Privacy

Privacy Notice of ES Developpement – Le Toiny SA Trading as Hotel Le Toiny St Barth

Background

Hotel Le Toiny understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, suppliers and employees and we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

ES-Developpement – Le Toiny. Société Anonyme.

Registered in France under company number R.C.S.349 121 368 – No. de Gestion 89 B 234.

Registered address: Le Toiny Ansé de Toiny – 97133 Saint Barthélemy, French West Indies.

Data Protection Officer: Mr Luc Lanza – General Manager

Email address: luc.lanza@letoiny.com

Telephone number: +590 590 27 88 88.

2. What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions by contacting our Data Protection Officer as detailed in Part 1.
  2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact our Data Protection Officer using the details in Part 1 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact our Data Protection Officer using the details in Part 1 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and if that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact our Data Protection Officer using the details provided in Part 1.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

  • Name;
  • Date of birth;
  • Gender;
  • Address;
  • Email address;
  • Telephone number;
  • Business name;
  • Job title;
  • Profession;
  • Payment information;
  • Information about your preferences and interests;

Your personal data is obtained from the following third party:

  • Google Analytics – When someone visits our website (letoiny.com) we use Google Analytics to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make an attempt to find out the identities of those visiting out website. If we want to collect personally identifiable information through our website, we will make it clear when we collect this information and we will explain what we intend to use it for.
  • As part of the registration process for our monthly e-newsletter, we collect personal information. We use that information for a couple of reasons: to tell you about products, events, and packages; to contact you if we need to obtain or provide additional information; to check if our records are right and to check every now and then if you’re happy and satisfied. We don’t rent or trade email lists with other organisations and businesses. We use a third party provider, MailChimp, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s privacy notice. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by emailing our Data Protection Officer as detailed in Part 1.

6. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of, or some of the following purposes:

  • Providing and managing your account.
  • Supplying our services to you. Your personal details may be required in order for us to enter into a contract with you.
  • Personalising and tailoring our services for you.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email and post that you have opted-in to receive (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing our data protection officer as detailed in Part 1.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message an post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept:

  1. For as long as there is a legal requirement for the data to be retained,
  2. Subject to (a) above, the person or persons to whom the data relates asks for the data to be deleted from our records, and
  3. The reason for obtaining the data originally no longer has business relevance.

8. How and Where Do You Store or Transfer My Personal Data?

Given the location of Hotel Le Toiny we may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries”. We will take all necessary steps in order to ensure that your personal data is treated just as safely and securely as it would be within the European Economic Area (EEA) and under the GDPR as follows.

We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.

Please contact our data Protection Office by using the details in Part 1 for further information about the particular data protection mechanism used by us me when transferring your personal data to a third country.

The security of your personal data is essential to us me, and to protect your data, we  take a number of important measures, including the following:

  • Nominated system administrators,
  • System secured access codes,
  • Secured backup systems,
  • Physical data secured by nominated keyholders

9. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to any legal requirement to provide such data.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made by contacting our Data protection Officer using the details shown in Part 1.

We will respond to your subject access request as quickly as possible, but certainly within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please contact our data Protection Office using the contact details shown in Part 1.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website www.letoiny.com