There are various texts of international, European or national scope which are now applicable to the protection of personal data. The main ones are:
Law No 78-17 of 6 January 1978 on computer science, files and freedoms.
Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealed on 25 May 2018 by Regulation (EU) 2016/679.
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
Charter of Fundamental Rights of the European Union (2012/C 326/02).
Convention for the Protection of Persons with regard to the Automatic Processing of Personal Data.
Pension Anahata undertakes to comply with its obligations under the regulations and, in particular, the General Data Protection Regulation (GDPR). The purpose of this Data Protection Policy (hereinafter referred to as the "Data Protection Policy") is to inform you of the commitments made by Pension Anahata to ensure compliance with your personal data.
Scope
This Data Protection Policy applies to all processing of personal data carried out by Pension Anahata, as data controller, within the European Union and concerning external individuals (hereinafter “you”), including customers, prospective customers, partners, suppliers, service providers and website users.
Definitions
“Personal data” means any information relating to an identified or identifiable natural person. “Data processing” means any operation performed on personal data, including collection, recording, use, transmission or disclosure. “Data controller” means the legal entity that determines the purposes and means of the processing. “Data processor” means the legal entity that processes personal data on behalf of the data controller.
Data collected
Pension Anahata shall ensure the collection and processing of relevant, adequate, non-excessive and strictly necessary personal data to achieve the purposes previously determined. Pension Anahata takes all the necessary steps to ensure that your data is accurate, complete and, if necessary, updated. Pension Anahata undertakes to obtain the consent of the persons concerned when required and to inform them of the processing of their data. We process personal data about you that you are likely to provide to us, in particular during the following operations:
- When you subscribe to one of our services;
- When you browse our site;
- When you provide us with products or services;
- When you consent to receive our newsletters and other commercial information from us;
- When you want to contact us to ask questions or make complaints.
In this context, Pension Anahata may in particular collect and process the following personal data:
- Your identity: first name, last name, civility, date of birth, photocopy of identity card where necessary, function;
- Your contact details: postal address, email, telephone number;
- Your transactions and payment information: transaction details, bank check, bank details;
- Your technical and browsing information on our websites (please refer to section 8 below on cookies);
- Any other information that you provide directly and voluntarily to us in connection with the use of our sites, services and contracts that we may have entered into with you.
The mandatory nature of the information you must provide is generally indicated by an asterisk on the relevant forms. Pension Anahata may invite you to provide certain personal data for marketing or communication purposes. You may freely and explicitly consent, or decline to consent, to the collection and processing of your personal data for these purposes by means of a checkbox. You undertake to ensure that the personal data you provide to Pension Anahata is up to date, accurate, complete and unambiguous.
Purpose of collection
Pension Anahata undertakes to collect and process your personal data fairly and lawfully. The processing operations carried out by Pension Anahata serve specified, explicit and legitimate purposes. Your data may be processed for the following purposes:
- To allow you to access our services (rent of bungalows);
- To manage your use of our services;
- To process your transactions and payments;
- To manage the contractual relationship with our customers, suppliers and partners (management of contract, orders, deliveries, invoices, public relations, etc.);
- To send you commercial information about us;
- To analyse your browsing on our website and improve its use (please refer to section 8 below on cookies);
- To answer your questions and complaints.
Information on data collected
In accordance with the French Data Protection Act, Pension Anahata undertakes to inform you about the processing of your personal data. When collecting your data, Pension Anahata therefore clearly informs you, in particular, of:
- the identity of the controller (this is the legal entity of Pension Anahata responsible for processing your data);
- the purpose for which your data is collected;
- the optional or compulsory nature of the replies;
- recipients of data;
the existence and manner in which the rights of questioning, access, rectification and opposition are exercised in relation to all data concerning you.
Recipients of data collected
Pension Anahata discloses your personal data only to authorised and designated recipients, in accordance with applicable regulations. Pension Anahata may, in particular, provide access to your personal data to its partners and to third-party service providers acting as data processors, in order to perform services relating to Pension Anahata’s services and IT applications, including hosting, storage, analytics, data processing, database management and IT maintenance. Acting solely on Pension Anahata’s instructions, these providers will have access to your personal data only to fulfil the purposes identified when the data was collected and will be bound by the same security and confidentiality obligations as Pension Anahata. Pension Anahata undertakes to obtain your prior consent, including through a pop-up checkbox, before disclosing your data to partners for direct marketing purposes. Your personal data may also be shared for the following reasons:
- In response to judicial or administrative proceedings of any kind or enforcement measures requested by the competent authorities;
- To comply with legal obligations, to protect the rights and/or security of an individual, to protect the rights and property of Pension Anahata, including the need to see this Data Protection Policy respected and to prevent fraud, security or technical problems.
Data retention
Pension Anahata keeps your personal data as long as necessary for the purposes for which it was collected and processed. Pension Anahata may, however, retain your personal data for a longer period of time to comply with legal obligations, including the applicable limitation periods. In order to define an appropriate data retention period, Pension Anahata uses in particular the following criteria:
- Data relating to your payments and the use of our services are kept for the duration of the contractual relationship and then in accordance with the applicable limitation periods;
- The data relating to the management of the commercial relationship with our suppliers and partners are kept for the duration of the contractual relationship and then in accordance with the applicable limitation periods;
- When you have consented to receive marketing communications, Pension Anahata retains your personal data until you indicate that you no longer wish to receive such communications, unless a different period is required by applicable law;
- When your data is collected as part of requests/questions relating to IT services and applications, Pension Anahata keeps this data for the period necessary to process such requests.
Cookies
You are informed that, during your visits to our website, cookies (log-in cookies) can be installed on your browser software to allow you, in particular, optimal navigation. Cookies are data stored in Internet terminal equipment. They are used by our site to send information to the internet browser, and allow this browser to return information to the original site (e.g. a session ID, choice of a language or date). Other types of tracers, such as pixel tags, can also be used. These tags send calls to servers, to display a pixel, and allow us to share data with third parties for the purposes described in our Cookie Policy.
Security
Pension Anahata ensures the security of your personal data by putting in place data protection through the use of physical and logical means of security.
Rights of data subjects
In accordance with applicable legislation on the protection of personal data, you have a number of rights relating to the collection and processing of your personal data, namely:
- The right to be informed: You have the right to be informed in a concise, transparent, understandable and easily accessible manner of how your personal data is processed.
- The right of access: You have the right to obtain confirmation that personal data concerning you are or are not processed and, where they are processed, to obtain access to the said data and a copy thereof.
- The right to rectification: You have the right to obtain rectification of personal data concerning you that are inaccurate. You also have the right to have incomplete personal data completed, including by providing a supplementary declaration.
- The right to erasure: In some cases, you have the right to have your personal data deleted. However, this right is not an absolute right and Pension Anahata may have legal or legitimate reasons to retain such data.
- The right to restriction of processing: In certain cases, you have the right to obtain restriction of the processing of your personal data.
- The right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you where that processing is based on Pension Anahata’s legitimate interests. Pension Anahata may, however, demonstrate compelling legitimate grounds requiring the processing to continue. Where your personal data is processed for direct marketing purposes, you have the right to object at any time. You may exercise this right by clicking the “unsubscribe” link at the bottom of the messages you receive.
- The right to lodge a complaint with a supervisory authority: You have the right to contact a Supervisory Authority (such as the CNIL in France) in order to lodge a complaint concerning the practices relating to the protection of personal data of Pension Anahata.
- The right to transmit instructions concerning the use of data after death (this right applies in France): you have the right to give the Pension Anahata instructions regarding the use of your personal data after your death.
- To exercise these rights, you can apply to the following address: gerance@pensionanahata.com, by attaching a copy of an identity document to your application.
Policy change
Pension Anahata will be able to update this Data Protection Policy at any time to adapt it to any new practices and service offerings. In this case, the date of update of the Data Protection Policy will be updated and will indicate the date the changes were made. It is your responsibility to verify any updates to this Data Protection Policy published on the Pension Anahata website. If Pension Anahata makes any changes that it considers important, you will be notified through information on our website.
Links to third-party sites
While browsing our websites, you are likely to see content that includes links to third-party applications and websites. Pension Anahata cannot control cookies or other functions used by third parties' applications and websites, and the processing of personal data implemented by such applications and sites is not governed by this Data Protection Policy. Therefore, it is your responsibility to contact and/or directly consult the applications and websites of these third parties to obtain additional information about their personal data protection procedures.
Contact
For any request for information regarding this Personal Data and Privacy Policy, you may contact administrateur@pensionanahata.com.
Update
This Policy can be updated at any time, so we advise you to consult it regularly. Last updated : 26 October 2022.