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Data Protection Policy

PRIVACY POLICY

Updated: September 18, 2023

I.    General information

This Policy contains information on the data protection measures implemented by the Cheval Blanc hotels(1) (‘Hotel(s)’), restaurants, spas and hair salons managed by LVMH Hotel Management (‘LVMH HM’), as data controllers.

(1) A list of our Hotels is available on our website at www.chevalblanc.com.

This Policy applies to all the personal data and information that you provide to us or that we collect when you stay at one of our Hotels or browse the www.chevalblanc.com website (the ‘Website’).

Our Hotels and/or LVMH HM may collect personal details from anyone who makes an inquiry via the ‘Contact’ form on our Website, makes an online reservation at one of our Hotels via our Website, or makes an online reservation in a Restaurant or Café of one of our Hotels. Any personal information which you provide to our Hotels and/or to LVMH HM is governed by French Data Protection Act No 78-17 of 6 January 1978 (as amended) and by the European General Data Protection Regulation.

II.  For what purposes and on what bases will your data be processed?

The personal data which we collect from you and process can be used to:

-  reply to your e-mail messages and provide you with information about our guest services, restaurants, spas, etc., based on our legitimate interest in replying to your requests;

-  enable you to make a reservation with us online, by e-mail or telephone or in person. Your data will be processed for the purpose of fulfilling our contract with you;

-  manage your stay at our Hotels and manage the restaurants, spas, points of sale and other services we offer. Your data will be processed for the purpose of fulfilling our contract with you and in the Hotel’s legitimate interest in running our business, finding out more about you and providing you with your chosen products and services;

-  offer you an optimal guest experience and provide you with the same personalised service whenever you stay at one of our Hotels. Your data will be processed for the purpose of fulfilling our contract with you and in the Hotel’s legitimate interest in providing the services we offer;

-  share personal data concerning our clients’ preferences and reservations with other Cheval Blanc Hotels. Your data will be processed based on our legitimate interest in finding out more about our clients in order to provide them with an optimal guest experience;

-  manage payment irregularities, behaviour that conflicts with our Code of Etiquette and subsequent access restrictions imposed on the person responsible. Your data will be processed in the Hotel’s legitimate interest in providing the services we offer;

-  complete check-in and check-out formalities when you stay at one of our Hotels. Your data must be processed in this way in order to comply with a legal obligation;

-  manage security at our Hotels. Photos and images taken from our CCTV systems are processed in our legitimate interest in protecting people and property. This enables us to recognise our clients and to identify any unusual inappropriate behaviour;

-  interact with you and provide you with personalised services without needing to systematically ask you to prove your identity during your stay with us;

-  collect, with your prior consent, data concerning your children if they are minors and sensitive data concerning you;

-  manage newsletter subscriptions and cancellations, and provide you with information and special offers concerning our Hotels. Your data will be processed with your consent or based on our legitimate interest if you are already a Cheval Blanc client;

-  share your data with our partners, with your consent, to enable them to offer you property-related products and services and accommodation associated with our Hotels;

-  continually improve your guest experience by proposing personalised offers and services to you. The Cheval Blanc Hotels

belong to the LVMH group, which includes many luxury Maisons that offer exceptional products and services in all sectors: Fashion & Leather Goods, Perfumes & Cosmetics, Watches & Jewellery, Wines & Spirits, Selective Retailing and Hospitality, Culture & Leisure. A list of all LVMH Maisons is available at https://www.lvmh.com. If you are an existing Cheval Blanc client, you may also be a client of one or more other LVMH Maisons. Therefore, with your express prior consent, pseudonymised data (i.e., data that do not include your name or contact details) concerning the purchases you have made from us over the last three years will be transferred to LVMH, our parent company acting in the capacity of processor. All data concerning the purchases you make from our Maison and from our group’s other Maisons to which you have also given your consent will then be compared. On the basis of this analysis, LVMH HM will receive additional information concerning your purchasing habits and preferences (which will not include information on the other Maison(s) from which you made those purchases);

-  secure and improve your use of our Website. Your data will be processed based on the Hotel’s legitimate interest in running its business and in managing and protecting its systems against fraud and hacking; and

-  manage accounting and financial matters and potential disputes. Your data will be processed for the purpose of fulfilling our contract with you and to comply with a legal obligation.

You may withdraw your consent at any time, without affecting the lawfulness of the processing operations carried out previously with your consent. If you withdraw your consent to the processing of data needed to provide a service, you will no longer be able to receive the relevant service.

III. Are you obliged to provide us with your personal data?

The data which our Hotels and/or LVMH HM require for the above purposes are marked with an asterisk on the relevant forms. If you do not complete the required fields, we will be unable to provide you with your chosen services or to fulfil your request, as applicable.

The data not marked with an asterisk are optional and will enable our Hotels and LVMH HM to find out more about you and improve the services we offer.

IV. How long will we retain your data for?

Your data will be retained strictly for the period of time necessary to fulfil the following purposes:

Manage client data

Your data will be retained for the duration of your stay at a Cheval Blanc Hotel and for five years after the end of your last stay with us.

Passport details

Manage sensitive data

With your consent, your sensitive data will be retained for the duration of your stay at a Cheval Blanc Hotel and for five years after the end of your last stay with us.

Manage payments

Your payment details will be retained until the relevant transaction has been completed and for up to ten days after the end of your stay with us in case any further charges are incurred.

With your prior consent, your payment details (excluding your 3-digit security code) will be retained for 13 months after the date of any debit card transaction or for 15 months if you paid using a deferred payment method.

Manage financial and accounting information

Your data will be retained until the end of the relevant financial year and approval of our accounts.

Contract data will be retained for five years after the end of your stay (the limitation period). Your data will then be stored on an archive database for ten years from the end of your stay.

Manage our newsletter

Your data will be retained for as long as your subscription is active and we remain in contact, i.e., providing that you open our Newsletter or interact with us. If we do not hear from you for three years and if you do not reply to two successive messages from us, your data will be deleted.

Manage marketing operations

Your data will be retained for three years after our last contact or if you do not reply to two successive messages from us.

V. Who will your data be transferred to ?

Your data will be communicated or transferred strictly on a need-to-know basis.

Your data will be sent to the following:

Internal recipients

External recipients

Our Hotels and/or LVMH HM will only transfer your data to a third party in the following cases:

-  if our Hotels and/or LVMH HM are required to share data with a third party in order to provide the service you have requested or to reply to your inquiry;

-  if our Hotels and/or LVMH HM are required to share data with other Cheval Blanc Hotels. Your data will be processed based on our legitimate interest in finding out more about our clients in order to provide them with an optimal guest experience;

-  if you have given your prior consent for our Hotels and/or LVMH HM to share your data with our partners or other LVMH Maisons; and

-  if our Hotels and/or LVMH HM are required by a competent authority (including a court of law or an administrative authority) to provide the relevant data.

VI.    Will your data be transferred outside the European Economic Area?

The persons to whom we transfer your data may be located in a foreign country, including outside the European Economic Area. Any of your data transferred to countries outside the European Economic Area are transferred subject to appropriate safeguards, including contractual safeguards and our Binding Corporate Rules (BCR) in relation to job applicants’ personal data, in accordance with applicable data protection regulations.

You may obtain a copy of the appropriate safeguards by contacting LVMH HM by post at 24-32 Rue Jean Goujon, 75008 Paris, France or by e-mail at: dataprivacy@chevalblanc.com.

VII.  Data security and confidentiality

Our Hotels and/or LVMH HM have implemented technical and organisational security measures in accordance with industry standards, particularly in order to safeguard our information systems.

Our Hotels and/or LVMH HM have endeavoured to take appropriate measures to protect the confidentiality and security of your personal data which we process, ensure that they are not corrupted, damaged or destroyed and ensure that they are not accessed by unauthorised third parties.

In accordance with the security policy implemented by our Hotels and/or LVMH HM, when making a reservation with us, you must enter a password for your client account, which will be strictly personal to you.

VIII. Payment security

Payments made by bank card will be processed by a secure system in accordance with applicable regulations and standards. The payment details will therefore be encrypted by a piece of software and no third party will be able to access the information whilst it is on our system.

IX. What are your rights?

You have a right to access your personal data, request the rectification, erasure or portability of your data, restrict the processing of your data, withdraw your consent and give instructions regarding the use of your data after you die.

You may also object, at any time, to:

·       the processing of your data for the marketing operations carried out by our Hotels and/or LVMH HM; and

·       processing based on the legitimate interest of our Hotels and/or LVMH HM, for reasons pertaining to your personal circumstances.

You may exercise these rights at any time by contacting our Data Protection Officer (DPO) by post at LVMH HM, 24-32 Rue Jean Goujon, 75008 Paris or by e-mail at: dataprivacy@chevalblanc.com.

You also have the right to submit a complaint to a supervisory authority concerning the data processing operations carried out by our Hotels and/or LVMH HM.

COOKIE POLICY

I.    What is a cookie?

A cookie is a small text file that uploads to your device (computer, tablet, smartphone, etc.) and collects and stores some of your personal data when you browse our Website (such as your preferences, the elements you click on, the time and number of times you visit our Website, your login details, etc.), thus enabling our Website to recognise your device.

Not all cookies are the same. They may differ depending on their origin and for how long they are stored on your device.

Our external partners will install cookies on your device when you visit their web pages.

Third-party cookies are governed by the privacy policy published by the relevant third party on its website.

A list of our partners that use cookies on our Website is available in the Privacy Preference Center, which can be accessed by clicking on the ‘Manage cookie settings’ link at the bottom of the web page.

There are other types of tracking technologies, which are commonly referred to as web beacons and also collect information about you. Although this information will not necessarily include your personal data, it will also be linked to your browsing of a website and will be combined with the information collected by cookies, such as digital footprints, tags, logs, http variables, localStorage mechanisms, advertising identifiers, etc.

These other trackers are subject to the same rules as cookies and are therefore also governed by this policy. For the sake of simplicity, the term ‘cookies’ will be used here to refer to all types of tracker.

More information is available at https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs and https://www.youronlinechoices.com/uk/

II.  The cookies we use on our Website

When you log into our Website, cookies will be stored on your device that will enable us to recognise the browser you are using for as long as the cookies remain valid. This section contains information on the cookies that will be stored on your device, which will also appear on our cookies banner.

The various cookies we use are stored for different periods of time, after which they will be automatically deleted unless you renew your consent.

Information concerning the name and functionality of each cookie as well as the period of time for which it will be stored is available in the Privacy Preference Center, which is accessible by clicking on this link: https://www.chevalblanc.com/en/cookies/.

a.           Strictly necessary cookies

These cookies are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

These cookies are based on our legitimate interest and cannot therefore be deactivated via our settings system.

You may however configure your browser to block strictly necessary cookies, although if you do, we cannot guarantee that you will be able to use our Website.

b.           Functionality cookies

These cookies enable our Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to the pages of our Website.

We use these cookies based on your consent. If you do not allow these cookies, then some or all of these services may not function properly.

c.            Performance cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They also help us to know which pages are the most and least popular and see how visitors move around our Website.

We use these cookies based on your consent. Blocking them will not affect your browsing of our Website, but we will be unable to monitor and analyse how you move around and interact with our Website.

d.           Targeting cookies

These cookies may be set through our Website by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

We use these cookies based on your consent. If you do not allow these cookies, you will experience less-targeted advertising.

III. Why do we use cookies?

Cookies are used on our Website for the following purposes:

-  to prepare statistics on visits to and the use of the various elements of our Website (pages and content visited, and how you move around and interact with our Website) to enable us to improve the appeal and efficiency of the services we offer;

-  to adapt the presentation of our Website to your device’s display preferences (language, screen resolution, operating system, etc.) when you visit our Website, depending on your device and the visualisation and player software installed on it;

-  to link any personal details (particularly your e-mail address) you provide to us when you register for or access one of our services with browsing information concerning your device, in order to send you marketing e-mails that might be of interest to you for example;

-  to memorise information contained on a form you complete on our Website (when you register or access your account) or information about products, services or items you select on our Website (services, reservation details, etc.);

-  to enable you to access reserved and personal pages on our Website, such as your account, using login details or data you have provided to us in the past; and

-  to implement security measures, for example when you are asked to log in again to content or a service after a certain period of time.

IV. Your cookie choices

Cookies will only be installed on your device with your consent, unless they are strictly necessary, in which case their use is based on our legitimate interest.

Consequently, you may choose to allow or block the majority of cookies used on our Website, at any time.

IV.1 The choices that will be put to you on our Website

As soon as you visit our Website, a cookie banner will appear, containing information on how cookies are used.

This banner enables you to allow or block some or all of the cookies we use. Your decision will apply solely to the cookies used on our Website.

If you block one or more cookies, you will not be able to use the relevant functionalities described above.

Your decision to allow or block the cookies that require your consent will apply for a maximum of six months.

You may change the cookie preferences you selected when you first visited our Website at any time by going to the Privacy Preference Center, which is accessible by clicking on this link: https://www.chevalblanc.com/en/cookies/.

IV.2 The choices offered to you by your browser software

You may also configure your browser software to store cookies on your device or block them, either systematically or based on their origin.

You may also configure your browser software to ask you to allow or block cookies from time to time before they are stored on your device.

Cookies are managed differently, depending on your browser. Information on how to change your cookie preferences is available in the help section of your browser.

Internet Explorer™

http://windows.microsoft.com/fr-FR/windows-vista/Reject-or-allow-cookies

Safari™

https://support.apple.com/kb/ph21411?locale=fr_CA 

Chrome™

http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

Firefox™

https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences

Opera™

http://help.opera.com/en/latest/web-preferences/#cookies

Your decision to allow or block cookies will affect your browsing experience and determine whether you may access certain services that require the use of cookies.

We decline all responsibility for any consequences due to the downgraded operation of our services resulting from the fact that it is impossible for our Hotels and/or LVMH HM to store or consult the cookies necessary which you have blocked or deleted.

V.   If you share your device with others

If your device has several pieces of browsing software and is used by others, we cannot guarantee that the services and advertisements intended for your device will be suitable for you rather than another user.

You may decide to share your device with others and must configure your cookie settings accordingly, under your sole responsibility.

VI. Security

Payments made by card are performed via a secure system using the SSL (Secure Socket Layer) protocol in such a way that information transmitted is software-encrypted, and no third party can access it during transport on the network.