1. PERSONAL DATA COLLECTED BY OENOTHERA
The personal data we may collect comes from 3 different sources:
- Data collected from customers
- Data supplied by third parties (partners or service providers)
- Data collected automatically
This data includes the following:
1. Identity and family status (title, surname, first name, status, etc.)
2. Address and contact details (email address, postal address, mobile no., etc.)
3. Education and career (qualifications, jobs, etc.)
4. Financial details (bank card no., payment methods)
5. Consumption of goods and services, preferences and areas of interest (transactions; date, place and amount of expenditure; activities, etc.)
6. Electronic identification data (customer identification no., IP address, location data, MAC address, etc.)
7. Time and location information (monitoring of activities, cookies, logs, geolocation, etc.)
8. Loyalty programs of Oenothera and its partners, loyalty program membership no., etc.)
9. Health information provided by the customer (allergies, disabilities, etc.)2. USE OF DATA
Your personal data is used by Oenothera for the purpose of managing and delivering the services provided to you and without which Oenothera would be unable to provide or render these services.
This use covers, firstly, the management of offers, the monitoring of services and, more generally, our entire business relationship (subscription to Oenothera's newsletter or communication materials; visits to our channels; quotes; reservations; orders; subscriptions; loyalty accounts; Wi-Fi or home automation services; reviews; surveys; information and marketing communications through all the means of communication you have provided for this use; and your contributions and posts on Oenothera's accounts, social media or mentioning hashtags, brands, events, places, offers, services, products, channels, etc. (including through third parties)).
Oenothera may also use your data to evaluate and improve its services and to develop new ones, as well as to run loyalty campaigns, target potential customers, conduct surveys and carry out promotional activities. Unless you object, you may receive offers from Oenothera or its business partners through all the means of communication you have provided for this use for services similar to those offered by Oenothera.
With your express consent, Oenothera may through all the means of communication you have provided for this use, send you marketing information for services that are not similar to those already provided.
This data will be stored for as long as is necessary for these purposes and for a maximum of three years from the date of the end of the business relationship with regard to direct marketing. Oenothera may also use your data to meet its legal requirements (in particular the fight against fraud and money laundering) and/or in response to requests from public and governmental authorities.3. PERSONAL DATA ACCESS AND CUSTOMER RIGHTS
In accordance with Regulation (EU) 2016/679 of 27 April 2016 and amended (Monegasque) Law No. 1.165 of 23 December 1993, you have a right of access to and a right to the rectification, erasure and portability of your personal data as well as a right to object and restrict the processing of this personal data. You may also define the instructions for the outcome of your personal data after your death. With proof of your identity, you may exercise your rights by email at firstname.lastname@example.org
. If, after contacting the email, you do not feel that your rights have been observed, you may make a claim with the French Data Protection Authority (CNIL – Commission Nationale de l'Informatique et des Libertés) or the Monegasque authority, the Commission for Control of Personally Identifiable Information (CCIN.mc – Commission de Contrôle des Informations Nominatives). The data which Oenothera needs for the purpose for which they were collected, necessary for compliance with a legal obligation and/or for the establishment, exercise or defence of rights in court, may not, however, be deleted.4. SUBCONTRACTING OF PERSONAL DATA PROCESSING
Your personal data is processed by Oenothera, its subcontractors or partners for the purpose of managing and delivering the services you have requested or authorised. Your data may also be transferred to third-party service providers who provide services or support and advice to Oenothera. On request, data may also be transferred to persons and authorities whose right to access personal data is recognised by the law, regulations or provisions issued by the legally competent authorities. Subcontractors and partners of Oenothera may be located outside the European Union. When a subcontractor or partner is located in a country that has not been recognised as having an adequate level of protection, Oenothera requires it to comply with its own requirements on the security and privacy of your personal data and to process your data only for the purposes it has identified. 5. PERSONAL DATA RETENTION
Your personal data is stored in our databases in Monaco or in those of our subcontractors for a period in accordance with legal provisions or proportional to the purposes for which they were saved. In some cases, and mainly for technical reasons, your data may be stored on servers located outside of Monaco or the European Union.
The table below lists the main retention periods for your data.
In any case, we regularly revise the relevance of any information we hold. When their retention is no longer justified by commercial requirements or requirements related to the management of your customer account or if you have exercised a right of modification or erasure, we will securely delete them (with the exception of data necessary to establish proof of a right or contract).
- Data category: Civil status, contact data
- Purpose: Creation and management of a prospective customers file
- Retention period: 3 years, starting with the collection of data or the last communication from the prospective customer
- Data category: Civil status, contact data, Lifestyle habits, economic and financial information
- Purpose: Management of the customer and provision of subscribed services, concierge services, data relating to bill payments
- Retention period: duration of the contractual relationship or 10 years for financial data
- Data category: Civil status, contact data, social network username
- Purpose: completing tasks for loyalty cards, prospective customers, studies, surveys, promotions and offers, complaint management
- Retention period: duration of the contractual relationship or 3 years, starting with the data collection or last communication.
- Data category: Contact data
- Purpose: Sending personalised marketing communications
- Retention period: Maximum of 3 years, starting with unsubscribing or last communication from customer
6. PERSONAL DATA SECURITY
- Civil status: Civility, surname, first name, date of birth, place of birth, address, postal code, city, country, nationality, passport number or identity card
- Contact data: E-mail, telephone number, fax
- Lifestyle habits: Contact preferences, contact language, tastes and preferences
- Economic and financial information: Banking information, subscription, payment method, card number
Oenothera implements the necessary measures to protect the personal data it processes. Your data is processed electronically and/or manually, and in any case, in such a way to ensure its security, protection and privacy appropriate for its sensitivity level, through administrative, technical and physical measures to prevent loss, theft and unauthorised use, disclosure or changes. In case of breach of your personal data liable to pose a high risk to your rights and freedoms, Oenothera shall inform you as soon as possible and take all necessary measures to limit the risks related to this breach. Whether your data is processed by Oenothera or by its subcontractors and partners, the same security and privacy requirements apply to your personal data.7.COOKIES AND OTHER TRACKERS