VILLA KOEGUI (whose registered office is at 7 rue de Gascogne, 64200 Biarritz France), acting as data controller, is committed to protecting and respecting your privacy. This notice (the “Privacy Notice”) is designed to tell you about our practices regarding the collection, use and disclosure of information that you may provide via this website or our mobile applications (the “Platforms“)..
This privacy notice (together with our Terms and Conditions, any other documents referred to in it and our cookie notice) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. What information do we collect from you and for how long?
We may collect and process the following data about you :
2.1. Information you give us
You may give us information, including information that can identify you (“Personal Data“), when you use our platforms, by filling in forms on the platforms (such as the sign-up form), when you enter into any of our competitions, promotions or surveys, when you correspond with us by phone, e-mail or otherwise, and when you report a problem with our platforms.
The information you give us may include :
Mandatory information required to register for the service we provide on our platforms or to access other services provided by us, including your name, email address, gender, mobile phone number and a password. All these fields are mandatory. VILLA KOEGUI will not be able to provide you with the services offered on our platforms if the required information is not provided, consequently you will not be able to register for a user account on our Platforms.
2.2. Information we collect automatically
With regard to each of your visits to our platforms we may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our platforms, products you viewed or searched for, download errors, length of visits to certain pages, page interaction and any phone number used to call our customer service number. We collect this information through the use of various technologies including cookies (for further information please refer to our cookie notice).
2.3. Data retention
2.3.1. Except regarding the categories of personal data mentioned in clauses 2.3.2 and 2.3.3 below, your personal data will be stored for the duration of your relationship with us and then put beyond use :
- 5 years after your last use of our platform, if you did not close your account
- 1 year after the closing of your account..
2.3.2. The following categories of personal data may be stored for different durations :
- Financial data (e.g. payments, reimbursements, etc.) is stored for the duration required by applicable tax and accounting laws;
2.3.3. In the event that your account is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to our platforms.
3. How do we use the information we collect from you
|1. To manage your platform user registration||We process your data because this is necessary on the terms regulating the use of the platform. In other words, for you to be able to register as a user on the platform, we need to process your personal data, since we would otherwise be unable to manage your registration.|
|2. Development, performance and making of
the purchase or services contract
|We process your data because their processing is necessary for us to make the purchase or services contract with you.|
|3. Customer Support||We consider that we have lawful interest in answering the requests or consultations raised by you through the existing different contact channels. We understand that the processing of these data is also beneficial to you to the extent that it enables us to assist you adequately and answer to the consultations raised. When you get in touch with us, in particular, for the management of incidents related to your order or the product/service acquired through the platform, the processing of your data is necessary to make the purchase contract. When your consultation is related to the exercise of your rights on which we inform you below, or to claims on our products or services, we are legally permitted to process your data for compliance with our legal obligations|
|4. For marketing purposes||We are legally permitted to process your data for marketing purposes due to the consent that you give us, for example when you accept receiving customized information through multiple channels, when accepting the legal terms and conditions to participate in a promotional action or to publish your pictures on the Platform or on our social networks' channels.|
|5. Analysis of usability and quality||We consider that we have a lawful interest in analysing the platform usability and the user's satisfaction degree, since we understand that that the processing of these data is also beneficial for your because the purpose is to improve the user experience and provide a higher quality service|
4. Who are the recipients of the Information we collect from you and for which purposes?
4.1. When you use our services, some information about you is shared during the booking process.
4.2. We may receive and send information about you, including your personal data, if you use any of the platforms we operate or from other KOEGUI entities and affiliates, for the purposes outlined in this privacy notice.
4.3. We are also working closely with third parties which may be the recipients of your personal data such as:
- our business partner who is booking partner (reservit) which may provide you booking & payment services,
4.4. We only share your Personal Data with any of these third parties in the following cases :
- 4.4.1. Where it is necessary to involve a third party service provider, for the performance of any contract we enter into with you in order to facilitate or extend our services (e.g. if we charge you any fees or collect any money from you in relation to any services on the platforms) ;
- 4.4.2. We use analytics and search engine providers to assist us in the improvement and optimisation of our Platforms ;
4.4.3. VILLA KOEGUI may also disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (i) respond to claims asserted against VILLA KOEGUI, (ii) to comply with legal proceedings, (iii) to enforce any agreement with our users such as our terms and conditions and our privacy notice, (iv) in the event of an emergency involving the danger of public health, death or physical injury to a person (v) in the framework of investigation or (vi) to protect the rights, property or personal safety of VILLA KOEGUI, its members or others;;
4.4.4. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
4.4.5. If VILLA KOEGUI or all or part of its assets are acquired by a third party, in which case personal data held by it about its members will be one of the transferred assets.
5. Targeted ads and our communications sent by e-mail and/or text messages
In accordance with applicable laws and where required with your consent, we may use the information you give us on our Platforms for electronic direct marketing purposes (e.g. (i) receiving our newsletters, invitations to our events or other communications that we think may interest you or (ii) serving you with targeted advertising on social media platforms or third parties websites)
For electronic marketing communications : You can withdraw your consent at any time by (i) unticking the relevant box in your member account, (ii) clicking on the unsubscribe link we provide in each VILLA KOEGUI communication sent to your attention or (iii) contacting us using the contact details provided in section 12 below...
For targeted ads and content :
- on social media (e.g. Facebook and Twitter): you can object at any time by configuring your settings regarding advertisement via your social media account ;
6. Is your Information being transferred? how and where?
In principle, we store the personal data that we hold about you in the European Union (“EU“). However, since for example some of our service providers are based in countries outside of the European Union (“third countries”), we also transfer some of your data to third countries. This may include third countries where the European Commission has not taken the decision that such third country ensures an adequate level of protection (for example the United States). In that case, we ensure that the transfer is performed in accordance with the applicable legislation and that appropriate safeguards have been put in place (especially standard contractual clauses as issued by the European Commission) in order to guarantee a sufficient level of protection of individuals’ private life and fundamental rights
By sending a request to firstname.lastname@example.org, we can provide you with the details regarding such appropriate safeguards (for example, the standard contractual clauses issued by the European Commission).
7. What are your rights in respect of your personal data?
7.1. You are entitled to receive a copy of your personal data that is in our possession (your right of data access).
7.2. You may request the deletion of personal data or the correction of inaccurate personal data (your right to erasure and rectification). Please note that we may keep certain information concerning you, as required by law, or when we have a legal basis to do so (e.g., our legitimate interest to keep the platform safe and secure for other users).
7.3. You have the right to object at any time (i) to the processing of your personal data for the purpose of direct marketing, or (ii) to the processing of your personal data for other purposes on grounds relating to your particular situation (your right to object to processing). Please note that in the latter case, this right only applies if the processing of your personal data is based on our legitimate interest.
7.4. You have the right to restrict the processing of your personal data (your right to restriction of processing). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether our legitimate grounds to process your personal data in that case override your interests, rights and freedoms; or (iii) your personal data has been processed by us in an unlawful way but you either oppose the erasure of the personal data or want us to keep your personal data in order to establish, exercise or defend a legal claim.
7.5. You have the right to receive and/or have us transfer to another data controller a subset of personal data, that concern you and that you provided us with, and which we process for the performance of our contract or because you previously consented to it, in a structured, commonly used and machine-readable format (your right to data portability).
7.6. To exercise your rights, please contact the Group Data Protection Officer (see under Article 13).
7.7. You also have the right to make a complaint to the relevant data protection supervisory authority or to seek a remedy through the courts if you believe that your rights have been breached.
8. Cookies & similar technologies
To find out more, please see our Cookie Notice.
9. Confidentiality of your password
Where you have chosen a password which enables you to access certain parts of our Platforms, you are responsible for keeping this password confidential.
We ask you not to share a password with anyone.
10. Links to other websites and social media
Our platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy practices and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12. Changes to our Privacy Notice
Any changes we may make to our privacy notice in the future will be posted on this page. Where appropriate, we will notify you or seek your consent. Please check back frequently to see any updates or changes to our privacy notice.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal data, please use one of the following means:
via email to email@example.com
by letter to : Villa KOEGUI – A l’attention du Délégué à la Protection des Données – 7 rue de Gascogne
Version mise à jour le 18 septembre 2018