Privacy and personal data policy

Definitions of the terms used in this privacy policy

The following terms are used below:

• “Personal Data” : means “ any information relating to an identified natural person or a natural person who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person ”, in accordance with the French Data Protection Act of 6 January 1978.
• “Website” or “Service” : the website en.refletdescimes.fr and all of its pages.
• “Publisher” or “We” : Au coeur des cimes, the legal entity or individual responsible for publishing the Website and its content.
• “User” or “You” : the internet user visiting and using the Website’s Services.

Article 1 – Introduction and purpose of the privacy policy

This policy explains the Website’s commitments to respecting your privacy and protecting your Personal Data collected and processed when you use the Service.

Please read this privacy policy so that you understand why and how we use your data.

By registering on the Website, you agree to provide accurate information about yourself. Providing false information is contrary to the general terms and conditions published on the Website.

Please note that this privacy policy may be amended or supplemented at any time, particularly to reflect changes in legislation, regulations, case law or technology. Where applicable, the date of the update will be clearly stated. 

These changes are binding as soon as they are published online. We therefore invite you to consult this privacy policy regularly to keep informed of any changes.

You will also find a description of your privacy rights and how the law protects you.

If you have any questions about this privacy policy or wish to exercise your rights as described in Article 10, please contact us by email at: contact@lerefletdescimes.fr or by post at: Les Ménuires, Résidence « Le Reflet des cimes », 461 route de brelin 73440 Les Bellevilles

Article 2 – Data collected on the Website

The Data collected and subsequently processed by the Website is information you voluntarily provide by completing its various forms. For certain operations involving content, you may be asked to provide Data to third-party partners through their own services, particularly when making payments. We will not have access to this data, whose collection and processing are governed by those parties’ own terms. Please consult their terms before providing your Data in this context.

Your IP address (the identification number assigned to your computer on the internet) is collected automatically. The Service may use an automatic tracking mechanism (a cookie), which you can prevent by changing the relevant settings in your internet browser, as explained in the Website’s general terms and conditions.

In general, you can visit en.refletdescimes.fr without providing any personal information. You are under no obligation to provide this information. However, if you choose not to do so, you may be unable to access certain information or services.

We also collect, use and share aggregated data, such as statistical or demographic data, for various purposes. Aggregated data may be derived from your personal information but is not considered personal data in law because it does not directly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a particular Website feature.

To provide better content and services, en.refletdescimes.fr uses Google Analytics. Google Analytics does not track your browsing habits on third-party websites. The information available to Google Analytics does not contain personal data about you.

We do not collect so-called “sensitive” data.

The contact details of Users registered on the Website will be stored in accordance with the French Data Protection Act of 6 January 1978. Under that Act, they have the right to access, withdraw, amend or correct the Data they have provided. To do so, they simply need to make a request by email to: contact@lerefletdescimes.fr, or by post to: Les Ménuires, Résidence « Le Reflet des cimes », 461 route de brelin 73440 Les Bellevilles.

The Publisher’s collection of Users’ Personal Data does not require a declaration to the French data protection authority (Commission Nationale de l’Informatique et des Libertés – CNIL).

Article 3 – Identity of the data controller

The data controller is Au coeur des cimes, whose registered office is at: Les Ménuires, Résidence « Le Reflet des cimes », 461 route de brelin 73440 Les Bellevilles.

Article 4 – Purposes of the Data collected

Data marked as mandatory on Website forms is necessary to use the corresponding features, particularly operations involving the content offered on the Website.

The Website may collect and process its Users’ Data:

• To provide information or services you have requested, including commercial offers.
• To gather information that helps us improve our website, products and services (particularly through the use of cookies).
• To contact you.

Article 5 – Recipients and use of the Data collected

The Data we collect is processed to carry out operations involving the Service’s content.

You may receive emails from our Service, including newsletters you have agreed to receive. You may ask to stop receiving these emails by contacting us at contact@lerefletdescimes.fr or by using the link provided in each email sent to you.

Only Au coeur des cimes receives your Personal Information. It is never passed to a third party, apart from the processors engaged by Au coeur des cimes . Neither Au coeur des cimes nor its processors sell the personal data of Website visitors and users.

Your personal data may be shared with the parties indicated below for the purposes set out in this privacy policy.

We require all third parties to ensure the security of your personal data and process it in accordance with the law. We do not allow our third-party service providers to use your data.

Article 6 – Legal bases for processing data

In accordance with the General Data Protection Regulation (GDPR), Au coeur des cimes processes personal data only in the following circumstances:

• with your consent ;
• where there is a contractual obligation (a contract between Au coeur des cimes and you);
• to meet a legal obligation (under EU or national law).

Article 7 – Data security

Your Data may be disclosed pursuant to a law or regulation, a decision by a competent regulatory or judicial authority, or where necessary for the Publisher to protect its rights and interests.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation.

Article 8 – Data retention period

The Data is not stored with the website’s hosting provider, whose contact details appear in the Website’s legal notice.

Article 9 – Service providers and transfers outside the European Union

Au coeur des cimes informs you that it uses authorised service providers to facilitate the collection and processing of the data you have provided. These service providers are located exclusively within the European Union.

Au coeur des cimes has first ensured that its service providers implement adequate safeguards and comply with strict conditions relating to confidentiality and the use and protection of data. These providers are also subject to the General Data Protection Regulation (GDPR).

Article 10 – Data protection rights

Under personal data protection legislation, you have the rights detailed below. As indicated in Article 1 of this privacy policy, you may exercise them by writing to the postal address given above (Les Ménuires, Résidence « Le Reflet des cimes », 461 route de brelin 73440 Les Bellevilles) or by emailing contact@lerefletdescimes.fr :

• The right to be informed: we must inform you how we use your personal data, as described in this privacy policy.
• The right of access: you may request access to your data and receive a copy of the personal data we hold. However, because of the security and confidentiality obligations applying to personal data processed by Au coeur des cimes, your request will be processed subject to proof of your identity, particularly a scan or photocopy of a valid identity document.
• The right to rectification: you may ask us to correct personal data that is incomplete or inaccurate. Under this right, the law allows you to request the correction, updating, blocking or deletion of data about you that may be inaccurate, incorrect, incomplete or outdated.
• The right to erasure, also known as the “right to be forgotten”: in certain circumstances, you may ask us to delete the personal data we hold about you, unless there is an overriding legal reason requiring us to keep it.
• The right to restriction of processing: in certain circumstances, you may ask us to suspend the processing of personal data.
• The right to data portability: you may ask us for a copy of your personal data in a commonly used format, such as a .csv file.
• The right to object: you may object to the processing of your personal data, for example by preventing us from processing it for direct marketing purposes.

However, this right may be exercised only in one of the following circumstances: where the objection is based on legitimate grounds, or where its purpose is to prevent the collected data from being used for commercial prospecting.

If you wish to exercise any of the rights described above, please write to us at Les Ménuires, Résidence « Le Reflet des cimes », 461 route de brelin 73440 Les Bellevilles or email contact@lerefletdescimes.fr

You will not have to pay to access your personal data or exercise any other right. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. In that case, we may also refuse to respond to your request.

Au coeur des cimes may, where appropriate, reject requests that are clearly abusive because of their systematic or repetitive nature, or their number.

We may ask you for specific information to confirm your identity and ensure your right to access your personal data or exercise another right. This is a security measure to prevent personal data from being disclosed to anyone who is not authorised to receive it. We may also contact you for further information about your request to help us respond more quickly.

We aim to respond to all legitimate requests within one month. It may take longer if your request is particularly complex or you have made several requests. In that case, we will notify you and keep you informed.

Article 11 – Complaints to the data protection authority

If you believe that Au coeur des cimes is not meeting its obligations regarding your Personal Information, you may submit a complaint or request to the relevant authority. In France, the competent authority is the CNIL, which you can contact online at: https://www.cnil.fr/fr/plaintes/internet.

Article 12 – Cookie policy

When you first visit en.refletdescimes.fr, a banner at the bottom of your screen informs you that information about your browsing may be stored in alphanumeric files called “cookies”. Our cookie policy explains the measures we use in connection with browsing our website. In particular, it describes the cookies on our website, their purposes and how to configure them.

a) General information about cookies on the Website

Au coeur des cimes, as the publisher of this website, may place cookies on your device’s hard drive (computer, tablet, mobile phone, etc.) to ensure smooth and optimal browsing.

Cookies are small text files that allow us to recognise your computer, tablet or mobile phone so that we can personalise the services we offer you.

The information collected through cookies does not identify you by name. It is used exclusively for our own purposes to improve the interactivity and performance of our website and provide content suited to your interests. None of this information is disclosed to third parties unless Au coeur des cimes has obtained your prior consent or disclosure is required by law, by a court order or by an authorised administrative or judicial authority.

To help you understand the information identified by cookies, a table lists the different types of cookies that may be used on the website of Au coeur des cimes, their names, purposes and retention periods.