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 Menez-Hom Atlantique Tourisme, whose main activities are the development of the tourism offer, the promotion of tourist destinations and the marketing of Menez-Hom Atlantique Tourisme's tourism offer.
In the context of its activity, Menez-Hom Atlantique Tourisme 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 any natural or legal person who has entered into a contract of any kind with Menez-Hom Atlantique Tourisme, it being understood that the latter is intended to work with tourism professionals, departments or the general public;
partners are understood to be all natural or legal persons involved in the tourism sector and maintaining relations with Menez-Hom Atlantique Tourisme in this capacity, such as, in particular, tourism professionals in the département, project sponsors and internal and external investors, holiday distributors, local authorities and their groupings, and institutional partners;
Prospects are understood to be any potential customer or any contact recipient of promotional messages from Menez-Hom Atlantique Tourisme whose data has been collected directly via contact forms, events or indirectly via any partner of Menez-Hom Atlantique Tourisme.

1.2. PURPOSE AND SCOPE

The present personal data protection policy is intended to apply to the processing of personal data of customers, partners and prospects of Menez-Hom Atlantique Tourisme.
As such, the present policy is intended to meet Menez-Hom Atlantique Tourisme's obligation to provide information and thus to formalize the rights and obligations of customers, partners and prospects with regard to the processing of their data.
This policy applies only to data processing for which Menez-Hom Atlantique Tourisme is responsible and to data qualified as "structured".
The processing of personal data may be managed directly by Menez-Hom Atlantique Tourisme or through a subcontractor specifically appointed by it.
This policy is independent of any other document that may apply within the contractual relationship between Menez-Hom Atlantique Tourisme and its customers, partners and prospects.
No processing is implemented by Menez-Hom Atlantique Tourisme 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

Menez-Hom Atlantique Tourisme 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 Menez-Hom Atlantique Tourisme (e.g. trade fairs, workshops, etc.);
rental or acquisition of databases on an exceptional basis ;
communication of contacts through specialized companies or partners of Menez-Hom Atlantique Tourisme.

2.3 PURPOSE

Depending on the case, Menez-Hom Atlantique Tourisme 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 Menez-Hom Atlantique Tourisme (trade fairs, workshops, etc.) ;
sending newsletters or information feeds;
customer account management ;
answers to questions that may be asked by telephone or online ;
improvement of Menez-Hom Atlantique Tourisme services;
meet the administrative obligations of Menez-Hom Atlantique Tourisme ;
community management ;
statistics.

2.4. SHELF LIFE

The length of time Menez-Hom Atlantique Tourisme keeps customer data is defined by Menez-Hom Atlantique Tourisme in the light of the legal and contractual constraints it is subject to 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 Menez-Hom Atlantique Tourisme, plus 3 years for promotional and prospecting purposes, without prejudice to retention obligations or limitation periods
Technical data 1 year from the date of 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 Menez-Hom Atlantique Tourisme 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

Menez-Hom Atlantique Tourisme collects data from its partners from :

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, Menez-Hom Atlantique Tourisme processes the data of its partners for the following purposes:

partner relationship management ;
labeling of sites and facilities for the sectors entrusted by Menez-Hom Atlantique Tourisme ;
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 Menez-Hom Atlantique Tourisme (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 Menez-Hom Atlantique Tourisme in the light of legal and contractual constraints and, failing that, according to its needs and in particular according to the following principles:
Processing Retention period
Data relating to partners For the duration of the contractual relationship with Menez-Hom Atlantique Tourisme, increased by 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

Menez-Hom Atlantique Tourisme 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 Menez-Hom Atlantique Tourisme (e.g. trade fairs, workshops, etc.);
list provided by the organizers of events or conferences in which we participate;
database rental by Menez-Hom Atlantique Tourisme on an exceptional basis;
communication of contacts through specialized companies or partners of Menez-Hom Atlantique Tourisme.

4.3. PURPOSE

Depending on the case, Menez-Hom Atlantique Tourisme processes the data of its prospects for the following purposes:

prospect relationship management (PRM) ;
management of events organized by Menez-Hom Atlantique Tourisme (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 ;
promotion of Menez-Hom Atlantique Tourisme and Menez-Hom Atlantique tourism on social networks (Facebook, Twitter, YouTube, Instagram, ...) ;
behavioral analysis of prospects ;
community management ;
statistics.

4.4. SHELF LIFE

The length of time Menez-Hom Atlantique Tourisme keeps prospect data is defined by Menez-Hom Atlantique Tourisme in the light of legal and contractual constraints and, failing that, according to its needs and in particular according to the following principles:
Processing Length of retention
Data relating to contacts and prospects 3 years from their collection by Menez-Hom Atlantique Tourisme or the last contact from the prospect/contact
Cookies 13 months
Technical data 1 year from their collection

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.
Prospects are reminded that deletion or anonymization are irreversible operations and that Menez-Hom Atlantique Tourisme 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

Menez-Hom Atlantique Tourisme ensures that data is only accessible to authorized internal or external recipients.
Recipients of personal data of customers, partners and prospects within Menez-Hom Atlantique Tourisme are subject to an obligation of confidentiality.
Menez-Hom Atlantique Tourisme decides which recipient may have access to which data according to an authorization policy.
Menez-Hom Atlantique Tourisme 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, Menez-Hom Atlantique Tourisme is not responsible for the conditions under which the personnel of these authorities have access to and use the data.

Internal recipients External recipients

Authorized Menez-Hom Atlantique Tourisme 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 request confirmation from Menez-Hom Atlantique Tourisme as to whether or not data concerning them is being processed.
Customers, partners and prospects also have the right to access their personal data, 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: Office de Tourisme Menez Hom Atlantique, 9 rue Camille Danguillaume - 29150 Plomodiern or at info@mha-tourisme.com.
Customers, partners and prospects have the right to request a copy of their personal data processed by Menez-Hom Atlantique Tourisme. However, in the event of a request for an additional copy, Menez-Hom Atlantique Tourisme may require customers, partners and prospects to bear the cost.
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 Menez-Hom Atlantique Tourisme.

6.2. UPDATES AND CORRECTIONS

Menez-Hom Atlantique Tourisme 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 Menez-Hom Atlantique Tourisme, 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 Menez-Hom Atlantique Tourisme is lawful and that all personal data collected is necessary for the implementation of the purposes of such processing.

6.5. RIGHT TO PORTABILITY

Menez-Hom Atlantique Tourisme grants the right to data portability in the particular case of data communicated by customers, partners and prospects themselves, on online services offered by Menez-Hom Atlantique Tourisme 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

Menez-Hom Atlantique Tourisme does not make automated individual decisions.
The tools offered on the Menez-Hom Atlantique Tourisme website are only intended to help customers and prospects and should not be considered as anything else.

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 info@mha-tourisme.com or by post to the following address: Office de Tourisme Menez Hom Atlantique, 1 rue du Menez-Hom - 29550 Plomodiern, 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, Menez-Hom Atlantique Tourisme explains to customers, partners and prospects the consequences of failing to reply.

7.2. RIGHT OF USE

Customers, partners and prospects grant Menez-Hom Atlantique Tourisme the right to use and process their personal data for the purposes set out above.
However, enhanced data resulting from processing and analysis by Menez-Hom Atlantique Tourisme, otherwise known as enhanced data, remains its exclusive property (usage analysis, statistics, etc.).

7.3. SUBCONTRACTING

Menez-Hom Atlantique Tourisme 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, Menez-Hom Atlantique Tourisme ensures that the subcontractor complies with its obligations under the RGPD.
Menez-Hom Atlantique Tourisme undertakes to sign a written contract with all its subcontractors and imposes the same data protection obligations on subcontractors as it does. In addition, Menez-Hom Atlantique Tourisme reserves the right to audit its subcontractors to ensure compliance with the provisions of the RGPD.

7.4. TREATMENT REGISTER

Menez-Hom Atlantique Tourisme is implementing a data processing register.

8. SAFETY

8.1. SAFETY MEASURES

It is the responsibility of Menez-Hom Atlantique Tourisme to define and implement the physical or logical technical security measures it deems appropriate to protect against 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 event, Menez-Hom Atlantique Tourisme 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, Menez-Hom Atlantique Tourisme undertakes to contractually impose security guarantees on its subcontractors by means of technical data protection measures and appropriate human resources.

8.2. DATA BREACH

In the event of a personal data breach, Menez-Hom Atlantique Tourisme undertakes to notify the Cnil under the conditions prescribed by the RGPD.
If the said breach poses a high risk to customers, partners and prospects and the data has not been protected, Menez-Hom Atlantique Tourisme:

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. Menez Hom Atlantique Tourist Office CONTACT

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

Name: Centre de Gestion du Finistère - Service RGPD
E-mail address: protection.donnees@cdg29.bzh

9.2. DPO CONTACT

Menez-Hom Atlantique Tourisme has appointed a data protection officer whose contact details are as follows:

Name: Centre de Gestion du Finistère - Service RGPD
E-mail address:protection.donnees@cdg29.bzhr
Address: 7 bd du Finistère - 29 000 Quimper

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 Menez-Hom Atlantique Tourisme, including electronic means (e.g. distribution by e-mail or online).

11. FOR FURTHER INFORMATION

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