Customer personal data protection charter

1. Adagio’s commitment to privacy protection

As a subsidiary company of two major players in the tourism industry (Accor and Groupe Pierre & Vacances Center Parcs), we would like to confirm that our top priority is to offer you high-quality stays at our establishments.

Maintaining your complete satisfaction and trust are vital considerations for us.

That is why, as part of our commitment to meeting your expectations, we have implemented a privacy protection policy. This Charter sets out our commitments to you and describes how we use the personal data you provide to us when making your booking or during your stay.

2. Consent

“Personal data” means any information gathered and logged in a format that enables you to be identified personally, as an individual. Before you send us this information, we recommend you to take due note of the rest of this document, describing our policy concerning protection of your personal data.

This Personal Data Protection Charter forms part of the general terms and conditions governing our accommodation services. By accepting our general terms and conditions of sale, you are expressly accepting the provisions of this Charter.

3. Our principles governing protection of your personal data

To protect your data, we apply and adhere to the following principles:

1. Transparency: when gathering and processing your personal data, we will provide you with full information and tell you why the data is being processed and who is receiving it.
2. Legitimacy: we will gather and process your personal data solely for the purposes described in this Charter.
3. Pertinence and accuracy: we gather only personal data that is necessary for data-processing purposes. We will take all reasonable measures to ensure that the personal data we hold on you is accurate and up to date.
4. Retention: we will retain your personal data for the period necessary to process the data in accordance with the requirements laid down by law.
5. Access, rectification and withholding permission: you are entitled to access, amend, correct or delete your personal data. You can also withhold permission for the use of your personal data, so that you do not receive any marketing material.
6. Confidentiality and security: we will put in place reasonable technical and organisational measures to protect your personal data against accidental or illicit corruption or loss or unauthorised use, disclosure or access.
7. Sharing and international transfers: we are entitled to share your personal data with our shareholders or third parties (such as business partners and/or service providers) for the purposes set out in this Charter. We will take appropriate measures to guarantee the security of the sharing and transfer processes.

4. Scope of application

This Charter applies to:

1. All data-processing undertaken in our aparthotels operated either directly (by the Adagio SAS entity) or indirectly by Adagio (under a management agreement) or its franchisees;
2. Our booking websites, notably www.adagio-city.com
3. Although our customer privacy protection policies cannot be imposed on our aparthotel franchisees, we make every effort to promote the principles laid down by this Charter, so that our franchisees will comply with the laws applicable in connection with the processing of your personal data.

5. What personal data do we gather?

At various times, in your capacity as a customer, we may have to ask you to provide us with information about yourself and/or members of your family, such as:

• contact details (e.g. surname, first name, telephone no., email address, etc.);
• personal information (e.g. date of birth, nationality, etc.);
• information on your children (e.g. first name, date of birth, age, etc.);
• your credit card no., (for transaction and booking purposes);
• your membership no. of the loyalty programme or of any other partner programme (e.g. airlines);
• your arrival and departure dates;
• your preferences and interests (e.g. smoking or non-smoking room, preferred floor level, bedding type, newspapers/magazines you read, sports, cultural interests, etc.);
• any queries/comments you make, either during or after a stay in one of our establishments.

The information that can be gathered on persons aged under 18 is limited solely to their name, nationality and date of birth, which can be supplied to us only by an adult. Please ensure that your children do not transmit any personal data to us without your permission (notably via the Internet). If data is transmitted in this way, you can contact the Data Privacy Department (see “Access and Amendments” article), and arrange for this information to be deleted.

We do not intentionally gather sensitive information, such as that concerning racial or ethnic origins, political opinions, religious and philosophical beliefs, trade union membership, details of personal health or sexual orientation.

Depending on the local laws applicable, other information may also be deemed sensitive, and in particular: your credit card no., your leisure interests, personal activities and hobbies, whether or not you are a smoker, etc. We may have to gather this information in order to comply with your requests or to provide you with the service required, such as a specific diet, for example.

In this case, depending on the laws in force in certain countries, you may be asked to give your permission before any sensitive information is gathered.

6. When do we gather your personal data?

Personal data may be gathered at various times, including in connection with:

1. Accommodation and related activities:
   • Booking an aparthotel;
   • Registration and payment;
   • Food and drink consumed in the bar or restaurant of the aparthotel during a stay;
   • Requests, complaints and/or disputes.
2. Participation in marketing programmes or events:
   • Registering for loyalty programmes;
   • Contributing to satisfaction surveys;
   • On-line competitions or games;
   • Subscribing to newsletters, in order to receive email offers and promotions;
   • Requesting a quotation;
   • Requesting information by telephone.
3. Transmission of information from third parties:
   • Tour operators, travel agents, GDS booking systems, others, etc.;
4. Internet activities:
   • Connecting to Adagio, all.accor.com, Pierre & Vacances websites (IP address, cookies);
   • Completing on-line forms (on-line bookings, questionnaires, Adagio social media pages, connection facilities such as Facebook Login, etc.).

7. What is the data used for?

We gather your personal data for the following purposes:

1. Meeting our obligations to our customers.
2. Managing accommodation bookings and enquiries:
   • Preparing and holding on file legal documents that comply with accounting standards;
3. Managing your stay at the aparthotel:
   • Monitoring items consumed by you (telephone, bar, payTV, etc.)
   • Managing access to accommodation units
   • Internal management of a list of customers who have behaved inappropriately during their stay at the aparthotel (aggressive and anti-social behaviour, breach of the accommodation agreement or of safety rules, incidents of theft, damage and vandalism or payment incidents).
4. Enhancing our accommodation service, and in particular:
   • Processing your personal data in our customer marketing programme, for the purpose of undertaking marketing and brand promotion operations, and improving our understanding of your needs and wishes;
   • Adapting our products and services to meet your requirements as effectively as possible;
   • Personalising the marketing offers and customer-relationship messages sent to you;
   • Keeping you informed of any special offers and new services created by Adagio or one of its shareholders
5. Managing our relationship with our customers before, during and after your stay:
   • Managing the loyalty programme;
   • Feeding information into the customer database;
   • Segmentation operations based on customers’ booking history and travel habits, with a view to sending out targeted communications;
   • Predicting and anticipating future behaviours;
   • Preparing business statistics and ratings, and carrying out reporting;
   • Providing context data for the offer push tool when a customer visits our websites or makes a booking;
   • Finding out and managing the preferences of existing and new customers;
   • Sending you newsletters, promotions and tourism-related offers covering accommodation or services, or offers from our partners or contacting you by telephone;
   • Managing requests to unsubscribe from newsletters, promotions, tourism-related offers and satisfaction surveys;
   • Taking appropriate action where customers withhold permission for the company to contact them;
   • Using a dedicated telephone service to establish the whereabouts of persons staying in aparthotels in the event of any serious events impacting the site in question (natural disasters, terrorist attacks, etc.);
6. Cross-checking, analysing and combining, via a trusted third party, the data gathered on you at the time of your booking or your stay, so that we can establish your interests and your customer profile and send you personalised offers.
7. Enhancing our services, and in particular:
   • Performing studies and analyses of customer questionnaires and comments;
   • Managing complaints;
   • Allowing you to enjoy the benefits of our loyalty programme.
8. Enhancing your use of our website and ensuring you can use it under secure conditions, and in particular:
   • Enhanced browsing
   • Ensuring security and fraud prevention
9. Complying with local legislation (e.g. holding accounting documents on file)

10. Finally, and if you have consented, we may send you direct messages containing promotional offers and news via other communication channels such as mobile push notifications or social channels such as WhatsApp. By accepting the communication channel, you agree that Adagio may communicate directly with you using the WhatsApp messaging service. You may unsubscribe at any time via the same messaging service. The information collected by Adagio on its own behalf as part of this service is governed by this Policy. However, Adagio is not responsible for the subsequent use of your data by WhatsApp on its own behalf. We therefore invite you to consult the WhatsApp privacy policy in order to be aware of the information collected by this third party: https://www.whatsapp.com/legal/#privacy-policy.

8. Conditions governing third-party access to your personal data

To ensure that our services proceed smoothly, we are required to share your personal data with internal and external recipients, under the following conditions:

a. Within Adagio: we are entitled to share your personal data and allow the following persons to have access to your data:

• Staff of the aparthotel at which you have made a booking;
• Reservation staff using our booking tools;
• IT services;
• Business partners and marketing services;
• Medical services, if applicable;
• Legal services, if applicable;
• In general terms, any appropriate person linked to certain specific categories of personal data.

b. In the case of suppliers, service providers and partners: your personal data may be passed on to a third party with a view to providing you with services and enhancing your stay, including:

1. External service providers: IT subcontractors, international call centres, banks, credit card issuers, external law firms, printers.
2. Business partners: unless you have withheld your permission by writing to the Data Privacy Department, we will be entitled to enrich your profile by sharing, with our favoured business partners, certain information held on you. In this case, the tasks of cross-checking, analysing and combining your data may be performed via a trusted third party. This will enable us to establish your interests and customer profile, and to send you personalised offers.
3. Social media sites: We have set up the Facebook Login system, so that you can identify yourself easily on the website without needing to complete a registration form. If you connect using the Facebook Login system, you explicitly authorise us to access and store the public data held in your Facebook account, together with any other data referred to when using the Facebook Login system. We will also be entitled to provide Facebook with your email address for the purpose of identifying whether you are already a Facebook user so that, if applicable, we can display personalised and pertinent advertisements on your Facebook account.

c. Local authorities: we may also have to pass on your information to local authorities, if required to do so by law or within the framework of an investigation, and in accordance with local regulations.

9. Protection of your personal data in the case of international transfers

For the purposes set out in Article 7 of this Charter, we can transfer your personal data to internal or external recipients who may be based in countries offering different levels of protection of personal data.

As a result, in addition to establishing this Charter, we implement appropriate measures to secure the transfer of your personal data to an Adagio entity or an external recipient located in a country offering a level of protection different from that offered in the country in which the personal data is gathered.

In this context, notably that of the booking process, your data may be passed on to aparthotels located outside the European Union, and in particular in the following countries: Brazil, the United Arab Emirates, Morocco, Qatar, Russia and Dubai.

The flow of data, other than that necessary to execute your booking, to countries that do not have equivalent personal data protection standards, will then be governed by standard contractual clauses setting out the responsibilities and liabilities of controllers and processors, as defined by the European Commission.

10. Data security

We take appropriate technical and organisational measures, in accordance with the legal provisions applicable, to protect your personal data against illicit or accidental destruction, accidental loss or corruption, or unauthorised disclosure or access. To this end, we have put in place technical measures (such as firewalls) and organisational measures (such as a log-in name / password system, physical protection means, etc.).

Where you transmit information concerning your credit card at the time you make your booking, your transactions will be secured by SSL (Secure Socket Layer) encryption technology.

11. Cookies and other tracers

We use cookies and other tracers on our on-line booking site. For further information on the use of these tracers and how to define their settings, please consult our tracer policy.

12. Data retention

We hold on to your personal data only for the period necessary for the purposes set out in this Charter or as provided for by the governing law.

13. Access and amendments

You are entitled to access the personal data we hold on you and to amend it, subject to the legal provisions applicable.

You can also exercise your right to withhold permission or to issue instructions on what should happen to your data when you die, by writing to the address below.

If you encounter any difficulties in exercising your rights, please contact the department responsible for personal data directly, either by email at the address data.privacy@adagio-city.com or by writing to the following address:

ADAGIO SAS
Département Protection des Données Personnelles 
(Data Privacy)
11, rue de Cambrai
75019 Paris, France

For the purposes of maintaining confidentiality and protecting your personal data, we will have to check your identity in order to comply with your request. Accordingly, in support of your request, you may be asked to attach a copy of an official ID document, such as a driving licence or passport.

If your personal data is not accurate, complete or up to date, please send the amendments to the Data Privacy Department indicated above.

All requests will be processed as soon as possible and in accordance with the governing law.

You can also exercise your rights in respect of the personal data held on you and processed by an aparthotel following a stay there. In this case, you must contact the aparthotel in question directly.

14. Updates

We may amend this Charter from time to time. We therefore invite you to consult this Charter at regular intervals, especially when making a booking at one of our aparthotels.

15. Queries and contact

If you have any queries concerning this Charter and our personal data management policy, please contact the Data Privacy Department (see “Access and Amendments” article).