevail, which the user of our sites acknowledges and accepts.

This personal data management policy reflects the desire of Maisons & Hôtels Sibuet to be completely transparent to the user about how to manage their personal data and integrates the latest requirements from the European regulation on the protection of personal data.

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The person responsible for processing personal data at Maisons & Hôtels Sibuet is:

Mr FRUITIER — 144 Chemin du Petit Darbon — 74120 MEGEVE, Email: privacy@mhsibuet.com

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The personal data protection officer of Maisons et Hôtels Sibuet is:

Mr Frédéric MOUNIER, Email: dpo@mhsibuet.com

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For any questions from the user regarding this personal data management policy, the user is invited to ask his question by sending a message to privacy@mhsibuet.com

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Summary

Section 1. What is the purpose of the Personal Data Management Policy?

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I.PERSONAL DATA

Section 2. What is personal data?

Section 3. What personal data is collected by Maisons & Hôtels Sibuet and for what purposes?

Section 4. Who has access to the User's personal data?

Section 5. What are the rights of Users concerning the personal data collected?

Section 6. For how long is personal data collected?

Section 7. What measures are put in place to protect Users' personal data?

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II.COOKIES

Section 8. What is a cookie?

Section 9. What are the tracking systems used by Maisons & Hôtels Sibuet and for what purpose?

Section 10. How do I authorize/deactivate cookies?

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III. MODIFICATION OF THE PRIVACY POLICY

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Personal data management

Section 1. What is the purpose of the Personal Data Management Policy?

The purpose of this Personal Data Management Policy is to inform the User about how Maisons & Hôtels Sibuet manages the personal data of users of its websites, whether or not they are customers (hereinafter “Users”).

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I. PERSONAL DATA

Section 2. What is personal data?

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, personal data is “any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); is deemed to be an “identifiable natural person” a natural person who can be identified, directly or indirectly, a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to his physical, physiological, genetic, psychological, psychological, economic, cultural or social identity”.

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Section 3. What personal data is collected by Maisons & Hôtels Sibuet and for what purposes?

The company Maisons & Hôtels Sibuet collects personal data on the following websites (hereinafter “the Sites”):

Hotels, online booking site and online store:

- https://www.fermesdemarie.com/fr

- https://www.lodgepark.com/fr

- https://www.hotelmontblanc.com/fr

- https://www.chaletsdesfermes.com/

- https://www.gypsea-beach.com/

- https://www.epiceriedesfermes.com/

- https://www.labastidedemarie.com

- https://saint-tropez.villamarie.fr

- https://saint-barth.villamarie.fr

- https://booking.groupe-sibuet.com

- https://shop.experience-sibuet.com

Winery and online store:

- https://www.domainedemarie.com

- http://boutique.domainedemarie.com

Cosmetics and online store:

- https://www.pure-altitude.com

- https://boutique.pure-altitude.com

Recruiting site:

- http://www.recrutement-sibuet.com

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PERSONAL DATA COLLECTED VIA THE WEBSITES OF THE COMMERCIAL BRAND MAISONS & HÔTELS SIBUET:

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Purpose: To allow the user to receive exclusive offers from each of our hotels.

• Data collected: Email address

• Legal basis:Execution of a contract. Necessary for our legitimate interests (in order to allow the user to receive our best offers, on the site).

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Purpose: To allow the user to be called back or contacted again by our reservation/conciergery/marketing/press services, by the sales department of Domaine de Marie or Pure Altitude (depending on the nature of the need).

• Data collected: Name, first name, email address, telephone number (optional)

• Legal basis: Execution of a contract. Necessary for our legitimate interests (in order to answer questions from our customers, adapt our offers to their expectations, and increase our business)

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Purpose: To allow the user to make a reservation and pay for their reservation online

• Data collected: Name, first name, email address, postal address, postal address, telephone, telephone, bank card identifiers, validity date, CVV code

• Legal basis: Execution of a contract. Necessary for our legitimate interests (in order to book services, to promote our products and services, to develop them and to increase our activities)

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Purpose: To allow our hotels and our services to communicate with the customer, at different times during their stay.

- Personalization of the stay, preparation of arrival

- Sending a satisfaction questionnaire at the end of the stay

- Promotional and administrative communication, namely:

• Sending important information about our establishments

• Information on the evolution of our general conditions and our privacy policy

• Sending administrative information concerning travel reservations, such as reservation confirmations and communications prior to arrival at a Maisons & Hôtels Sibuet hotel

• Measuring the effectiveness of our marketing or commercial actions

• Evolution of our products and services by better measuring the expectations of our customers

• Data collected: Name, first name, email address, postal address, telephone

• Legal basis: Execution of a contract. Necessary for our legitimate interests (in order to book services, to promote our products and services, to develop them and to increase our activities)

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PERSONAL DATA COLLECTED VIA THE SITES SELLING PRODUCTS OF THE COMMERCIAL BRAND MAISONS & HÔTELS SIBUET:

- https://shop.experience-sibuet.com

- http://boutique.domainedemarie.com

- https://boutique.pure-altitude.com

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Purpose: To allow the user to create an account and connect to our online product sales sites in order to:

- Manage shopping carts, gift vouchers,...

- Track orders, returns, alerts,...

- To be contacted again

- Manage personal information

- Subscribe to newsletters published by Maison & Hôtels Sibuet

• Data collected: Civility, last name, first name, email address, email address, birthday (optional), password

• Legal basis: Execution of a contract. Necessary for our legitimate interests (in order to buy products or book services, to promote our products and services, to develop them and to increase our business)

On each of the collection forms, data marked with an asterisk is essential. Otherwise, the User will not be able to access the services offered on our sites.

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PERSONAL DATA COLLECTED VIA THE SITE WWW.RECRUTEMENT-SIBUET.COM

Purpose: To allow the User to spontaneously apply for a position within Maisons & Hôtels Sibuet. Allow Maisons & Hôtels Sibuet to contact the User again if their spontaneous application was accepted.

• Data collected: CV, cover letter, Civility, Name, Last name, First name, email address, mobile

• Legal basis: Necessary for our legitimate interests (in order to recontact a person whose profile would correspond to a position within the company)

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Purpose: To allow the user to apply for a specific job offer on the site http://www.recrutement-sibuet.com/

• Data collected: CV, cover letter, Civility, Name, Last name, First name, email address, mobile

• Legal basis: Necessary for our legitimate interests (in order to recontact a person whose profile would correspond to a position within the company)

Data marked with an asterisk is essential. Otherwise, the User will not be able to submit applications on the site www.recrutement-sibuet.com.

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Section 4. Who has access to the User's personal data?

The only recipients of Users' personal data are:

- the services and employees concerned of the company Maisons & Hôtels Sibuet (in particular: IT, sales/ marketing, operational department);

- companies that assist Maisons & Hôtels Sibuet in the operation and/or operation of the sites, and in particular the services and employees of the company that hosts the sites. These companies are:

• Amazon Web Services, Inc. P.O. Box 81226 Seattle, WA 98108-1226, http://aws.amazon.com

• Opwan, 150, Pierre and Marie Curie Street 34430 Saint Jean de Vedas, www.opwan.com

- Our hotel subcontractors, for example:

• Ski schools

• Activity organizers (dog sledding, paragliding, yoga classes...)

• Partner restaurants

• Shuttles, partner taxis

•...

These structures only receive the personal information that is strictly necessary for making reservations and for the possible reminder of customers.

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Section 5. What are the rights of Users concerning the personal data collected?

The User has access to the rights detailed in Chapter III of the RGPD, including the following rights:

- Right to access personal data collected on the Website and via the Application,

- Right to modify/rectify them,

- Right to erasure (“right to be forgotten”), unless there is a legal reason that requires us to keep them,

- Right to the limitation of processing, i.e. the right to ask us in certain cases to suspend the processing of personal data,

- Right to data portability, i.e. the right to request a copy of your personal data in a current format (for example, a.csv file),

- Right to object to the processing of personal data,

- Rights relating to individual decision-making and profiling, i.e. the right to ask us to be transparent about any profiling we carry out or any automated decision,

All of these rights are exercised

- for all Maisons & Hôtels sites requesting personal information (registration forms, contact requests, reservation confirmation, etc.), by sending an email to the address privacy@mhsibuet.com.

- For the site http://www.recrutement-sibuet.com/: by sending an email to the address privacy@mhsibuet.com.

The User is reminded that he can:

- access and modify your contact details and identifiers on the sites:

• https://shop.experience-sibuet.com

• http://boutique.domainedemarie.com

• https://boutique.pure-altitude.com

via the “My Profile” and “My Personal Information” section;

The User also has the right to file a complaint with the Commission Nationale Informatique et Libertés (CNIL), the supervisory authority for data protection issues in France (www.cnil.fr). However, Maisons & Hôtels Sibuet would like to have a chance to respond to your concerns before we contact the CNIL. Also, contact us in the first place.

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Section 6. For how long is personal data collected?

- History of stays and consumption: The personal data of customers who have not booked, stayed or consumed in one of our establishments are deleted after a period of 3 years. Consumption data and historical stays are anonymized and used only for statistical purposes.

- Bank details: Credit card numbers are automatically deleted one day after the customer leaves.

- Information on participants in the stay: The personal data of participants in the stay who have not booked, stayed or consumed in one of our establishments again are deleted after a period of 3 years.

- Billing data: Invoices are archived for a period of 5 years.

- Feedback from satisfaction questionnaires: They are kept nominatively for a period of 3 years, then used anonymously for statistical purposes.

- Recruitment data: The CVs of unrecruited candidates are kept for 3 years.

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Section 7. How is personal data protected?

Maisons & Hôtels Sibuet is very vigilant about the security of personal data and takes all reasonable precautions to prevent any unauthorized access and disclosure, alteration or destruction of personal data.

The personal data collected is stored by Maisons & Hôtels Sibuet or by its service providers, and is protected by means of physical and electronic access controls, firewall technologies and other reasonable security measures.

However, such measures cannot prevent all risks of loss, access, misuse, or alteration of the personal information collected. In cases where required by law, Maisons & Hôtels Sibuet will notify the User of any case of loss, access, abusive use or alteration of his personal data, in order to allow him to take the appropriate steps to enforce his rights. The company Maisons & Hôtels Sibuet will notify the User electronically, by post or by telephone, if authorized by law.

The User is invited not to transmit payment information or sensitive information by email or in sections not provided for this purpose (for example, sending a credit card number by email).

You have the option to choose what personal data you want to provide to us.

However, your decision not to transmit certain data could alter your experience of our services. For example, we cannot make anonymous bookings and, if we are not authorized to disclose your personal data to hotels in our group, we may not be able to provide you with certain services, reservations or otherwise.

Likewise, if you do not authorize us to disclose your personal data to third parties, such as to subcontractors of our hotels (ski school, car rental companies, etc.), we may not be in a position to provide you with all the possible services or the provision of these services may be delayed. We will do our best to respond to your request as soon as possible.

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II. COOKIES

Section 8. What is a cookie?

According to the Commission Nationale de l'Informatique et des Libertés, a cookie corresponds to information placed on the User's means of Access by the server of the Website or Application that he is visiting.

A cookie contains several pieces of data:

- the name of the server that deposited it,

- an identifier in the form of a unique number,

- possibly an expiration date.

This information is sometimes stored on an access device in a simple text file that a server accesses to read and save information.

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Section 9. What are the tracking systems used by Maisons & Hôtels Sibuet and for what purposes?

The User is informed that the company Maisons & Hôtels Sibuet uses the following tracking tools:

Maisons & Hôtels Sibuet websites, online services, interactive applications, electronic messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons.

These technologies help us better understand user behavior, tell us what parts of our websites are visited, and facilitate and measure the effectiveness of advertising and web searches.

We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information under local law, we also treat these identifiers as personal information.

Likewise, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this privacy policy.

Maisons & Hôtels Sibuet also uses cookies and other technologies to remember personal information when you use our website, online services, and applications.

Our aim in these cases is to make your experience more convenient and personal. For example, knowing your country and language helps us provide a personalized and more useful marketing experience.

We use this information to understand and analyze trends, administer the site, learn about user behavior on the site, improve our products and services, and gather demographic information about our user base as a whole. Maisons & Hôtels Sibuet may use this information in its marketing and advertising services.

Pixel tags allow us to deliver targeted advertising messages in a format that customers can read. We may use this collected information to reduce or eliminate messages sent to customers.

The User is informed that he has, at any time, a right to access data concerning him concerning cookies and to object, allowing him at any time to choose whether or not to accept cookies.

However, if the User does not accept cookies, the use of the Services (and in particular the navigation on the Sites) may not be carried out correctly.

With regard to “Facebook” cookies, the company Maisons & Hôtels Sibuet collects the User's prior consent.

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Section 10. How do I authorize/deactivate cookies?

The User can manage, deactivate and authorize cookies at any time by configuring their internet browser. For example:

- for smartphone or Mac tablet: via the Settings sections/Then select the browser concerned/Accept cookies/Never/or Sites visited/or Always.

- for Android smartphones: by pressing, after launching the browser, on the menu button (at the bottom left of the Mobile Device) /More/Settings/Accept cookies or do not accept cookies.

- for computer:

• under Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

• under Safari: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html

• in Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

• in Firefox: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

• under Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

For more information on the management and deactivation of cookies, the User can use the help section of their browser.

In case of difficulty in exercising their right of access or opposition to cookies, the User may contact the company Maisons et Hôtels Sibuet via the email address: privacy@mhsibuet.com

The maximum duration of a cookie is thirteen months.

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III. MODIFICATION OF THE PRIVACY POLICY

Maisons & Hôtels Sibuet reserves the right to change, modify or revise this policy at any time.

The date the document was last updated is February 12, 2019.

If there is a material change to this policy, we will post on the Sites that our privacy policy has changed.

If we make material changes to how we use your personal information, we will notify you by email to the address in your account (if applicable) or by means of a notification on the home page of our Sites while giving you the opportunity to opt out of this new use.

Any changes to this privacy policy will take effect at the time they are posted on the Sites.

Your use of our Sites after these changes take effect means acceptance of this privacy policy under the new terms made public.