Privacy Policy

CHARTER FOR THE PROTECTION OF PERSONAL DATA
The company Club Med SAS, registered under the number FC014776, (hereinafter the "Club Med" or "we"), attaches great importance to the protection of your personal data and attentively observes the respect of the provisions protection of privacy and the processing of personal data, in particular the European Regulation on the protection of individuals with regard to the processing of personal data and the free movement of such data (EU Regulation 2016/679 of April 26, 2016), the law of January 6, 1978 called "Computing and freedom" amended in 2004 as well as recommendations from ICO (Information Commissioner’s Office).
The purpose of this Privacy Policy (hereinafter the "Charter") is to describe how and when Club Med, as data controller, collects, uses and discloses certain personal data (hereinafter referred to as "Data Protection"). Data ") that you send to him to meet your needs but also to optimize and improve the quality of the services we offer.
1. In what assumptions does this Charter apply?
2. What Data is collected by Club Med?
3. How do we use the Data we collect?
4. Which cookies are used by Club Med?
5. How long do we keep your Data?
6. What are the categories of recipients of your Data?
7. What is the legal basis for your data?
8. What are your rights?
9. Is your Data being transferred outside the European Union?
10. The protection of your Data by Club Med.
11. Revision of the Charter

1. WITH WHICH ASSUMPTIONS DOES THIS CHARTER APPLY?
This Charter informs you about how to collect, process and use your Data when:
you book a package-stay with Club Med;
you visit the Club Med website or our mobile application (hereinafter the "Site");
subscribe to our Club Med news (product information & promotional offers) and personalized content;
you contact our customer service department;
you participate in our quizzes.
2. WHAT ARE THE DATA COLLECTED BY THE MED CLUB?
2.1 The information you send us directly
You transmit us Data including:
when you register on the Site by completing various forms relating to your account or loading Data;
when you subscribe to a package-stay;
when you participate in a quiz;
when completing a Club Med questionnaire;
when you contact our customer service department.

This information may for example contain:
your name (s) and first name (s),
your date of birth,
your sex,
your postal address,
Your email address,
your phone number (s),
your means of payment,
your booking history.
The same goes for all the information you give us about people for whom you book a package. You agree here to obtain their prior consent to communicate their Data.
You can choose not to give us certain information; however, this decision may deprive you of some of the services and features we offer. Information essential to the provision of our services and features is identified by an asterisk on our collection forms.
2.2 Data collected automatically
When browsing the Site, Club Med may collect, in strict compliance with the applicable legislation and your rights, data relating to:
the characteristics of the operating system, browser or devices (computer, tablet, smartphone) that you use to access our services;
your location such as your IP address;
your browsing history and your interactions with the content of the Site, such as the pages visited, the search keywords used, the frequency of your visits to the Site, the advertisements you click on.
3. HOW DO WE USE THE DATA WE COLLECT?
The browsing data is collected in particular by means of cookies. For more information about these cookies, please see article 4.
3.1 Data from other sources
We may also collect Data via third parties, including social networks, when you use the account you hold with these third parties to register or connect to our services. During this use, you are informed of the Data that the third party transmits to us.
We use, store and process your Data to process your inquiries, manage our business relationship, optimize our services and tools to create and maintain a more secure trust environment, and to comply with our legal obligations as we specify herein. -after.
3.2 Executing the contracts concluded between us
We use your Data to enable the management of your subscription to a package-stay and the execution of the various services related thereto.
Your data will be used to collect your payments, inform you by SMS, email or any other means of communication on the terms of execution of the contract that binds us (information on your trip, on possible delays in transport, offer of additional services to your package-stay, etc.).
As part of our business, we may use commercial partners whose mission is to provide certain services on our behalf.
For example, we do not have our own fleet of planes, trains or buses. We are thus obliged to conclude contracts with carriers to be able to propose you a routing towards our villages. As a result, some of your Data (surname, first name, date of birth, etc.) will be forwarded to the carrier so that he can issue your ticket.
However, our business partners may not use your Data for purposes other than those necessary to fulfil the services you have requested. Finally, they are obliged to treat them in strict compliance with the legislation in force.
3.3 Provide you with access to the Site and certain services
The Data you provide allows us to identify you in order to access your Account which access is restricted to authenticated persons.
3.4 Send you our Club Med news and personalized content
If, at the time of the reservation of a stay-package, the creation of your account on the Site or later, you ticked the box or filled the form that allows you to receive Club Med news (product information and offers Club Med promotions) and personalized content, so we may use your Data to communicate to you, depending on your preferences (including email, SMS, phone or mail):
information relating to the Site;
invitations to Club Med events that may interest you;
information about our offers;
information on Charter updates or security measures.
You may, at any time, object to the commercial communications of the Club Med Group (i) by clicking on the unsubscribe link or by following the opposition procedure indicated on these communications, or (ii) by contacting us as described in Article 6 below.
We may also use your Data to send you advertising messages that may be of interest to you on third-party sites or social media platforms. For further information on this subject, we invite you to read the conditions relating to the use of your Data directly on these sites and / or platforms of third parties.
3.5 For profiling purposes
We may also process your Data as part of profiling operations.
Profiling consists of automated data processing operations designed to analyse, anticipate and evaluate your interests and preferences in order to send you personalized content and commercial offers tailored to your specific needs.
Club Med will only share your Data with third-party providers to determine your profile and preferences with greater accuracy and thus send you more relevant Club Med content. In any case, Club Med will not communicate your Data to commercial partners.
You may, at any time, object to the use of your Data for profiling purposes by accessing your Customer Account or by contacting us as described in Article 6 below.
3.6 Optimize the Site and our services
We use your Data to conduct studies, technical tests (including an anonymization of your Data), deduplications, which allow us to improve and optimize the Site and customize our tools and services. For example, it will ensure that the display of our various content is adapted to the terminal that you use, or allow us to host your data to even more secure servers, etc.
3.7 Deal with your complaints
When you contact our customer service by telephone, via the contact form available on the Site or any other means provided by Club Med (social networks, chat, etc.), we use your Data (including record your calls with your prior agreement) for:
answer you and provide a solution to your complaint;
ensure and manage the follow-up of your claim;
improve the customer relationship service.
3.8 For internal statistics and surveys
We may use your Data to perform various statistical studies and / or solicit you to participate in our own surveys.
3.9 Ensuring respect for the law and court decisions
Your data can be used for:
respond to a request from an administrative or judicial authority, a representative of the law, an auxiliary of justice or comply with a court order;
ensure compliance with our terms and conditions and the Charter;
protect our rights and / or obtain compensation for any damage we may suffer or limit its consequences;
to prevent any act contrary to the laws in force, in particular in the framework of the prevention of the risks of fraud.
3.10 Manage your participation in the Contests
When you participate in a quiz, you provide us with a certain amount of Data. They are essential to take into account your participation, and if necessary, the delivery of the lot.
In addition, with your prior and express consent, we may use this Data to send you Club Med news (product information and promotional offers from Club Med) and personalized content.
4. WHAT COOKIES ARE USED BY THE MED CLUB?
4.1 What is a cookie?
When you use the Site, Club Med may deposit on your device (computer, tablet for example), through your browser, a file called "cookie". It allows, during its registration period, to identify your computer during your next visits. Thus, each time you visit the Site, the Data of your previous visit can be kept.
4.2 Which cookies are used by Club Med?
Club Med uses, in particular, the cookies listed in the appendix of this document.
a) Cookies necessary to provide the requested services
Club Med may use cookies strictly necessary to provide the services or information you have requested, including:
cookies "session IDs to your Customer Account";
"shopping cart" cookies;
authentication cookies;
load balancing session cookies ("load balancing");
persistent cookies customizing the user interface;
audience measurement analysis cookies ("statistical cookies").
Data collected by statistical cookies are not cross-checked with other treatments (or previously anonymized) and are used only for the production of anonymous statistics.
These cookies do not make it possible to follow your navigation towards other sites, nor to geo-locate you precisely.
You can simply oppose cookies, including statistical cookies (see below "Disabling cookies").
b) Cookies for monitoring and personalization
Certain cookies make it possible to analyze, optimize and personalize your navigation on the Site. They may also allow automated processing of your Data in accordance with the terms and conditions specified in Article 3.4. These are installed only with your prior consent and express.
c) Monitoring and customization cookies
During your browsing on the Site, cookies issued by third parties (communication agency, audience measurement company, targeted advertising provider, etc ...) may allow these, during the period of validity of these cookies. (i) collect browsing information about the devices viewing the Site; and (ii) determine advertising content that may be relevant to your interests. The issue and use of cookies by third parties are subject to the cookie management policies of these third parties.
5. DURING WHAT TIME ARE WE RETAINING YOUR DATA?
In general, your Data is kept only for the time necessary to complete the operations for which it was collected.
Here are the different retention periods of the data collected by Club Med:
the Data which has been sent to us directly as detailed in Article 2.1 are kept for the period necessary for the purpose of their processing;
the Navigation Data is retained for a maximum of 13 months;
Prospect Data is retained for a maximum of 3 years from the last contact you initiated with Club Med;
the Data relating to the identity documents that you transmit to us when you exercise your right of access or rectification are kept for a maximum period of 12 months;
the information allowing to take into account the rights of opposition of the persons concerned to receive commercial prospection are preserved for a maximum duration of 3 years as from the exercise of this right.
We may also delete your Data on request from you.
However, at the end of the aforementioned deadlines, including your request for deletion, your Data may be stored in order to meet our legal, accounting and tax obligations (eg: obligation to keep invoices for 6 years) in accordance to HM Revenue and Customs (HMRC)) and / or during the applicable limitation period and / or in contentious proceedings for the duration of said proceedings.
6. WHAT ARE THE CATEGORIES OF RECIPIENTS OF YOUR DATA?
We may share your Data with different third parties, including:
with our affiliated entities to provide you with the services requested or acting as a subcontractor in accordance with the Applicable Legislation;
our business partners, our suppliers and / or subcontractors who process your Data on our behalf, according to our instructions, for the purposes detailed in Article 2 (in particular transport companies, insurance companies, customs authorities, receptive service providers , financial institutions, technical subcontractors, etc.). We take special care to ensure that these third parties provide sufficient safeguards to ensure the protection and security of your Data;
the duly authorized French or foreign authorities, in particular in the context of a legal action or a request for communication of information.
7. WHAT LEGAL BASIS ARE YOUR DATA PROCESSED?
In accordance with the Legislation in force, to process your Data, we rely on various legal bases, and in particular:
your prior and express consent to the processing of your Data for one of the purposes referred to in Article 3;
the execution of the contract that binds us;
the need to comply with a legal obligation or to defend ourselves in the event of legal proceedings;
the realization of the legitimate interest that Club Med pursues;
safeguarding your vital interest.
8. WHAT ARE YOUR RIGHTS?
8.1 Your rights of access, rectification, deletion and opposition
You are able to ask us to access, correct, update or erase personal information about you.
You also have the right to object to the processing of your Data.
8.2 The right to portability of your Data
The right to portability gives you the opportunity to recover some of the Data that concerns you, namely:
the Data you have provided directly to us as detailed in Article 2.1;
the Data generated by your activities on the Site as detailed in Article 2.
We will endeavour to comply with your request within a reasonable time and, in any case, within the deadlines set by the Legislation in force.
8.3 Define guidelines on the fate of your Data
You have the right to set general or specific guidelines for the retention, deletion and communication of your Post-mortem Data.
8.4 Contact
To exercise all these rights, you must send a mail to the following address: Club Med, Customer Relations Department, Connect House, 133-137 Alexandra Road, SW19 7JY London, United Kingdom, enclosing with your request a copy of your document 'identity.
At any time, if you feel that your rights have not been respected, you have the option to make a complaint to the Club Med Customer Relations Department, at Club Med, Customer Relations Department, Connect House, 133-137 Alexandra Road, SW19 7JY London, United Kingdom.
You can, at any time, bring a claim before the competent supervisory authority (in the UK, ICO (ico.org.uk).
9. ARE YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?
We may transfer your Data to countries outside the European Union for the sole purposes described in this Policy.
For each of these transfers, we ensure that your Data has a level of protection equivalent to that offered in Europe.
Transfers are made exclusively to countries that are recognized as providing an adequate level of data protection by the European Commission.
In the event that the data are transferred to a country that does not offer an adequate level of protection, the Club Med Group and its partners or service providers undertake to supervise the transfer by means of appropriate guarantees (such as contractual clauses). European Commission types) which can be requested from the DPO address indicated above.
10. THE PROTECTION OF YOUR DATA BY THE MED CLUB
Club Med undertakes to guarantee the integrity and reliability of the Data entrusted to it, in particular by taking all the physical, organizational and logistical measures necessary to prevent any alteration or destruction of such Data, in particular by ensuring secure access only to authorized to treat them.
11. REVISION OF THE CHARTER
Club Med may have to modify this Charter, especially if the current legislation changes. Any changes will be posted on this page.
LIST OF COOKIES USED BY CLUB MED
This list is updated regularly by Club Med; last updated: October 15, 2018
Editor: Adobe Analytics
Name of the cookie / Purpose:
Cmcid / C_m: to identify the origin of a visitor when it arrives on the Site
s_cc: to know if the parameters of the navigator of the Net surfer allow or not the implantation of cookies
s_sq: to know what was the previous page visited
s_vi: to identify the different routes on the
iccm Website : to recognize the visitor on our entire website
Cookie retention period: 13 months maximum

Publisher: Google Analytics Premium (GAP)
Name of the cookie: _ga
Purpose: to distinguish the users of the site in the solution (takes a random ID)
Duration of conservation of the cookie: 13 months maximum

Publisher: Neolane
Name of the cookie: neolaneID
Purpose: to identify prospects and customers in Club Med base who are browsing the site (takes their ID in base)
Cookie retention period: 13 months maximum

Publisher: Kameleoon
Name of the cookie: kameleoonVisitIdentifier / kameleoonSessionId
Purpose: to test new features of the Site Cookies
retention period: 13 months maximum

Publisher: DoubleClick
Cookie Name: DoubleClick "ID" cookie
Purpose: allows DoubleClick to offer a better level of advertising. They serve to serve search-targeted ads, improve campaign performance reporting, and prevent replay of ads that users have already seen.
Shelf life of the cookie: 13 months maximum

Publisher: AdmotTV
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Freespee
Name of the cookie: __fs_dncs_exttrack
Purpose: Freespee tracking information Cookie
retention period: 13 months maximum

Publisher: Freespee
Cookie Name: __fs_dncs_sessionid
Purpose: Freespee Tracking Information Cookie
Retention Period : 13 months maximum

Publisher: Freespee
Cookie Name: __fs_dncs_trackingid
Purpose: Freespee Tracking Information Cookie
Retention Period: 13 months maximum

Publisher: Google analytics
Name of the cookie: gat_cmTracker
Purpose: Google Analytics statistics Cookies
retention period: 13 months maximum

Publisher: Tradelab
Name of the cookie: _tlc; _tls; _tlv
Purpose: Allows the display of targeted advertisements on third party sites.
Cookie retention period: 13 months maximum

Publisher: Criteo
Name of the cookie: uid, tc, nxtck_srv
Purpose: to identify the users who navigate on the site
Cookie retention period: 13 months maximum

Publisher: Nextperformance
Name of the cookie: ccv2
Purpose: to identify the users who navigate on the site
Cookie retention period: 13 months maximum

Publisher: Facebook
Purpose: to identify the users who navigate on the site
Cookie retention period: 13 months maximum

Publisher: Adobe
Purpose: to identify the users who navigate on the site
Cookie retention period: 13 months maximum

Publisher: Ligatus
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Gemini
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Google Adwords
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Bing
Purpose: to identify the users who navigate on the site
Cookie retention period: 13 months maximum

Publisher: DoubleClick
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Lengow
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Quantum
Purpose: to identify the users who navigate on the site
Cookie retention period: 13 months maximum

Publisher: Spin
Purpose: to identify the users who are browsing the site
Cookie retention period: 13 months maximum

Publisher: Tradedoubler
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

Publisher: Outbrain
Purpose: to identify users browsing the site
Cookie retention period: 13 months maximum

HOW TO BLOCK COOKIES?
You can set your browser to change your consent or express your refusal of cookies.
You can either accept all cookies, or be notified when a cookie is placed, or refuse all cookies. If you refuse all or part of cookies, some features of the Site may be compromised or some pages inaccessible.

To disable cookies:
If you are using Internet Explorer 8. and following:
Go to "Tools" in the menu bar and click on "Internet Options"
Click on the "Privacy" tab at the top
Drag the cursor up to the "Block all cookies" setting to block all cookies, or down to the "Accept all cookies" setting to accept all cookies.
For more information, visit https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

If you are using Firefox 30.0 and later:
Click the "menu" button and select "Options"
Select the "Privacy" panel.
In the History box, for the "Retention rules" option, select "Use custom settings for history."
Check the "Accept cookies" box to enable cookies, or uncheck them to disable them.
If you have problems with cookies, make sure the "Accept third-party cookies" option is not set to Never.
Choose how long cookies can be kept.
Keep them until: "Their expiration": Each cookie will be deleted on its expiry date, date fixed by the website issuing the cookie.
Keep them until: "Firefox Shutdown": Cookies saved on your computer will be deleted when you close Firefox.
Keep them until: "Ask Me Every Time": A warning appears each time a website wants to send a cookie, asking you whether you agree to save the cookie or not.
Click OK to close the "Options" window
For more information, see https://support.mozilla.org/en/products/firefox/privacy-and-security/cookies

If you use Google Chrome:
Go to the "Tools" menu
Click on "Settings"
Click on "Advanced Settings"
Click on "Privacy / Content Settings"
"Cookies" must be selected. Then select "Block cookies and data from third-party sites".
For more information, see https://support.google.com/chrome/answer/95647?hl=en

If you are using Safari 5.0:
Choose Safari> Preferences and click on "Security".
In the "Accept cookies" section, indicate if and when Safari must accept cookies from websites. To see an explanation of the options, click
the Help button (looks like a question mark). If you have set Safari to block cookies, you may need to temporarily accept cookies to open a page. Repeat the above steps, selecting "Always". When you are done with the page, turn off cookies again and delete cookies from the page.
For more information, see https://support.apple.com/en-us/HT201265 If you have a different browser type or version, you are invited to consult the "Help" menu of your browser.