Privacy Policy - D-EDGE (original) (raw)

This Privacy Policy applies to personal data collected by D-EDGE, as a data controller through the use of (i) its corporate website (www.d-edge.com) by web users and (ii) its online services related to the hospitality industry: « Website creation » and « Traffic Acquisition Program » (« Services ») by its customers**.**

For the sake of clarity, personal data that we receive, collect or process on behalf of third parties, including from our customers and business partners, is only governed by the privacy policies of those third parties. For example, the personal data that we receive from individuals making a hotel reservation at a particular hotel managed by our customers or business partners using our Services belongs to the hotel property and is governed by its own privacy policy. We are not responsible for the policies or actions of our customers, business partners, or other third parties with respect to their use of your personal data.

WHAT IS PERSONAL DATA?

Personal data (hereinafter “Personal Data” or “Data“) is any information that enables you to be identified, whether directly or indirectly. This may include your surname, first name, e-mail address, telephone number, IP address, etc.

WHAT INFORMATION DO WE COLLECT?

• Names and contact information from our customers and business partners and, in some cases, directly from individuals when we act as a contractor for our customers and partners in providing our Services; and from individuals who voluntarily submit it to us by requesting products, services or other information through this website, by participating in surveys or promotions or by engaging in other communications with D-EDGE.
• When our customers grant staff administrator rights for D-EDGE, then we will also collect some Personal Data about these administrators in order to provide the services and for security reasons. This will include log-in details such as name, email address and password, IP address, time of access to the service, as well as a record of whether the administrator has accepted D-EDGE’s terms and conditions and privacy policy.
• When individuals visit this website, and the websites of our customers, we use cookies, tracking pixels, web beacons and other technologies to collect Data that allows us to customise and improve user experience with our website and our Services. For example, these technologies allow us to identify whether an individual is a first-time or returning visitor and to provide faster data retrieval for return visitors. When an individual voluntarily submits information to us or one of our customers or business partners, we may associate this Personal Data with information gathered through these technologies so that we can offer increased personalisation and functionality services to our customers or business partners.

WHAT DATA DO WE RECEIVE FROM THIRD PARTIES?

The Personal Data above may be combined with Data that we receive from other sources, including from third-party business partners. For example, we may use third-party information to confirm contact information or to better understand your interests by associating demographic information with the information you have provided.

HOW DO WE USE THIS DATA, AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We process this Personal Data for the below purposes. For the sake of clarity, we listed them according to the legal basis that legitimises them

• To fulfil a contract, or take steps linked to a contract: this is relevant where you use our Services. This includes:
  • taking payments;
  • communicating with you;
  • providing customer services and provision of the Services.
  • As required by D-EDGE to conduct our business and pursue our legitimate interests, in particular:
  • we will use your Data to provide the Services you have requested, and respond to any comments or complaints you may send us;
  • we monitor the use of our website and online services, and we use this Data to help us monitor, improve and protect our products, content, Services and website, both online and offline;
  • we use Data you provide to personalise our website and Services for you;
  • to maintain and improve our Services, for example for testing and development purposes;
  • we monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
  • we provide industry-related analysis, reporting and marketing Services to our customers and other third parties in the hospitality industry;
  • we use Data you provide to investigate any complaints received from you or from others, about our website or our Services;
  • we will use Data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
• Where you give us consent:
  • where required by law to send you direct marketing in relation to our relevant Services;
  • we set cookies and use similar technologies on users’ devices. See Use of Cookies and Similar Technologies below;
  • On other occasions where we ask you for consent, we will use the Data for the specific purpose which we explain at that time.
• For purposes which are required by law:
  • in response to requests by government or law enforcement authorities conducting an investigation.

HOW LONG ARE WE USING YOUR DATA?

Your Personal Data will be kept for the period necessary to achieve the purposes of the processing carried out. As examples:

• Personal Data related to your use of the Services are, by way of principle, kept for the duration of our contractual relationship, and for a period of 3 years from your last contact with us.
• Personal data collected through cookies are kept for a maximum period of 25 months from their collection.

After these periods, we will either delete your Data or make it anonymous. Your Data may also be archived for a certain period of time in a separate database with limited access, in the event that we are required to keep a record of some of your information by virtue of a legal obligation to which we may be subject in order to prevent any litigation, prior to its definitive deletion or anonymisation (e.g. 10 years for accounting obligations).

For your information, when we process your Personal Data on behalf of our customers, the retention periods are defined by the latter. However, we provide them with tools allowing the setting of an appropriate retention period with regard to the applicable regulation.

TO WHOM DO WE TRANSMIT YOUR DATA?

Your Personal Data is only accessible to our staff members, who are authorised by their function to process it.

We may share your Personal Data with third parties for the purposes identified above, such as:

• Third-party service providers to help us manage our business and provide goods and services to our customers and business partners. In particular, we use third party providers of website hosting, technology support and maintenance, call center operation, and marketing.
• Our customers and business partners for their own marketing and internal business purposes.

If we share Personal Data with third parties, we require that they only use such information received from us for their intended purpose.

D-EDGE also may disclose any Personal Data as required by law, court order or other valid legal processes or in connection with a merger, acquisition, reorganisation or sale of D-EDGE, any of D-EDGE’s business lines, or all or substantially all of D-EDGE’s assets or a D-EDGE business line’s assets.

IS YOUR DATA SHARED OUTSIDE THE EUROPEAN UNION?

Your Personal Data is mainly processed within the European Economic Area (EEA). Nevertheless, some of your Personal Data, such as your browsing data, may be transferred to countries outside the EEA, whose level of protection would not be considered adequate by the European authorities.

For any Data transfer outside the EEA, we undertake to implement appropriate agreements or transfer mechanisms such as standard contractual clauses (SCC) adopted by the European Commission (accompanied, where appropriate, by any additional guarantees to ensure their effective application) to provide appropriate safeguards for such transfers in accordance with applicable law.

For more information on transfers outside the EEA, you can contact us at the address indicated in the “What are your rights regarding personal data” section.

WHAT ARE YOUR RIGHTS REGARDING PERSONAL DATA?

In accordance with the applicable regulations, you have the following rights:

• The right to ask the access to your Personal Data;
• The right to request the rectification or deletion of your Data;
• If necessary, the right to request a limitation of the processing of your Data;
• The right to object to the processing, in particular when the purpose of the processing in question is marketing communication. For processing based on your consent, you may withdraw your consent at any time.
• In certain circumstances, the right to portability of your Personal Data. The right to data portability enables you, where the processing of your Data is based on your consent or on an agreement, and is implemented using automated processes, to obtain from us that your Data be provided to you in a structured, commonly used and machine-readable format. Personal Data obtained in this way may then be passed on to another data controller without us interfering.

You may also define general or specific directives as to the fate of your Personal Data after your death. General directives can be registered with a trusted third party certified by the CNIL, while specific directives can be addressed directly to us.

For more information on your rights: Les droits pour maîtriser vos données personnelles | CNIL.

You may exercise your right with our data protection officer that may be contacted at the following email address: data-privacy@d-edge.com

Should you sign up for our mailing list and then change your mind and no longer wish to receive our newsletter in the future, please click the unsubscription link at the bottom of any of the newsletters you received from us.

If you believe that we are not complying with our obligations or your rights with respect to your Personal Data, you may file a complaint with the CNIL, in accordance with the applicable regulations.

WHAT IS OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES?

The website and its partners set cookies or other tracking devices on your device. To learn more about our use of cookies, please see our Cookie Policy & Preferences.

PRIVACY POLICY UPDATES

If we decide to change our privacy policy, we will post those changes on this site and notify you of material changes with an alert on the site or a communication to you.

LEGAL NOTICE

EDITOR’S INFORMATION

This site is edited by D-EDGE SAS

**Headquarters address:**64-66 rue des Archives
75003 Paris
FRANCE
Phone: +33 1 44 71 05 05

Trade and Companies Registry n° RCS: PARIS 431 513 852
Capital: 41,086,597.58€​
Publishing director: Isabelle Falque

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