Personal Data Management

Introduction

Maisons & Hôtels Sibuet is a brand that encompasses all the hotels designed and managed by the Sibuet family, Le Domaine de Marie (wine production and sales), and Pure Altitude (a line of cosmetics). Our properties are located in mainland France and Saint Barthélemy. Our mission is to offer unique and personalized experiences in the art of living, constantly adapting our services and products to the preferences of our guests.

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This Personal Data Management Policy of Maisons & Hôtels Sibuet constitutes an appendix to the General Terms and Conditions (“GTC”) and is therefore contractually binding. In the event of any conflict between the GTC and this policy, the GTC shall prevail, which users of our websites acknowledge and accept.

This privacy policy reflects Maisons & Hôtels Sibuet’s commitment to being fully transparent with users regarding how it handles their personal data and incorporates the most recent provisions of the European General Data Protection Regulation.

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The data controller for Maisons & Hôtels Sibuet is:

Mr. FRUITIER – 144 Chemin du Petit Darbon – 74120 MEGÈVE, France, Email: privacy@mhsibuet.com

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The Data Protection Officer for Maisons et Hôtels Sibuet is:

Mr. Frédéric MOUNIER, Email: dpo@mhsibuet.com

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If you have any questions about this privacy policy, please contact us at privacy@mhsibuet.com

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Table of Contents

Article 1. Whatis the purpose of the Personal Data Management Policy?

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I. PERSONAL INFORMATION

Article 2. What is personal data?

Article 3. What personal data does Maisons & Hôtels Sibuet collect, and for what purposes?

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

Article 5. What rights do Users have regarding the personal data collected?

Article 6. How long is personal data retained?

Article 7. What measures are taken to protect Users' personal data?

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II. COOKIES

Article 8. Whatis a cookie?

Article 9. Whattracking systems does Maisons & Hôtels Sibuet use, and for what purposes?

Article 10. Howdo I enable or disable cookies?

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III. CHANGES TO THE PRIVACY POLICY

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Personal Data Management

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

The purpose of this Privacy Policy is to inform Users about how Maisons & Hôtels Sibuet handles the personal data of users of its websites, whether or not they are customers (hereinafter referred to as “Users”).

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I. PERSONAL INFORMATION

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Article 2. What Is Personal Information?

According to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, “personal data” means “any information relating to an identified or identifiable natural person (‘data subject’); a natural person is considered identifiable if they 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 factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.”

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Article 3. What personal data does Maisons & Hôtels Sibuet collect, and for what purposes?

Maisons & Hôtels Sibuet collects personal data on the following websites (hereinafter "the Sites"):

Hotel, 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

Recruitment website:

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

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PERSONAL DATA COLLECTED THROUGH THE MAISONS & HÔTELS SIBUET WEBSITES:

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

• Data collected: Email address

• Legal basis: Performance of a contract. Necessary for our legitimate interests (to allow you to receive our best offers on the website).

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Purpose: To allow the user to be contacted by our reservations, concierge, marketing, or press departments, or by the sales department of Domaine de Marie or Pure Altitude (depending on the nature of the request).

• Data collected: Last name, first name, email address, phone number (optional)

• Legal basis: Performance of a contract. Necessary for our legitimate interests (responding to customer inquiries, tailoring our offerings to their expectations, and growing our business)

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Purpose: To allow users to make a reservation and pay for it online

• Data collected: Last name, first name, email address, mailing address, phone number, credit card information, expiration date, CVV code

• Legal basis: Performance of a contract. Necessary for our legitimate interests (booking services, promoting our products and services, developing them, and growing our business)

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Purpose: To enable our hotels and services to communicate with guests throughout their stay.

- Personalizing your stay, preparing for your arrival

- Sending a satisfaction survey at the end of the stay

- Promotional and administrative communications, specifically:

• Sending important information about our facilities

• Information about changes to our Terms and Conditions and Privacy Policy

• Sending administrative information related to travel reservations, such as booking confirmations and pre-arrival notifications for a Maisons & Hôtels Sibuet hotel

• Measuring the effectiveness of our marketing or sales activities

• Developing our products and services through a better understanding of customer expectations

• Data collected: Last name, first name, email address, mailing address, phone number

• Legal basis: Performance of a contract. Necessary for our legitimate interests (booking services, promoting our products and services, developing them, and growing our business)

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PERSONAL DATA COLLECTED THROUGH THE MAISONS & HÔTELS SIBUET PRODUCT SALES WEBSITES:

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

- http://boutique.domainedemarie.com

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

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Purpose: To allow users to create an account and access our online stores selling products for:

- Manage shopping carts, gift cards, etc.

- Track orders, returns, notifications, etc.

- To be contacted

- Manage your personal data

- Subscribe to the newsletters published by Maisons & Hôtels Sibuet

• Information collected: Title, last name, first name, email address, date of birth (optional), password

• Legal basis: Performance of a contract. Necessary for our legitimate interests (purchasing products or booking services, promoting our products and services, developing them, and growing our business)

In each data collection form, fields marked with an asterisk are required. Otherwise, the User will not be able to access the services offered on our websites.

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PERSONAL DATA COLLECTED THROUGH THE WEBSITE WWW.RECRUTEMENT-SIBUET.COM

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Purpose: To allow the User to submit an unsolicited application for a position at Maisons & Hôtels Sibuet. To allow Maisons & Hôtels Sibuet to contact the User if the unsolicited application is successful.

• Data collected: resume, cover letter, title, last name, first name, email address, cell phone number

• Legal basis: Necessary for our legitimate interests (contacting a person whose profile matches a position within the company)

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

• Data collected: resume, cover letter, title, last name, first name, email address, cell phone number

• Legal basis: Necessary for our legitimate interests (contacting a person whose profile matches a position within the company)

Fields marked with an asterisk are required. Otherwise, the User will not be able to submit applications on the website www.recrutement-sibuet.com.

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

The only recipients of Users' personal data are:

- the relevant departments and employees at Maisons & Hôtels Sibuet (specifically IT, sales/marketing, and operations);

- the companies that assist Maisons & Hôtels Sibuet in managing the properties, specifically the services and employees of the company that operates the properties. These companies are:

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

• Opwan, 150 Rue Pierre et Marie Curie, 34430 Saint Jean de Védas, France, www.opwan.com

- Subcontractors for our hotels, such as:

• Ski Schools

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

• Partner Restaurants

• Shuttle and partner taxi

- • …

These organizations receive only the personal information strictly necessary to make reservations and, if necessary, to contact guests.

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Article 5. What rights do Users have regarding the personal data collected?

The User has the rights set forth in Chapter III of the GDPR, including:

- The right to access your personal data collected on the Website and through the App,

- Right to correction,

- Right to erasure ("right to be forgotten"), unless there are legal grounds requiring us to retain the data,

- Right to restriction of processing, that is, the right to ask us, in certain cases, to suspend the processing of your personal data,

- Right to data portability, which is the right to request a copy of your personal data in a commonly used format (such as a .csv file),

- Right to object to the processing of personal data,

- Rights related to individual decision-making and profiling, specifically the right to request transparency from us regarding any profiling or automated decision-making we carry out,

All of these rights may be exercised:

- For all Maisons & Hôtels Sibuet websites that request personal information (registration forms, contact requests, booking confirmations, etc.), please send an email to privacy@mhsibuet.com.

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

Please note that you may:

- access and edit your contact information and login credentials on the following websites:

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

- http://boutique.domainedemarie.com

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

through the "My Profile" and "My Personal Information" sections;

You also have the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the data protection supervisory authority in France (www.cnil.fr). However, Maisons & Hôtels Sibuet would appreciate the opportunity to address your concerns before you contact the CNIL; we therefore encourage you to contact us first.

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Article 6. How long is personal data retained?

- Stay and Purchase History: The personal data of customers who have not made a reservation, stayed at, or made a purchase at one of our properties is deleted after 3 years. Purchase data and stay history are anonymized and used exclusively for statistical purposes.

- Banking information: Credit card numbers are automatically deleted the day after the guest's departure.

- Information about other guests: The personal data of guests who have not made a reservation, stayed at, or made a purchase at one of our properties is deleted after 3 years.

- Billing Information: Invoices are retained for 5 years.

- Responses to satisfaction surveys: These are retained in a personally identifiable form for 3 years and then used in an anonymous form for statistical purposes.

- Recruitment information: The resumes of unsuccessful candidates are retained for 3 years.

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Article 7. How Is Personal Information Protected?

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

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

However, these measures cannot eliminate all risks of loss, unauthorized access, misuse, or alteration of the personal information collected. Where required by law, Maisons & Hôtels Sibuet will notify the User of any loss, unauthorized access, misuse, or alteration of their personal data so that they may take appropriate measures to exercise their rights. Maisons & Hôtels Sibuet will notify the User electronically, by mail, or by telephone, if permitted by law.

Users are asked not to send payment information or sensitive data via email or in sections not intended for that purpose (for example, sending a credit card number via email).

You can choose which personal data you would like to provide to us.

However, your decision not to provide certain information may affect your experience with our services. For example, we cannot process anonymous reservations, and if we are not authorized to share your personal information with the hotels in our group, we may not be able to provide you with certain reservation or other services.

Similarly, if you do not authorize us to share your personal information with third parties, such as our hotels’ subcontractors (ski schools, car rental companies, etc.), we may not be able to offer you the full range of available services, or there may be delays in providing them. We will do our best to respond to your request as quickly as possible.

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II. COOKIES

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Article 8. What is a cookie?

According to the French Data Protection Authority (CNIL), a cookie is a piece of information stored on the user's device by the server of the website or app being visited.

A cookie contains various types of data:

- the name of the server that uploaded it,

- an identifier in the form of a unique number,

- an expiration date, if applicable.

This information is sometimes stored on the device in a simple text file that a server accesses to read and record information.

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Article 9. What tracking systems does Maisons & Hôtels Sibuet use, and for what purposes?

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

Maisons & Hôtels Sibuet's websites, online services, interactive applications, emails, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons.

These technologies help us better understand user behavior, show us which parts of our websites have been visited, and facilitate and measure the effectiveness of advertising and web searches.

We treat information collected through 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 such identifiers as personal information.

Similarly, 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 store personal information when you use our website, online services, and applications.

Our goal in these cases is to make your experience more practical and personalized. For example, knowing your country and language helps us provide you with 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 for its marketing and advertising purposes.

These pixel tags allow us to send targeted advertisements in a format that customers can read. We can use the information collected to reduce or eliminate the number of messages sent to customers.

The User is informed that he or she has the right to access his or her personal data related to cookies at any time, as well as the right to object, which allows him or her to choose at any time whether or not to accept cookies.

However, if the User does not accept cookies, the Services (and in particular browsing the Sites) may not function properly.

With regard to "Facebook" cookies, Maisons & Hôtels Sibuet obtains the User's prior consent.

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Article 10. How do I enable or disable cookies?

Users can manage, disable, and enable cookies at any time by changing their browser settings. For example:

- On an Apple smartphone or tablet: Go to Settings > select the browser in question > Accept Cookies > Never > or From websites you visit > or Always.

- On an Android smartphone: After opening the browser, tap the menu button (at the bottom left of the device) / More / Settings / Choose whether to accept cookies.

- on your computer:

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

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

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

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

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

For more information on managing and disabling cookies, the User can consult the help section of their browser.

If you encounter any difficulties exercising your right of access or objection regarding cookies, you may contact Maisons et Hôtels Sibuet at: privacy@mhsibuet.com

The maximum duration of a cookie is thirteen months.

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III. CHANGES TO THE PRIVACY POLICY

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

This document was last updated on February 12, 2019.

In the event of a significant change to this policy, we will post a notice on the Sites indicating that our privacy policy has been updated.

If we make significant changes to the way we use your personal data, we will notify you via email at the address associated with your account (if applicable) or through a notice on the home page of our Sites, giving you the option to opt out of this new use.

Any changes to this privacy policy will take effect upon their publication on the Sites.

Your continued use of our Sites after these changes take effect constitutes your acceptance of this privacy policy as amended.