SARL OCTOPUS, in its capacity as data controller, attaches great importance to the protection and respect of your privacy. The purpose of this policy is to inform you of our practices regarding the collection, use, and sharing of information that you may provide to us through our website, which is accessible from https://www.hotel19-21.com. 
By accessing our website and using our services, you acknowledge that you have read and understand this privacy policy and the information collection and processing practices described herein.
To this end, the company SARL OCTOPUS and all of its employees undertake to: 

  • Only collect and use data for a specific and legitimate purpose determined beforehand;
  • To collect data only for one of the following purposes: 
    • Data necessary for the execution of contracts and services requested
    • Your express and specific consent
    • Legitimate interest of the company duly justified
  • Only collect and use data that is strictly necessary for processing 
  • To keep data only for a limited period of time consistent with the services provided;
  • Only transfer data when necessary, and in compliance with legal security rules;
  • To ensure that your rights are respected and that the conditions for exercising them are respected.
  1. THE INFORMATION WE COLLECT 

1.1 Information that you transmit to us directly 

By using our services, you are led to transmit information to us, some of which are of a nature to identify you “personal data”. This is particularly the case when you fill in our contact forms.
The data necessary for the use of the service that we may collect are: 

  • Name 
  • First name 
  • Date of birth 
  • E-mail address 
  • Postal address 
  • Phone number
  • Password with non-reversible encryption
  • A copy of all exchanges between you and SARL OCTOPUS
  • The details of your visits to our website
    For each of them, you are informed of the data that are necessary and those that are optional by asterisks on the input forms. 

1.2 The information we collect automatically 

In the event that you connect to our services, using the social network features made available to you (such as Facebook, Twitter, LinkedIn), SARL OCTOPUS will have access to some of the data (including name, surname, photograph, e-mail address and number of friends) of your account on the said social network, in accordance with the general terms of use of the social network concerned. If you are connected to our website and a social network, certain parts of the website may be personalized for you when you visit our website through the information you have chosen to make public. 
If you wish to disable personalization, you must first log in to your social network and follow the procedures set forth on that third party site. 
During each of your visits, we may collect, in accordance with applicable law and with your consent, if any, information about the devices on which you use our services or the networks from which you access our services, such as your IP addresses, connection data, type and versions of Internet browsers used, types and versions of browser plug-ins, operating systems and platforms, and data about your browsing experience on our site (including pages visited, content, search terms used, and length of time spent on certain pages). This information is collected through the use of cookies. This information may also be used to improve the functionality and performance of the application used.

1.3 How is your personal data collected? 

The data we collect and process may be provided by you when you fill out forms on the company’s sites and applications or when you specifically give your consent.
Technical information is collected through your browser on the operating system and browser used, or through cookies. 

  1. HOW LONG WE KEEP YOUR DATA 

We retain your personal data only for as long as is necessary for the purposes for which we collected it, including as necessary to meet any legal or accounting requirements and any legal accountability obligations. 
In determining the appropriate retention period for personal data, we take into account the nature and sensitivity of the data, the risk of harm that may arise from its unauthorized use or disclosure, the purposes for which we process it, and the possibility of achieving those purposes by other means, as well as applicable legal requirements. 
The time periods are as follows: 

  • 5 years from the closure of the customer relationship 
  • 3 years for prospects from the date of the last visit to the website. 
  • 13 months for cookies from the date of their deposit on your computer or terminal
  • Geolocation data: only for the duration of the session or navigation

  • 3.  USE OF THE DATA

SARL OCTOPUS collects and uses your data only for specific purposes and limited to what is necessary for you, namely 

3.1 To manage your registrations

SARL OCTOPUS may request certain information, such as your e-mail address, in order to send you information and news. You always have the option to unsubscribe from these news feeds by following the link in the email. 
This processing is carried out on the basis of your consent.

3.2 Communicating with you 
SARL OCTOPUS may need to collect and process certain information necessary for the execution of the commercial relationship. For example, to perform after-sales services. The data collected allows us to communicate with you. 
This processing is necessary for the execution of our contractual obligations, or is carried out with your consent and / or necessary for the establishment, exercise or defense of a right in justice. 
This data may also allow us to inform you of changes to our services, improve and optimize our services.
3.3 Communicating with third parties 
SARL OCTOPUS may use your information if we believe that it is necessary to defend ourselves in the event of legal action, when there is an obligation or a request for communication with a legal basis, in order to act against any illegal or presumed illegal activity, in order to protect and defend a right or to secure our information system.
3.4 Processing your order 
SARL OCTOPUS cannot execute contracts concluded with it or its commercial partners without obtaining certain information from you. 
This processing is necessary for the performance of the respective contractual obligations. 
When you make a transaction through our website, SARL OCTOPUS does not store your payment data but only the data related to the transaction (date, amount, place of delivery…). 

  1. RECIPIENTS OF THE INFORMATION COLLECTED 

In the context of the use of our services, we may share information about you, including personal data, with the subcontractors we use for technical services, payment services, or providers of analytical solutions and software solutions and business applications. 
We only share your data with the above-mentioned third parties in the following cases:

  • When we use a service provider in connection with the performance of any contract between you and us or in order to provide or improve our services;
  • When we use technical subcontractors chosen by the Company, on behalf of or on the instructions of SARL OCTOPUS, in particular to host and store user data on their servers and ensure the integrity and security of our data. 
  • When we use analytical solution providers to improve and optimize our website;
  • When we use software solutions and business applications to better manage our business;
  • When we are legally required to do so, in the event of an emergency involving public health or the physical integrity of a person, in the context of investigations and inquiries, or in order to guarantee the rights, property and safety of the Company, its members and more generally any third party;
    In the event of a sale of the Company or a portion of its assets, we reserve the right to share your personal data with the purchaser of such business or assets.
  1. WHERE IS YOUR DATA TRANSFERRED TO?
    5.1 Where does OCTOPUS SARL transfer data? 
    The Company does not want your data to be stored outside the European Union. However, some service providers, in particular software solution providers, may be located outside the European Union. 
    Prior to transfers outside the European Union, OCTOPUS SARL undertakes to implement the procedures required to obtain the necessary guarantees for the security of such transfers, in particular to countries that do not offer an adequate level of protection, by means of the European Union’s standard clauses. 
    5.2 Where is the data collected via our website hosted? 
    SARL OCTOPUS uses an IT service provider to host the data related to the management of the website and the applications
    These data are hosted via collective or dedicated servers at OVH. This subcontractor allows the IT service provider to choose the physical location of data storage. The IT Service Provider has made the choice that the data be hosted on servers located on French territory. 
    You will find all the information relating to the protection of personal data on their site: https://www.ovh.com/fr/protection-donnees-personnelles/. 
  2. USERS’ RIGHTS 
    In accordance with the provisions of the EU Regulation 2016/679 known as the General Data Protection Regulation, you have the following rights over your data:
  • Right of access: you have the right to request us to know what data we have about you; you have the right to request the deletion of erroneous or obsolete data;
  • Right of correction and deletion: you have the possibility to correct your data and to ask for their deletion; 
  • Right to object: you have the possibility to object to the transmission of your data.
  • Right to data portability: you have the right to ask us for a digital copy of your data or to transfer them directly to another service provider. 
  • Right to complain to the competent authorities: you have the right to complain to the competent authorities if you consider that we have not respected your rights;
  • You have the right to define directives concerning the fate of your personal data after your death;
    The exercise of these rights is however limited to a reasonable processing of your requests, for which we reserve the right to refuse any excessive requests or for reasons of legitimate interests (litigation or legal obligations or data necessary for the contractual relationship). 
    In order to exercise your rights, you can send us an e-mail via our contact form or by sending us a letter to the following postal address: 19 avenue Francis Vals 11370 Leucate.
    You may be asked to provide proof of identity. 
  1. MINORS
    The modified article 40 of the French law “Informatique et Liberté” provides a specific right to be forgotten for minors. 
    An Internet user under 18 years of age at the time of publication or creation of an online account may directly request SARL OCTOPUS to delete data concerning him/her, as soon as possible
    This deletion is however limited when the published information is necessary for information purposes, for reasons of public interest or to comply with a legal obligation.
  2. COOKIES 
    8.1 What is a cookie? 
    A cookie is a system capable of storing and/or collecting information relating to the browsing of the user’s terminal (computer, tablet, etc.) subject to the user’s agreement and unless the user objects. 
    8.2 Purposes of the cookies used on the web
     These cookies allow SARL OCTOPUS to memorize information related to the registration or access to our services, to implement security measures or to adapt the presentation of the services to the display preferences of the terminal (language, operating system…). They also allow you to access your personal account. 
    Cookies make it possible to establish statistics and volumes of frequentation and use of the various elements making up the Services (pages and content visited, path) such as GOOGLE ANALYTICS, to carry out studies in order to improve the content offered by the Services. Cookies also allow us to personalize your relationship with our Company by offering you targeted advertising. For this purpose, we may use the services of online advertising companies
    If the User wishes to obtain more information on cookies, his rights and how to block them, he can consult the website http://www.youronlinechoices.eu/ or the CNIL website at https://www.cnil.fr/vos-droits/vos-traces/les-cookies/. The User can also modify his preferences on cookies directly from the interface provided for this purpose by clicking on this link
    8.3 User’s choice regarding cookies
    The User may at any time express and modify his/her wishes regarding cookies.
    The User can configure his browser so that cookies are saved or rejected, either temporarily or permanently.
    The fact of continuing your navigation after having been informed of the categories of cookies likely to be installed on your computer and their purposes is equivalent to your consent to the deposit of cookies on your computer.
    It is possible that the chosen settings may modify and/or restrict access to and use of the Services.
    The Site includes different categories of cookies which will only be installed if you continue your navigation after having read the banner displayed on the first page of the site and informing you of their existence and purpose or once you have set your preferences in terms of cookies by using the link provided for this purpose on the cookie banner.
    8.3.1 Technical cookies
    If you refuse to accept cookies on your computer, you will no longer be able to benefit from a certain number of functionalities and your navigation on the Website may be modified or simply impossible. 
    SARL OCTOPUS declines all responsibility concerning the consequences of the degraded functioning of the Services resulting from the impossibility for SARL OCTOPUS to record or consult the tracers necessary for the functioning of the Site which are refused or deleted by the User.
    8.3.2 Statistics and audience analysis cookies
    These cookies enable us to establish statistics concerning the volume of visits to our websites and services (number of visits, unique visitors, pages viewed) and statistics concerning the use of the various elements that make them up (sections and content visited, navigation paths taken).
    These cookies also allow us to improve the interest and ergonomics of our website, our services and the various elements that make them up. They are also used to offer you content adapted to your interests. Finally, they allow us to detect any navigation difficulties.
    8.3.3 Advertising and targeted advertising cookies
    Advertising cookies allow us to:
  • to avoid the repetition of the display of the same advertisement, even when the advertisement is not linked to your preferences,
  • to determine in real time which advertisement to display according to your centers of interest with regard to your recent navigation on the Sites and the Application and on other sites,
  • to help improve your browsing experience and make it more interesting, as well as to improve the relevance of messages that may be sent to you if you have previously accepted the possibility,
    In addition, SARL OCTOPUS may, subject to your choice, associate browsing information processed by cookies with your Personal Information in order to send you, for example, electronic marketing material.
    You may exercise a choice of cookie preferences in accordance with Article 8.4.
    8.3.4 Third party cookies
    The Site may use social network plug-ins such as YouTube, Facebook, Twitter, LinkedIn… For example, if the Customer is connected to YouTube while browsing the Site, and he/she activates a YouTube video used on the Site, YouTube will be able to directly link his/her visit to his/her YouTube profile even if the Customer did not use the share button.
    If the Customer interacts with the plug-ins, for example by clicking on the Facebook “Like” button or by leaving a Facebook comment, the corresponding information will be transmitted and stored on a Facebook server.
  • SARL OCTOPUS does not manage the data collected by the Social Networks via the buttons or widgets. You should read the privacy policy published by the Social Networks concerned, in order to know how they process and use the data collected by them, as well as the settings they have to protect your privacy.
    If you do not want the Social Network to link the information collected through our Company to your Social Network user account, you should disconnect from the Social Network before consulting the Site.
    8.4 How can you exercise your cookie management choices? 
    By continuing to browse the Site, you agree that cookies from the Publisher and third parties may be deposited on your terminal, for the purposes specified in the information banner and in this Charter.
    You can exercise your choices by using the link provided for this purpose on the cookies banner.
     9- SECURITY
    SARL OCTOPUS implements directly or ensures with its service providers that they implement all the technical means adapted in accordance with the rules of the art, to maintain the integrity, the numerical and physical safety, the confidentiality of the data and in particular to prevent that they are deformed, damaged, or that unauthorized third parties have access to them, to capture them or to use them, in particular by the means of protection such as the installation of a certificate SSL, of encoding, codes of accesses, firewall, antivirus and all other adapted technical means.

Attention: Only the French legal notice and privacy policy are valid