Last update: December 5th 2018
Eluxfrance, an Elux Groupe brand, SASU with a capital of 100 000 € registered in Versaille’s Commercial Register under n° 809 018 609, whose headquarters are located at “11bis, rue Albert Joly - 78000 Versailles”, registered in the Registre Atout France n° IM078170011, which is a French travel agency specialized in designing luxury tailor-made holidays to most countries in the world, wishes to inform you of the measures implemented for the purpose of protecting your personal data and your private life in accordance with current legislation and more specifically the modified provisions of January 6th 1978 "Database and Privacy" Law (Informatique et Libertés), of the 2016/679 European Regulation as well as the recommendations from the National Commission on Informatics and Liberties (CNIL) (hereinafter “the current legislation”).
I. PERSONAL DATA TRANSMITTED TO ELUXFRANCE.
a) Data relating to your personal information
It is information about you as a natural or legal person that you have voluntarily communicated to Eluxfrance through different Communication Channels and that is essential to designing and implementing your trip (examples: surname, first name, email address, telephone number, postal address, date of birth…).
We inform you that the information which must be provided to Eluxfrance is visibly marked by an asterisk on our website. The information that isn’t marked by an asterisk is optional. Whenever you contact us, by telephone or in one of our agencies, your Travel Designer will infirm you which essential information he or she needs.
This information is essential to processing your travel service requests, they unfortunately won’t be able to be processed in the absence of this information.
b) Data relating to third party personal information
As part of your quote request and then while creating your account, you have the possibility of filling in the contact details for one or multiple people (other travel participants, emergency contact…).
In this case, the data filled in for the other people will only be used by Eluxfrance to ensure that the quote request is processed and then, for the creation of your holiday. If Eluxfrance wishes to use other people’s data for another purpose than those listed above, Eluxfrance will seek their consent beforehand.
Therefore, you guarantee that the other people, whose data you communicated to Eluxfrance, are informed of this transfer regarding their information and accept it.
Eluxfrance will inform the people whose personal data it has collected indirectly, about their rights under this policy, during its first communication to these other people, informing them by email and including all useful information for organizing their trip.
The different Communication Channels aren’t, in theory, intended to be used by minors without their parents’ or legal guardian’s authorization. A minor that is at least 16 ears old can request a quote with the aim of organizing a trip and provide the necessary personal data for this purpose. Eluxfrance shall make an effort to verify, in view of the information provided and the technological means available, the minor’s age. By no means will the minor be able to finalize, confirm and pay for the trip without the consent of their legal guardian.
Eluxfrance makes a reasonable effort to verify that consent is given or authorized by the legal guardian in regards to the minor, in view of the available technological means.
d) Sensitive data
Eluxfrance may have to collect data of a particular category such as health data (handicap, allergy or specific conditions) and indirectly know the religion, beliefs or personal convictions of the people affected, even though this data collection is never done directly and is only made by deduction (this is the case for your diet). This data is only collected for organizing transport needs and/or the trip of the person concerned and will not be used in any other way.
II. FOR WHAT PURPOSES IS YOUR DATA COLLECTED?
We only collect personal data when we have a legal basis to do so.
The personal data collections described above are carried out because they are (i) necessary for enforcing the contracts which you have taken out, (ii) necessary for the purpose of legitimate interest, in particular, to offer you suitable content, compile statistics, protect the Website against unauthorized use, (iii) necessary to conform with our legal obligations.
Apart from these cases, they are also collected based on your consent, for example when you fill in a contact form or a quote request, if you sign up to an email alert or when such consent is requested by law (for example, to send you an email with partners’ offers).
a) Answering your requests
When you contact Eluxfrance through the different Communication Channels mentioned above, collecting your personal data may have as an objective:
- Supplying access to the Website and access to your dedicated customer account allowing you, among other things, to peruse your quotes and/or any information relating to your trips.
- Implementing the requests that you made on the Website or through the other Communication Channels (booking through our partners, drawing up your sales contract, tracking the provision of services related to your trip, in accordance with the statutory periods of limitation…)
- Sending information newsletters and any other documentation (mainly brochures) that you have requested
- Answering your questions
- Informing you of new trips or similar services that could interest you
- More generally, complying with Eluxfrance’s legal, regulatory, accounting and tax obligations
- Processing the requests and complaints made by or for yourself and pertaining to travel
b) Compiling statistics
For the purpose of improving our services, your personal data is collected by Eluxfrance for the following reasons:
- Statistical calculations, especially for Website traffic
- Conducting surveys and polls
- Carrying out studies and research in order to improve your experience with Eluxfrance
c) Seeking your feedback in the event of marketing operations
Your data can also be used for commercial purposes:
- Managing any subscription or cancellation to information newsletters upon your request
- Communicating information related to Eluxfrance and its partners: new features, products and services, commercial prospecting and personalized offers
III. HOW AND FOR HOW LONG?
a) Securing your data
Being the controller of your data processing, Eluxfrance implements all technical and organizational measures that are necessary to comply with protecting your personal data: access control, safeguarding, traceability, secure premises, protective measures, seeking to limit the amount of data being processed in view of the pursued purposes.
b) Data storing period
We store this information for a proportionate period of time, necessary for the purpose for which we process them and, in any event, for the necessary period of time in order to comply with legal or regulatory obligations. The data is stored for a duration that doesn’t exceed the period of time necessary for the following purposes:
- Newsletter: your data will be stored for as long as your membership is active. You can end it at any time and unsubscribe by clicking on the link that will be sent to you.
- Quote request for travel services, subscribing to and carrying out travel services: the data necessary to processing your request will be stored for the time period necessary for drawing up a quote or a contract and for the duration of your trip, in accordance with the relevant legislation, and in any case, for the period of time necessary to comply with legal or regulatory obligations.
- Commercial offers: your data will be stored for as long as you agree to receive our commercial offers. You can reject them at any time and unsubscribe by clicking on the link that will be sent to you.
- Statistics and surveys: your data will be stored for the period of time necessary to compile reliable statistics and process your surveys that were carried out with your approval.
In any case, in the absence of any contact from you over a period of 5 years, your personal data will be archived for five additional years before being permanently deleted or made anonymous.
In some cases, we can keep some of your personal data, due to legal obligations, or if there is a problem regarding your trip, for example the presence of a complaint or an unresolved dispute. In this case, the data necessary to resolving the problem or dispute will be stored for the duration of the dispute within the limits of applicable rules regarding the statute of limitations.
IV. FOR WHICH RECIPIENTS?
a) Eluxfrance and its partners
We wish to inform you that, in order to fulfil the purposes mentioned in the above paragraph, your data can be stored, processed and transmitted to Eluxfrance’s subsidiaries and/or partners, in particular reserved service providers (hoteliers, transporters…) or technical service providers (computing, accommodation, email distribution, online payment service provider etc.), who could be located outside of the European Union and whose applicable data protection legislation differs from that applicable in France.
Our subsidiaries and/or partners commit to only using your personal data to execute some tasks that are indispensable for fulfilling the purposes mentioned in the above paragraph, in strict compliance with your rights regarding personal data protection and in accordance with current legislation.
Such transfers are subjected to adequate safeguards in accordance with applicable regulations regarding protecting personal data.
b) Non-partner third parties
Eluxfrance undertakes not to transfer or sell your personal data to non-partner third parties. We will not communicate any personal data to agencies or companies for marketing or commercial purposes.
If the law, an authority (for example, the tax administration or the National Commission on Informatics and Liberties (CNIL)) or a judge should compel Eluxfrance to communicate your personal data, Eluxfrance, commits to informing you, whenever possible (unless Eluxfrance is not authorized to do so, particularly in view of legal or judicial obligations that could fall upon them).
Finally, it is possible that we buy or merge with or be bought by another company or that we transfer all or a part of our assets. In such a case, your personal data could be communicated to another company, but this communication will be subjected to the current policy regarding confidentiality and cookie protection.
V. HOW DO THE LINKS ON THE WEBSITES THAT REDIRECT ME TO OTHER WEBSITES AFFECT ME?
We can, on occasion, place links on our Website than redirect to other websites and applications operated by third parties. These links are only there for your convenience and aim to bring added value to your visit. However, by including these links, we don’t have any control over these websites and applications, that are independent from Eluxfrance and have their own policies regarding confidentiality protection.
When you leave our Website, know that our policies cease to apply. Thus, we will not be held responsible for the exactitude, the relevance, the availability, the reliability, the respect of copyrights, the legality, the decency of third party website and application content linked to our Website. We strongly urge you to consult the conditions and policies regarding confidentiality protection of any third party website and application before using the websites.
VI. HOW DO I ACCESS MY PERSONAL DATA? HOW DO I CORRECT OR DELETE IT OR EXERCISE MY OTHER RIGHTS?
a) Access and copy
You have a right to access and communicate your personal data.
Before responding to your request, we are obligated, under law, to verify your identity. We may have to ask you to supply more information to respond to your request. We will strive to process your request at the earliest opportunity. Contact us through the “Contact Us” heading.
b) Correcting inaccurate personal data
You also have the possibility to request the correction of your personal data that is incorrect and limit its processing for the time needed to correct it. You also have the right, depending on the nature of the process, to request that the personal data in our possession be completed. We may, in this case, ask you for documentary proof. Contact us through the “Contact Us” heading.
c) Withdrawing your consent regarding the processing of your personal data
d) Deleting your personal data
You can also request that your personal data be deleted in the following cases:
- You believe that our processing of your data is no longer necessary in regards to the subscribed Services or your use of the Website, fulfilling the purposes mentioned above in this policy or that their storing is unlawful
- You have withdrawn your consent to the processing of your data (see above “Withdrawing your consent regarding the processing of your personal data”)
- You are opposed to the processing of your personal data for reasons relating to your personal situation
- You are opposed to the use of your data for commercial prospection services
- Your data has been collected online when you were a minor
Alternatively, you can, within the limits provided by the law, request that the processing of your personal data be limited. Contact us through the “Contact Us” heading.
Please note that, notwithstanding the exercise of your right to the deletion or limitation, we may keep some of your personal data when we are required or permitted to by law, when we have a legitimate reason to do so, for the exercise or protection of rights in the courts or when the exercise of this right violates the right to freedom of expression and information.
e) Giving us your post mortem directives
You also have the right to define the directives relating to the fate of your Personal Data after your death.
For any question regarding this data protection policy or for any request relating to your personal data, you can contact us:
Online, by sending an email to the following address: firstname.lastname@example.org
By post to the following address:
11bis rue Albert Joly
Furthermore, you are informed that you have the right to bring before the National Commission on Informatics and Liberties (CNIL) any claim regarding the processing of your personal data.
We may modify this policy from time to time to reflect the changes in our practices, to better clarify our practices or to enforce safety regulations.