{"id":718,"date":"2022-07-05T14:50:31","date_gmt":"2022-07-05T12:50:31","guid":{"rendered":"http:\/\/palaisroyalrestaurant.com\/venizia\/?page_id=718"},"modified":"2024-02-27T10:36:49","modified_gmt":"2024-02-27T09:36:49","slug":"charter-of-personal-data","status":"publish","type":"page","link":"https:\/\/palaisroyalrestaurantvenezia.com\/en\/charter-of-personal-data\/","title":{"rendered":"Charter of personal data"},"content":{"rendered":"
I. SCOPE OF APPLICATION AND DEFINITIONS<\/u><\/strong>\u00a0<\/strong><\/p>\n NOLINSKI VENEZIA<\/strong>\u00a0(hereinafter \u201cNolinski\u201d) is a French\u00a0soci\u00e9t\u00e9 par actions simplifi\u00e9e\u00a0<\/em>registered at the Commercial and Companies Registry of Venise under the number 04707740272, whose registered office is located at Calle Larga XXII Marzo-S. Marco 2032 \u2013 30124 Venezia, whose business activity is the operation and management of high-end hotels, spas and restaurants including related events associated with or hosted by these establishments.<\/p>\n Nolinski is a member of the hotel group known as Evok H\u00f4tels Collection (hereinafter the \u201cEvok\u00a0Group\u201d), which is coordinated by the partnership known as Evok H\u00f4tels Collection SNC, located at 17, avenue de l\u2019Op\u00e9ra in the 1st<\/sup>\u00a0arrondissement\u00a0<\/em>of Paris (hereinafter \u201cEvok\u201d)<\/p>\n Nolinski currently conducts its business within the framework of the following establishments (hereinafter the \u201cEstablishments\u201d) and bespoke websites (hereinafter the \u201cWebsites\u201d):<\/p>\n Within the framework of its business activities, Nolinski processes personal data within the meaning of the French Act of 6 January 1978 on computer technology, computer files and civil liberties and of the European Regulation (EU) 2016\/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data which entered into force on 25 May 2018, hereinafter \u201cProcessing\u201d.<\/p>\n <\/p>\n Personal data<\/strong>: personal data is any and all information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or to one or more factors specific to that natural person. To determine whether a person is identifiable, account should be taken of all the means enabling his or her identification which are available or accessible to the controller or to any other person.<\/p>\n Processing<\/strong>: Processing of personal Data means any operation or set of operations performed on such Data, whatever the means used, and in particular the collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as locking, erasure or destruction.<\/p>\n Data Subject<\/strong>: a person concerned by the Processing of personal Data is the person to whom the Data which is the subject of a Processing relates.<\/p>\n The purpose of this Personal Data Processing Charter\u00a0<\/strong>is to set out for the benefit of those persons coming into contact, or wishing to come into contact, in one way or another, with Nolinski, and in particular users of the Websites, the conditions according to which their Personal Data will be subject to Processing, and the rights of the Data Subjects in this regard.<\/p>\n II. DATA PROCESSED<\/u><\/strong><\/p>\n 1\u00b0) Categories of Data :<\/strong><\/p>\n The Data liable to be processed by Nolinski, from whatever source they are collected, are the following:<\/p>\n Nolinski will only process\u00a0specific Data\u00a0<\/em>where such are combined with a request presented by a Data Subject and that the Processing is necessary to the performance of the services thus requested.\u00a0Specific Data\u00a0<\/em>which is revealed incidentally or allegedly by other non specific Data processed by Nolinski shall not be,\u00a0per se<\/em>, subject to Processing.<\/p>\n The Data above marked with an asterisk (*) are indispensable to the conclusion and efficacy of bookings, stays or services ordered, which cannot be validated or provided without disclosing such Data.<\/p>\n The other Data are necessary only to the extent where the Data Subject intends to procure performance of services whose contents or nature are dependent on the relevant\u00a0Data<\/em>; their supply is therefore strictly a matter of appraisal by the Data Subjects.<\/p>\n 2\u00b0) Data Subjects :<\/strong><\/p>\n Data relating to vital statistics\u00a0<\/em>and\u00a0Contact data\u00a0<\/em>processed by Nolinski are collected from all persons coming or wishing to come into contact with Nolinski or with the Establishments: customers, prospective clients, suppliers, trade partners, press, job seekers etc., whether by visiting or browsing the Websites, by sending contact forms, via booking forms, e-mails or other correspondence,\u00a0or verbally by phone or actual physical contact.<\/p>\n Login data<\/em>\u00a0and\u00a0Browsing data\u00a0<\/em>processed by Nolinski are collected from all persons that continue browsing the Websites after having accepted the use of Cookies other than mere functional Cookies (find out more about\u00a0Cookies<\/u>)\u00a0;<\/p>\n Personal-related data, Professional-related data, Specific data, Location data\u00a0<\/em>and\u00a0Payment data\u00a0<\/em>are collected, as appropriate, according to what is stated in 2\u00b0), from all persons making a booking or a stay or other experience (meals, receptions, events, beauty care or use of the spa) within one of the Establishments, or more generally receiving a service or goods from one of the Establishments.<\/p>\n Minors.<\/em>\u00a0The Websites are designed for majors. Legal guardians of minors must take responsibility to monitor and supervise their use of communication tools, and in particular their web browsing behaviour.\u00a0<\/strong><\/p>\n 3\u00b0) Data collected directly by Nolinski\u00a0:<\/strong><\/p>\n 4\u00b0) Data collected by Nolinski\u2019s trade partners\u00a0:<\/strong><\/p>\n Nolinski processes\u00a0Data relating to vital statistics<\/em>,\u00a0Contact data, Personal-related data, Professional-related data, Specific data, Location data, Payment data<\/em>\u00a0collected by the following persons which are Nolinski partners:<\/p>\n Nolinski also processes the same categories of\u00a0Data\u00a0<\/em>that are disclosed to it by booking operators, in particular on-line booking operators, which people use and supply Data to for the purpose of making a booking in an Establishment. Data subjects are required to check on the websites of these operators, or by any other means available, their policies or terms applicable to personal data processing (such as, for instance, but not limited to: Bookatable Limited, website publisher for restaurant.michelin.fr including a booking module, see\u00a0Privacy Policy of Bookatable Limited<\/u>\u00a0; Booking.com BV; see\u00a0Privacy Statement of Booking.com).<\/u><\/p>\n 5\u00b0) Data collected via third-party Cookies enabled on the Websites<\/strong><\/p>\n Nolinski processes\u00a0Login data<\/em>\u00a0and\u00a0Browsing data<\/em>\u00a0collected by the Cookies enabled by Nolinski Venezia and implemented on the Websites by Google, via Google Analytics and Adwords which are used by Nolinski Venezia.<\/p>\n Find out more about\u00a0Cookies<\/a>.<\/u><\/p>\n 6\u00b0) Publicly accessible Data :<\/strong><\/p>\n Nolinski also processes publicly accessible\u00a0Data relating to vital statistics\u00a0<\/em>and\u00a0Contact data<\/em>, such as for instance, data supplied on a website, a telephone messaging service, the masthead in print publications, publicly available professional registers etc.\u00a0\u00a0<\/strong><\/p>\n III.\u00a0CHARACTERISTICS OF PROCESSING<\/u><\/strong><\/p>\n 1\u00b0) Activities giving rise to Processing :<\/strong><\/p>\n The personal Data described in II 1\u00b0 are processed by Nolinski within the framework of the following activities:<\/p>\n Activities(i)\u00a0<\/u>:<\/p>\n \u2013 Hotel, bar and restaurant services delivered by the Establishments, spa, beauty care and wellness services associated with the Establishments;<\/p>\n \u2013 Establishment Venues: organisation of cultural, artistic and entertainment or public relations venues;<\/p>\n \u2013 Sale of furniture and decorative items on display in the Establishments;<\/p>\n \u2013 Correspondences with people coming into contact with Nolinski (enquiries, candidacies, offers for goods or services etc.)<\/p>\n All categories of Data\u00a0<\/em>according to what is necessary to perform the service or to process the request and what is disclosed by the Data Subject.<\/p>\n Activity (ii)\u00a0<\/u>: Involvement of Nolinski and of the afore mentioned activities, in the business activity of the Evok\u00a0Group (comprising: development of hotel establishments, restaurants, and wellness centres, conception of promotional strategies and tools, diffusion and communication of the Group, development of commercial packages, creation of events) in its development, in its communications, media exposure and commercial attraction strategy:\u00a0Data relating to vital statistics, Contact data, Login data\u00a0<\/em>and\u00a0Browsing data<\/em>.<\/p>\n 2\u00b0) Processing purposes\u00a0:<\/strong>:<\/p>\n Activities (i)<\/u>: the purposes of the Processing are:<\/p>\n \u2013 As a general rule: to satisfy, handle, process requests or offers of any kind addressed to Nolinski; to perform, improve, diversify and anticipate services requested by Nolinski\u2019s clients in relation to their stay or experience at the Establishments:<\/p>\n \u2013 As concerns the hotel, bar and restaurant services and the spa, beauty care and wellness services associated with the Establishments, and as concerns Establishment Venues: to manage the capacity, organisation, reception desk and customer access services at the accommodation or at the Establishment; to satisfy specific customer requests during their stay or experience at an Establishment (meals, receptions, beauty care, use of the spa, valet parking, supply of smartphones, pet hospitality, babysitting etc.), to personalise or provide customer courtesy or loyalty services, to plan Nolinski\u2019s resources and supplies, to pay for services;<\/p>\n -As concerns the Sale of furniture and decorative items on display in the Establishments: to ensure payment, supply, follow-up, deliver orders and to manage after sales services,<\/p>\n \u2013 As concerns other solicitations received by Nolinski: to respond to the contact, to possibly satisfy their request or accept their offer, even at a later date.<\/p>\n Activities\u00a0(ii)<\/em>:\u00a0<\/u>The purpose of the Processing by Nolinski is the transmission of Data to the partnership known as Evok H\u00f4tels Collection SNC, with the following purposes:<\/p>\n Data relating to vital statistics\u00a0<\/em>and\u00a0Contact data<\/em>: to provide trade communications, promotional and prospecting services relating to the development of the activities of the Evok Group, to implement loyalty programs (to provide a news feed relating to the Evok Group, in particular via the newsletter, invitations to public relations events and communications relating to commercial packages) by means of e-mailing and text messaging campaigns.<\/p>\n Login data\u00a0<\/em>and\u00a0Browsing data<\/em>: See the\u00a0Cookies<\/u><\/em><\/a>\u00a0section.<\/em><\/p>\n For further details: see\u00a0Evok\u2019s Personal Data Processing Charter<\/u><\/a>.<\/p>\n 3\u00b0) Controller:<\/strong><\/p>\n Activities\u00a0<\/u>(i)\u00a0: Nolinski is the Controller.<\/p>\n Activities\u00a0<\/u>(ii)\u00a0: Evok is the Controller.<\/p>\n SeeEvok\u2019s Personal Data Processing Charter<\/u>.<\/a><\/p>\n 4\u00b0) Basis for Processing:<\/strong><\/p>\n Activities\u00a0<\/u>(i)\u00a0<\/em>: The Processing is based:<\/p>\n For the hotel and restaurant services delivered by the Establishments; the spa, beauty care and wellness services associated with the Establishments; Establishment Venues, comprising the organisation of cultural, artistic and entertainment or public relations venues; the Sale of furniture and decorative items on display in the Establishments: on performance of the contractual or pre-contractual service requested by the Data Subject\u00a0; on the implementation of the legal requirements of the Controller in particular as concerns account keeping and the archiving of business records and invoices; in addition, on the achievement of the legitimate interests pursued by Nolinski * in any case.<\/p>\n For all other solicitations received by Nolinski: on the achievement of the legitimate interests pursued by Nolinski or on the processing of the solicitation.<\/p>\n *The legitimate interests of Nolinski are in particular to successfully develop, maintain and constantly improve customer relations, to achieve their satisfaction, as well as to diversify and give incentive to its customer base, to maintain the quality of and renew its offering, to maintain an image and brand of luxury hotels, restaurants and venues which are viewed both as high-end, cultural, refined and diverse;<\/p>\n Activities<\/u>\u00a0(ii):<\/p>\n Data relating to vital statistics\u00a0<\/em>and\u00a0Contact data.<\/em>\u00a0The Processing is based on the consent of the Data Subject and, for communication requirements directed at Nolinski\u2019s customers and professionals affiliated with or interested in the business sector of Nolinski and Evok, on the achievement of the legitimate interests pursued by Nolinski and Evok*.<\/p>\n Login data\u00a0<\/em>and\u00a0Browsing data.\u00a0<\/em>The Processing is based on the consent of the Data Subject, which is solicited from the very first visit to the Websites from which the Data are collected.<\/p>\n *The legitimate interests of Nolinski and Evok are in particular to develop the Evok Group and its establishments, to promote media exposure, commercial attraction, the quality and diversification of its offering and of its key achievements, to maintain and develop an image, a brand and a label of luxury or very high-end amenities.<\/p>\n It is recalled that the Controller in charge of the Processing carried out within the framework of the Activities (ii) is Evok. See\u00a0Evok\u2019s Personal Data Processing Charter<\/u>.<\/a><\/p>\n 5\u00b0) Contractual requirement of Data:<\/strong><\/p>\n Only\u00a0Data relating to vital statistics<\/em>, certain\u00a0Contact data<\/em>\u00a0(e-mail address and mobile phone number, postal address as appropriate),<\/em>\u00a0certain\u00a0Personal-related data,\u00a0<\/em>certain\u00a0Location data<\/em>\u00a0and the\u00a0Payment data<\/em>\u00a0are necessarily required to conclude a booking and to perform a service; they are marked with an asterisk above and are specified to the Data Subject prior to each booking or purchase.<\/p>\n Other Data may be freely and voluntarily disclosed by Data Subjects within the framework of their specific requests.<\/p>\n 6\u00b0) Recipients of the Data:<\/strong><\/p>\n Data relating to vital statistics<\/em>,\u00a0Contact data<\/em>,\u00a0Login data<\/em>\u00a0and\u00a0Browsing data<\/em>\u00a0collected or received by Nolinski are transmitted to Evok within the framework of the aforementioned Processing for which Evok is the Controller. See\u00a0Evok\u2019s Personal Data Processing Charter.<\/u><\/p>\n For Processing operations whose purpose is the management and performance of hotel services, Nolinski uses a platform provided by the German company known as protel hotelsoftware GmbH, which also ensures the storage of the\u00a0Data\u00a0<\/em>collected within the framework of this activity, acting as a processor.\u00a0See protel\u2019s Privacy Policy.<\/u><\/p>\n The performance of certain operations necessary to the Processing implemented within the framework of the Activities (ii) (database formatting and maintenance, storage of\u00a0Personal data\u00a0<\/em>and\u00a0Contact data<\/em>) are carried out on behalf of Evok by the company known as Sarbacane Software SAS, registered at the Commercial and Companies Registry of Lille no. 509 569 598, whose registered office is located at 3 avenue Antoine Pinay \u2013 Industrial Estate (ZA) \u201cdes Quatre Vents\u201d \u2013 59510 HEM, and Experience Hotel Software SAS, RCS Paris B 798 181 699 whose registered office is located at 128 avenue La Bo\u00e9tie 75008 Paris,\u00a0acting in a processor capacity. The Data collected or received by Nolinski are not transmitted by Nolinski, or by Evok, to any other recipient apart from, as applicable, the legally empowered authorities, within the framework of a specific assignment or of the exercise of a right of communication.<\/p>\n 7\u00b0) Data retention period:<\/strong><\/p>\n The Data will be kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which they are processed.<\/p>\n Where Processing is based on the Data Subject\u2019s consent, the Data processed will only be kept by Nolinski for as long as the consent prevails.<\/p>\n Any new disclosure of Data, even where such have already been disclosed beforehand by the Data Subject, according to one or the other of the means of collection mentioned under section II \u201cData processed\u201d will trigger a new retention period, irrespectively of the previous retention periods.<\/p>\n Personal-related data, Professional-related data<\/em>,\u00a0Specific data, Location data\u00a0<\/em>and\u00a0Payment data<\/em>\u00a0are kept for the period necessary to the performance of the contractual and pre-contractual services requested by Data Subjects and for which such Data are disclosed.<\/p>\n Personal-related data<\/em>\u00a0and\u00a0Professional-related data<\/em>, can be kept for an additional period of one year from the end of the Data Subject\u2019s stay or experience within the Establishment.<\/p>\n Specific data<\/em>\u00a0are only kept for the period strictly necessary to the performance of the contractual or pre-contractual services requested by Data Subjects and for which such Data are disclosed, or to Nolinski\u2019s adherence to legal requirements (in particular storage and archiving of nominal invoices, book keeping and other accounting or tax requirements).<\/p>\n Payment data<\/em>\u00a0are kept for the period strictly necessary to each payment in view of which they are disclosed and to Nolinski\u2019s adherence to legal requirements (in particular storage and archiving of invoices, book keeping and other accounting or tax requirements).<\/p>\n IV. COOKIES<\/u><\/strong><\/p>\n 1\u00b0) Definition\u00a0:<\/strong><\/p>\n A Cookie is a tracking tool which consists of a small computer file or a short alphanumeric combination, which is automatically installed or read by a network provider or a website on the terminal device (computer, mobile phone, tablet, video games console) of the Data Subject, that can access the data already stored in said terminal, or write or store information on that device.<\/p>\n 2\u00b0) Purposes to the use or enabling of Cookies and information transmitted by Cookies:<\/strong><\/p>\n The operation of the Websites requires the implementation of the following Cookies, which are presented according to the functionalities provided by each type of Cookie\u00a0:<\/p>\n \u2013 Implementation and facilitation of electronic communication and supply of online communication services, exclusively:\u00a0Functional cookies<\/em>;<\/p>\n \u2013 Improvement of Website browsing experience; organisation of visualized content (including Google Maps interactive maps and YouTube videos), saving of personal data already entered by the Data Subject, tracking of user preferences and options, for instance for the efficiency of a booking, saving services already requested:\u00a0Efficiency cookies<\/em>;<\/p>\n \u2013 Measuring web traffic: Web traffic cookies;<\/em><\/p>\n \u2013 Monitoring browsing habits (Websites and pages visited, search history and search terms used) and preferences of Data Subjects in view of customized ads:\u00a0Advertising cookies;\u00a0Advertising cookies\u00a0<\/em>are also installed by Google via YouTube videos and Google Maps interactive maps accessible on the Websites: the data collected (login, location and browsing data) are not processed by Nolinski but by Google\u00a0;<\/p>\n \u2013\u00a0<\/em>Promotion of the websites and improvement of their user-friendliness, via social media sharing functionalities (Facebook, Twitter, Instagram, Google+, Pinterest, Linkedin), by means of the share button enabling web browsing to be tracked by the websites of these social media, whether or not these buttons or links are hit by the Website user:\u00a0Social media cookies.\u00a0<\/em>The Data collected by these Cookies are not processed by Nolinski, but by the aforementioned social media operators.<\/p>\n 3\u00b0) Consent of Data Subjects:<\/strong><\/p>\n The use of\u00a0Efficiency cookies,<\/em>\u00a0Advertising cookies<\/em>,\u00a0Web traffic cookies\u00a0<\/em>and\u00a0Social media cookies,\u00a0<\/em>that is to say all Cookies apart from\u00a0functional Cookies,<\/em>\u00a0implies the consent of the Data Subject.<\/p>\n In accordance with article 32 II of the act of 6 January 1978, the consent of the Data Subject can result from his or her connection settings. Website users are prompted to check or alter their settings before pursuing their browsing experience on the Website. By continuing to browse the Website, that is to say by visiting another page of the Website from the Website or by clicking on any item of the Website (image, link, thumbnail etc.), the Data Subject expresses his or her consent to the use of the above mentioned Cookies.<\/p>\n The user can object to the use of Cookies or withdraw at any moment his or her consent: see Blocking or Managing\u00a0Cookies<\/u>.<\/p>\n 4\u00b0) Cookies\u2019 validity period:<\/strong><\/p>\n Save exercise by the Data Subject of his or her right of objection or of withdrawal of consent, the consent to the installation of the Cookies is granted for a period of thirteen (13)\u00a0months. On the expiry of this period, the Data Subject\u2019s consent will have to be re-obtained to enable the use of Cookies.\u00a0As a consequence, Cookies are only active for thirteen months after their initial installation on the terminal device of the user having consented to such. The validity period of Cookies is not extended by new visits to the sebsites.<\/p>\n 5\u00b0) Blocking or Managing Cookies:<\/strong><\/p>\n The user of the Websites can object to the use of Cookies or of certain Cookies on his or her terminal and in particular benefits from the following means to this effect.<\/p>\n Browser settings:<\/em><\/strong><\/p>\n Click on the browser menu (Safari, Mozilla etc.), then choose\u00a0\u201cPreferences<\/em>\u201d\u00a0or\u00a0\u201cSettings<\/em>\u201d or \u201cTools\u201d<\/em>; then proceed as follows depending on your web browser:<\/p>\n Safari<\/u>:\u00a0\u201cPrivacy\u201d<\/em>\u00a0>\u00a0\u201cCookies and website data\u201d<\/em>: choose the desired options; to block cookies entirely, select:\u00a0\u201cAlways block\u201d\u00a0<\/em>and check the box \u201cWebsite tracking: Ask websites not to track me\u201d<\/em>\u00a0if not already checked;<\/p>\n > also, to manage Data and Cookies already stored on the terminal:\u00a0\u201cManage website data\u201d<\/em>: make the desired data deletions by selecting the Data and Cookies sources and categories in the panel then by clicking the \u201cdelete<\/em>\u201d button;<\/p>\n Mozilla Firefox<\/u>: \u201cPrivacy and Security\u201d<\/em>\u00a0>\u00a0\u201cCookies and site data\u201d<\/em>: make the desired settings, after consulting the\u00a0\u201cLearn more\u201d\u00a0<\/em>section;<\/p>\n \u2013 to block all Cookies\u00a0: click the button \u201cBlock Cookies and site data (may cause websites to break)\u201d\u00a0<\/em>;<\/p>\n \u2013 to manage Cookies: click on the button \u201c\n
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\nSee Sarbacane\u2019s Personal Data Processing Charter.\u00a0<\/a>
\n<\/u>See Experience Hotel\u2019s Personal Data Processing Charter<\/a><\/p>\n