Club Med privacy policy

Club Med SAS, registered in the Paris Trade and Companies Register under number 572 185 684 (hereinafter, “Club Med” or “We”), believes it is important to protect your personal data and ensures strict compliance with provisions relating to the protection of privacy and the processing of personal data, especially the European Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (EU Regulation 2016/679 of 26 April 2016), the French Data Protection Act (Acte informatique et libertés) of 6 January 1978, as amended in 2004, as well as the recommendations of the CNIL (hereinafter, the “laws in force”).

The purpose of this personal data protection charter (hereinafter, the “Charter”) is to describe how and when Club Med, as a data controller, collects, uses and discloses certain personal data (hereinafter, the “Data”) you send us to respond to your requests and optimise and improve the quality of our services.

• When does this Charter apply?
• What Data does Club Med collect?
• How does Club Med use the Data collected?
• What cookies does Club Med use?
• How long does Club Med keep your Data?
• What categories of recipients receive your Data?
• What are the legal bases for the processing of your Data?
• What are your rights?
• Will your Data be transferred outside the European Union?
• The protection of your Data by Club Med.
• Revision of the Charter

This Charter informs you how your Data is collected, processed and used when:

• You book a stay with Club Med;
• You visit the Club Med website or our mobile application (hereinafter, the “Website”);
• You subscribe to our Club Med newsletter (information on products & special offers) and customised content;
• You contact our Customer Service Department;
• You take part in our contests.

You provide us with your Data when:

• You register on the Website by filling in the various forms relating to your account or by uploading Data;
• You book a holiday package;
• You take part in contests;
• You complete a Club Med questionnaire;
• You communicate with our Customer Service Department.

This Data may, for instance, consist of your:

• Last and first name(s);
• Date of birth;
• Gender;
• Mailing address;
• Email address;
• Telephone number(s);
• Means of payment;
• Booking history.

The same applies for any information you provide about anyone for whom you book a holiday package. In this respect, you agree to obtain their prior consent before disclosing their Data.

You may opt not to disclose certain information to us; however, this decision may prevent you from using our services. The required information for the provision of our services is identified with an asterisk in our information gathering forms.

While browsing the Website, Club Med may collect Data on the following, in strict compliance with the laws in force and your rights:

• Features of the operating system, browser or devices (computer, pad, smartphone) you use to access our services;
• Your location, such as your IP address;
• Your browsing path and interactions with the content of the Website, such as pages viewed, key search words used, frequency of your visits to the Website, advertising clicked on.

We may also collect Data through third parties, including in particular social media, when you register or log in to our services using a third-party account. When you do this, you will be informed of the Data transferred to us by the relevant third party.

We use, store and process your Data to process your requests, manage our commercial relationship, and optimise our services and tools to create and maintain a more secure environment and to comply with our statutory obligations.

We use your Data to manage your holiday package booking and to perform various related services.

In particular, we use your Data to process your payments, to inform you by text message, e-mail or other about how the contract you enter into with us is performed (information on your journey, any transport delays, extra services proposed, etc.).

As part of our commercial activity, we may use commercial partners to provide certain services on our behalf.

For instance, we do not have our own fleet of aircraft, trains or coaches. We are required to enter into contracts with various carriers to offer you ways of getting you to our various resorts. Accordingly, some of your Data (last name, first name, date of birth, etc.) will be provided to the carrier in order for it to issue you a travel ticket.

Our business partners may not use your Data for purposes other than those required to perform services that you have requested. They are also required to process your Data in strict compliance with Existing Legislation.

We use the Data you provide to identify you in order to access your Account, access to which is restricted to authenticated persons.

If, on booking a holiday package, setting up your account on the Website or thereafter, you ticked the box or filled in the form to receive the Club Med newsletter (information on Club Med products and commercial offers) and customised content, we may use your Data to send you the following, according to your preferences (in particular, by e-mail, text message, telephone or letter):

• Information on the Website;
• Invitations to Club Med events which may be of interest to you;
• Information on our offers;
• Information on updates to the Charter or security measures.

To stop receiving commercial offers and communications from the Club Med Group, you may at any time unsubscribe by (i) clicking on the unsubscribe link or completing the objection process indicated in Club Med communications or (ii) contacting us (see Section 6 below).

We may also use your Data to send you advertising messages which may be of interest to you on third-party websites or on social media platforms. For more information, we suggest you read the terms relating to the use of your Data on these third-party websites and/or platforms.

We may also process your Data for profiling operations.

Profiling is the automated process of your Data to analyse, anticipate and assess your interests and preferences in order to send you customised content and commercial offers suited to your specific requirements.

Club Med will only share your Data with third-party service providers to determine your profile and preferences and send you more relevant Club Med content. Club Med will not disclose your Data to commercial partners.

You may object at any time to the use of your Data for profiling purposes by accessing your Account or by contacting us (see Section 6 below).

We use your Data to carry out analyses, technical tests (including the anonymisation of your Data) and data deduplication in order to improve and optimise the Website and customise our tools and services. This means, for example, ensuring that the display of our content is adapted to your device or hosting your Data on even more secured servers, etc.

When you contact our Customer Service Department by telephone or using the contact form available on the Website or by any other means made available by Club Med (social media, chat, etc.), we use your Data (including the recordings of your calls, with your prior consent) to:

• respond to and resolve your complaint;
• track and manage the follow-up of your complaint;
• improve customer service.

We may use your Data to carry out various statistical analyses and/or to ask you to take part in our surveys.

Your Data may be used to:

• respond to a request from an administrative or judicial authority, a law enforcement representative, an officer of the court or to comply with a judicial decision;
• ensure compliance with our general terms and conditions of sale and with the Charter;
• protect our rights and/or obtain compensation for any harm we may suffer or mitigate the consequences thereof;
• prevent any act contrary to the laws in force, including in particular the prevention of fraud risks.

When you participate in contests, you provide us with a certain amount of Data. This Data is essential in order for you to participate and for us to award a prize.

With your prior and express consent, we may use this Data to send you the Club Med newsletter (information on Club Med products and commercial offers) and customised content.

a) Cookies needed to provide the services requested

Club Med may have to use those cookies which are strictly necessary to provide you with requested services and/or information, including in particular:

• session ID cookies;
• shopping cart cookies;
• authentication cookies;
• load balancing session cookies;
• user interface customization cookies;
• analytic (or statistical) cookies
  Data collected from statistical cookies is not cross-checked with other data processed (or previously anonymised) and is only used to collect anonymous information about the user’s behaviour on our Website.

These cookies are not used to follow users’ surfing behaviour after visiting our Website nor are they used to geolocate a visitor.

You may block the placement of cookies, particularly statistical cookies (see “Disable cookies”).

b) Improvement and customisation cookies
Certain cookies are used to analyse, optimise and customise your browsing experience. Cookies are also used to automatically process your Data in accordance with the terms and conditions specified in Section 3.4. Cookies are only placed on your device with your prior express consent.

c) Improvement and customisation cookies

When you browse the Website, third-party cookies (set by a communications agency, measurement company, targeted advertising service provider, etc.) may enable these third parties, during the cookie’s lifespan, (i) to collect browsing information about our Website users and (ii) to post advertising content based on your interests. The setting and use of third-party cookies are subject to the cookie management policies of these third parties.

You may change your browser settings to disable/block cookies.

You may either accept all cookies or you can configure your browser to display a message when a server wants to store a cookie. You may also disable all cookies. Note that if you disable all cookies, you may not be able to access parts of our Website or use some of our services.

To disable cookies, follow the instructions provided in the appendix.

De manière générale, vos Données sont conservées uniquement le temps nécessaire à l’accomplissement des opérations pour lesquelles elles ont été collectées.

Voici les différentes durées de conservation des Données collectées par le Club Med :

• les Données qui nous ont été transmises directement telles que détaillées à l’article 2.1 sont conservées pendant la durée nécessaire à la finalité de leur traitement ;
• les Données de navigation sont conservées pendant une durée maximum de 13 mois ;
• les Données relatives aux prospects sont conservées pendant une durée maximum de 3 ans à compter du dernier contact que vous avez initié avec le Club Med;
• les Données relatives aux pièces d’identité que vous nous transmettez lorsque vous exercez votre droit d’accès ou de rectification sont conservées pendant une durée maximum de 12 mois ;
• les informations permettant de prendre en compte les droits d’opposition des personnes concernées à recevoir de la prospection commerciale sont conservées pendant une durée maximum de 3 ans à compter de l’exercice de ce droit.

Nous pouvons également supprimer vos Données sur demande de votre part.

Toutefois, à l’issue des délais précités, en ce compris votre demande de suppression, vos Données pourront faire l’objet d’une conservation afin de satisfaire à nos obligations légales, comptables et fiscales et/ou pendant le délai de prescription applicable et/ou en cas de procédure contentieuse pour la durée de lAs a general rule, your Data is kept only for the time necessary to carry out the operations for which the Data was collected.

Depending on the Data category, Club Med keeps the Data for the following time periods:

• Data directly sent to us as specified in Section 2.1 is kept for the time necessary to process the Data;
• Browsing Data is kept for a maximum of 13 months;
• Prospect Data is kept for a maximum of three years from the last contact you initiated with Club Med;
• Data relating to identity documents sent to us to exercise your right to access or rectify the Data is kept for a maximum of 12 months;
• Information provided to process a data subject’s exercise of its right to object to the receipt of electronic marketing is kept for a maximum of three years from the exercise of this right.

We may also delete your Data on request.

Note that on the expiry of these periods, and on receipt of your request to delete, your Data may be kept to comply with statutory, accounting and tax obligations (e.g. obligation to keep invoices for 10 years in accordance with Article L.123-22 of the French Commercial Code and/or during the applicable limitation period and/or for the duration of any legal dispute. adite procédure.

We may share your Data with various third parties including in particular:

• our affiliated entities to provide you with the requested services or acting as data processors in accordance with applicable laws;
• our commercial partners, suppliers and/or data processors who process your Data on our behalf, according to our instructions, for the purposes specified in Section 2 (including in particular carriers, insurance companies, customs authorities, local service providers, financial institutions, technical data processors, etc.). We take special care to ensure that these third parties provide adequate guarantees to ensure the protection and security of your Data;
• duly authorised French or foreign authorities, particularly pursuant to legal proceedings or data transmission request.

In accordance with the laws in force, we rely on various legal bases to process your Data, including:

• your prior express consent to the processing of your Data for one of the purposes listed in Section 3;
• the performance of the contract you entered into with us;
• the need to comply with a statutory obligation or to defend ourselves in the event of legal proceedings;
• the legitimate interests pursued by Club Med;
• the safeguarding of your vital interests.

8.1 Your rights of access, rectification, deletion and objection

You may ask us to access, rectify, update or delete your personal information.
You may also exercise your right to object to the processing of your personal Data.

8.2 The right to portability of your Data

The right to portability allows you to recover some of your personal Data, namely:

• Data you sent us directly as specified in Section 2.1;
• Data generated by your use of the Website as specified in Section 2;
  We endeavour to respond to your request within a reasonable time and no later than the time limit provided by law.

8.3 The right to determine what happens to your Data

You have the right to set general or specific guidelines for the retention, deletion and disclosure of your Data after you close your account.

8.4 Contact

To exercise your rights, simply send a letter to: Club Med, Service Relation Client, 11 rue de Cambrai, 75957 Paris Cedex 19, France and enclose a copy of your identity documents along with your request.
If you believe your rights have not been respected, you may, at any time, file a complaint with Club Med’s Data Protection Officer (DPO) by sending a letter to: DPO, Club Med (Swiss office) SA, Customer care, 40 avenue d’Aïre, 1203 Geneva

You may also file your complaint with the competent regulatory authority (PFPDT: http://www.edoeb.admin.ch).

We may transfer your Data to countries outside the European Union for the sole purposes indicated in this Charter.

When your data is transferred, we ensure that your Data is protected in accordance with protection levels provided for in Europe.

Transfers are made exclusively to countries that are recognised as providing an adequate level of data protection by the European Commission.

In the event the Data is transferred to a country that does not offer an adequate level of protection, the Club Med Group and its partners or service providers agree to implement appropriate guarantees to govern the transfer (e.g. standard contract clauses of the European Commission), which you may request by sending a letter to the DPO as specified above.

Club Med undertakes to guarantee the integrity and reliability of Data entrusted to it, including by taking all physical, organisational and logistical measures necessary to prevent any alteration or destruction of such Data and by ensuring secure access only to those persons authorised to process the Data.

You can change your cookie settings for the Club Med website with the banner at the bottom of the page. You may also change your global browser settings to disable/block cookies.
You may either accept all cookies or you can configure your browser to display a message when a server wants to store a cookie. You may also disable all cookies. Note that if you disable all cookies, you may not be able to access parts of our Website or use some of our services.
To disable cookies:

If you use Internet Explorer 8 and following:
Consult http://windows.microsoft.com/en-en/internet-explorer/delete-manage-cookies

If you use Firefox 30.0 and following:
Consult https://support.mozilla.org/en/products/firefox/privacy-and-security/cookies

If you use Google Chrome:
Consult https://support.google.com/chrome/answer/95647?hl=en

If you use Safari 5.0 and following:
Visit https://support.apple.com/en-gb/HT201265 about settings for iPhone, iPad and iPod, visit https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac for Mac computers.

If you have a different browser type or version, see your browser’s "Help" menu.