Club Med offers a corporate website (hereinafter the “Site”) accessible at the URL address www.clubmeddevelopment.com for free browsing by internet users visiting the Site (hereinafter the “Users”) to enable them to Club Med’s development projects.
In this respect, Club Med is particularly sensitive to Users’ privacy and the protection of their personal data. Club Med thus undertakes to ensure the compliance of the processing carried out in its capacity as data controller in accordance with the regulations on personal data and in particular with Law No 78-17 of 6 January 1978 known as “Informatique et Libertés” as amended and General Data Protection Regulation 2016/679 of the European Parliament and of the Council dated 27 April 2016 known as “GDPR” (hereinafter the “Regulations”).
In the context of this policy, the expression “Personal Data” refers to any data relating to the user of the Site (the “User” or “You”) which enables the User to be identified directly or indirectly.
Article 1. Personal Data collected
Club Med collects your Personal Data, in particular when you fill in a form such as the form related to the subscription for the Corporate Newsletter or when you browse the Site.
Your Personal Data may have been provided directly to Club Med by you (for example when you complete a form available on the Site) or obtained indirectly from third parties by various technological means (in particular through cookies).
In principle, Club Med’s Personal Data processing activities do not lead to the collection of sensitive data through the Site or by other means. Where Club Med is required to collect and process sensitive data, it will do so in accordance with the Regulations and legal requirements relating to the protection of privacy.
Through the various forms on the Site, the following Personal Data may be collected and processed by Club Med:
- Identification data: email address;
- Browsing data: IP address, internet service provider, type of browser used, operating system, pages of the Site visited, date and time of access, or behavioural data relating to the behavioural analysis of actions and choices made.
All Users undertake to provide only accurate, complete, and regularly updated data concerning their identity, content and information in general. Club Med may not be held liable in the event of communication of data that is illicit or contrary to public order.
When browsing the Site – Cookies
Club Med informs the User that tracking technologies such as cookies are deposited on the User’s terminal when the User browses the Site.
Cookies are trackers that are deposited and/or read, for example when you visit a website, and stored in your terminal’s browser. They are used to recognise your computer’s browser and store information for the duration of the cookie’s validity.
Below is a list of the cookies used on the Site, their purpose and how to disable them.
Strictly necessary cookies:
These cookies are necessary for the proper functioning of the Site, for the use of its most important functions and for smooth browsing. These include security features and easy access functions. These cookies cannot be disabled.
These cookies are used to improve the quality of navigation on the Site, in particular by saving your preferences expressed during your visit to the Site. The information collected via these cookies is anonymous and does not enable you to be identified. They cannot be disabled.
Tracking and personalization cookies:
You can manage, disable or authorize cookies by indicating your choices on the cookie manager accessible on your first visit via the cookies banner.
Users can also manage their cookies globally by modifying the settings of their internet browser, depending on the browser used.
Article 2. Purposes of the processing carried out
The information you provide when using the Site is used to manage access to and use of the Site.
More specifically, Personal Data collected as part of browsing, accessing and using the Site is processed for the following purposes:
– Contact request: Club Med processes the Personal Data of Users who choose to complete the contact form.
Processing for marketing purposes requires the User’s consent. The User may withdraw it at any time to unsubscribe from communications.
Article 3. Legal basis for data collection
The legal bases for the processing carried out by Club Med from the Site can only be the following:
- the User’s consent; or
- the legitimate interests of Club Med that do not override the User’s own interests.
When, in application of the Regulations, the processing of Personal Data requires your consent, Club Med will ensure that it first obtains such consent.
Club Med will not process Users’ Personal Data for purposes other than those initially agreed without first informing them and obtaining their consent to the new processing, unless the processing is required or authorised by law, or is in your vital interest.
Article 4. Data retention period
Club Med informs the User that Personal Data is only kept for the time strictly necessary for the purposes set out above and in accordance with the Regulations. The length of time we keep your Personal Data varies depending on the type of Personal Data and the purposes for which it is processed.
Personal Data collected in the contact form will be kept for a period of three (3) years from the date of collection or last contact by the User.
Article 5. Exercising user rights
Users are duly informed that they have the right to access, copy, rectify, oppose, port, limit and delete their Personal Data, within the limits set out by the applicable Regulations.
Insofar as the processing of their Personal Data is based on their consent, Users have the right to withdraw this consent at any time.
These rights may be exercised:
- either by email to the following address: firstname.lastname@example.org;
- or by email to the following address: email@example.com, specifying “exercising my rights” in the subject line of your email.
In addition, Users whose Personal Data is collected may lodge a complaint with the competent supervisory authority if they consider that their rights have not been respected. For more information, you can consult your rights on the websites of the competent authorities (in France, this is the CNIL: www.cnil.fr).
Article 6. Data security
Club Med undertakes to guarantee the integrity and reliability of the Data entrusted to it, in particular by taking all physical, organisational and logistical measures necessary to prevent any alteration or destruction of said Data, in particular by ensuring secure access only for persons authorised to process said Data.
In addition, Club Med requires its subcontractors to implement appropriate technical and organisational security measures to guarantee the confidentiality of Personal Data and a level of security appropriate to the risk.
Article 7. Transfer of your Personal Data
Club Med processes and stores your Personal Data within the European Union. Thus we do not transfer your Data outside the European Union.
However, if Club Med were to transfer such Data outside the European Union, appropriate measures would be taken to ensure that your Personal Data is adequately protected in the country of destination. Where appropriate, we put in place contractual measures and controls concerning the technical and organizational measures necessary to ensure that Personal Data is processed with the same level of security as that required by European regulations.
Article 8. Subcontractors
The User’s Personal Data is only accessible to persons duly authorized by Club Med for the purposes of management, administration or maintenance of the Site, to the exclusion of any commercial use and, where applicable, for the purposes of enforcing the Users’ rights to their Data.
In any event, Club Med asks third parties receiving the User’s Personal Data to undertake to comply with the Regulations in force and with a certain number of contractual undertakings.
Club Med thus informs the User that it uses the following subcontractors in particular:
- SPIN (site infrastructure supplier, hosting, maintenance)