Privacy Policy

1. Data Controller

The controller of personal data processing carried out on the Prestige Hôtellerie website is:

LEADER EXPERTISE
Simplified joint-stock company (SAS) with share capital of €1,000
58 rue de Monceau
75008 Paris – France

• SIREN: 934 798 125
• SIRET: 934 798 125 00019
• RCS Paris
• EU VAT number: FR33 934798125

President: Mene Berre Leandre

Website: Prestige Hôtellerie
Email: contact@prestigehotellerie.com

2. Personal Data Collected

In the course of its activity, LEADER EXPERTISE may collect different categories of personal data.

The data collected depends on how the user uses the site and the services they use.

2.1. Identification and Contact Data

The following may in particular be collected:

• first and last name;
• email address;
• phone number;
• postal address;
• delivery address;
• billing address.

2.2. Order-related Data

When a Customer places an order, LEADER EXPERTISE may process:

• order number;
• products ordered;
• quantities;
• order amount;
• delivery address;
• billing address;
• order history;
• information required for order tracking;
• information relating to after-sales service requests.

2.3. Professional Customer Data

When the Customer acts in a professional capacity, LEADER EXPERTISE may also process:

• company name;
• contact position;
• business address;
• SIRET number or other professional identifier;
• EU VAT number;
• information required for the preparation of quotes and invoices.

2.4. Data Exchanged with Customer Service

When the user contacts LEADER EXPERTISE, the information they communicate may be retained in order to process their request and ensure customer relationship follow-up.

3. Payment Data

When a payment is made online, the banking data required for payment may be processed directly by the payment provider used by LEADER EXPERTISE.

LEADER EXPERTISE does not intend to retain the full bank card details of its Customers, except where this is expressly provided for and authorised within the framework of the payment service used.

Payment-related information may in particular include:

• the payment method used;
• the payment status;
• the payment date;
• the amount paid;
• a transaction reference.

Payment data is processed in accordance with the security rules applicable to payment service providers.

4. Technical Data and Navigation Data

When browsing the site, certain technical data may be automatically collected, in particular:

• IP address;
• browser type and version;
• operating system;
• type of device used;
• pages viewed;
• date and time of connection;
• data relating to navigation on the site;
• technical data necessary for the operation and security of the site.

Some of this data may be collected through cookies or similar technologies.

The conditions of use of cookies are detailed in the Cookie Policy, where a separate policy is offered on the site.

5. Purposes of Processing

Personal data is collected and used for determined, explicit and legitimate purposes.

It may in particular be used for:

Order Management

• record and process orders;
• prepare orders;
• organise their delivery;
• track shipments;
• manage returns;
• manage after-sales service;
• manage complaints.

Commercial Management

• prepare quotes;
• prepare and send invoices;
• manage payments;
• manage the relationship with Customers;
• respond to information requests;
• ensure commercial follow-up.

Customer Account Management

Where the site offers a personal space, the data may be used to:

• create and manage the account;
• allow the Customer to access their history;
• manage their information;
• ensure account security.

Site Security

Technical data may be used in order to:

• secure the site;
• detect fraudulent behaviour;
• prevent unauthorised access attempts;
• ensure the operation and maintenance of the site.

Commercial Prospecting

Subject to compliance with applicable rules, LEADER EXPERTISE may use the contact details of its Customers or prospects in order to send them commercial information concerning its products, services, offers or news.

Where consent is required, no electronic commercial prospecting will be carried out without obtaining the prior consent of the data subject.

Each electronic commercial communication allows its recipient to easily unsubscribe.

6. Legal Bases of Processing

LEADER EXPERTISE processes personal data on different legal bases depending on the purpose pursued.

Performance of the Contract

Certain data is necessary for the performance of the order or contract concluded with the Customer.

This concerns in particular:

• order management;
• delivery;
• invoicing;
• after-sales service;
• returns management.

Without this information, LEADER EXPERTISE may be unable to properly execute the order.

Compliance with a Legal Obligation

Certain data is retained or processed in order to comply with applicable legal and regulatory obligations, in particular regarding:

• accounting;
• invoicing;
• taxation;
• fraud prevention.

Legitimate Interest

LEADER EXPERTISE may also process certain data on the basis of its legitimate interest, in particular to:

• improve its products and services;
• ensure the security of the site;
• prevent fraud;
• manage the commercial relationship;
• develop its activity;
• produce commercial statistics.

Consent

Where required by regulation, LEADER EXPERTISE collects the consent of the data subject, in particular for certain cookies or certain prospecting operations.

The data subject may withdraw their consent at any time.

The withdrawal of consent does not call into question the lawfulness of the processing carried out before such withdrawal.

7. Mandatory or Optional Nature of Data

When certain information is necessary to process an order or provide a service, it is indicated as mandatory at the time of collection.

If the necessary information is not provided, LEADER EXPERTISE may not be able to:

• record the order;
• prepare the invoice;
• deliver the product;
• respond to certain requests;
• or properly execute the contract.

Information that is not necessary for the performance of the contract may be optional.

8. Recipients of Data

Personal data is accessible only to persons and organisations that need it in the course of their duties or missions.

This may in particular include:

• persons in charge of commercial management;
• persons in charge of accounting and invoicing;
• persons in charge of order preparation;
• logistics providers and carriers;
• IT providers;
• payment providers;
• providers responsible for hosting the site;
• providers involved in marketing or communication where necessary;
• consultants or providers acting for LEADER EXPERTISE where their intervention justifies it.

LEADER EXPERTISE does not sell the personal data of its Customers to third parties.

When LEADER EXPERTISE uses a processor processing personal data on its behalf, it ensures that the latter provides sufficient guarantees in terms of data protection and security.

9. Data Transfers outside the European Union

Certain technical or commercial providers used by LEADER EXPERTISE may be established outside the European Union or process certain data from a country located outside the European Economic Area.

When personal data is transferred to a third country, LEADER EXPERTISE ensures that the transfer is carried out in accordance with the GDPR.

Depending on the circumstances, the transfer may in particular be based on:

• an adequacy decision by the European Commission;
• standard contractual clauses adopted by the European Commission;
• or any other guarantee recognised by the applicable regulations.

10. Retention Period

LEADER EXPERTISE retains personal data only for the period necessary for the purposes for which it is processed.

As an indication:

Order and Commercial Relationship Data

It is retained for the period necessary for the management of the commercial relationship and may then be archived for the applicable legal periods.

Invoicing and Accounting Data

Certain data must be retained for the periods imposed by legal obligations, in particular accounting and tax obligations.

Prospects

Data used for prospecting purposes is retained for an appropriate period in accordance with applicable recommendations and rules.

A prospect showing no activity or interaction with LEADER EXPERTISE during the applicable period may be deleted or archived.

Technical Data

Technical data and connection logs are retained for the period necessary for their purpose, in particular to ensure the security and operation of the site.

The exact periods may vary depending on the nature of the processing and the applicable legal obligations.

11. Rights of Individuals

In accordance with the GDPR and applicable regulations, any person has, under the conditions provided by law, several rights regarding their personal data.

Right of Access

You may request confirmation that your personal data is being processed and, where applicable, obtain access to such data.

Right to Rectification

You may request the correction of inaccurate or incomplete personal data.

Right to Erasure

You may request the deletion of your personal data when the conditions provided by the regulations are met.

This right is not absolute, however: certain data must in particular be retained in order to comply with legal obligations.

Right to Limitation

You may request the limitation of the processing of your data in the situations provided by the GDPR.

Right to Object

You may object to certain processing of your data, in particular when it is based on legitimate interest.

You may also object at any time to the use of your data for commercial prospecting purposes.

Right to Portability

When the conditions provided by the GDPR are met, you may request to receive the personal data you have provided in a structured, commonly used and machine-readable format, or request its transmission to another controller.

Right to Withdraw Consent

Where the processing is based on your consent, you may withdraw it at any time.

12. Exercising Your Rights

To exercise your rights or obtain information concerning the processing of your personal data, you may contact:

LEADER EXPERTISE
58 rue de Monceau
75008 Paris – France

Email: contact@prestigehotellerie.com

In order to prevent any disclosure of data to an unauthorised person, LEADER EXPERTISE may request proof of identity where this is necessary and proportionate.

LEADER EXPERTISE endeavours to respond to requests within the timeframe provided by the applicable regulations.

13. Complaint to the CNIL

If, after contacting LEADER EXPERTISE, you consider that your rights relating to your personal data are not respected, you may file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL).

Official CNIL website: https://www.cnil.fr

14. Cookies and Similar Technologies

The Prestige Hôtellerie website may use cookies and similar technologies necessary for its operation or intended to measure its audience, improve the user experience or, where applicable and with the required consent, offer adapted content or advertisements.

Cookies strictly necessary for the operation of the site may be deposited without consent when they are exempt from consent in accordance with the applicable regulations.

Other cookies are subject to the applicable rules on consent.

Where necessary, the user may accept, refuse or configure cookies via the consent management mechanism offered on the site.

15. Data Security

LEADER EXPERTISE implements appropriate technical and organisational measures to protect personal data against:

• destruction;
• loss;
• alteration;
• unauthorised disclosure;
• unauthorised access;
• and any other form of unlawful processing.

Access to data is limited to persons who need it in the course of their duties.

However, no computer system or means of transmission over the Internet can guarantee absolute security.

16. Links to Third-party Sites

The Prestige Hôtellerie website may contain links to sites or services operated by third parties.

LEADER EXPERTISE is not responsible for the privacy practices of these third-party sites.

It is up to the user to read their own privacy policies when consulting them.

17. Update of this Policy

LEADER EXPERTISE may modify this Privacy Policy in order to take into account in particular:

• the evolution of its services;
• the evolution of the site;
• the evolution of regulations;
• recommendations from the competent authorities.

The applicable version is the one published on the site at the time of consultation.

The date of last update appears at the top of this document.

18. Contact

For any question concerning this Privacy Policy or the processing of your personal data:

LEADER EXPERTISE
58 rue de Monceau
75008 Paris – France

Email: contact@prestigehotellerie.com