Privacy Policy

When you use the website https://hotel-josephine.com/, L'Hôtel Joséphine & Spa by HappyCulture may collect and process your personal data, either on its own or in collaboration with member establishments of the Honotel hotel network or the HappyCulture-branded services program, which enable Our Users to benefit from Our services and exclusive offers.

The purpose of this Privacy Policy is to inform users of the Service about the methods used to collect and process your personal data, in compliance with applicable French and European legislation, in particular Law No. 78-17 of January 6, 1978, on information technology, files, and civil liberties, as amended by Law No. 2004-801 of August 6, 2004, and by Law No. 2018-493 of June 20, 2018, Regulation (EU) No. 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons withregarding the processing of personal data and on the free movement of such data, and Directive 2002/58 of July 12, 2002, as amended by Directive 2009/136/EC, and any national implementing legislation or subsequent legislation that may replace them.

We attach the utmost importance to respecting your privacy and protecting your personal data.

By accessing and/or using the Service, you agree that your personal data may be collected and processed under the terms and conditions set forth below. If you do not agree to this Policy, you must cease all use of the Service.

This Policy is an integral part of the Service’s Legal Notice and must be read in conjunction with these Terms of Use, accessible at the following address: https://hotel-josephine.com/fr/politique-confidentialite.html, as well as with Our Privacy Policy, accessible below.

We may modify this Policy, in particular to comply with any legislative, regulatory, jurisprudential, editorial, or technical changes, under the conditions described in the Terms of Service. You must therefore refer to the latest version of this Policy before using the Service.

1. Definitions

The terms “personal data,” “process/processing,” “data controller,” “data processor,” “recipient(s),” “consent,” and “file” have the same meaning as set forth in Article 4 of the GDPR.

2. Data Controller

The data controller for the User’s Personal Data collected through the Service is Honotel Développement, whose contact information is provided in Article 10.

3. What Personal Data Is Collected?

When Personal Data is collected, the User will be informed whether certain Personal Data is required or optional. If the required Personal Data is not provided, access to certain features of the Service—such as the online room reservation service—and their use by the User will be impossible.

In particular, we may collect the following categories of Personal Data:

Identity: title, last name, first name, organization, phone number, email address;

Interests declared via a form or inferred from use of the Service;

Contacts and communications with Us;

Technical browsing and interaction data: traffic statistics: IP address, cookies, for example, the pages viewed by the User, the date and time of the visit (see the Cookie Policy)

4. Why do we collect your personal data?

The Personal Data you provide to us, as well as that which is collected and/or processed in connection with your use of the Service, is processed for the following purposes, among others:

Legal Bases

Purposes

Contract between you and us (Terms of Use and this Policy)

To make the Service available to You, ensure its proper functioning, including to process Your requests, facilitate Your navigation, etc.

Our legitimate interest in improving Our Service

To improve the Service, including to optimize or offer new features to the Service, or to provide You with simplified auto-fill functionality

Our legitimate interest in offering You services and offers that match Your preferences and interests

Adapt and optimize the display of Service content and promotional offers to the User’s settings or preferences, tastes, and interests—whether proven, presumed, or inferred—which may result from Your use of the Service, the information You have entered, or Your browsing and interactions with the Service

- Our legitimate interest in promoting Our Service and providing You with offers and news

- Your consent to receive offers and news from Our partners

To inform You of Our offers and news, unless You object, as well as offers and news from Our partners, if You have given Your consent

5. Who are the recipients of Your Personal Data?

The Personal Data database created during your use of the Service is strictly confidential. We are committed to taking all necessary precautions and appropriate organizational and technical measures to preserve the security, integrity, and confidentiality of Personal Data, and in particular to prevent it from being distorted, damaged, or accessed by unauthorized third parties.

5.1 Data transferred to authorities and/or public bodies

In accordance with applicable regulations, Personal Data may be transmitted to competent authorities upon request, and in particular to public bodies, exclusively to meet legal obligations, as well as to court officers, ministerial officers, and entities responsible for debt collection.

5.2 Data accessible to third parties

Personal Data may be used by Us, Our subcontractors, Our affiliates, and/or, where applicable, by Our business partners, for the purposes described in Article 4 above.

· Our staff, the departments responsible for auditing (including the auditor), and Our subcontractors will have access to the Personal Data collected in connection with the use of the Service;

· Our business partners, such as restaurants or spas, will have access to the User’s Personal Data for purposes including the management of their reservations and after-sales service;

· Social media: if the User has an account on social media sites and accesses the Service, We may receive information from such social media platforms, and social media services may receive information regarding the User’s use of the Service. When the User accesses the Service via a social media platform, the User grants Us access to certain information they have provided to the social media platform, such as their username, first and last name, their profile picture, and their Personal Data related to the use of that service. By accessing the Service via a social media site, the User authorizes Us to collect, store, and use all information that the User has authorized the social media site to provide to Us.

5.3 Transfers Outside the European Union

The User’s Personal Data may be processed outside the European Union, including via remote access.[KO4] We undertake not to transfer any Personal Data outside the European Union without implementing appropriate safeguards in accordance with the Applicable Regulations.

6. What are Your rights regarding Your Personal Data?

In accordance with Applicable Regulations, subject to an express request and proof of Your identity to Us, You have the right to access Your Personal Data, the right to rectification, the right to object, and the right to erasure, under the conditions set forth in Applicable Regulations.

Your right to erasure of Your Personal Data applies subject to any legitimate reasons We may have for retaining Personal Data, particularly in relation to Our legal obligations.

If you exercise your right to object, we will cease processing your Personal Data, unless there are legitimate and compelling grounds for the processing, or to ensure the establishment, exercise, or defense of our legal rights, in accordance with the Applicable Regulations.

You may also, subject to the conditions of the Applicable Regulations, request a restriction on the processing of Your Personal Data.

When the processing of Your Personal Data is based on Your consent, You have the right to withdraw Your consent at any time.

You also have a right to data portability regarding certain of Your Personal Data, allowing You to request an electronic copy in a readable and usable format of Your Personal Data processed by Us in connection with Your contractual relationship with Us for the provision of products or services to which You have subscribed, which excludes Personal Data that We may have generated for Our own purposes or to fulfill Our legal obligations, including accounting, social, or tax obligations, as well as information regarding the history of bookings made, amounts paid or payable, and any information We may have generated in pursuit of Our legitimate interests.

You have the right to provide Us with instructions regarding the disposition of Your Personal Data after Your death.

If applicable, We will inform You of the reasons why the rights You exercise cannot be fulfilled in whole or in part.

To exercise the rights mentioned in this Article, you may contact us by including a copy of a valid ID with your request at the contact information provided in Article 10 below.

7. Retention Period for Your Personal Data

We undertake not to retain Your Personal Data beyond the period strictly necessary for the purposes for which it was collected, and in accordance with Applicable Regulations.

We undertake to anonymize or delete Your Personal Data as soon as the purpose and/or the defined retention period expires.

However, Personal Data may be archived beyond the specified periods for the purposes of investigation, detection, and prosecution of criminal offenses, solely to enable, as needed, the provision of such Personal Data to judicial authorities, or for other retention obligations, particularly for accounting or tax purposes. Archiving means that this Personal Data will be subject to access restrictions and will no longer be accessible online but will be extracted and stored on a separate, secure medium.

The maximum retention periods defined in the table below apply, unless You request the erasure or cessation of the processing of Your Personal Data before the expiration of these periods, in accordance with Article 7 above.

Category

Retention Period

Audience measurement and Service personalization, management of cookies and other trackers

13 months from the placement of the cookie or other tracker

Personal Data that We process in connection with solicitations and promotional activities, sending offers and news

3 years from the end of the relationship with the User or from the last interaction initiated by the User

Personal Data relating to the management of requests to exercise rights and questions regarding Personal Data

3 years from the last interaction initiated by the User

8. Protection of Minors’ Personal Data

The Service is generally not intended for minors under the age of 15. For this reason, We do not collect or retain Personal Data concerning children under the age of 15 without obtaining verifiable parental consent, noting that those with parental authority may request to receive information regarding their child and request its deletion.

When an adult User enters Personal Data relating to a minor under the age of 15, they agree to have verifiable consent from the holders of parental authority and to provide, upon request, any evidence demonstrating such consent.

9. Security

Given the evolution of technologies, implementation costs, the nature of the Personal Data to be protected, and the risks to individuals’ rights and freedoms, we implement appropriate technical and organizational measures to ensure the confidentiality of the Personal Data collected and processed and a level of security appropriate to the risk, in accordance with this Policy.

Information collected as part of the booking process is transmitted over the Internet using SSL (Secure Socket Layer) encryption. All necessary precautions, in accordance with state-of-the-art standards, given the nature of the Personal Data and the risks posed by its processing, will be taken to preserve the security of the Personal Data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties.

10. Contact

For any inquiry regarding the processing of your Personal Data, you may submit your request or complaint directly to us by contacting us at Honotel Développement SAS, 20 Rue Treilhard, 75008 PARIS, or via email at dpo@honotel.fr

We will strive to find a satisfactory solution to ensure compliance with Applicable Regulations.

In the absence of a response from us or if the dispute persists, you may file a complaint with the CNIL or the supervisory authority of the European Union Member State in which you habitually reside.

PRIVACY POLICY

The purpose of this Privacy Policy is to inform users of the website https://hotel-josephine.com/ of the measures that Hotel Joséphine implements, either alone or in collaboration with member establishments of the Honotel hotel network or the Happyculture-branded service program, to access and store information regarding your browsing activity on the Service.

When using the Service, information regarding the browsing activity of your computer, tablet, smartphone, etc., may be stored in text files known as “cookies” installed on your Device, subject to the choices you have made regarding “cookies,” which you may modify at any time.

The Cookie Policy is an integral part of the Service’s Legal Notice and must be read in conjunction with these Terms of Use, accessible at the following address: https://www.happyculture.com/pages/mentions, as well as Our Privacy Policy accessible above.

We may modify the Cookie Policy, in particular to comply with any legislative, regulatory, jurisprudential, editorial, or technical changes under the conditions described in the Terms of Use. You should therefore refer to the latest version of the Cookie Policy before browsing.

1. What is a cookie?

A “cookie” is a small text file, image, or piece of software that we may store on your device’s hard drive via your web browser when you use the Service, subject to your consent and unless you object.

A “cookie” allows its issuer, during its validity period, to recognize the relevant Device each time that Device accesses digital content containing “cookies” from the same issuer.

Once installed, “cookies” allow us to recognize you each time you visit the Service, and thus enable you to take full advantage of all the Service’s features, track your visits to specific pages, and provide you with additional services. They also allow us to improve your browsing experience, secure your connection, or tailor a page’s content to your interests or usage preferences.

The information stored by cookies, for a limited period of validity, includes the pages visited, the type of browser you use, and other data that our online services process automatically, such as the identity of your Internet service provider, your IP address, or the information you have entered on the Service (to avoid having to re-enter it).

“Cookies” are not active files and therefore cannot contain viruses. For more information, please visit https://www.cnil.fr/fr/comment-ca-marche.

2. What are the “cookies” issued on the Service used for?

Only the issuer of a “cookie” can read or modify the information contained therein.

“Cookies” are used for the purposes described below, subject to the choices you can express and modify at any time via the settings of the browser software used while browsing the Service.

2.1 Browsing “cookies”

Browsing “cookies” help improve the Service’s performance to provide the User with a better experience. These “cookies” do not require the User’s prior information or consent to be placed on the User’s Device.

More specifically, these browsing cookies enable, among other things:

to adapt the Service’s presentation to your device’s display preferences (language used, screen resolution, operating system, etc.) while you use the Service, based on the hardware and software used for viewing or reading on your device;

to grant access to a restricted area requiring a username and password;

to store information regarding the forms you have filled out while using the Service;

to store your usage preferences, display settings, and the browsers you use to facilitate your navigation during your next visit to the Service;

to tailor the Service’s informational or promotional content based on Your interests and preferences—whether assumed, stated, or inferred from Your browsing activity on the Service—and based on Your location when connecting to the Service;

to implement security measures, for example, when the User is asked to log in again to the Service after a certain period of time has elapsed.

2.2 Statistical “cookies”

Statistical “cookies” issued on the Service enable, in particular, the compilation of statistics and metrics regarding traffic and usage of the various elements comprising the Service (sections and content visited, navigation paths, etc.), allowing us to improve the relevance and usability of the Service.

The results of statistical “cookie” analyses are processed anonymously and used exclusively for statistical purposes.

2.3 Advertising “cookies” and third-party “cookies”

Advertising cookies and third-party cookies enable, in particular:

determining in real time which advertisements to display based on your recent browsing activity in order to limit the number of times an advertisement is displayed and to help measure the effectiveness of an advertising campaign;

personalizing your browsing experience on the Service, maintaining and improving the quality of our Service, and protecting you from any fraudulent activity. When third-party sites, such as social media sites, receive information contained in “cookies” through the use of a specific module of the Service, this information is presumed to be anonymous and is intended solely to enable Your identification on the Service.

3. Validity Period of “Cookies”

The “cookies” issued on the Service are session “cookies” (whose duration is limited to the time of a connection to the Service) and persistent “cookies” (whose duration, though limited, exceeds the duration of a connection).

Session “cookies” are active only for the duration of your visit and are deleted when you close your browser. Persistent “cookies” remain stored on your Device’s hard drive after your browser is closed.

In accordance with Applicable Regulations and the recommendations of the French Data Protection Authority (“CNIL”), cookies are retained for a maximum period of 13 (thirteen) months after their initial placement. Upon expiration of this period, your consent must be obtained again for the collection of cookies subject to consent.[KO2]

4. Your choices regarding “cookies”:

All User rights recognized in Article 6 of the Personal Data Protection Policy also apply to the use of “cookies.”

You have several options for managing cookies. The User understands that “cookies” enhance the browsing experience on the Service. Any settings the User may configure may alter their browsing experience on the Service and their access conditions to certain services requiring the use of “cookies.” We cannot be held liable for the consequences of reduced Service performance resulting from the inability to install or read cookies necessary for its proper functioning, provided that the User has rejected or deleted them.

Users may configure their browser software so that “cookies” are stored on their Device or, conversely, rejected, either systematically or depending on the issuer. Users may also configure their browser software so that they are prompted to accept or reject “cookies” on a case-by-case basis, before a cookie is likely to be stored on their Device.

Please note that exercising the right to object will not prevent the display of advertisements. Only advertisements using the Service’s personalization features will cease. In other words, the User will no longer be exposed to advertisements tailored to their interests through the use of “cookies” on the Service but will continue to see advertisements whose content may no longer align with their interests, or may even be questionable.

The help menu or dedicated section of your browser will allow you to learn how to set or modify your cookie preferences:

• For Internet Explorer™:

http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

• For Safari™:

https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

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

• For Firefox™:

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

• For Opera™:

https://help.opera.com/en/latest/web-preferences/#cookies

• iOS:

https://support.apple.com/fr-fr/HT201265

• Android:

https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DAndroid&hl=fr

• BlackBerry:

https://global.blackberry.com/fr/legal/cookies

• Windows Phone:

https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies