Personal data protection policy

Last updated on: 10/01/2023

PREAMBLE

To facilitate the reading of our Personal Data Protection Policy (hereinafter the "Policy"), terms using capital letters, such as "Personal Data", "Customer", "Users" or "Network" refer to the definitions in section 15.

The Policy binds TULIP RESIDENCES (hereinafter "TULIP RESIDENCES", "we", "us", "our"). and applies to all processing of Personal Data that we implement via the website https://www.tulipresidences.com/ (hereinafter the "Site") and its associated subdomains.
This Site allows you to find out about the offers of TULIP RESIDENCES, to be redirected to a website allowing you to make online reservations, in particular accommodation, with establishments operated under the TULIP RESIDENCES brand (hereinafter our " Hotels") and obtain franchise information.

Be aware that some hotels in which you are going to stay do not belong to TULIP RESIDENCES: they are operated, as a franchised/managed hotel, by a perfectly autonomous and independent entity. The Hotel is thus responsible for the processing of Personal Data that it carries out for its own account: monitoring of your reservation, payment, invoicing... Our organization as a network of franchisees/managed companies obliges our Hotels to respect the principles of protection of your Personal Data. in accordance with the applicable legislation, in particular in order to ensure the management of your rights when you exercise them.

We offer Users and Customers (hereinafter: "you") via the website accessible at https://www.goldentulip.com/fr-fr/ an Online Hotel Room Reservation Service and associated services. These Services may also, in whole or in part, be offered to you when you book through a contact form.

As part of the Services, we collect and process Personal Data about you. Because respecting your privacy is essential for us and justifies the trust you place in us, we have implemented this Policy which, in a process of transparency, aims to inform you about:

• the methods of collection and processing of your Personal Data by TULIP RESIDENCES and their transmission to the Hotels in the event of a reservation;

• the commitments made by TULIP RESIDENCES to ensure the security of your Personal Data;

• the rights you have over the Personal Data processed by TULIP RESIDENCES;

• the obligations of TULIP RESIDENCES but also yours, in order to ensure maximum protection for your data.

Your privacy is important, and that is why we have implemented the necessary measures to protect it and minimize the Personal Data that we collect and process, in compliance with the General Data Protection Regulations⁽¹⁾. (hereinafter "GDPR") and the French Data Protection Act⁽²⁾.

As such, we implement the principles of privacy protection from the design of our projects and by default, and respect the principles of the GDPR and the Data Protection Act, in particular:

• the security of your Personal Data,

• compliance with the legality of the processing of your Data,

• the processing of your Data for a specific and transparent purpose,

• compliance with appropriate retention periods for these processing purposes,

• respect for the accuracy of your Data,

• respect for your rights and fairness in the processing of your Data,

• compliance with appropriate safeguards with regard to transfers of your Data outside the European Economic Area.

1. IDENTITY AND CONTACT DETAILS OF THE PROCESSING RESPONSIBLE

We, TULIP RESIDENCES, a simplified joint-stock company with a capital of 1000 euros, whose head office is located at Tour Voltaire – 1 Place des Degrés, 92800 Puteaux / La Défense CEDEX, registered with the NANTERRE Trade and Companies Register under number 844 183 434, process your Personal Data as data controller within the framework of the Services offered on the Site.

In other words, we control the way your Personal Data is processed and we determine the purposes, i.e. the objectives (reservation, complaint, etc.). This also means that we give precise instructions to the subcontractors processing your Personal Data on our behalf and to operate part of the Services from which you benefit.

You can send us any questions, requests for information or complaints by referring to article 6.

2. WHAT PERSONAL DATA DO WE COLLECT, AND FOR WHAT REASONS?

1. Data we collect directly from you

In particular, we collect identification and contact data (surname, first name, email address, etc.), which allow us to know who you are, in order, among other things, to better manage your reservations and the commercial relationship we have with you, or more simply to be able to ensure the management of our Site. In order to offer you suitable offers, we also process data relating to your centers of interest from your consumption data during your stay on site.

We thus collect the data resulting from your interactions with us, on the Site, by telephone, via hotel comparators or directly during your stay.

Namely: We collect certain data automatically through the use of the Services:

Technical data: IP address, internet connection, browser type, information about the Terminal used;

Data collected using cookies: for more information, see the Cookies Policy.

Namely: we also collect data indirectly.

The main Personal Data that we collect and their uses are presented to you below:
​​​​​​

Why do we process your Personal Data?	What data do we collect?
For the reservation of a hotel room or the follow-up of your reservation via our customer service	Your identification data such as: title, surname, first name, email address, postal address, date of birth, your mobile and/or landline telephone number and possibly the recording of your telephone conversations when you make a reservation by telephone. The data of your stay: dates, number of nights, destination, presence of an adult/child.
As a guarantee, when you book a room online	Data relating to your credit card: credit card number, validity date of the credit card, cryptogram (only the time of the transaction), if applicable, name of the credit card holder (fight against fraud).
For the administration of the Site	Data related to your terminal and your connection, including: IP address, internet connection, browser type, information about the Terminal used
When you seek to contact us via a form or by telephone or when you wish to leave a review	Vos données d’identification : nom, prénom, adresse email, objet de votre message

1. 3. The reasons why we process your Personal Data

2.3.1 Operations necessary to deploy our Services:

• Managing and administering the Site and our social media pages:

  • the management of cookies under the conditions defined by the Cookies Policy;

  • Managing your online reviews and our e-reputation.

• Managing your hotel stay:

  • ensure that the Hotel registers you;

  • in certain cases (when we operate the network), allow you to benefit from the Wi-Fi network in our Hotels and restaurants;

  • monitor your consumption and your expectations during the stay in order to adapt our service offers;

  • manage our customer lists.

• Enable You to benefit from the Services we offer:

  • placing, tracking and history of bookings;

  • prepayment and payment by credit card: recording of credit card data to secure the reservation, fight against fraud, operate reservation statistics;

  • cancellation of a booking and, where applicable, refund;

  • the processing of your preferences (food for example) and the personalization of our offers;

  • monitoring our commercial relationship (sending "pre stay" and "post stay" emails) and sending satisfaction surveys and surveys by email.

2.3.2 Operations necessary for marketing and commercial prospecting:

• Send you our commercial offers adapted to your profile and display targeted advertisements, in particular on your social network pages (offers from TULIP RESIDENCES and concerning TULIP RESIDENCES;

• The communication of your email address to our specialized subcontractors (Facebook, Amazon) in order to help us find new prospects, with a profile similar to yours, likely to be interested in our Services. These companies, with which you have subscribed, do not send us information about you, they only search for people with interests and a profile similar to yours and offer suitable advertisements on our behalf;

• The use of your Data to create personalized audiences with our partner Facebook and thus offer you targeted advertising;

• The analysis of connection and navigation data (collected via tracers/cookies or via your browser) for the purpose of targeted advertising on the Services of the Site;

For more information, see our Cookies Policy.

Important: with regard to these operations, you have the possibility of implementing your right of opposition and in particular your right of opposition specific to commercial prospecting (by refraining, on the one hand, from ticking the box opt-in and/or by following the procedure described in article 4) which assures you, once taken into account, of the cessation of the processing of your Personal Data for this purpose.

2.3.3 Managing your various requests

• processing your online applications;

• the processing and documentation of your requests to exercise rights (access, rectification, opposition, erasure, limitation, portability, etc.);

• the processing of your calls and requests by our customer service.

3. ON WHAT BASIS DO WE COLLECT AND USE YOUR PERSONAL DATA?

We may process your Personal Data on several grounds:

Legal basis	Exemples de traitements
The execution of a contract or pre-contractual measures taken at your request	Registration and management of your reservations, billing follow-up
Your consent	For example, when we send you emails or text messages containing news, special/commercial offers or satisfaction surveys
The legitimate interest of LOUVRE HOTELS GROUP	manage your requests for information and your online opinions in order to improve your User experience and our customer approach; in some cases, the management of a wi-fi network in our Hotels; to make you benefit from our promotions and personalized recommendations and those from our Hotels or our partners; help us find new prospects by analyzing your browsing data; setting up and improving distance selling tools and constantly improving your shopping experience; managing and administering the Site.
A legal obligation	For example, when we collect information about you in order to respond to your requests to exercise your rights (see article 6).
If the processing of your Personal Data is one day necessary to safeguard your vital interests or those of another natural person

4. WHAT ARE YOUR RIGHTS ?

You have a right of access, rectification, erasure, limitation, opposition and right to portability (in accordance with the provisions of Articles 15 to 21 of the GDPR).

You also have the right to lodge a complaint with the competent supervisory authority (in France, the Commission Nationale de l'Informatique et des Libertés, or "CNIL").

You can exercise these rights at any time and free of charge, except in the case of manifestly unfounded or excessive requests (in particular due to their repetitive nature). In this exceptional case, we reserve the right, in accordance with the GDPR, to demand the payment of reasonable costs (indexed to the administrative costs of your request) or to refuse your request.

TULIP RESIDENCES informs you that it has a Personal Data Protection Officer who you can reach either by email: dpo@groupedulouvre.com, or at the following address:

DPO

LOUVRE HOTELS GROUP

Voltaire Tower – 1 Place des Degrees

92800 Puteaux

You have an absolute right to oppose commercial prospecting: you can thus request, free of charge and at any time, to no longer receive commercial communication from us.

You can also exercise your rights with regard to your Personal Data stored and processed by a Hotel in its capacity as data controller. We invite you to exercise your rights directly with this or these Hotels and to consult their privacy policy if necessary.

Summary of rights available to you:

Rights you have	Usefulness
Permission to access	Right to know if we hold Personal Data concerning you and to obtain a copy of it, as well as, in particular, the following information: purpose of the processing, categories of Personal Data processed, categories of recipients of the Data, retention period when this is possible (or the criteria used to determine this duration), rights which you benefit from.
Right to erasure (right to be forgotten)	Right to obtain the deletion of your Personal Data in the cases provided for by the GDPR (Article 17), in particular when the data we process is no longer necessary for us; when you object to commercial prospecting and request deletion in addition to stopping processing; when the processing is unlawful.
Right of opposition	This right applies when we process your data in order to pursue one of our legitimate interests, such as advertising on your social media pages. In the event of your request for opposition, we will analyze the reasons relating to your particular situation and will determine whether we have a legitimate and compelling reason to continue processing your Data. Otherwise, we will cease the processing concerned.
Right of opposition to commercial prospecting	In the event of opposition to commercial prospecting, we will simply cease the processing of the Data concerned.
Withdrawal of consent	Where the processing of your Personal Data is based on your consent, the withdrawal of your consent prevents us from continuing to process the Data in question.
Right to rectification and right to limitation	You can request the updating or rectification of any Personal Data that you consider inaccurate or obsolete. You can also request that the processing be suspended, with the exception of the retention of Personal Data, when: you contest the accuracy of the data (this limitation lasts for the time of our verification of this possible inaccuracy); the processing is unlawful and you prefer to obtain the limitation of the processing rather than the erasure of the data; we no longer need the data but you consider that they are still necessary for the recognition, exercise or defense of legal rights; you have made a request for opposition due to your particular situation and this limitation is obtained during the time of verification of the balance of interests between our legitimate interests and your rights and freedoms. When processing has been restricted, your Data may only be processed with your consent or for the exercise e, the recognition and defense of rights in court.
Right to portability	You have the right to receive the Personal Data that you have directly provided to us, in a structured, commonly used and machine-readable format. You also have the right to transmit this Data or to request that we transmit it to another data controller. This right only applies to processing based on the consent of the person, or on the performance of the contract and which is carried out using an automated process.

5. FATE OF DATA IN THE EVENT OF DEATH

In accordance with the provisions of article 85 of the Data Protection Act, we inform you that, as a natural person:

• You have the right to define with us directives relating to the storage, erasure and communication of your Personal Data after your death;

• You can modify or revoke these instructions with us at any time;

• You may designate a person in charge of the execution of these directives, who will have the capacity after your death, to take cognizance of the said directives and to request their implementation from us.

You are also informed that in the absence of transmission to TULIP RESIDENCES of specific directives on the fate of your Personal Data, your heirs may exercise after your death the rights relating to the storage, erasure and communication of your Personal Data to the extent necessary for the organization and settlement of your estate as well as for TULIP RESIDENCES to take your death into account.

6. HOW TO REACH YOU HOW TO MAKE A CLAIM?

You can make a request to exercise any of the rights mentioned in Article 4 as follows:

• by sending an email explaining the subject of your request to the following address: relation@louvre-hotels.com.

• by sending a letter explaining the subject of your request to the following address: TULIP RESIDENCES - Service clients - Tour Voltaire, 1 Place des Degrés, 92800 Puteaux.

For security reasons and because our Services present sensitive issues in terms of confidentiality, any request for the right of access to the Data must be signed and specify the address to which the response is expected. You will be asked for a photocopy of an identity document if TULIP RESIDENCES has a reasonable doubt about your identity. In this case, TULIP RESIDENCES will send you the procedure to follow in order to guarantee the security of this transmission. According to the risk assessment for the persons concerned carried out by TULIP RESIDENCES, these security measures could also apply to other requests for the exercise of rights. A response will then be sent to you within one (1) month of receipt of the request, which may be extended by two (2) months depending on the complexity or the number of requests.

For any request for information on the processing of your Personal Data, you can contact us at: dpo@groupedulouvre.com.

For any information relating to the protection of Personal Data, you can also consult the CNIL website.

7. HOW LONG DO WE KEEP YOUR DATA?

The Personal Data collected is kept for the time necessary to achieve the purposes described in Article 2 "WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT REASONS?" », increased by the duration of the legal prescriptions.

The main retention periods are:

Finalités	Goals
Traffic data (internet)	One (1) year from the date of the relevant connection
Data relating to Customers for the purposes of animation and commercial prospecting	Three (3) years for animation and prospecting purposes from the end of your stay or your last contact with us
Data relating to prospects for the purposes of animation and commercial prospecting	Three (3) years from the last incoming contact with TULIP RESIDENCES
Documents and accounting records (e.g. invoice)	Ten (10) years, as accounting evidence
Data relating to transactions and means of payment	Duration of the transaction (until the TULIP RESIDENCES account is credited); In intermediate storage, to meet administrative requirements such as the establishment, exercise and defense of our legal rights: up to thirteen (13) months from the date of debit or fifteen (15) months for deferred debit cards
Data relating to your identity documents	In case of exercise of the right of access, deletion, portability, limitation or rectification: one (1) year In case of exercising the right of opposition: six (6) years
The possible recording of your telephone conversations when you make a reservation by telephone	Two (2) months
Personal data recovered via tracers (Cookies, SDK)	Six (6) months

Unless you specifically direct us to do so (provided such specific direction is reasonable and practicable for us), we will delete all of your Personal Data, in the event of your death, at the end of the applicable retention period and applicable requirements, or upon request of a successor in interest and proof of your death and in accordance with Section 5 "DEATH OF DATA".

8. TO WHOM MAY WE SEND YOUR DATA (THE RECIPIENTS)?

The Personal Data we collect may be transmitted, in order to ensure the purposes listed in article 2 :

• to the authorized personnel of TULIP RESIDENCES ;

• to authorized personnel of any Hotel;

• to technical service providers providing services that contribute to the achievement of the purposes described in the article "2. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT REASONS?", who are our subcontractors and for whom we are legally responsible, and in particular the service providers in charge of :

  • the execution of the Services, reservations and orders, their management and processing.

  • the after-sales service;

  • the processing of payments and security measures concerning the transmission of payment data;

  • the sending of prospecting emails, invitation to register and any other information email to you; 

• to companies with which we have commercial agreements intended to enable us to offer you coupled or personalized offers or as part of a loyalty program, unless you object;

• to social networks acting as a subcontractor: we may share your email address or phone number in order to identify whether you are already a user of one of these social networks (such as Facebook) and to display ads tailored to you on your account page.

If you do not want your Personal Data to be transmitted to our Hotels or partners for commercial purposes or to social networks for targeted advertising, you can object at the time of collection or exercise your right to object as described in Article 4 "WHAT ARE YOUR RIGHTS?

You agree that we may also be required to disclose any information about you in order to comply with Applicable Regulations, or to respond to any judicial or administrative request.

9. HOW TO FILL IN THE FREE FIELDS AND HOW TO MANAGE YOUR SENSITIVE DATA?

In general, failure to fill in the fields identified on the Sites by an asterisk (*) does not allow us to provide you with all or part of the Services we offer and the features of the Site, and your requests may not be taken into account in an optimal manner.

The other fields are optional and are intended to improve the quality of the Services offered to you.

When a form (notice, contacts) offers a free field, we ask you not to indicate any personal information and to limit yourself to the information strictly necessary to process your request. We reserve the right to remove any information that is not relevant to your initial request.

We do not collect Sensitive Data about you.

We remind you that Sensitive Data are data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning the sexual life or sexual orientation of a natural person.

If you voluntarily provide us with Sensitive Data, including in connection with your special requests related to your reservation, you explicitly consent to our processing of these particular categories of Personal Data.

10. WHAT SECURITY MEASURES DO WE APPLY TO YOUR PERSONAL DATA?

We implement appropriate technical and organizational measures to protect your Personal Data against accidental or illicit destruction, accidental loss, alteration, distribution or unauthorized access to such Data.

However, we do not control all the risks associated with the operation of the Internet and draw your attention to the existence of possible risks inherent to its operation.

We also monitor how our service providers handle your Personal Information to ensure that they provide sufficient guarantees that they have implemented appropriate data security measures.

In the event that you identify a security breach affecting the Site, you agree to provide us with relevant information about the breach on a confidential basis.

11. HOW DO WE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EU?

In the course of performing our Services, we may transfer your Personal Data to recipients, in particular Hotels, which may be located outside the European Union.

In the event of a transfer of Personal Data outside the European Union, we undertake to comply with the requirements of the Applicable Regulation and will put in place the appropriate safeguards necessary for such transfer.

12. ACCURACY OF DATA

As a User of the Site or a Client of TULIP RESIDENCES, you declare that you are aware of the importance of the accuracy of the Personal Data concerning you and that you provide through the Site or in the context of your exchanges with us.

You also commit yourself to provide only accurate Personal Information during your exchanges, contractualization with us, requests for Service and during the entire duration of the use of the Site and to update them immediately if one or more of these Personal Information should change during the said duration of use of the Site or of the Contract binding you to us.

In this respect, you may request access and rectification, as well as opposition or deletion as provided for (among others) in Article 4 "WHAT ARE YOUR RIGHTS?" of this Policy.

13. MODIFICATIONS

This Policy may be updated from time to time and will be posted online. The previous Policy will then be automatically replaced by the new version, which will be immediately enforceable against you. Use of the Site is subject to the Policy in effect at the time of use. In order to remain informed of any changes and updates, we recommend that you consult the Policy regularly.

14. GENERAL

If any provision of this Policy is invalid due to a change in law, Applicable Regulations or a court decision, this will not affect the validity of the remaining provisions of the Policy.La présente Politique et les documents auxquels elle fait référence sont régis par le droit français.

15.  DEFINITIONS

For the proper understanding of this document, the terms defined below beginning with capital letters and used in both the singular and plural, shall have the following meaning:

« Client » : natural person, holder of an Account, residing in France and/or abroad who uses the Site.

"Personal Data" or "Data": This is "any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); An "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity" according to Article 4 of the European Regulation on the protection of personal data.

For example, data allowing you to be identified, such as your title, surname, first name and email address are Personal Data.

"Applicable Regulations" means all existing or future regulations and standards applicable to Users and the Site and in particular: the legislation and regulations applicable to Internet platforms such as the Site and concerning the protection of Personal Data, including the French Data Protection Act (Loi Informatique et Libertés) and the European Regulation on the protection of Personal Data.

"Our Hotels" or our "Network" means any franchised entity of TULIP RESIDENCES or managed by TULIP RESIDENCES, or any subsidiary of TULIP RESIDENCES, which operates under one of the brands of TULIP RESIDENCES.« Service(s) » : prestations hôtelières et connexes proposées aux Clients par TULIP RESIDENCES via le Site et en face à face dans nos Hôtels.

"Site": any internet site or mobile application published by LOUVRE HOTELS GROUP, presented under the domain name LOUVRE HOTELS GROUP or presented under the domain name of its brands.« Terminal » : moyen technique quel qu’il soit permettant aux Utilisateurs d’accéder au Site. Les Terminaux pourront notamment être les Smartphones, tablettes Apple ou Android, les micro-ordinateurs via internet et tout objet connecté/connectable à un autre objet ainsi qu’à Internet.

"User": any natural person accessing the Site, on his or her own behalf or on behalf of a legal entity, and having the capacity and/or the power to contract through the Site, whether he or she is a simple visitor or a Customer.

⁽¹⁾ Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

⁽²⁾ Law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms