Privacy Policy

Version updated as of 08/25/2020

__SOCIETE_ is committed to protecting your privacy. Please contact us if you have any questions or problems regarding the use of your personal data and we will be happy to help you. This privacy policy is part of our Conditions of sale ; By accepting the terms and conditions, you also agree to this policy. In the event of a collision of terms used in the Conditions of Sale and the Privacy Policy, the latter will prevail.

Definitions

__SOCIETE_ Trade name used by SAS __SOCIETE_, with capital of €50,000, having its registered office at __ADRESSE_ France, registered in the Nantes Trade and Companies Register under number __IMMAT_, represented by Mr __NOM_ in his capacity as Chairman;
Administration State service that gives concrete form to the exercise of public powers in civil status or immigration matters;
Application IT solution that enables the User to use the Features and Services offered by __SOCIETE_ ;
Customer : Person who has signed and adhered to the General Terms and Conditions and the obligations they contain;
Administrative document : Document requested by the Client to carry out personal or professional administrative procedures;
Data) Any element (information, texts, photographs, photocopies, messages, etc.) collected by the User and implemented by him/her within the Site, the Application and the Services through his/her use;
Personal data) Identifiable natural or legal person" means any natural or legal person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, economic, cultural or social identity;
Functionality : Each element implemented, accessible and usable within the different Services;
Access Methods and/or functions by which the User can access one or more Services in order to use them for his or her own needs;
Operator Company that operates the various electronic telecommunications networks required for access to and use of the Services;
Services All the services made available to the User by __SOCIETE_ and accessible via the Means of Access;
Site (or Website) The __SOCIETE_ website enabling the User to access the Services, namely : https://www.carte-touristique-cuba.com Third party Individuals: Refers to natural or legal persons who are not linked by common ownership or control to __SOCIETE_ or other individuals unrelated to __SOCIETE_ and/or the User;
User : Refers to any natural or legal person accessing the Site and, where applicable, the Application.

Data protection principles

The company __SOCIETE_ undertakes to comply with the following data protection principles:

  • Processing is lawful, fair and transparent. The processing activities have legitimate reasons. The company __SOCIETE_ always considers your rights before processing personal data. It will provide you with information about the processing on request.
  • Processing is limited to the purpose. The processing activities correspond to the purpose for which the personal data was collected.
  • The company __SOCIETE_ collects and processes only the minimum amount of personal data required.
  • Processing is limited in time. The company __SOCIETE_ does not keep your personal data for longer than necessary.
  • The company __SOCIETE_ will do its utmost to ensure the integrity and confidentiality of the data.

In accordance with the Current regulations regarding Personal Data (RGPD), the processing operations described in this documentation must receive your prior consent. When you request Administrative Documents via the Website, you are asked to accept this Data Protection Policy.

The processing that we carry out may also be dictated to us by a legal obligation incumbent on us, in particular at the accounting or tax level.

Most of the processing carried out by __SOCIETE_ falls within the scope of the processing necessary for the contractual relationship and the provision of the service requested, namely the provision of Administrative Documents for the Customer.

Thus, the execution of the (pre)contractual relations which bind us, at your initiative, require the carrying out of a certain number of processing operations.

In any case, we ensure not to disregard your interests or your fundamental rights and freedoms by allowing you, at any time, to object to all or part of the processing described in this Personal Data Protection Policy.

As minors are also concerned by our services, this confidentiality policy also applies to them. Data concerning them is available to their legal representatives.

Who collects your Personal Data?

The Website is published by SAS __SOCIETE_, with share capital of €50,000, having its registered office at __ADRESSE_ in France and registered in the Nantes Trade and Companies Register under the number __IMMAT_, represented by Mr __NOM_ in his capacity as Chairman;

As part of the management and operation of the Site, and in its capacity as data controller under the French Data Protection Act of 6 January 1978, as amended, __SOCIETE_ may collect Users' Personal Data.

The Company __SOCIETE_ attaches great importance to respect for privacy and takes all necessary measures to ensure the confidentiality and security of Users' Personal Data. To this end, the Company __SOCIETE_ invites Users to familiarise themselves with this Data Protection Policy in order to be informed of how their Personal Data is processed and of their rights.

Who are the recipients of Personal Data?

The Personal Data of Users are collected and processed by the Company __SOCIETE_. The data may also be communicated to subcontractors of the Company __SOCIETE_ who act in the name and on behalf of the Company __SOCIETE_, and in particular the host of the Site.

The Company __SOCIETE_ may communicate Users' Personal Data in order to cooperate with the administrative and judicial authorities.

Lastly, the Company __SOCIETE_ may communicate Users' Personal Data to Third Party service providers as part of statistical studies of the use of the Site and for the purposes of optimising the Site. In this context, Users' Personal Data will be anonymised.

What personal data does __SOCIETE_ collect?

The Company __SOCIETE_ offers a platform to assist in the provision of Administrative Documents for Customers. In this respect, __SOCIETE_ collects personal data from Users submitting the request. Declarative information, provided by you, among:

  • Civility ;
  • Full name ;
  • Year and place of birth ;
  • Phone number* ;
  • E-mail address ;
  • Place of residence (address declared by the User) ;
  • Religion
  • The level of studies
  • Marital status and contact details of spouse
  • The civility of the parents and their place of birth
  • The employer (name and address)
  • Nationalities (current and original)
  • Passport (number, place of issue, validity dates)
  • Travel data (travel dates, place of arrival, content of the trip, purpose and history in the country or related countries)
  • Contacts in the Customer's country of origin and in the country targeted by the Customer

Information about you, collected automatically

  • The identifier of the connection at the origin of the communication;
  • Traces of connections (via cookies);
  • The identifier assigned by the information system to the content that is the subject of the operation;
  • The types of protocols used for connection to the service and for the transfer of content;
  • The nature of the operation.

Information provided by third parties

  • The presumed location of the User, based on IP data
  • His career on other websites
  • Payment information, secured so that it cannot be used for other purposes

* In accordance with article L.223-2 of the French Consumer Code, Users are hereby informed that they may, if they so wish, register on an opposition list against telephone canvassing available on the following website www.bloctel.gouv.freven though the telephone number provided to __SOCIETE_ is not passed on to any third party for commercial purposes during the ordering process.

For what purposes are personal data collected?

__SOCIETE_ uses Users' personal data for the following purposes:

  • Provision of Services;
  • Billing;
  • Obtaining Administrative Documents from Administrations;
  • Monitoring of files with Administrations;
  • Response to possible questions/complaints from Users;
  • Preparation of commercial statistics;
  • Marketing ;
  • Management of unpaid debts and disputes.

Does __SOCIETE_ use the services of external service providers?

YES, __SOCIETE_ wishes to offer the best service to its Users. In this respect, __SOCIETE_ relies on the best external service providers to :

  • Storage of personal data ;
  • Instant messaging ;
  • Email marketing;
  • Internal messaging;
  • Submitting Customer requests to authorities;
  • Online advertising;
  • Billing;
  • Collect opinions from Users;
  • Online payment.

Regarding the storage of personal data:

With regard to the storage of personal data, __SOCIETE_ has selected a Third Party service provider which has all the necessary approvals for the collection and storage of data. The servers used by this third party service provider are located in Switzerland.

In this regard, the selected service provider is the company Infomaniak, located at 25 rue Eugène-Marziano, 1227 Les Acacias (Switzerland), Tel. : +41 (0) 22 820 35 44. Its confidentiality policy is available at this address: https://www.infomaniak.com/fr/cgv/reglement-general-protection-donnees

The company __SOCIETE_ also uses Google Cloud solutions to manage its data and transfer it to external service providers. The Google Cloud confidentiality policy is available at this address: https://business.safety.google/intl/fr_fr/

About instant messaging :

__SOCIETE_ has an online instant messaging service through which the User can contact the services of __SOCIETE_. Some data may be collected in this context. The service used by __SOCIETE_ to provide this service is Brevo.

Brevo's privacy policy is available at : https://www.brevo.com/fr/rgpd/

Concerning email marketing (email & SMS):

__SOCIETE_ takes the liberty of sending you certain emails as part of your transactional process, in compliance with good practice, particularly with regard to unsubscribing. Certain data may be collected in this context. The service used by __SOCIETE_ to provide this service is Brevo.

Brevo's privacy policy is available at : https://www.brevo.com/fr/rgpd/

Internal messaging :

In order to process your data, __SOCIETE_ uses a high-performance messaging service, enabling it to work efficiently and effectively. To do this, it uses the messaging services of Google Workspace, whose confidentiality policy is set out below: https://business.safety.google/intl/fr_fr/ All data from this service provider (Google) via its services is hosted expressly in Europe. No message exchanged leaves the company, except to contact the Customer or the Administrative Services, and unless otherwise instructed by the Customer.

Regarding the submission of Customer requests to authorities:

Each external partner working with __SOCIETE_ must sign an NDA (non-disclosure agreement) particularly restrictive for the strict use of data for the sole purpose of submitting them to the competent authorities for the performance of the service for which the Customer mandates __SOCIETE_.

Online advertising:

The company __SOCIETE_ may occasionally use services to promote its activities. These services use Users' browsing patterns to provide them with a personalised message. These services are as follows:

Invoicing:

The company __SOCIETE_ relies on an external invoicing service, entirely dematerialised, in order to centralise and optimise the accounting management processes. This data is used to keep a history of Customer orders on the __SOCIETE_ Internet Sites and to keep its accounting documents, as required by the administration in the country of __SOCIETE_. Incwo's privacy policy is available at this address: https://go.incwo.com/termes-dutilisation-incwo/

Concerning the collection of Customer opinions:

The company __SOCIETE_ uses a trusted third party to collect Customer reviews following their order. The Google Reviews privacy policy is available at this address: https://privacy.google.com/intl/fr_fr/businesses/compliance/

Online payment:

When making a payment, __SOCIETE_ uses the resources of an external payment service provider in order to guarantee the fluidity and quality of its services.

For online payment, __SOCIETE_ uses the Stripe company. Stripe's confidentiality policy is available at the following address: https://stripe.com/ie/privacy

In particular, when making a payment, the service provider collects Personal Data concerning your means of payment (bank card number, expiry date of the bank card, visual cryptogram, the latter not being retained, etc.). Please note that __SOCIETE_ does not collect or hold any banking data directly.

How long is my personal data kept?

Your Personal Data on the Website as you have declared and/or completed on the Site are only kept for a strictly necessary period, namely:

Internal messaging :

  • Sensitive Customer documents: 18 months after receipt
  • Form entries: 18 months for a completed application
  • Product: 18 months after sending them to the Customer
  • Exchanges with Administrations: 18 months after their receipt

Website :

  • 30 days for partial entries
  • 6 months after customer return date for complete entries

Cloud :

  • Follow-up: 6 months after the customer return date
  • Files: 6 months after the customer return date

Billing and payment :

  • 10 years at the end of the financial year

These deadlines do not apply in the event of ongoing legal or administrative proceedings.

As part of a request for complete data on all media, the Customer may make a request on the contact form of the Website. You can also exercise your right to be forgotten by submitting a complaint to the CNIL.

On the other hand, cookies and Website audience measurement statistics are not kept for more than thirteen (13) months.

How does __SOCIETE_ ensure the security of Personal Data?

The Company __SOCIETE_ ensures that Users' Personal Data is adequately and appropriately secured and has taken the necessary precautions to preserve the security and confidentiality of the Data and in particular to prevent it from being distorted, damaged or communicated to unauthorised persons.

All human service providers handling Customer data have signed a confidentiality contract with __SOCIETE_, guaranteeing discretion regarding the content exchanged. The company __SOCIETE_ has also taken out CYBER RISKS insurance to cover any possible loss of data and to anticipate future risks (contract AXA n°10282430204).

Concerning transmission security

The Website uses an "https" connection encryption protocol with a 128-bit TLS 1.2 key.

The User must be vigilant with regard to the encryption of the page. They must not provide any personal information if the page does not contain this encryption (symbolised by a padlock in the browser address bar), as this page is not administered by __SOCIETE_.

Use of cookies

In accordance with CNIL deliberation no. 2013-378 of 5 December 2013, the Company __SOCIETE_ informs Users that cookies record certain information that is stored in the memory of their hard disk. This information is used to generate Site audience statistics and to offer services according to the Services they have already selected during their previous visits.

Furthermore, Article 30 of the GDPR states: "Individuals may be associated [...] with online identifiers such as IP addresses and cookies or other identifiers [...]. These identifiers can leave traces which, particularly when combined with unique identifiers and other information received by servers, can be used to create profiles of natural persons and to identify those persons."

In this respect, Users wishing to browse the Site must accept the cookie management policy. An alert message, in the form of a banner, asks each person visiting the Site whether they wish to accept cookies. These cookies do not contain confidential information concerning Users of the Site.

In particular, we use cookies of different types:

  • Necessary cookies: These cookies are necessary for you to use certain important features on our website. These cookies do not collect any personal information.
  • Functionality cookies - these cookies provide functionalities that make using our service more convenient and allow us to offer more personalised features.
  • Analytical cookies: these cookies are used to track the use and performance of our website and services.
  • Advertising cookies: these cookies are used to deliver advertising relevant to you and your interests. They are also used to limit the number of times you see an advertisement. They are generally placed on the website by advertising networks with the permission of the website operator. These cookies remember that you have visited a website and that this information is shared with other organisations such as advertisers.

The User going to the home page or another page of the Site directly from a search engine will be informed of the possibility of opposing these cookies and changing the parameters by clicking on a link present in headband.

To guarantee the free, informed and unequivocal consent of the User visiting the Site, the banner will not disappear until the User has clicked on one of the action buttons on the banner.

Without the prior consent of the User, the deposit and reading of cookies will not be carried out:

  • if any person who visits the Site (on the home page or directly on another page of the Site using a search engine, for example) does not continue browsing: a simple absence of action cannot be considered as an expression of will;
  • or if she clicks on the link in the banner allowing her to refuse the deposit of cookies.

The effects of “private browsing” of your Internet browser

The “Private Browsing” mode offered today by almost all internet browsers allows the user to browse the internet without the history of pages visited or downloads being kept. Concerning Cookies, all those which were recorded during your navigation via “private browsing” will be automatically deleted when you close your browser. “Private browsing” mode therefore does not allow you to refuse or prevent cookies from being stored on your computer during browsing. “Private browsing” mode simply allows you to limit the retention period of collected cookies.

How to delete cookies?

Below, we explain the procedure to follow depending on your browser. For more information, we invite you to consult the conditions for deleting cookies by clicking on the following links:

What are the obligations of Users?

Users acknowledge that the Personal Data disclosed by them on the Site and/or the Application are valid, adequate and up to date. Only Users are responsible for their Personal Data communicated.

Users undertake not to violate the privacy and protection of Personal Data of any Third Party, in particular persons declared on their behalf as part of a process.

What rights do Users whose Personal Data is collected have?

In accordance with the laws and regulations in force concerning the processing of Personal Data, you may :

  • Access all of your Data at any time;
  • Oppose the processing of your Data for legitimate reasons;
  • Rectify, update and delete your Declarative Data, by contacting us via the Contact form of this site, subject to legitimate reasons ;
  • Request portability of your Data;
  • Request deletion of certain Data.

In addition, you have the possibility to communicate to us instructions relating to the conservation, erasure and communication of your Personal Data after your death. These directives, or a sort of “digital will”, can designate a person responsible for their execution; failing this, your heirs will be designated.

In the absence of any instructions, your heirs may contact __SOCIETE_ in order to :

  • to access Data processing allowing “the organization and settlement of the deceased’s estate”;
  • to receive communication of “digital assets” or “data resembling family memories, transferable to heirs” within the meaning of the law;
  • to have your data deleted on the Sites and to oppose the continued processing of your Personal Data.

In any case, you have the possibility to tell us, at any time, that you do not wish, in the event of death, for your Personal Data to be communicated to a third party.

How can I exercise my rights with regard to Personal Data?

In order to exercise your rights with regard to __SOCIETE_, you may send a request to __SOCIETE_ at the following address Contact form or to one of the addresses indicated below. The company __SOCIETE_ reserves the right to request proof of the applicant's identity.

A response is then sent within one week of receipt of the request.

How are Users informed of changes to this Data Protection Policy?

The Company __SOCIETE_ may modify this Data Protection Policy at any time. The Company __SOCIETE_ will inform Users by any means of changes to this. The Company __SOCIETE_ invites Users to regularly read the Data Protection Policy in order to keep themselves fully informed of its provisions.

Each transaction carried out on one of the __SOCIETE_ Internet Sites requires acceptance of this data confidentiality policy.

How to contact __SOCIETE_?

Users may contact the Company __SOCIETE_ for any questions they may have about this Data Protection Policy at the following addresses:

Data Protection Officer (DPO) If you have any questions about the processing of your personal data, your rights or this policy, please do not hesitate to contact our Data Protection Officer (DPO): __NOM_ ([email protected] - __TEL___TEL_)