Legal notice

1 – Cookies

When you open a page of our website, a message indicating the presence of Cookies will pop up. These “Cookies” files are installed on your terminal (Computer, Smartphone, Tablet etc.) for the purpose of collecting information related to your browsing. See below for further explanations and ways to configure cookies according to your choices.

2 – What are cookies ?

A cookie is a file in which information about your browsing is recorded, it is saved on your hard drive by your browser (such as browsing history for example) when you visit a website. This small file allows the server containing the website to identify and recognize you during the cookie’s lifespan

3 – Why use cookies ?

There are three types of cookies:
• Thechnical cookies
Most technical cookies (such as session cookies) are essential for operating the website. They allow access to protected areas (such as professional spaces for example) by means of personal credentials (login and session password). They usually have a very short lifespan. Their removal may cause navigation difficulties.

• Statistics cookies (web analytics):
These cookies collect your login information so that the website owner can get information about the number of visits to his website, the average duration of visit, the most visited pages, which browser was used, etc.
Google  Analytics,  for example, generate a cookie with a unique identifier that collects your IP address in order to know the city from which you are connecting but without ever knowing which computer or physical person you really are.

• Sharing cookies (social networks):
Our website contains sharing links to Facebook, Twitter, Google+, or other social networks, which allow you to share content from our site with other people. When you use these sharing buttons, a third-party cookie is set after we have obtained your consent. If you are connected to the social network while browsing our site, the sharing button allows you to link the content consulted to your user account.

5 – HOW TO MANAGE COOKIES?

Several possibilities are offered for you to manage cookies. Any settings you choose may modify your browsing on the Internet and condition your access to certain services requiring the use of Cookies.
You can choose at any time to express and modify your wishes regarding cookies, either via the consent given when you connect to the website or directly via the preferences of your browser. See below for help in setting up your browser.

6 –SETTINGS

• Setting up your browser:
Each browser can be configured to allow or disallow cookies on your terminal:
List of procedures:

• Pour Chrome
• Pour Internet Explorer
• Pour Firefox
• Pour Opéra

• Opt-out methods
You can set your choices directly on the platforms via the following links. Please note that if you refuse a cookie, a different cookie will be saved on your terminal with the sole purpose of deactivating the services associated with the cookie. Therefore, if you delete all cookies stored on your terminal, via your browser, we will no longer know that you have chosen this option.

– For statistics cookies deposited by Google Analytics
– For sharing cookies (social networks):

• For the cookies deposited by Facebook
• For the cookies deposited by Twitter
• For the cookies deposited by Google+

• En savoir plus
For more information on cookies, please refer to the CNIL website.

1 – PURPOSE OF THE POLICY

The Tourist Office of the Pays d’Aubagne et de l’Étoile values your privacy. This is one of the reasons why we have adopted a policy on confidentiality and protection of personal data.

We are committed to protecting your privacy rights and ensuring that your personal data is protected.

This Personal Data Management Policy (the “Policy”) details the types of personal data we collect, how we handle it and protect it in connection with the services we offer. This includes information collected offline or through our Customer Service Department, and online through our websites, applications (including mobile applications) and third-party platforms (“Websites”). It also reminds you of your rights and how to exercise them with us.

We maintain adequate technical and organisational measures to protect the personal data you provide us with, against accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access to your personal data.

This External Policy on Privacy and Protection of Personal Data is published by the Tourist Office of the Pays d’Aubagne et de l’Étoile whose head office is located at the following address: 8 cours Barthélemy – 13400 Aubagne – France

2 – YOUR RIGHTS AND HOW TO EXERCISE THEM?

Law No. 78-17 of 6 January 1978 on data processing, files, and freedoms, as well as European General Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) supplementing Law No. 78-17, grants you specific rights:
• A right of access: the right to ask us whether we hold Personal Data about you and to request to know it.

• A right of rectification: the right to ask us to rectify information about you in the event of errors or inaccuracies.

• A right to object: when the Processing is based on our legitimate interests, the right to object, for legitimate reasons, to a Processing of Personal Data, except for commercial prospecting where the reason is not required.

• A right to restrict the processing of your personal data: the right to ask us that some of your Personal Data shall not be retained for future processing when:
You dispute the accuracy of your Personal Data,
You consider and can establish that the Processing of Personal Data is unlawful, and you object to the erasure of Personal Data, but instead, request the limitation of the Processing,
We no longer need your Personal Data but it is still necessary for you to establish, exercise or defend legal claims;
You object to Processing as being based on our legitimate interest, while we verify whether the legitimate grounds pursued prevail over yours;

• A right to erasure: subject to the exceptions provided for by the Regulations, the right to obtain the erasure of your Personal Data, when one of the following reasons applies:
Your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed,
You wish to withdraw your consent on which the Processing of your Personal Data was based and there is no other basis for such processing,
You object to the Processing and there are no compelling legitimate grounds for such Processing, or you object to the sending of commercial solicitations,
You consider and can establish that your Personal Data has been unlawfully processed,
Your Personal Data must be erased under a legal obligation,

• A right to the portability of your data: where the Processing is based on your consent or a contract, the right to receive from us your Personal Data in a structured, commonly used format, and to transmit this Personal Data to another controller without our hindering it,

• A right to withdraw your consent: where the Processing is based on your consent, you have the right to withdraw your consent at any time, without such withdrawal affecting the lawfulness of the Processing carried out before such withdrawal,

• Right to decide what to do with your Personal Data after your death: you have the right to organize the future of your Personal Data post-mortem by adopting general or specific guidelines. We are committed to complying with these guidelines. In the absence of guidelines, we recognize the possibility for heirs to exercise certain rights, in particular the right of access, if it is necessary for the settlement of the deceased’s estate, the right to object and to proceed with the closure of the deceased’s user accounts and to object to the Processing of their data,
You can exercise each of these rights by proving your identity:

• By sending an email to our Data Protection Officer at: accueil@tourisme-paysdaubagne.fr

• By sending a letter to the following address: Tourist Office of the Pays d’Aubagne et de l’Étoile – 8 cours Barthélemy – 13400 Aubagne – France

• By following the instructions on the CNIL website at this address: https://www.cnil.fr/agir

If, despite our efforts to preserve the confidentiality of your Personal Data, you consider yourself a victim of a violation of the Regulations, you may submit a complaint to the CNIL.

3 – PERSONAL DATA

Personal data means information that can directly or indirectly identify you (“Personal Data”). It usually includes information such as your name, postal and e-mail address, telephone number, but also other information such as IP address, shopping habits, lifestyle information or preferences, such as hobbies and interests. Health information is referred to as “special categories of Personal Data” and requires special protection due to its level of sensitivity.

We collect your personal data directly in various ways, for example when:

• You browse our Website or use our services on our Website,
• You create an account, log in to your account or use your account on our Website,
• You subscribe to our newsletter,
• You place and pay for an order on our Website,
• You write a review or comment on our social networks or on our Website,
• You contact us through various channels including contact forms, by post or by telephone,
• You participate in a game or contest, product tests, satisfaction surveys, polls,
• You visit us in one of our Tourist Offices,
• You share content on social media using a hashtag #tourismepaysdaubagne or other hashtags available,
• You have given your consent to third parties to transmit your personal data to us,
• You share your content with us on our UGC (User Generated Consent),

When you provide us with your personal data, we process it in accordance with this Policy. If you do not want us to process your personal data in this way, please do not provide us with any personal information.

We process your personal data in order to provide you with our services, as detailed below. In some cases, we only process your personal data if you have expressly given us your consent, for example in most cases when we process your personal data for marketing purposes, use cookies or location data, or when we process your so-called specific personal data. In other cases, we may rely on other legal grounds to process your personal data, such as performing the contract between you and us, or a legitimate interest, such as fraud prevention.

If you become a customer, we may transparently infer that you want us to process your personal data for marketing purposes. You can always opt out of marketing communications without it affecting your benefits as a customer.

When we process your personal data, based on your consent, we will explicitly ask for your consent, and only for a particular purpose. We will also ask you to provide us with additional consent if we need to use your personal data for purposes not covered by this Policy.

Please see the following section for details on the different types of personal data we may collect, the purposes involved and the legal basis for such processing

4 – PROCESSING OF PERSONAL DATA

The Pays d’Aubagne et de l’Étoile Tourist Office considers the principles of data minimization, data protection on design and data protection by default. Consequently, we collect Personal Data that is relevant, adequate, and limited to what is necessary for the purposes for which it is processed.

This Personal Data is collected when you place an order or make a reservation, when you create or modify your customer account, when you browse one of our Sites, when you contact us, when you participate in an event, when you fill out forms.

When filling in input fields on a form, the mandatory nature of an answer is indicated by using an asterisk (*) at the end of the question. Failure to answer a question marked with an asterisk hinders the processing of your request.

When you choose to spontaneously send us your Personal Data, without being asked to do so, you agree to assume full responsibility for the Personal Data transmitted.

Please, be informed that you can register on the following link of “Bloctel”, a list of opposition to telephone canvassing: https://conso.bloctel.fr/

4.1 – NATURE OF PERSONAL DATA

We may collect and process, among other pieces of information, your first and last names, title, shipping address, telephone number, e-mail address, information about your order or claims, and payment information.

This may also include other types of information such as your IP address, shopping habits, lifestyle information or preferences.

These data are collected fairly, no collection is carried out without the knowledge of individuals and without them being informed.

4.2 – PURPOSES

The Pays d’Aubagne et de l’Étoile Tourist Office always processes your Personal Data for specific purposes and only implements Processing relevant to achieving these purposes.

Any processing of your personal data for a purpose other than those set out below will require your consent if it is not justified by a legitimate interest.

Specifically, we process your Personal Data for the following purposes:
• Answer your requests for information, questions, comments, satisfy your requests and provide you with effective assistance,
• Improve the relevance of the information sent,
• Manage your customer account,
• Establish, maintain, and manage the customer relationship and ensure its follow-up,
• Process and deliver your orders,
• Ensure proper accountancy,
• Manage invoices and receipts,
• Manage payment incidents or unpaid bills, and debt collection,
• Send commercial or promotional solicitations relating to products or services similar to those provided.
At any time, you can object, free of charge, to the use of your Personal Data for prospecting purposes, without having to justify this request by following the instructions in the section “Your rights and how to exercise them”. We draw your attention to the fact that exercising your right to object does not prevent us from continuing to contact you for other purposes, especially by virtue of a legal obligation or for the performance of the contract,
• Operate and optimize our website, help expedite your future activities and experiences on our website, evaluate the use of our website, our products and services and analyze the effectiveness of our communication campaigns and promotions, personalize your experience on our site and other platforms and evaluate anonymously and globally the activity on our site and other platforms (including, but not limited to, the time you visited, whether you visited previously, and which site referred you to it), make our website easier to use and tailor it better, together with our products and services, to your interests and needs,
• Manage our customer relationship via our CRM, in order to get to know you better, personalize our products and services and contact you regarding products and services that may be of interest to you (promotional offers, promotional events, Public Relations events, VIP gatherings, announcements/events, etc.), provided that you have given your consent, (or that you have not expressed your objection) or that you have previously requested a product or service from us and that the communication is relevant or related to this prior request and made within the time limits set by the applicable laws,
• Provide customer service that is reachable by phone or messaging,
• Provide sharing tools on our Website and/or social networks,
• Carry out the verification, identification, and authentication of the personal data that you have transmitted to us,
• Prevent and detect fraud, malwares, and manage security incidents,
• Manage possible litigations and disputes,
• Manage your requests for access, rectification, opposition, erasure, limitation, and portability of your Personal Data,
• Send you satisfaction surveys or conduct internal analysis,
• Invite you to events,
• Manage subscriptions to newsletters and event offers,
• Carry out analytical studies and trade statistics,
• Establish, exercise, or defend a right in court, whether in the context of judicial, administrative, or extrajudicial proceedings of any kind whatsoever,
• Manage archives,
• Ensure the compliance of our activities,
• And any other purposes imposed by law and authorities.

4.3 – LAWFULNESS OF PROCESSING

The Pays d’Aubagne et de l’Étoile Tourist Office collects and processes Personal Data if:

• We have obtained your prior consent,
• The processing is necessary for the performance of a contract to which you are a party or for the execution of pre-contractual measures taken at your request,
• The Processing is necessary to comply with our legal or regulatory obligations,
• The Processing is necessary for the purposes of our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms.

4.4 – RETENTION PERIODS

The Tourist Office of the Pays d’Aubagne et de l’Étoile keeps your Personal Data for the time necessary to achieve the purposes pursued, subject to the legal possibilities of archiving, obligations to retain certain Personal Data and / or anonymization.
Customer Personal Data that is not related to a specific contract is kept for a period of three years from your last interaction. Personal Data relating to a specific contract is kept for the duration of the contract.

At the end of the above-mentioned periods, Personal Data are subject to an Intermediate Archiving for the periods of legal or regulatory prescription.
At the end of the legal or regulatory limitation period, we commit to delete the Personal Data from our databases or to anonymize them.
Personal Data of prospects are kept for a period of three years from your last interaction and then deleted or anonymized.

4.5 – RECIPIENTS AND TRANSFER OF YOUR DATA

All such type of personal information is confidential and is only accessible through our services. It is not intended to be shared or sold.
We may share your personal data with service providers who help us carry out the above processing and in particular:
• Our advertising, marketing, and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions,
• Third parties required to deliver a product or service to you, such as a delivery or postal service delivering a product you have ordered,
• Third-party service providers, such as websites hosting service providers,
• Providers of web analysis tools, such as Google,
• Our service providers and/or economic partners when sharing is necessary to meet the purposes mentioned above,

We require these processing providers to comply with strict requirements in accordance with current data protection legislation, under which they can only process your personal data on our behalf and must comply with high standards of IT security.

Please note that we never share your personal data with social media platforms. When we expand our audience or conduct customer-matching activities with social media platforms such as Facebook or Google, your personal data is anonymized before the transfer.

If there are changes in the future and we need to share your personal data with a social media platform, we will ask for your consent.

Please note that we may share your personal data with law enforcement or other agencies where we have a legal obligation to do so, or in the case of a letter rogatory, a subpoena or a court order requiring us to disclose your personal data.

5 – SECURITY OF PERSONAL DATA

The Tourist Office of the Pays d’Aubagne et de l’Étoile commits, within the framework of its activities and in accordance with the Regulations, to ensuring protection, confidentiality, and security of Personal Data.
We take all necessary precautions, considering the state of knowledge, the costs of implementation and the nature, scope, context, and purposes of the Processing as well as the probability of each risk, to preserve the security and confidentiality of the Personal Data that you communicate, and particularly to prevent them from being distorted, damaged, or communicated to third parties (unless you agree).
Therefore, we implement all technical, logical, physical, and organizational measures to guarantee a level of security appropriate to the risk, and to prevent any loss, alteration, disclosure of Personal Data or access to unauthorized third parties.
However, given the intrinsic characteristics of the Internet, any transmission of information over the Internet is not completely secure. Personal Data transmitted are subject to measures that cannot protect against all risks of misappropriation and / or hacking. Transmission of your Personal Data therefore occurs at your own risk.

In the event of a personal data breach, and in accordance with the Regulations, we commit to notifying the CNIL.

6 – TRANSFER OF PERSONAL DATA TO A COUNTRY OUTSIDE THE EUROPEAN UNION

To date, the Tourist Office of the Pays d’Aubagne et de l’Étoile only transfers personal data of people located outside the European Union, under the terms and conditions set forth in the Regulations.

In the event that we are required to transfer Personal Data concerning people located within the European Union, we commit, from this day, to verifying and ensuring that appropriate safeguards in accordance with the Regulations are put in place by the Importer and that you have enforceable rights and effective legal remedies, so that your Personal Data benefits from an adequate level of protection.

Personal Data may, for the above-mentioned purposes, be transferred to a country located within the European Union, to a country outside the European Union that has been granted an adequacy decision by the European Commission, as well as to countries outside the European Union that have not been granted an adequacy decision by the European Commission if they are enforcing appropriate guarantees in accordance with GDPR.

7 – PROTECTION OF CHILDREN’S PRIVACY

Our products and services are not intended for children and do not target children under the age of fifteen. If you are under the age of fifteen, you may not order products or services and send us information about yourself.

8 – SOCIAL NETWORKS / HYPERTEXT LINKS

The Tourist Office of the Pays d’Aubagne et de l’Étoile is present on Social Networks, including Facebook, Twitter, YouTube, and Instagram.

We remind you that Processing is implemented by a Social Network when you access or use this Social Network, which requires that you consult and accept the privacy policy of each of the Social Networks you use.

Depending on the Social Network used, you may be able to access many features such as register for events that we offer, follow our news, comment, or share content published on your personal page within the Social Network, etc.

For these purposes, we will process some of your Personal Data, and particularly, your first and last names, as well as any type of information made public on your personal page.
As a service to our visitors, our Website may contain hypertext links to other websites that are not operated or controlled by us.
The Pays d’Aubagne et de l’Étoile Tourist Office will therefore not be held responsible for the content of such websites, nor for the data protection practices of the third parties that operate them. We draw your attention to the fact that the data protection practices of third parties may differ from those set out in this Policy. We urge you to verify and understand their practices in this area before entrusting them with your personal data.

9 – PUBLICITY AND UPDATING OF THE POLICY

This policy is effective May 25, 2018.
The Tourist Office of the Pays d’Aubagne et de l’Étoile reserves the right to modify its Privacy Policy. Any modification will be published on the Sites, Social Networks and, if applicable, notified to you by e-mail. Any navigation on the Sites and on the Social Networks, any subscription to a product and a service after the date of notification presumes your unreserved acceptance of the new Privacy Policy thus notified.