LA VILLA BAHIA

 

PRIVACY AND COOKIE POLICY

 

 

LAST UPDATED: May 17, 2024

 

 

LA VILLA BAHIA, a public limited company a limited company registered in the state of Bahia Trade Register under the register number 29 2 0277266-1, and whose registered office is located at Largo Do Cruzeiro de Sao Francisco, 16 Pelourinho, Salavdor de Bahia, BA, 40.020-280, represented by its manager Bruno Guinard (hereinafter referred to as « VILLA BAHIA, » « we, » « our, » « us ») takes the protection of personal data very seriously. LA VILLA BAHIA is committed to complying with the provisions regarding the protection of personal data, particularly the amended Law of January 6, 1978, known as the « Informatique et Libertés » law, the General Data Protection Regulation 2016/679 (« GDPR »), and the recommendations of the CNIL (hereinafter referred to as the « Applicable Legislation »).

 

1. ABOUT THIS PRIVACY POLICY

 

As the data controller of your personal data, LA VILLA BAHIA wishes to explain in this privacy and cookie policy (« Privacy Policy ») how we may collect, use, and process personal data (« Personal Data ») transmitted by users when using the website(s) (« Site ») or our services (« Services ») by our customers or prospects.

 

2. HOW ARE PERSONAL DATA COLLECTED?

 

We may collect your Personal Data directly from you:

 

• when you book a stay at LA VILLA BAHIA
• when you communicate with our customer service via email or during our telephone conversations.

 

We may obtain information about you from other sources. For example, we may request a third-party provider to provide us with additional information about our existing customers, including information from your profile or your posts on a third-party social network.

 

We may also collect information from your profile on a third-party social network (such as Facebook) if you authorize the third-party social network to share them with us or if you make them publicly available online. This information may include general information about your account (e.g., name, email address, profile picture, gender, date of birth, current city, username, friend list, etc.) and any other information or activity that you authorize the third-party social network to share with us or that you make publicly available on your profile. For example, we may receive your social media information (or part of it) when you download or interact with one of our applications on a social network site (such as Facebook). To learn more about how your social media information may be obtained by us, please refer to the terms of use of the relevant third-party social network.

 

3. WHAT PERSONAL DATA DO WE COLLECT?

 

Personal Data is any information about a person from which that person can be directly or indirectly identified.

 

The Personal Data we collect from users of the Site or customers or prospects using our Services includes the following:

 

• your name(s) and first name(s);
• your date of birth;
• your gender;
• your postal address;
• your email address;
• your telephone number(s);
• your booking history;
• where applicable, special category of data such as health data (disabilities, allergies, or specific conditions) or data that may indirectly provide information about the religion, beliefs, or personal convictions of the individuals concerned (e.g., dietary requirements);
• any other information you may provide when using the Site or our Services.

 

4. WHY DO WE COLLECT PERSONAL DATA?

 

The processing operations and the legal bases for which we collect your Personal Data are as follows:

 

Processing	Legal basis for processing
·        Establishing your customer file and a history of stays to improve our knowledge of the customer within the time limits referred to in  Article 8	·        Our legitimate interest: the management of our customer database to offer the most suitable services
·        Execution of the Services (organisation of your stay, booking with our partners, follow-up of any requests made by you in connection with your stay, including after your return from your stay, in accordance with the statutory limitation periods, etc.);	·        Execution of the service contract (GTC)
·        The collection of your special category data for the sole purpose of organising your stay;	·        Your consent pursuant to Article 9 of the GDPR and the performance of the sales contract (GTC) pursuant to Article 6 of the GDPR
·        Statistical calculations, in particular concerning the number of visits to the Site;	·        Your consent (cookies)
·        Carrying out studies and research in order to improve your experience with LA VILLA BAHIA ;	·        Your consent (cookies)
·        The retention of Personal Data in order to meet our legal obligations and to manage requests for the disclosure of data from authorised authorities;	·        Meet our legal and regulatory obligations
·        The sending of marketing communications concerning our Services (such as newsletters) and any other documentation (brochures in particular) that you have requested in order to establish a commercial relationship;	·        Your consent
·        The communication of information relating to LA VILLA BAHIA and its partners: news, products and services, commercial prospecting and personalised offers;	·        Your consent
·        Managing complaints and claims in relation to Services.	·        Execution of the service contract (GTC)

5. WHO WILL RECEIVE YOUR PERSONAL DATA?

 

Your Personal Data is designated for use by the departments of LA VILLA BAHIA relevant to your inquiries. We guarantee that only authorized individuals can access your Personal Data when necessary for the stated purposes.

 

LA VILLA BAHIA commits to not transferring or selling your Personal Data to third parties that are not partners.

 

We may disclose your Personal Data to the following entities, in accordance with applicable legislation:

 

– Affiliated entities, to deliver the services you have requested;

 

– Business partners, specifically service providers you have booked (such as transporters, activity organizers, excursion providers, etc.) or technical service providers (including IT, hosting, email distribution, online payment services, etc.), ensuring they provide adequate protection and security for your Personal Data;

 

– Authorized Moroccan or foreign authorities (for instance, tax authorities or the CNIL), particularly in the context of legal actions or requests for information provision.

 

6. SECURITY OF PERSONAL DATA

 

As the party responsible for processing your Personal Data, LA VILLA BAHIA implements all the technical and organisational measures necessary to respect the protection of your Personal Data and takes care to limit the amount of data processed in relation to the finalities pursued. We have put in place procedures to deal with any suspected breach of data security and we will notify you and any competent supervisory authority of a suspected breach where we are legally obliged to do so.

 

However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of an account you have with us has been compromised), please notify us immediately by contacting us using the details above.

 

7. PROCESSING OF DATA OUTSIDE THE EUROPEAN UNION

 

We may transfer your Personal Data to countries outside the European Economic Area (« EEA ») solely for the purposes outlined in this Privacy Policy.

 

When Personal Data is transferred outside the EEA, we will implement suitable measures to ensure that your Personal Data is protected in accordance with this Privacy Policy. These measures may include:

 

(a) obtaining your consent;

 

(b) confirming that the European Commission has made an adequacy decision regarding transfers outside the EEA, which indicates that the recipient country provides adequate protection for such Personal Data;

 

(c) entering into a data transfer agreement within our group that adheres to the EU’s standard contractual clauses; or

 

(d) adopting the standard contractual clauses issued by the European Commission, which provide specific safeguards to protect personal data.

 

8. DURATION OF PERSONAL DATA RETENTION

 

Your Personal Data will be retained only for the time necessary to fulfil the purposes for which it was collected, including satisfying any legal or accounting needs.

 

The appropriate retention period for Personal Data is determined by considering the volume, type, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the reasons for processing your Personal Data, whether we can achieve those reasons through other means, and legal requirements.

 

The following information is retained for the maximum periods listed below:

 

– 10 years from the last interaction between the customer and LA VILLA BAHIA

 

– 10 years following the stay if there is a personal injury related to the stay (legal requirement)

 

– In case of legal action, until the end of the proceedings.

 

Once the predetermined periods expire, the data is either deleted or archived after anonymization, especially for statistical analysis. Data may be retained for the purposes of pre-litigation and litigation. Please note that deletion or anonymization is a permanent process, and LA VILLA BAHIA cannot recover the data afterward.

 

9. RIGHTS OF DATA SUBJECTS

 

As a Data Subject, you have various rights. These rights are not absolute and each of these rights is subject to certain conditions in accordance with the GDPR and applicable national laws.

 

• The right of access – you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us, as well as certain other information (similar to that provided in this Privacy Policy) about how it is being used. You also have the right to access your Personal Data, by requesting a copy of your Personal Data. This allows you to know and verify that we are using your information in accordance with data protection laws. We may refuse to provide information where this may reveal Personal Data about another person or adversely affect the rights of another person.
• the right of rectification – you can ask us to take steps to correct your Personal Data if it is inaccurate or incomplete (for example, if we have the wrong name or address).
• the right to erasure – also known as the « right to be forgotten », this right allows you, in simple terms, to request the erasure or deletion of your Personal Data where, for example, there is no compelling reason for us to continue to use it or its use is unlawful. However, this is not a general right to erasure and there are some exceptions, for example where we need to use the information to defend a legal claim or to be able to comply with a legal obligation.
• the right to restrict processing – you have the right to « block » or prevent further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. Where processing is restricted, we may still retain your Personal Data, but we may not use it further.
• the right to data portability – you have the right to obtain and re-use certain Personal Data for your own purposes in different companies (which are separate data controllers). This only applies to Personal Data that you have provided to us, which we process with your consent and for the purpose of fulfilling the contract, which is processed by automated means. In this case, we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically possible) we may pass your data directly to another data controller.
• the right to object – you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time, insofar as such processing is carried out for the purposes of the legitimate interests pursued by LA VILLA BAHIA. We will be permitted to continue processing Personal Data if we can demonstrate that the processing is justified on compelling legitimate grounds that override your interests, rights and freedoms or if we need it for the establishment, exercise or defence of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.
• the right to withdraw your consent – where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that took place prior to such withdrawal.
• The right to provide us with instructions on the use of your Personal Data after your death – In France, you have the right to provide us with instructions on the management (e.g. retention, erasure and disclosure) of your data after your death. You may change or revoke your instructions at any time.

 

If you have any questions about this Privacy Policy, how we process your Personal Data or if you wish to exercise any of your rights, please send contact us via the website www.lavillabahia.com

 

Any request will be considered within the time limits set by the applicable law. Please note, however, that certain Personal Data may be exempt from such requests in certain circumstances, in particular if we need to continue processing your Personal Data for our legitimate interests or to comply with a legal obligation. There will be no charge for exercising your right of access (or any other right). For your information, sometimes we will not be able to comply with your request if it is manifestly unfounded or excessive.

 

We may need to ask you for specific information to help us confirm your identity and ensure your right to access this information (or exercise your other rights). This is an appropriate security measure to ensure that Personal Data is not disclosed to anyone who does not have a right to receive it.

If you are not satisfied with our response to your complaint or if you believe that the processing of your Personal Data does not comply with the Legislation in force, you may lodge a complaint with the competent data protection supervisory authority. The Commission Informatique et Libertés (« CNIL ») is LA VILLA BAHIA’s lead data protection authority.

 

10. THIRD PARTY SITES

 

The Site may contain links to other websites operated by third parties. Please note that this Privacy Policy applies only to Personal Information collected by LA VILLA BAHIA. We are not responsible for Personal Data that third parties may collect, store and use on their own websites or applications. We recommend that you carefully read the privacy policy of each website and/or application that you visit.

Furthermore, LA VILLA BAHIA is not responsible for hypertext links leading to the Site, which third party internet sites and/or applications may include even if LA VILLA BAHIA has authorised the third party publisher of said third party site and/or application to place such a link.

 

11. COOKIES

 

• What are cookies?

 

Cookies » are small text files, often containing unique identifiers, which are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server.

 

Cookies are very useful and enable a website to recognise you, to log you in when you visit a particular page, to provide a secure connection to a website and to improve your user experience by improving your browsing comfort and/or by adapting the content of a page to your areas of interest.

 

• How are cookies used?

 

The following types of cookies are used on our Site:

 

Types of cookie	Who places these cookies?	How can you accept or reject them?
Technical cookies: These cookies are strictly necessary to provide you with the services available on our website and to use some of its features, such as access to secure areas.	LA VILLA BAHIA	As these cookies are strictly necessary to provide you with access to the Site, it is not possible to refuse them.
Functional cookies: These cookies enable our Site to remember the choices you make during your visit in order to offer you improved and more personalised functionalities, but they are not essential to their use. However, without these cookies, certain functionalities may become unavailable.	LA VILLA BAHIA	To accept or refuse these cookies, please click on the « Accept » or « Refuse » button when the cookies banner appears.
Targeted advertising cookies: These cookies are used to make advertising messages more relevant to you. They perform functions such as preventing the regular reappearance of the same advertisement and, in some cases, selecting advertisements based on your centres of interest. We also use cookies or similar tracking technologies to combat advertising fraud.	LA VILLA BAHIA and its partners	To accept or refuse these cookies, please click on the « Accept » or « Refuse » button when the cookies banner appears.
Analytical cookies: These cookies are used by us or by third-party service providers to analyse the use and performance of our Site. We use cookies from Google Analytics, Piano Analytics, AB Tasty, Content Square, Hotjar, Issuu and Google Maps.	LA VILLA BAHIA and its partners	To accept or refuse these cookies, please click on the « Accept » or « Refuse » button when the cookies banner appears.
Cookies relating to social networks: LA VILLA BAHIA may integrate third-party computer applications on its Website that allow you to share content on the Website with other people. This is particularly the case for the « Share » or « Like » button on Facebook, Pinterest, X (formerly Twitter), Instagram, YouTube or LinkedIn. The social network concerned may then identify you and save cookies on your devices.	LA VILLA BAHIA and the relevant social networks	To accept or refuse these cookies, please click on the « Accept » or « Refuse » button when the cookies banner appears. We also invite you to consult their privacy policy.

 

 

Where prior consent is required for their use, the period of validity of consent to the deposit of cookies is 6 months. At the end of this period, we will ask you again for your consent.

 

The retention period for an audience measurement cookie that does not require consent is 13 months. However, the information collected by means of these cookies is kept by us for a maximum of 25 months, in accordance with the applicable regulations.

 

• How to block the use of cookies :

 

There are two ways of refusing the use of cookies.

 

On your first visit to our Site, you will be asked for your consent to the use of your data by cookies via an information banner which will be displayed visibly at the bottom of the page.

 

Using the « Accept » and « Refuse » buttons, you will be able to accept or refuse the deposit or non-deposit of cookies on your computer or device (cookies linked to targeted advertising operations, certain audience measurement cookies, social network cookies generated in particular by their sharing buttons when they collect personal data).

 

However, if you wish to refuse the use of any type of cookie on a website, you can do so by modifying your browser settings to block the use of cookies. Please note that if you block the use of cookies using this browser setting, you may not be able to use or view all or part of the website concerned, including our Site.

 

Each web browser offers different ways of configuring cookie management. Generally speaking, these are described in the help menu of each browser

 

• Firefox: https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent
  • Click on the menu button and select « Preference Options ».
  • Select the « Privacy and Security » panel.
  • Set the « Retention rules » menu to « Use personalised settings for history ».
  • Uncheck the « Accept cookies » box.
  • The changes you have made will be saved automatically.

 

• Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
  • Click on the « Tools » button, then on « Internet Options ».
  • Click on the « Privacy » tab, then under « Settings », move the cursor up to block all cookies or down to authorise all cookies, then click OK.

 

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr
  • Select the Chrome menu icon.
  • Select « Settings ».
  • At the bottom of the page, select « Show advanced settings ».
  • In the « Privacy » section, select « Content settings ».
  • Select « Block all sites from storing data ».
  • Select OK.

 

• Safari: https://www.apple.com/legal/privacy/fr-ww/cookies/
  • Click on « Settings » > « Safari » > « Privacy » > « Cookies and website data ».
  • Then select « Always block ».

 

Please note that if you block the use of cookies using this browser setting, you may not be able to use or view all or part of the website, including our Site.

 

In addition, if you wish to block the use of analytical cookies, both of which are provided by our third party service providers, please access the following URL to suspend the use of these cookies.

 

Google Analytics: the opt-out for cookies

Description of cookies and their purpose :

Google Analytics _ga ;

Google Analytics _gid. These cookies are used to distinguish users. [https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage];Google Analytics : l’opt-out pour les cookies

Google Analytics _gat. These cookies are used to reduce the number of requests. However, if Google Analytics is deployed via the Google tag manager, these cookies will be named : _dc_gtm_<property-id>. [https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage].

Google Analytics is a web analysis service provided by Google LLC (« Google »). The information generated by the cookie about your use of the website will usually be transmitted to and stored by Google on servers in the United States .

Google will use this information on our behalf to analyse your use of the website, to compile reports on website activity and to provide us with additional services relating to website use and internet use in general. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

 

You can refuse the use of the data created by these cookies in connection with the use of our Site (in particular your IP address) and the processing of this data by Google, by downloading and installing the plug-in available on your browser under the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

 

12. CONTACT INFORMATION

 

If you have any questions or doubts about the Privacy Policy, you can contact us by email at reservation@lavillanomade.net.

 

13. CHANGES TO THIS PRIVACY POLICY

 

LA VILLA BAHIA may modify this Privacy Policy from time to time to reflect changes in our privacy practices. When we change this Privacy Policy, we will also change the « Last Updated » date at the top of the first page. We encourage you to periodically review this Privacy Policy to be informed of how LA VILLA BAHIA is protecting your Personal Information.