Personal data protection charter
Privacy Policy
Last update: 01 - 04 - 2022
1. Preamble
OTOCTONE attaches great importance to the protection of and respect for your privacy and your personal data (hereinafter referred to as "Personal Data" or "Personal Data").
OTOCTONE undertakes to implement 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, in particular the General Regulation on the Protection of Personal Data EU 2016/679 of 27 April 2016 and the rules of national law taken for its application.
The purpose of this "Privacy Policy" (hereinafter the "Policy") is to inform all natural persons concerned (hereinafter referred to as "You" or "Your") about how OTOCTONE collects, uses and discloses Personal Data and how You can exercise your rights with respect to that information.
Therefore, OTOCTONE invites you to read this Policy carefully to know and understand the processing of Personal Data.
In any event, we undertake to respect the following two (2) essential principles:
1. the individual remains in control of his or her personal data;
2. data are treated transparently, confidentially and securely.
2. Identity of the controller
MODENATURE, a simplified joint stock company with a single shareholder, registered with the RCS of LYON under the number SIREN 753 782 515, whose registered office is located at 21 Place Bellecour BP 2255 69214 LYON CEDEX 02, manager of the OTOCTONE trade name, will have the status of data controller for the processing operations relating to the services provided via the "otoctone.com" website (hereinafter individually the "Website"). The processing operations concerned are :
1. Cookie management
2. Management of information requests via the contact form
3. Management of reservation requests
4. Newsletter management
3. Dedicated data protection contact
We have a member of staff responsible for personal data protection to deal with all your enquiries, including the exercise of rights, relating to the processing of your personal data.
You can reach him at
○ Or by e-mail to the following address: dpo@ooverture.fr
○ Or by post: MODENATURE (OTOCTONE), ATTN Référent-GDPR, 21 PLACE BELLECOUR BP 2255 69214 LYON CEDEX 02
4. Data collection & origin
OTOCTONE collects and processes personal data about you mainly via the website. We consider this data to come 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 via our Cookie Policy.
Your personal data collected by OTOCTONE is processed in accordance with the purposes for which it was collected, in compliance with the GDPR and the guidelines of the CNIL.
5. Purposes and legal bases of the processing
Below you will find details of how we process information about you, for example when you request information from us or when you apply for a job advertised on the dedicated section of the website.
5.1. Details of cookie processing
We use tracking tools developed by third parties, for example from Google and Facebook, to improve the experience on our site, when we set up on the site, the location by Google maps, Facebook buttons, or videos hosted via the VIMEO platform. In this context, Google and Facebook may collect data about you via cookies. In addition, by default, our data processing for site audience measurement is limited to producing anonymous statistical data, which is essential for the proper functioning of the site. For more information, please see our Cookie Policy.
5.1.1. Legal basis
The processing of data via cookies, excluding analytics, is based on your consent. With regard to analytics cookies, our legitimate interest in ensuring the proper functioning of the website constitutes the legal basis for this processing.
5.2. Details of the processing of requests received via the contact form
When you send us your personal data via the contact form, they will be processed for the following purposes
○ Receive your requests in addition to booking requests;
○ Put you in touch with the relevant department, and if necessary, make contact by telephone;
○ Respond to requests received electronically;
○ Establish statistics.
5.2.1. Legal basis
This processing is necessary to provide you with answers adapted to your request and thus the legitimate interest shall be the legal basis for this processing.
5.3. Details of the processing of reservation requests
When you provide us with your personal data in the context of this activity, it will be processed for the purposes of :
○ Record and process requests in order to provide a response
○ Confirming/rejecting reservations
○ If accepted, arrange your arrival
5.3.1. Legal basis
This processing is necessary for the execution of pre-contractual and contractual measures.
5.4. Details of the processing of newsletter subscriptions
When you send us your e-mail address, it will be processed to fulfill the purpose of including you in our advertising mailing list and newsletters related to our establishment.
5.4.1. Legal basis
The processing of canvassing is based on the consent of the persons concerned.
In keeping with the principles of data protection by design and data protection by default, OTOCTONE endeavours to ensure that the necessary consents are obtained when you sign up for the Newsletter and when you use our website, as well as when we offer you any other ancillary services as an extension of your expectations or outside of legal obligations or contractual performance. No profiling is carried out, either through the functionality of the Website or through the processing of files by the agencies and its agents.
6. Data processed
The compulsory or optional nature of the personal data collected and the possible consequences of a failure to reply are indicated at the time of their collection on the associated forms.
You can see details of the personal data we may have about you below.
NB: The information provided below is not intended to be exhaustive and is primarily intended 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 the management of requests received via the contact form :
○ Data relating to your identity: birth name, surname or married name, first name,
○ Data relating to your professional activity: e-mail address
○ Information provided by the application
6.3. For online booking management
○ Identity data: First name, Last name, Email, as mandatory information and Phone number - optional
○ Application information - Arrival and departure dates, Personalised message from you
6.4. For the Management of the subscription to the newsletters
○ Email address
○ Date of registration
○ Time-stamped proof of consent
○ Date of withdrawal of consent
7. Recipients of your data
Within the limits of their respective responsibilities and for the purposes set out in Article 6, the main people who are likely to have access to your data are, depending on the purposes, the authorised staff of our internal departments, in particular our human resources department and sales department.
Certain categories of processors have access to the data collected:
○ The website development provider.
○ The site host.
For any additional information on our subcontractors, you can send a request for additional information to our Data Protection Officer by e-mail to dpo@ooverture.fr
Other organisations that may have access to your data are
○ Where appropriate, the relevant courts, mediators, accountants, auditors, lawyers, bailiffs, debt collection agencies;
○ Third parties who may place cookies on your terminals (computers, tablets, mobile phones, etc.) when you give your consent
(For more details, see our Cookie Policy);
Your personal data will not be disclosed, exchanged, sold or rented without your prior express consent in accordance with the applicable legal and regulatory provisions.
8. Transfer of data outside the European Union
In some cases, your personal information will be stored on servers located outside the EEA.
This is particularly the case when we transfer information to some of our partners, including via cookies to Facebook and Google, which may store information on servers in the United States. We have ensured that standard contractual clauses approved by the European Union Commission are in place to contractualise the security obligations and measures set out in the GDPR, as set out in Article 46.
You may request access to documents ensuring the presence of appropriate safeguards by making a request to our Data Protection Officer by email at dpo@ooverture.fr.
9. Duration of data retention
We keep your data only for as long as is necessary for the purposes described in Article 4 of this Policy and, if necessary, extended by the legal requirements.
9.1. For cookie management
When you visit our website https://www.otoctone.com, the cookie containing your consent is stored for a maximum of 13 months. For more information, please see section 10 and our Cookie Policy.
9.2. For the management of requests received via the contact form
The data used in the management of property valuation requests is kept for up to 2 years from the last contact.
9.3. For the management of reservation requests
The data used in the management of online reservations is kept for up to 5 years from the end of your stay or from the refusal of your reservation.
9.4. Management of newsletter subscriptions
The data used for the management of commercial prospecting is kept until you expressly object to receiving our communications.
10. Rights of individuals
In accordance with the French Data Protection Act and the GDPR, you have the following rights:
10.1. Right to information on the processing of Personal Data
OTOCTONE will use its best efforts to provide concise, transparent and accessible information about the processing of your Personal Data.
10.2. Right of access to Personal Data
You may access your Personal Data processed by OTOCTONE and have the right to receive a copy in electronic form (for any additional copies, OTOCTONE shall be entitled to charge a fee 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 deletion and/or rectification of Personal Data concerning him or her if it is incorrect or obsolete.
OTOCTONE may retain certain Personal Data where required by law or for legitimate reasons. It is possible that if your Personal Data is deleted 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 may object at any time on legitimate grounds to the re-use of your Personal Data for processing other than that notified, except where OTOCTONE is fulfilling one of its legal obligations.
10.5. Right to limit the processing of Personal Data
You have the right to request that the processing of your Personal Data be limited to what is necessary. This right is applicable only :
○ if you dispute the accuracy of your Personal Data;
○ if you can establish that the processing of your Personal Data is unlawful and requires restriction of its use rather than erasure;
○ if OTOCTONE no longer needs your Personal Data but it is still necessary for the establishment, exercise or defence of legal claims;
○ if you object to processing based on a legitimate interest pursued by us as a Controller, having confirmed that the legitimate interests pursued by us prevail over yours.
10.6. Right of complaint to a supervisory authority
If you believe 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 of the above rights by contacting our Data Protection Officer at dpo@ooverture.fr.
11. Login data and cookies
OTOCTONE has set up a cookie manager via the Cookie Policy in order to inform you more specifically about the use of cookies.
If your browser permits, you can also deactivate these cookies at any time by following the procedure indicated by the browser. However, OTOCTONE informs you that such deactivation may result in a slower and/or more difficult access to certain sections of the website.
12. Minors
The OTOCTONE website is not intended for minors. OTOCTONE does not voluntarily collect personal data from minors under the age of 15.
13. Security
OTOCTONE complies with the GDPR and the French Data Protection Act in terms of security and confidentiality of your data.
We implement all necessary technical and organisational measures to ensure the security of our personal data processing and the
confidentiality of the data we collect.
In this respect, we take all the necessary precautions, with regard to the nature of the data and the risks presented by the processing, to preserve the security of the data and, in particular, to prevent the data from being deformed, damaged or accessed by unauthorised third parties (physical protection of the premises, secure https protocol, logging and traceability of connections to the software deployed in-house).
14. Change of Policy
OTOCTONE reserves the right to make changes to this Policy at any time in order to comply with legislative and regulatory developments and/or to improve this Policy.
In case of changes, a new version will be updated and put online with the date of "Last update".
15. Applicable law
This Policy is subject to French law, including the provisions applicable to the rules of private international law.