VACANCES ANDRE TRIGANO
Personal data protection charter for clients and related parties

Article 1 - Purpose

The company VACANCES ANDRE TRIGANO, Registered office: 15 rue du Faubourg Montmartre – 75009 Paris (hereafter referred to as the “Company”), proposes the rental of Accommodation and Camping Pitches located in France and abroad (hereafter referred to as the “Campsites”) via its website (hereafter referred to as the “Website”, its catalogue (hereafter referred to as the “Catalogue”) and by telephone.

During the course of its business, the Company collects personal data from the persons concerned, who are prospects or guests (clients of the Company, clients of tour operators, beneficiaries of works council activities and those accompanying them) who participate or envisage participating in stays in accommodation or on pitches rented by the Company.

For the guests, this data is required in order to process the reservation, for the payment of the rental price, to welcome them at the campsite (with the requirement for each guest to produce a currently valid identity document), for the payment of the deposit, for the payment on site of the tourist tax and to pay for any possible services proposed by the campsite, to manage their stay and more generally to manage the Company’s business relationship and to perform statistical analyses.

Any possible refusal by a guest to supply his personal data or any of this data, or the failure to produce the above-mentioned identity document, may prevent the Company from processing the reservation request and/or from admitting the guest to the campsite.

This personal data is intended only for the Company’s internal departments handling the processing of this data and may be communicated to its partners and subcontractors and to partners duly authorised by the Company, such as the Website host and IT maintenance providers, the Etapes André Trigano reservations centre, the service provider for online payments, the service providers for marketing services or any legal authority requesting this.

To ensure compliance with (EU) Regulation 2016/679 of 27 April 2016 referred to as the General Data Protection Regulation, hereafter referred to as the “Regulation“, the Company has introduced the various provisions of this Charter for the protection of the personal data of the persons concerned.

As these provisions may change over time, please refer to the most recent version available on the Website.

Article 2 – The collection and processing of personal data

The personal data of the persons concerned is the data collected by the Company, which chiefly includes identification data, the data shown on the reservation form, data supplied when creating a personal account on the Site and data necessary to the Campsite's operation and security.

This data is supplied directly to the Company by the persons concerned, in one or several of the following ways:

• By surfing the Website

• When the Client completes a Reservation Form on the Site, which is binding upon the Company the moment that this form or any document substituting it has been expressly accepted in writing by the Site, (referred to after acceptance as the “Reservation Form”); and, where applicable, when an online transaction is performed;

• By completing the printed Reservation Request form and sending the completed form to the Company by post or email;

• By calling the Company’s reservations centre by telephone;

• By calling the Campsites by telephone;

• By participating in competitions

• At the campsite reception

• On stands during shows and exhibitions

The Reservation Request form on the Website or a printed version of this form completed by the Client will be considered binding upon the Company the moment that this form or any document substituting it has been expressly accepted in writing by the Company and, where applicable, when an online transaction is performed.
Some personal data may also be supplied to the Company by a third party of whom the persons concerned are clients or beneficiaries.
By supplying this personal data to us, the persons concerned or the third parties agree that this data is accurate, truthful, up-to-date and complete. Under no circumstances may the Company be considered liable for any errors, omissions or lack of clarityconcerning the information supplied.

This personal information is processed exclusively by the Company in one or several of the processing cases mentioned below, authorised by the persons concerned:

• The processing is necessary to the performance of the contract or pre-contractual measures with the Company or to ensure compliance with a legal obligation to which the Company is subject. This is the case when renting accommodation or pitches for participants in a stay in outdoor accommodation. This concerns the Client’s identification data for sending the contract and implementing it, followed by the customer satisfaction questionnaire after the day, and, when necessary, the Client’s bankcard information.

• The processing is necessary to protect the vital interests of the person concerned. This is the case with regard to the security of the persons concerned during their stay in the event of any incidents affecting the site(weather alerts, etc). This concerns the guest’s mobile phone numberand the registration numberof the guest’s vehicle.

• The processing is performed in the Company’s legitimate interests. This is the case when sending commercial information to the clients regarding the Company’s offers. The data concerned includes in particular the client’s postal and email addresses.

For other forms of processing personal data, such as some cookies, the Company will offer the persons concerned the opportunity to grant their consent with the possibility to withdraw this consent subsequently if they wish.

What are cookies?
A cookie is a piece of data stored on a computer, a tablet or a mobile when you browse the Internet. Cookies allow websites to recognise your browser. They are mainly used to store your choices and preferences. They do not cause any type of damage to your device. For example, they can be used to customise the content you view.

Which types of cookies does Vacances André Trigano use?
We use three types of cookies: essential cookies (required for the website to work properly), functional cookies (which enable us to analyze how the site is used and improve its performance), and marketing cookies (which are used to tailor the advertising you receive to your interests). These cookies are activated by default when you click the "I accept" button or when you browse Vacances André Trigano.
NB: if you block certain advertising cookies, this will not remove online advertising. It simply means that the advertising displayed will not be based on your preferences or your user activity anymore and will therefore not be as relevant to you as before.

How can I manage my cookies?
You may enable or disable the installation of cookies on your terminal through the settings features of your Internet browser. The steps to be taken vary from one browser to another. Detailed instructions can often be found in the Help menu of your browser or you can click on the appropriate link below:

For Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
For Safari™: http://support.apple.com
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™: http://help.opera.com/Windows/10.20/fr/cookies.html

Article 3 – Protection of personal data

For the various processing operations concerning personal data covered by this Charter, the Company will:

• limit access to this data to only its staff with responsibility for processing it and those of its partners: the parent company, sister companies and subcontractors, all based in a member state of the European Union, with this data always being hosted in a member state of the European Union;

• protect this data by all appropriate organisational and technical measuresfrom unauthorised access and from accidental or criminal destruction or alteration;

• destroy this data (or anonymise it for statistical purposes) at the latest at the end of the calendar year after 3 (three) years have elapsed with no interaction between the Company and the persons concerned, unless a special agreement is obtained by any means for a longer period. The payment card data concerning the remote transaction concluded with regard to the Contract is stored strictly for the time required for the performance of the transaction. It is hereby stipulated that in compliance with the provisions of the monetary and financial code, the payment card number and validity date may be stored for a period of up to 15 months, to ensure proof, and to manage any possible complaints or claims from payment card holders. Furthermore, all data making it possible to establish proof of a right or contract or stored to ensure compliance with legal or statutory obligations maybe the subject of an archiving policy and be stored for this purpose pursuant to the applicable legal requirements.

Article 4 – The exercise of these rights by the persons concerned

The measures detailed below are taken by the Company to enable the persons concerned by this Charter to exercise their rights concerning their personal data in compliance with the Regulation (right of access, right of rectification, right of deletion, right to limit processing, right to portability, right of opposition).
To submit a request concerning any of these rights, the person concerned is invited to contact the Company, which is the data controller for the processing activities covered by this Charter:

• Either by post, by writing to:

Vacances André Trigano

Droits sur les données personnelles

15 rue du Faubourg Montmartre

75009 Paris

• Or by email, by writing to the following address: droits_sur_les_donnees_personnelles@vacances-andretrigano.com

• Stating his first name, last name, postal address, and possibly his fixed or mobile telephone number, and if possible the Email address at which he may possibly be contacted, among other things in order to clarify his request;

• Specifying the right or rights of which the person concerned is requesting application;

• Attaching a double-sided copy of his national identity card or a copy of his passport.

The Company or one of its service providers operating in its name will acknowledge receipt of the request, will reply to it as soon as possible and in all cases within a period of one month following receipt of the request, unless special circumstances apply as provided for in the Regulation, when this deadline may be extended to two months.

Furthermore, any person concerned may submit a complaint to the CNIL, the French data protection authority, following the steps mentioned at the following address:https://www.cnil.fr/fr/plaintes.

Last update on July, 3rd 2018.

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