Privacy policy

1. GENERAL PROVISIONS

1.1. BACKGROUND AND DEFINITIONS

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, otherwise known as the General Data Protection Regulation (hereinafter referred to as the GDPR) sets out the legal framework applicable to the processing of personal data.
The GDPR strengthens the rights and obligations of data controllers, data processors, data subjects and data recipients.
The present policy is implemented by Tourisme Côte des Légendes, whose main activities are the development of the tourism offer, the promotion of tourist destinations and the marketing of Tourisme Côte des Légendes' tourism offer.
As part of its activity, Tourisme Côte des Légendes implements personal data processing relating to the data of its customers, partners and prospects.
For a proper understanding of the present policy it is specified that:

customers are understood to be all natural or legal persons who have entered into a contract of any kind with Tourisme Côte des Légendes, it being specified that the latter is intended to work with tourism professionals, departments or the general public;
Partners are understood to be any natural or legal persons involved in the tourism sector and maintaining relations with Tourisme Côte des Légendes in this capacity, such as, in particular, local tourism professionals, project developers and internal and external investors, holiday distributors, local authorities and their groupings, or institutional partners;
Prospects are understood to be any potential customer or any contact recipient of Tourisme Côte des Légendes promotional messages whose data has been collected directly via contact forms, events or indirectly via any Tourisme Côte des Légendes partner.

1.2. PURPOSE AND SCOPE

This personal data protection policy is intended to apply to the processing of personal data of customers, partners and prospective customers of Tourisme Côte des Légendes.
The purpose of this policy is to meet Tourisme Côte des Légendes' obligation to provide information and to formalize the rights and obligations of customers, partners and prospective customers with regard to the processing of their data.
This policy applies only to processing for which Tourisme Côte des Légendes is responsible and to data described as "structured".
The processing of personal data may be managed directly by Tourisme Côte des Légendes or through a subcontractor specifically appointed by it.
This policy is independent of any other document that may apply within the contractual relationship between Tourisme Côte des Légendes and its customers, partners and prospects.
No processing is implemented by Tourisme Côte des Légendes concerning data of customers, partners and prospects if it does not concern personal data collected by or for its services or processed in relation to its services and if it does not comply with the general principles of the RGPD.
Any new processing, modification or deletion of existing processing will be brought to the attention of customers, partners and prospects by means of an amendment to this policy.

2. CUSTOMER DATA

2.1. TYPES OF DATA COLLECTED

Non-technical data

(as applicable) Identity and identification (surname, first name, date of birth, pseudonym, customer number)
Contact details (e-mail, postal address, telephone number)
Work-life balance when necessary

Technical data

(depending on use) Identification data (IP address)
Connection data (logs, tokens, etc.)
Acceptance data (click)
Location data.

2.2. DATA ORIGIN

Tourisme Côte des Légendes collects customer data from :

data supplied by the customer (paper form, order form, contract, business card) ;
electronic forms completed by the customer ;
data entered online (website, social networks, etc.) ;
registration for events organized by Tourisme Côte des Légendes (e.g. trade fairs, workshops, etc.);
rental or acquisition of databases on an exceptional basis ;
communication of contacts through specialized companies or Tourisme Côte des Légendes partners.

2.3 PURPOSE

Depending on the case, Tourisme Côte des Légendes processes customer data for the following purposes:

customer relationship management (CRM) ;
sale of tourist stays directly or through distribution partners;
management of events organized by Tourisme Côte des Légendes (trade fairs, workshops, etc.) ;
sending newsletters or information feeds;
customer account management ;
answers to questions that may be asked by telephone or online ;
improved services for Tourisme Côte des Légendes;
meeting the administrative obligations of Tourisme Côte des Légendes ;
community management ;
statistics.

2.4. SHELF LIFE

The length of time Tourisme Côte des Légendes keeps its customers' data is defined by Tourisme Côte des Légendes in the light of the legal and contractual constraints weighing on it and, failing that, according to its needs and in particular according to the following principles:
Processing Length of retention
Customer data For the duration of the contractual relationship with Tourisme Côte des Légendes, increased by 3 years for the purposes of promotion and canvassing, without prejudice to retention obligations or limitation periods
Technical data 1 year from collection
Cookies 13 months

After the set deadlines, data is either deleted or kept after being anonymized, notably for statistical purposes. They may be kept for pre-litigation and litigation purposes.
Customers are reminded that deletion or anonymization are irreversible operations and that Tourisme Côte des Légendes is no longer able to restore them.

2.5. LEGAL BASIS

The purposes of processing presented above are based on the following conditions of lawfulness:
Customers Pre-contractual or contractual performance

3. PARTNER DATA

3.1. TYPES OF DATA COLLECTED

Non-technical data

(as applicable) Identity and identification (surname, first name, date of birth, pseudonym, customer number)
Contact details (e-mail, postal address, telephone number)
Personal/professional life when necessary

Technical data

(depending on use) Identification data (IP address)
Connection data (logs)
Acceptance data (click)
Location data

3.2. DATA ORIGIN

Tourisme Côte des Légendes collects data from its partners using :

information gathered directly from partners;
electronic forms completed by partners ;
registrations or subscriptions to our online services (newsletter, social networks, etc.);

3.3. PURPOSE

Depending on the case, Tourisme Côte des Légendes processes the data of its partners for the following purposes:

partner relationship management ;
labeling of sites and facilities for the sectors entrusted by Tourisme Côte des Légendes ;
tourism engineering operations (diagnostics and feasibility studies, support in setting up projects and grant applications);
networking and consultation operations involving the various partners ;
marketing support operations for partner service providers ;
management of events organized by Tourisme Côte des Légendes (trade shows, workshops, etc.);
answers to questions that may be asked by telephone or online ;
training operations for partner service providers ;
operations to find distribution partners ;
statistics.

3.4. SHELF LIFE

The retention period for partner data is defined by Tourisme Côte des Légendes in the light of the legal and contractual constraints applicable to it and, failing that, according to its needs, and in particular in accordance with the following principles:
Processing Retention period
Data relating to partners For the duration of the contractual relationship with Tourisme Côte des Légendes, plus 3 years for the purposes of monitoring the relationship, without prejudice to retention obligations or limitation periods
Cookies 13 months
Technical data 1 year from collection

3.5. LEGAL BASIS

The purposes of processing presented above are based on the following conditions of lawfulness:
Partners Pre-contractual or contractual performance

4. PROSPECT DATA

4.1. TYPES OF DATA COLLECTED

Non-technical data

(as applicable) Identity and identification (surname, first name, date of birth, pseudonym, customer number)
Contact details (e-mail, postal address, telephone number): in particular for sending newsletters and delivering newspapers.
Professional life (function) when necessary

Technical data

(depending on use) Identification data (IP address)
Connection data (logs)
Acceptance data (click)
Location data

4.2. DATA ORIGIN

Tourisme Côte des Légendes collects the data of its prospects from :

data supplied by the prospect (paper form, business card, etc.) ;
electronic forms completed by the prospect ;
data entered online (website, social networks, etc.) ;
registration or subscription to our online services (website, social networks, ...) ;
registration for events organized by Tourisme Côte des Légendes (e.g. trade fairs, workshops, etc.);
list provided by the organizers of events or conferences in which we participate;
database rental by Tourisme Côte des Légendes on an exceptional basis ;
communication of contacts through specialized companies or Tourisme Côte des Légendes partners.

4.3. PURPOSE

Depending on the case, Tourisme Côte des Légendes processes the data of its prospective customers for the following purposes:

prospect relationship management (PRM) ;
management of events organized by Tourisme Côte des Légendes (trade fairs, workshops, etc.) ;
sending our newsletters or information feeds;
answers to the questions we receive (by telephone or online) ;
animation of websites in partnership with our partners ;
operation to promote Tourisme Côte des Légendes and tourism in the Lesneven-Daoulas region on social networks (Facebook, Twitter, YouTube, Instagram, etc.);
behavioral analysis of prospects ;
community management ;
statistics.

4.4. SHELF LIFE

The length of time Tourisme Côte des Légendes keeps prospect data is defined by Tourisme Côte des Légendes in the light of the legal and contractual constraints applicable to it and, failing that, according to its needs and in particular in accordance with the following principles:
Processing Length of retention
Data relating to contacts and prospects 3 years from the date of collection by Tourisme Côte des Légendes or the last contact from the prospect/contact
Cookies 13 months
Technical data 1 year from the date of collection

Once this period has elapsed, the data is either deleted or kept after being anonymized, notably for statistical purposes. They may be kept for pre-litigation and litigation purposes.
Prospects are reminded that deletion or anonymization are irreversible operations and that Tourisme Côte des Légendes is no longer able to restore them
4.5. LEGAL BASIS
The processing purposes described above are based on the following conditions of lawfulness:
Prospects - Pre-contractual measures

Legitimate interest
Consent when required by law (e.g. newsletter)

5. DATA RECIPIENTS

Tourisme Côte des Légendes ensures that data is only accessible to authorized internal or external recipients.
The recipients of personal data of customers, partners and prospects within Tourisme Côte des Légendes are subject to an obligation of confidentiality.
Tourisme Côte des Légendes decides which recipient may have access to which data according to an authorization policy.
Tourisme Côte des Légendes is in no way responsible for damages of any kind that may result from illicit access to personal data.
All accesses concerning processing of personal data of customers, partners and prospects are subject to a traceability measure.
In addition, personal data may be communicated to any authority legally entitled to know. In this case, Tourisme Côte des Légendes is not responsible for the conditions under which the personnel of these authorities have access to and use the data.

Internal recipients External recipients

Tourisme Côte des Légendes empowered staff (marketing, customer relationship management, service providers and prospects, administrative staff, IT staff) and their line managers;
Service providers or support services (e.g. IT service provider, etc.) ;
Authorized personnel from auditing departments (statutory auditors, departments responsible for internal audit procedures, etc.);
Administration, court officer where applicable.
Fédération Nationale des Gîtes de France
Clévacances France

6. PERSONAL RIGHTS MANAGEMENT

6.1. RIGHT OF ACCESS (RIGHT TO COPY)

Customers, partners and prospects traditionally have the right to ask Tourisme Côte des Légendes for confirmation as to whether or not data concerning them is being processed.
Customers, partners and prospects also have a right of access, which may be exercised provided that the request is made by the person concerned, is accompanied by a copy of a current identity document and is sent in writing to the following address: Tourisme Côte des Légendes, Place des 3 piliers, 29260 Lesneven or at tourisme@cotedeslegendes.bzh.
Customers, partners and prospects have the right to request a copy of their personal data processed by Tourisme Côte des Légendes. However, in the event of a request for an additional copy, Tourisme Côte des Légendes may require customers, partners and prospects to bear the cost of this.
If customers, partners and prospects submit their request for a copy of the data electronically, the information requested will be provided in a commonly used electronic form, unless otherwise requested.
Customers, partners and prospects are informed that this right of access may not relate to confidential information or data, or data for which communication is not authorized by law.
The right of access must not be exercised in an abusive manner, i.e. on a regular basis with the sole aim of destabilizing Tourisme Côte des Légendes.

6.2. UPDATES AND CORRECTIONS

Tourisme Côte des Légendes satisfies requests for updates:

automatically for online changes to fields that can be technically or legally updated;
upon written request from the person concerned, who must provide proof of identity.

6.3. RIGHT TO ERASURE

The right to erasure of customers, partners and prospects will not be applicable in cases where processing is carried out to meet a legal obligation.
Apart from this situation, customers, partners and prospects may request the erasure of their data in the following limited cases:

the personal data is no longer required for the purposes for which it was collected or otherwise processed;
when the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;
the data subject objects to processing that is necessary for the purposes of the legitimate interests pursued by Tourisme Côte des Légendes, and there is no compelling legitimate reason for the processing;
the data subject objects to the processing of his/her personal data for canvassing purposes, including profiling;
the personal data has been processed unlawfully.
In accordance with legislation on the protection of personal data, customers, partners and prospects are informed that this is an individual right that can only be exercised by the person concerned in relation to his or her own information: for security reasons, the department concerned will therefore need to verify your identity in order to avoid any communication of confidential information about you to anyone other than yourself.

6.4. RIGHT TO LIMITATION

Customers, partners and prospects are informed that this right is not intended to apply insofar as the processing carried out by Tourisme Côte des Légendes is lawful and that all personal data collected is necessary for the implementation of the purposes of such processing.

6.5. RIGHT TO PORTABILITY

Tourisme Côte des Légendes grants the right to data portability in the specific case of data communicated by customers, partners and prospects themselves, on online services offered by Tourisme Côte des Légendes and for purposes based solely on the consent of individuals and performance of a contract. In this case, data will be communicated in a structured, commonly used and machine-readable format.

6.6. AUTOMATED INDIVIDUAL DECISION

Tourisme Côte des Légendes does not make automated individual decisions.
The tools offered on the Tourisme Côte des Légendes website are only intended to help customers and prospective customers and should not be considered otherwise.

6.7. POST-MORTEM RIGHTS

Customers, partners and prospects are informed that they have the right to formulate directives concerning the conservation, deletion and communication of their post-mortem data. The communication of specific post-mortem directives and the exercise of their rights can be made by e-mail to tourisme@cotedeslegendes.bzh or by post to the following address: Tourisme Côte des Légendes, Place des 3 piliers, 29260 Lesneven, accompanied by a copy of a signed identity document.

7. ADDITIONAL PROVISIONS

7.1. OPTIONAL OR MANDATORY RESPONSES

Customers, partners and prospects are informed on each personal data collection form of the compulsory or optional nature of the answers by the presence of an asterisk. Where answers are compulsory, Tourisme Côte des Légendes explains to customers, partners and prospective customers the consequences of not answering.

7.2. RIGHT OF USE

Customers, partners and prospective customers grant Tourisme Côte des Légendes the right to use and process their personal data for the purposes set out above.
However, enriched data resulting from processing and analysis work carried out by Tourisme Côte des Légendes, otherwise known as enriched data, remains its exclusive property (analysis of usage, statistics, etc.).

7.3. SUBCONTRACTING

Tourisme Côte des Légendes informs its customers, partners and prospects that it may involve any subcontractor of its choice in the processing of their personal data.
In this case, Tourisme Côte des Légendes ensures that the subcontractor complies with its obligations under the RGPD.
Tourisme Côte des Légendes undertakes to sign a written contract with all its subcontractors and imposes the same data protection obligations on subcontractors as it does. In addition, Tourisme Côte des Légendes reserves the right to audit its subcontractors to ensure compliance with the provisions of the RGPD.

7.4. TREATMENT REGISTER

Tourisme Côte des Légendes is implementing a data processing register.

8. SAFETY

8.1. SAFETY MEASURES

It is the responsibility of Tourisme Côte des Légendes to define and implement the physical or logical technical security measures it deems appropriate to prevent the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of data.

These measures include the following:

data access authorization management ;
internal and external safeguards with our subcontractors
identification process to access the building and data
In any case, Tourisme Côte des Légendes undertakes, in the event of a change in the means used to ensure the security and confidentiality of personal data, to replace them with means of superior performance. No change may lead to a reduction in the level of security.
In the event of subcontracting all or part of the processing of personal data, Tourisme Côte des Légendes undertakes to contractually impose security guarantees on its subcontractors by means of technical data protection measures and the appropriate human resources.

8.2. DATA BREACH

In the event of a personal data breach, Tourisme Côte des Légendes undertakes to notify the Cnil under the conditions prescribed by the RGPD.
If the said breach poses a high risk to customers, partners and prospective customers and the data has not been protected, Tourisme Côte des Légendes:

will notify the customers, partners and prospects concerned;
communicate the necessary information and recommendations to the customers, partners and prospects concerned.

9. CONTACTS

9.1. Tourism Côte des Légendes CONTACT

The contact details of our personal data referent are as follows:

Name: Tourisme Côte des Légendes
E-mail address: tourisme@cotedeslegendes.bzh

9.2. DPO CONTACT

Tourisme Côte des Légendes has appointed a data protection officer whose contact details are as follows:

Name: Tourisme Côte des Légendes
E-mail address: tourisme@cotedeslegendes.bzh
Address: Tourisme Côte des Légendes
Place des 3 piliers, 29260 Lesneven

9.3. RIGHT TO LODGE A COMPLAINT WITH CNIL

Customers, partners and prospects concerned by the processing of their personal data are informed of their right to lodge a complaint with a supervisory authority, namely Cnil in France, if they consider that the processing of personal data concerning them does not comply with European data protection regulations, at the following address:
Cnil - Service des plaintes
3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07
Tél : 01 53 73 22 22

10. EVOLUTION

The present policy may be modified or amended at any time in the event of changes in legislation, case law, decisions and recommendations of the Cnil or usage.
Any new version of the present policy will be brought to the attention of customers, partners and prospective customers by any means chosen by Tourisme Côte des Légendes, including electronic means (distribution by e-mail or online, for example).

11. FOR FURTHER INFORMATION

For further information, please contact us at the following e-mail address: tourisme@cotedeslegendes.bzh.
For more general information on the protection of personal data, please consult the Cnil website www.cnil.fr.