This post is also available in: FR
ARTICLE 1: PREAMBLE
- The way in which their personal data are collected and processed. All data that can identify a user should be considered as personal data. These include the first and last name, age, postal address, email address, location of the user or its IP address;
- What are the rights of users regarding these data;
- Who is responsible for the processing of personal data collected and processed;
- To whom this data is transmitted;
- Possibly, the site’s policy regarding “cookies” files.
ARTICLE 2: GENERAL PRINCIPLES FOR DATA COLLECTION AND PROCESSING
In accordance with the provisions of Article 5 of the European Regulation 2016/679, the collection and processing of site users’ data complies with the following principles:
- Lawfulness, loyalty and transparency: data can only be collected and processed with the consent of the user who owns the data. Whenever personal data are collected, the user will be informed that his / her data is being collected, and for what reasons his / her data is collected;
- Minimizing the collection and processing of data: only the data necessary for the proper execution of the objectives pursued by the site are collected;
- Conservation of data reduced in time: the data are kept for a limited time, of which the user is informed. If the shelf life can not be communicated to the user;
- Integrity and confidentiality of the data collected and processed: the data controller is committed to ensuring the integrity and confidentiality of the data collected.
In order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data may only take place if they comply with at least one of the conditions set out above. after listed:
- The user has expressly consented to the treatment;
- Processing is necessary for the proper performance of a contract;
- Treatment meets a legal obligation;
- Treatment is due to a need to safeguard the vital interests of the data subject or other natural person;
- The treatment can be explained by a necessity related to the performance of a mission of public interest or that comes under the exercise of the public authority;
- The processing and collection of personal data is necessary for the legitimate and private interests pursued by the controller or a third party.
ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN THE CONTEXT OF NAVIGATION ON THE SITE
A. DATA COLLECTED AND PROCESSED AND METHOD OF COLLECTION
The personal data collected on the Triptyque Travel website are as follows:
and via the online store:
- First and last name
- phone number
This data is collected when the user performs one of the following operations on the site:
- When the visitor subscribes to our newsletters
- When the visitor buys products or services online
Moreover, during a payment on the site, it will be kept in the computer systems of the publisher of the site a proof of the transaction including the purchase order and the invoice.
The data controller will keep all data collected for a period of: 3 years in his computer systems and under reasonable security conditions.
The collection and processing of data serves the following purposes:
The location and IP address data are saved to improve the quality of our services but also to improve the security of our website
B. TRANSMITTING DATA TO THIRD PARTIES
The data may be transmitted to the following third party (s) listed:
Some collected data may be transferred to our host to optimize our services.
C. ACCOMMODATION OF DATA
The website of the Triptyque Travel is hosted by: Netsive – marketing & communication agency Luxembourg – France – Belgium, whose head office is located at the address below:
N ° 8 Z.I Am Bruch, L-3327 Crauthem – Luxembourg
The host can be contacted at the following number: 00352 27 12 61 74
The data collected and processed by the site are transferred to the following country (ies): Luxembourg.
ARTICLE 4: RESPONSIBLE FOR DATA PROCESSING AND DELEGATE FOR DATA PROTECTION
A. THE PERSON RESPONSIBLE FOR DATA PROCESSING
The person responsible for the processing of personal data is: Netsive Sarl. He can be contacted as follows:
The person in charge of data processing can be contacted by email at the following address: email@example.com
The person responsible for data processing is responsible for determining the purposes and means used for the processing of personal data.
B. OBLIGATIONS OF DATA PROCESSING MANAGER
The data controller undertakes to protect the collected personal data, not to transmit it to third parties without the user having been informed and to respect the purposes for which the data was collected.
The site has an SSL certificate to ensure that information and data transfer through the site is secure.
An SSL certificate (“Secure Socket Layer” Certificate) aims to secure the data exchanged between the user and the site.
In addition, the Data Controller agrees to notify the user in case of rectification or deletion of the data, unless this entails for it disproportionate formalities, costs and procedures.
In the event that the integrity, confidentiality or security of the user’s personal data is compromised, the controller commits to inform the user by any means.
C. THE DELEGATE OF DATA PROTECTION
In addition, the user is informed that the following person has been appointed Data Protection Officer: Netsive Sarl.
The role of the Data Protection Officer and ensure the proper implementation of national and supranational provisions relating to the collection and processing of personal data. It can also be named DPO (for Data Protection Officer).
The data protection officer can be reached as follows:
by phone on: 00352 27 12 61 74
by email on: firstname.lastname@example.org
ARTICLE 5: RIGHTS OF THE USER
In accordance with the regulations on the processing of personal data, the user has the rights listed below.
In order for the Data Controller to comply with the request, the user is required to provide him / her with: first name, last name, e-mail address and, if applicable, his account number or personal space number or subscriber.
The data controller is responsible for responding to the user within a maximum of 30 (thirty) days.
A. PRESENTATION OF THE USER’S RIGHTS IN DATA COLLECTION AND PROCESSING
a. Right of access, rectification and right to erasure
The user can take knowledge, update, modify or request the deletion of the data concerning him, by respecting the following procedure stated:
The user must send an e-mail to the controller of personal data, specifying the subject of his request and using the contact e-mail address that is provided above.
If he has one, the user has the right to request the removal of his personal space by following the following procedure:
The visitor / user must send an e-mail to the person in charge of data processing, specifying his name and surname. The request to delete the data will be processed within 10 working days.
b. Right to data portability
The user has the right to request the portability of his personal data, held by the site, to another site, by following the procedure below:
The user must make a request for portability of his personal data to the person responsible for data processing, by sending an e-mail to the address provided above.
c. Right to limitation and opposition of data processing
The user has the right to request the limitation or to oppose the treatment of his data by the site, without the site can refuse, except to demonstrate the existence of legitimate and compelling reasons that may prevail over the interests and the rights and freedoms of the user.
In order to request the limitation of the processing of his data or to oppose the processing of his data, the user must follow the following procedure:
The user must make a request for limitation to the processing of his personal data with the data controller, by sending an e-mail to the address provided above.
d. Right not to be the subject of a decision based exclusively on an automated process
In accordance with the provisions of Regulation 2016/679, the user has the right not to be the subject of a decision based exclusively on an automated process if the decision has legal effects concerning him or affects him significantly from similar way.
e. Right to determine the fate of data after death
The user is reminded that he can organize what should be the future of his data collected and processed if he dies, in accordance with the law n ° 2016-1321 of October 7th, 2016.
f. Right to seize the competent supervisory authority
If the data controller decides not to respond to the request of the user, and the user wishes to contest the decision, or if he thinks that one of the rights listed above, it is entitled to refer to the CNIL (National Commission for Computing and Freedoms, https://www.cnil.fr) or any competent judge.
B. PERSONAL DATA OF MINOR PERSONS
In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over can consent to the processing of their personal data.
If the user is a minor under the age of 15, the consent of a legal representative will be required so that personal data can be collected and processed.
The publisher of the site reserves the right to verify by any means that the user is older than 15 years, or that he has obtained the consent of a legal representative before browsing the site.
ARTICLE 6: USE OF “COOKIES” FILES
The site may use “cookies” techniques.
A “cookie” is a small file (less than 4 KB), stored by the site on the user’s hard disk, containing information about the user’s browsing habits.
These files allow it to process statistics and traffic information, facilitate navigation and improve service for the convenience of the user.
For the use of “cookie” files involving the backup and analysis of personal data, the consent of the user is necessarily requested.
This consent of the user is considered valid for a duration of 13 (thirteen) months maximum. At the end of this period, the site will request again the user’s permission to save “cookies” files on his hard drive.
a. Opposition of the user to the use of “cookies” files by the site
It is brought to the attention of the user that he can oppose the registration of these files “cookies” by configuring his browser software.
For information, the user can find at the following addresses the steps to follow in order to configure his browser to oppose the registration of “cookies” files:
- Chrome : https://support.google.com/accounts/answer/61416?hl=en
- Firefox : https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferences
- Safari : http://www.apple.com/legal/privacy/en-ww
- Internet Explorer : https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Opera : http://www.opera.com/help/tutorials/security/cookies/
Dans le cas où l’utilisateur décide de désactiver les fichiers “cookies”, il pourra poursuivre sa navigation sur le site. Toutefois, tout dysfonctionnement du site provoqué par cette manipulation ne pourrait être considéré comme étant du fait de l’éditeur du site.
b. Description des fichiers “cookies” utilisés par le site
By browsing the site, it is made known to the user that third-party cookies can be saved.
These are particularly the following third parties:
In the case where the user decides to disable the “cookies” files, he can continue his navigation on the site. However, any dysfunction of the site caused by this manipulation could not be considered as being due to the editor of the site.
In addition, the site includes social networking buttons, allowing the user to share his activity on the site. Cookie files of these social networks are therefore likely to be stored on the user’s computer when using these features.
The user’s attention is drawn to the fact that these sites have their own privacy policies and general conditions of use that may differ from the site. The publisher of the site invites users to consult the privacy policies and general conditions of use of these sites.
The publisher of the site reserves the right to modify it to guarantee its conformity with the law in force.
However, in case of substantial modification of this policy, the user will be informed as follows:
Or by “push” notification when the user visits the site again;
E-mail to the address provided by the user;
Or by SMS if it has been requested by the visitor / user or customer.