1. General information
The present confidentiality policy (hereinafter the “Confidentiality Policy”) applies to personal data (hereinafter the “Personal Data”) processed by LION DE MONTAGNE, a limited liability company, whose registered office is located in ANNECY (74000), 129 avenue de Genève, registered in the Annecy Trade and Companies Register under number 810 607 325, Code APE 6201Z, intra-community VAT number FR74810607325 (hereinafter “ChaletOwners”) on the occasion of any relationship with its prospects, customers and users (hereinafter together referred to as the “Users”) through the browsing and use of the website https://www. chaletowners.com/ (hereinafter referred to as the “Site”) by any individual who has access to the Site or uses the commercial services of ChaletOwners.
The term “Personal Data” refers to information that directly or indirectly identifies a User, such as his/her name, e-mail address, the property rented on the Site, his/her personal interaction with the Site, etc.
2. Scope of Application
- the Users of the Site,
- clients and prospects of ChaletOwners as well as their representatives, natural persons,
- suppliers and business partners and their representatives, natural persons.
3. Processor and contact
ChaletOwners and any of its affiliated entities are responsible for the processing of Users’ Personal Data.
4. Nature of the Personal Date processed
ChaletOwners is likely to process Personal Data of Users collected both :
- offline : direct interaction between the ChaletOwners teams and a User, a natural person, in particular by any request for information, telephone or email exchanges, drawing up of contracts, an exchange by message on the Site, an appointment to visit a property advertised, intervention with the tenant, etc.
- and online : use of the Site, activity on the website, creation of an account, operations of creation of an online advertisement, management of rentals, exchanges with any dialogue box on the Site, exchange by instant messaging on the site between Users, etc.
The Personal Data of any User that ChaletOwners is likely to collect and process include the following :
- name, first name, title, physical address, e-mail addresses and telephone numbers ;
- individual user IDs and passwords ;
- identification and characteristics of the rental property ; rental conditions ;
- any conversational or no-conversational exchange between Users on the Site ;
- commercial and accounting data, rights and limitations of acces to the site created by ChaletOwners, financial details and methods of payment, establishment and archiving of invoices ;
- IP address and information derived from the IP address, including geographic location, technical characteristics of the device used to access the Site ;
- Any information about a device used, such as browser, device type, operating system, technical characteristics of the device used, screen resolution and language used ;
- Behavioral data from the computer or device connected to the Site, such as content areas or date and time of activities.
5. Purpose of the processing of Personal Data
ChaletOwners processes the Personal Data of the Users, mainly for the proper performance of its contractual obligations relating to the provision of the Site and its operation in accordance with its purpose. More precisely, ChaletOwners processes Personal Data for the sole purposes defined below :
- To allow access, interaction, operation, hosting, security and corrective and evolutionary maintenance of the Site, of all its services and purposes;
- To execute and ensure the execution of any contractual obligation related to the general conditions of use and sale for advertisers and the general conditions of use of the Site : management of advertisements posted on the Site, management of rental schedules ;
- Concerning any user of the Site proceeding to a request for information on an advertisement, to allow the automatic creation of its account and the sending of its access identifiers by email;
- Particularly, to control the exchanges by messaging on the Site between Users to ensure the respect of the general conditions of ChaletOwners;
- Communicate and respond to questions and inquiries from any User: contact form, email or telephone exchanges, etc;
- Carry out transactions with advertisers, suppliers and business partners;
- To manage the archives, invoicing, accounting and more generally, the normal functioning of the relationship between the Users and ChaletOwners;
- To comply with the Regulations, and more generally, with the laws and regulations in force.
6. Lawfulness of Processing of Personal Data
ChaletOwners has the following legal bases for processing Users’ Personal Data :
Performance of its contractuel obligations :
- Including advertisers’ terms and conditions of sale and use and the Site’s terms and conditions of use, only when the performance of these contracts requires the processing of Users’ Personal Data;
- to carry out any transactions with ChaletOwners’ client Users, suppliers and business partners, and to process the creation of Users’ accounts.
Legitimate interest :
- in particular to control exchanges between Users on the Site and to avoid any eviction from ChaletOwners’ services and generally, any fraud and agreement contrary to Users’ commitments;
- To proceed to any modification or adaptation of the Site and to ensure its security;
- To analyze the volume and history of the Site, and more generally, to carry out any statistics concerning the use of the Site;
- To carry out controls, audits, restructuring operations or transfer of control or any similar legal operations, ChaletOwners ensuring that any third party involved in these operations is bound by a professional or contractual obligation of confidentiality.
Fulfillment of its legal obligations :
- To comply with obligations regarding bookkeeping, invoicing, tax returns and any other regulations related to the normal and current operation of a company
- To comply with applicable laws and regulations, or any legal process, or to exercise the rights of Users.
7. Sharing of Personal Data
ChaletOwners may share the Client’s Personal Data under the following conditions:
- Sharing within ChaletOwners: ChaletOwners’ subcontractors and employees are authorized to access Personal Data only to the extent necessary to perform their functions;
- Sharing with third parties: only the third party service providers of ChaletOwners strictly necessary for the operation of the Site (data hosts, possible online payment processing services, security and maintenance of the Site, order processing services, event or advertising campaign management, services performed for Users, audits and other similar service providers are likely to know and process Personal Data;
- Third parties in the event of a restructuring, merger, sale, joint venture, assignment, transfer or other disposition of all or part of ChaletOwners’ business, assets or shares;
- As required by law, including to comply with a subpoena or other legal process, where disclosure is necessary to protect the rights of the User or ChaletOwners, to protect the safety of ChaletOwners, the User or the safety of others, to investigate fraud, or to respond to requests from the state, including public authorities.
8. Length of retention of Personal Information
ChaletOwners may keep Personal Data for the following retention periods:
- The Personal Data collected for the management of transactions with clients, suppliers and commercial partners of ChaletOwners, will be kept for the duration of the contract in question, and for the entire legal prescription period, it being specified that the data not essential to the designation of the contract and the financial and accounting transactions may be automatically deleted within thirty-six (36) months following the end of the contract, the other data being then partially kept;
- The Personal Data collected from any User are kept as long as his account is considered active on the Site, then are deleted in the absence of connection to the Site after thirty-six (36) consecutive months, except for the Personal Data necessary to identify the User, his dates of account creation and connections, his last activities on the Site, kept for the duration of legal requirements before being automatically deleted;
- The Personal Data of any subscriber to the ChaletOwners’ newsletter mailing list and similar communications, kept until the request to unsubscribe to this mailing list, these data being then deleted within ninety (90) days following this request;
- The Personal Data of any User, such as name, first name, e-mail address or telephone number collected online on the Site when using the contact form, creating a rental ad, managing rentals and any exchange with ChaletOwners will be kept as long as ChaletOwners keeps an active relationship with this User. An active contact is considered to be (i) the maintenance of an active client account on the Site; (ii) the User’s interaction with ChaletOwners or the updating of contact and reference information within the last thirty-six (36) months.
9. Rights of the Users and the persons concerned
In accordance with the aforementioned Regulation, any User or natural person concerned by the processing of Personal Data by ChaletOwners has the right to access, oppose, rectify and delete personal data concerning him/her. He/she may exercise this right, under the restrictive conditions of the Regulation, upon simple request to the DPO. He also has the right to refuse any automated processing and the right to refer to the CNIL.
The right to the deletion of personal data of Users shall not be applicable in cases where the processing is implemented to meet a legal obligation.
The User also has the right to refuse in writing any processing and profiling based on his/her personal data and the right to refer to the CNIL.
To assert his rights :
Contact the ChaletOwners DPO :
- At the following e-mail address : firstname.lastname@example.org ;
- By registered letter addressed to ChaletOwners - Service Données Personnelles - 129 avenue de Genève - 74000 ANNECY.
Requests will be processed and applicants informed within sixty (60) days from the date of acknowledgement of their request.
10. Google Maps
The Site uses the Google Maps and rentals technology of the Google Maps service owned by Google LLC, 1600 Amphitheatre Parkway, Mountain Viex, CA 94043 USA, in particular to allow the geolocation of the real estate put on the Site. Users are not geolocated by this or any other technology.
Some Personal Information is collected automatically by the User’s actions on the Site. ChaletOwners uses cookie technology and tracking in order to improve and personalize the use of the Site and/or measure the audience.
The cookies used by ChaletOwners are intended to allow or facilitate communication, the provision of services requested by the Users, the proper functioning of the Site and to recognize the Users when they connect to the Site.
For the management of cookies on any browser, the User can refer to the recommendations of the CNIL at the following address: https://www.cnil.fr/fr/les-conseils-de-la-cnil-pour-maitriser-votre-navigateur.
12. Location of data storage and transfers
The hosting servers on which ChaletOwners processes and stores its databases are located exclusively within the European Union:
Southeast AMS 5 Schepenbergweg 42
1105 AT Amsterdam
Within the framework of its services and the management of the Site, ChaletOwners attaches the utmost importance to the security and integrity of Personal Data.
Thus, and in accordance with the Regulations, ChaletOwners undertakes to take all necessary precautions to preserve the security of the Personal Data and in particular to protect them against any accidental or illicit destruction, accidental loss, alteration, unauthorized distribution or access, as well as against any other form of illicit processing or communication to unauthorized persons.
In order to comply with this policy, ChaletOwners has put in place technical and organizational measures to ensure the highest level of security and confidentiality of Users’ Personal Data.
In addition, in order to prevent unauthorized access, to ensure the accuracy and proper use of Personal Data, ChaletOwners has put in place appropriate electronic, physical and managerial procedures to safeguard and preserve the data collected through its services and the Site.