GDPR
Protection Charter / Privacy Policy
Personal Data Protection Charter
Privacy Policy
Last Updated: 01 - 04 - 2022
1. Preamble
OTOCTONE attaches great importance to the protection and respect of your privacy and your personal data.
OTOCTONE commits to implementing adequate measures for the protection, confidentiality, and security of Personal Data in accordance with the regulations in force in France and in the European Union, particularly the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 and the national legal rules adopted for its application.
The purpose of this "Privacy Policy" is to inform all concerned natural persons about how OTOCTONE collects, uses, and discloses Personal Data and about the means available to You to exercise your rights over this information.
Consequently, OTOCTONE invites you to read this Policy carefully to understand the processing relating to Personal Data.
In any event, we commit to respecting the following two essential principles:
1. The individual remains in control of their personal data;
2. The data is processed in a transparent, confidential, and secure manner.
2. Identity of the Data Controller
The company MODENATURE, a simplified joint-stock company with a single associate, registered with the LYON Trade and Companies Register (RCS) under SIREN number 753 782 515, with its registered office located at 21 PLACE BELLECOUR BP 2255 69214 LYON CEDEX 02, and manager of the commercial name OTOCTONE, will have the status of Data Controller for the processing operations related to the services provided via the website "otoctone.com". The processing operations concerned are:
1. Management of cookies
2. Management of information requests via the contact form
3. Management of reservation requests
4. Management of newsletters
3. Dedicated Data Protection Contact
We have a dedicated staff member in charge of personal data protection to respond to all your requests, including the exercise of rights, relating to the processing of your personal data.
You can reach them:
• Either by email at the following address: dpo@ooverture.fr
• Or by mail: MODENATURE (OTOCTONE), ATTN RGPD Contact Person (Référent-RGPD), 21 PLACE BELLECOUR, BP 2255 69214 LYON CEDEX 02
4. Data Collection & Origin
Via the Website, OTOCTONE collects and processes personal data concerning you. We consider this data to originate directly from you.
In all cases, you are informed of the purposes for which your data is collected by us via the various online data collection forms or through our Cookie Policy.
Your personal data collected by OTOCTONE is processed in accordance with the purposes set out during collection, in compliance with the GDPR and the guidelines of the CNIL.
5. Purposes and Legal Basis for Processing
Below you will find details of the information processing activities that concern you, particularly when you request information from our organization or when you submit your application for a job published in the dedicated section of the website.
5.1. Details of Cookie Processing
We use tracking tools developed by third parties, such as Google and Facebook, to improve the experience on our site, particularly when we implement Google Maps location, Facebook buttons, or videos hosted via the VIMEO platform on the site. In this context, Google and Facebook are likely to collect data about you via cookies.
Furthermore, by default, our data processing for site audience measurement is limited to producing anonymous statistical data essential for the proper functioning of the site. To learn more, please refer to our Cookie Policy.
5.1.1. Legal Basis
Data processing via cookies, excluding analytics, is based on your consent. Regarding analytics cookies, our legitimate interest in ensuring the proper functioning of the website constitutes the legal basis for this processing.
5.2. Details of Processing for Managing Requests Received via the Contact Form
When you submit your personal data to us via the contact form, it will be processed to achieve the following objectives:
* Receiving your requests, excluding reservation requests;
* Connecting you with the relevant department, and contacting you by phone if necessary;
* Responding to requests received electronically;
* Establishing statistics.
5.2.1. Legal Basis
This processing is necessary to provide you with appropriate answers to your request, and therefore legitimate interest remains the legal basis for this processing.
5.3. Details of Processing for Managing Reservation Requests
When you submit your personal data to us as part of this activity, it will be processed to achieve the following objectives:
* Recording and processing requests in order to provide a response
* Confirming/refusing reservations
* If accepted, organizing your arrival
5.3.1. Legal Basis
This processing is necessary for the performance of pre-contractual and contractual measures.
5.4. Details of Processing for Managing Newsletter Subscriptions
When you provide us with your email address, it will be processed to achieve the objective of including you in our mailing list for advertising and newsletters related to our establishment.
5.4.1. Legal Basis
The processing for prospecting is based on the consent of the data subjects.
In compliance with the principles of data protection by design and data protection by default, OTOCTONE strives to ensure that the necessary consents are collected when you subscribe to the Newsletter and when you use our website, as well as when we offer you any other accessory service extending beyond your expectations or outside legal obligations or the performance of the contract. No profiling operations are carried out, neither via the Website functionalities nor via the processing of files by the agencies and their agents.
6. Processed Data
The mandatory or optional nature of the personal data collected and the possible consequences of a failure to respond are indicated at the time of their collection on the associated forms.
You can consult the details of the personal data that we are likely to hold about you below.
NB: The details of the information provided below are not intended to be exhaustive and primarily aim to inform you about the categories of data that OTOCTONE may process.
6.1. For Cookie Management:
* Electronic information (e.g., IP addresses, MAC addresses, history of pages visited, etc.)
6.2. For Managing Requests Received via the Contact Form:
* Data related to your identity: Birth name, usual or married name, First name
* Data related to your professional activity: Email address
* Information submitted in the request
6.3. For Managing Online Reservations:
* Data related to your identity: First name, Last name, Email, as mandatory information, and Phone number - optional
* Information related to the request: Arrival and departure dates, Personalized message from you
6.4. For Managing Newsletter Subscriptions:
* Email address
* Subscription date
* Timestamped proof of consent
* Date of withdrawal of consent
7. Recipients of Your Data
Within the limits of their respective responsibilities and for the purposes outlined in Section 6, the main individuals who will likely have access to your data are, depending on the purposes pursued, the authorized personnel of our internal departments, notably our human resources department and commercial department.
Certain categories of sub-processors have access to the collected data:
* The website development service provider.
* The website host.
For any request for further information on our sub-processors, you can send a request for additional information to our Data Protection Officer by email at admin@otoctone.com.
The other organizations that may have access to your data are:
* Where applicable, the relevant courts, mediators, chartered accountants, statutory auditors, lawyers, bailiffs, and debt collection agencies.
* Third parties likely to deposit cookies on your devices (computers, tablets, mobile phones, etc.) when you consent (For more details, consult our Cookie Policy);
Your personal data is neither communicated, exchanged, sold, nor rented without your prior express consent in accordance with the applicable legal and regulatory provisions.
8. Transfer of Data Outside the European Union
In certain cases, your personal information will be backed up on servers located outside the European Economic Area (EEA).
This is notably the case when we transfer information to some of our partners, particularly via cookies to Facebook and Google, which may store data on servers in the United States. We have ensured that standard contractual clauses approved by the European Union Commission are in place to contractually formalize the security obligations and measures provided for by the GDPR, as stipulated in its Article 46.
You can request access to the documents ensuring the presence of appropriate safeguards by sending a request to our Data Protection Officer by email at dpo@ooverture.fr.
9. Data Retention Period
We retain your data only for the time necessary for the purposes pursued, as described in Article 4 of this Policy, and if necessary, extended by statutory limitation periods.
9.1. For Cookie Management
When you visit our website https://www.otoctone.com, the cookie managing your consent is recorded for a maximum duration of 13 months. For more information, please consult Article 10 and our Cookie Policy.
9.2. For Managing Requests Received via the Contact Form
Data used in the context of managing property valuation requests is retained for up to 2 years from the last contact.
9.3. For Managing Reservation Requests
Data used in the context of managing online reservations is retained for up to 5 years from the end of your stay or the refusal of your reservation.
9.4. Management of Newsletter Subscriptions
Data used in the context of managing commercial prospecting is retained until you expressly object to receiving our communications.
10. Data Subjects' Rights
In accordance with the French Data Protection Act (Loi Informatique et Libertés) and the GDPR, you have the following rights:
10.1. Right to Information on the Processing of Personal Data
OTOCTONE commits to making its best efforts to provide concise, transparent, and accessible information on the conditions for processing your Personal Data.
10.2. Right of Access to Personal Data
You can access your Personal Data processed by OTOCTONE and have the right to receive an electronic copy (for any additional copy, OTOCTONE shall be entitled to request payment of fees based on the administrative costs incurred).
10.3. Right to Erasure ("Right to be Forgotten") and Rectification of Personal Data
You have the right to request the erasure and/or rectification of your Personal Data when it is inaccurate or obsolete.
It is specified that OTOCTONE may retain certain Personal Data when required by law or in the event of a legitimate reason.
If your personal data is erased following your request and before the expiry of the valid retention period, this may prevent us from providing you with the services you expect from us.
10.4. Right to Object
You can object at any time, on legitimate grounds, to the reuse of your Personal Data for processing purposes different from those notified, except when OTOCTONE is executing one of its legal obligations.
10.5. Right to Restriction of Processing of Personal Data
You have the right to request that the processing carried out on your Personal Data be limited to what is necessary.
This right is applicable only:
• if you contest the accuracy of your Personal Data;
• if you can establish that the processing of your Personal Data is unlawful and request a limitation of their use rather than erasure;
• if OTOCTONE no longer needs your Personal Data but they are still necessary for you to establish, exercise, or defend legal claims;
• if you object to processing based on a legitimate interest that we pursue as a Data Controller, having confirmed that the legitimate interests pursued by us override yours.
10.6. Right to Lodge a Complaint with a Supervisory Authority
If you consider that the efforts made by OTOCTONE to preserve the confidentiality of Personal Data do not guarantee the respect of your rights, you have the possibility to lodge a complaint with the competent supervisory authority (CNIL or any other authority mentioned on the list available from the European Commission).
You can exercise all your aforementioned rights by email by contacting our Data Protection Officer at their email address dpo@ooverture.fr.
11. Connection Data and Cookies
OTOCTONE has implemented a cookie manager via the Cookie Policy to inform you more specifically about their use.
If the browser allows it, you can also disable these cookies at any time by following the procedure indicated by the browser. However, OTOCTONE informs you that such a deactivation may slow down and/or disrupt access to certain sections of the website.
12. Minors
The OTOCTONE Website is not intended for minors. OTOCTONE does not knowingly collect personal data from minors under the age of 15.
13. Security
OTOCTONE complies with the GDPR and the French Data Protection Act regarding the security and confidentiality of your data.
We implement all necessary technical and organizational measures to ensure the security of our personal data processing operations and the confidentiality of the data we collect.
As such, we take all useful precautions, considering the nature of the data and the risks presented by the processing, to preserve their security and, in particular, to prevent the data from being distorted, damaged, or accessed by unauthorized third parties (physical protection of premises, secured HTTPS protocol, logging and traceability of connections to internally deployed software).
14. Modification of the Policy
OTOCTONE reserves the right to make modifications to this Policy at any time in order to comply with legislative and regulatory changes and/or to improve the Policy.
In case of modification, a new version will be updated and posted online with the "Last Updated" date.
15. Applicable Law
This Policy is subject to French law, including the provisions applicable to international private law rules.
Ceci conclut la traduction de l'intégralité de votre Charte de protection des données à caractère personnel.