Personal data

The purpose of this Personal Data Protection Policy is to inform you about the processing of your personal data when you browse the luxuryhotelschool.fr website, published by the company LUXURY HOTELSCHOOL (the ” Site “).

We want you to understand what personal information we collect, how we use it, with whom we share it, how we seek to protect it, how you can access and/or correct it and how you can contact us.

The purpose of this document is also to provide you with all the information required by Article 32 of the French Data Protection Act and Article 13 of Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data GPDR “).

Lastly, we draw your attention to the fact that we may make changes to this document, in particular, to bring it into line with any new regulations or to adapt it to our current practices.

Article 1 – Data controller

The personal data collected on the Site is processed by the company LUXURY HOTELSCHOOL, SARL with capital of 7 ,028,754 euros, whose registered office is located at 76, rue Villeneuve 92110 Clichy.

Article 2 – Personal data that may be collected on the Site

Personal data refers to any information relating to an identified or identifiable natural person (data subject).

LUXURY HOTELSCHOOL  collects and processes the following personal data :

• When browsing our Site: browsing data such as IP address and communication indications that are made available as a result of the use of your computer are collected automatically… This data is only used for purposes relating to the settlement of disputes. In addition, statistical data may be collected during your visit and used (number of pages viewed, number of visits to the site, etc.).
• When registering or requesting information on the site : identification datasuch  as the User’s first name and email address.
• When subscribing to the Newsletter: identification datasuch  as the User’s first name and email address.

The required fields must be completed, otherwise, the LUXURY HOTELSCHOOL cannot process your data.

Article 3 – Purposes of personal data processing and legal bases

Your Data is processed by LUXURY HOTELSCHOOL to enable you to benefit from the services offered by the Site. The data collected, how it is processed and the list of partners are presented in the ” Refine my preferences ” tab.

If you expressly agree, your data may also be used by LUXURY HOTELSCHOOL to :

• Send you newsletters by email
• Send you our offers by email
• Evaluate, understand and report on how you use the service
• Subsequently, send personalised information and/or content in other contexts
• Select and distribute content for you, then evaluate its distribution and effectiveness

The legal basis for such processing is consent. This processing is optional and only applies if you expressly agree to it.

Your data will also be processed by LUXURY HOTELSCHOOL to:

• Respond to your complaints: the legal basis for this processing is legitimate interest 
• Manage requests to exercise individuals’ rights (right of access, rectification, erasure, objection and portability) : the legal basis for this processing is legal obligation
• To justify compliance with our legal and regulatory obligations in the event of a dispute : the legal basis for this processing is legal obligation.

Article 4 – Recipients or categories of recipients of personal data

The recipients of the personal data collected are the members of staff of the marketing and development department of LUXURY HOTELSCHOOL.

LUXURY HOTELSCHOOL may also disclose your Personal Data where such disclosure is necessary to:

• Comply with the law (or a subpoena or court order);
• Comply with legitimate requests from public and government authorities ;
• Prevent a crime or carry out an investigation, for example, in the case of fraud or identity theft ;
• Protect the rights, property or safety of LUXURY HOTELSCHOOL, Users or third parties.

Your personal data may, where applicable, be passed on to subcontracting companies that LUXURY HOTELSCHOOL may call upon for the performance of its services. LUXURY HOTELSCHOOL ensures compliance with data protection requirements for all its subcontracting companies.

Article 5 – Transfer of your data to a country outside the European Union

Data transfer is understood to mean any communication, copy or movement of personal data intended for processing in a third country or any data to which a third party located outside France may have access.

In the event that your data is transferred to our partners located outside the European Union, the data controller guarantees:

• They have obtained all necessary authorisations from the competent authority to carry out the transfer;

• That the transfer is governed by the European Commission’s standard contractual clauses or by internal company rules (Binding Corporate Rules) or ad hoc contractual clauses, which the CNIL has previously recognised as guaranteeing a sufficient level of protection for the privacy and fundamental rights of individuals.

Article 6 – Individual rights

You have the right to access, rectify, delete and transfer your personal data. You may also request that the processing of your personal data be restricted or object to such processing. You have the right to inform LUXURY HOTELSCHOOL of your instructions concerning the fate of your personal data in the event of your death.

Your rights may be exercised by contacting the Data Protection Officer of the LUXURY HOTELSCHOOL, whose contact details are given in this Policy.

We reserve the right to demand payment of “reasonable costs” relating to the administrative costs incurred in providing the information if your request is manifestly unfounded or excessive. We will endeavour to respond to your requests within the time limits required by the GDPR.

To protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access to your personal information or correcting, modifying or deleting your subscriptions. All requests must be accompanied by a copy of your ID.

You may, at any time and free of charge, withdraw your consent to receive newsletters/promotional offers :

• By clicking on the link offering the option to unsubscribe  from the newsletter that appears on every email sent to you 

• By Contacting the LUXURY HOTELSCHOOL at [email protected]

Unsubscribing means that no new emails will be sent.

If your rights are not respected, you can lodge a complaint with the CNIL.

Article 7 – Data security and confidentiality

We implement organisational and technical security measures to guarantee the confidentiality and integrity of your personal data. To this end, administrative, organisational, technical and physical precautions are taken to protect your personal data against loss, theft, misuse, unauthorised access, unauthorised transmission and unauthorised alteration or destruction.

In all cases, the data controller will take security measures appropriate to the nature of the data collected.

The data collected is stored confidentially and protected with a high level of security. The servers on which these data are stored comply with current security standards. They are protected against both digital and physical attacks.

All the pages of the Site on which you are asked to communicate personal data are secure and are in https format.

However, despite our best efforts, we cannot guarantee the infallibility of this protection due to the inevitable risks that may arise when personal data is transmitted.

Article 8 – Retention period for Personal Data

The LUXURY HOTELSCHOOL only retains your personal data for as long as is necessary for the operations for which it was collected and in compliance with the regulations in force.

Generally, your Personal Data is kept for as long as your Personal Account remains active and is then archived to comply with legal obligations or for evidential purposes or is anonymised for research and statistical purposes.

Your Personal Data collected for the purpose of sending you newsletters, offers, or content will be used by the LUXURY HOTELSCHOOL for this purpose until you withdraw your consent and, at the latest, for a period of three years from the date your consent was obtained.

The data enabling the collection of your consent to be traced is kept by the LUXURY HOTELSCHOOL for a period of five years in order to be able, if necessary, to provide proof of your consent.

The data is deleted without delay when the   LUXURY HOTELSCHOOL becomes aware of the person’s death.

Some data may be kept for an additional period to manage complaints and/or disputes, to meet our legal or regulatory obligations or to respond to requests from authorised authorities.

Article 9 – Links to external sites

It is specified that certain links on the Site allow access to external sites (i-frame, banners, etc.) and give you access to third-party services (such as social networks). 

This Policy only concerns information collected on the Site As such, LUXURY HOTELSCHOOL cannot be held responsible for the use of your Data on these other sites.

10.1 Advertising displays :

Certain processing operations used for advertising displays on the Site are carried out in whole or in part by third-party partners (for example, advertising or sponsored links). They are responsible for the technologies used to enable the collection of data (such as identifiers contained in cookies associated with the pages visited), for the purposes of advertising targeting, including on other sites.

On this point, please refer to our Cookie Policy.

10.2 Links to other sites

The Site may also contain links to other sites or services offered by third parties.

10.3 Liability

We have no control over the way in which third-party sites and services process your Personal Data. We do not verify third-party sites and services, and we are not responsible for these third-party sites and services or their privacy protection practices. We invite you to refer to the confidentiality policies or privacy statements of third-party sites or services that you access from our sites or services.

Article 11 – Cookies

We use cookies on our web pages. These are small text files placed on your hard drive by the website visited, enabling it to record and store certain information about your computer and also about you.

They are essential to the operation of the Internet, as they enable two computers to communicate properly. The information recovered is also used to run applications that you use on the website.

For further information, please consult our Cookie Policy.

Cookie policy

This Cookie Policy supplements the LUXURY HOTELSCHOOL Personal Data Protection Policy and is addressed to all persons accessing and browsing this website (hereinafter referred to as ” the Site “) regardless of the type of terminal used (computer, tablet, smartphone, etc.). It explains the use of cookies on the Site, describes the types of cookies used and how to manage and delete them.

By expressly accepting the deposit of cookies via the cookie banner or by personalising your choice using our Cookie Management tool, you consent to all or some of the cookies described below being placed on your terminal.

1. What is a Cookie?

A cookie is a small text file stored in a dedicated space on your terminal’s hard drive when you use your browser to consult an online service. It enables its sender to identify the terminal on which it is stored for the duration of the Cookie’s validity or storage.

When consulting the Site or after opening emails sent by LUXURY HOTELSCHOOL and/or its partners, information relating to your browsing may be recorded in files known as “Cookies” installed on your terminal, subject to the choices you have expressed concerning Cookies and which you may modify at any time.

Cookies enable the site to monitor, store and retrieve information about your browsing habits and to obtain technical information about the navigability of the site. Cookies enable us to provide you with personalised services and to improve the functionality, user-friendliness and accessibility of the web pages concerned.

Cookies issued on the Site or after the opening of emails are used for the purposes described below, during the period of validity of the Cookie concerned, subject to your choices resulting from the parameters of your browser software used during your visit to the Site, which you may modify at any time.

Cookies from partner companies of LUXURY HOTELSCHOOL (third-party cookies) may be placed on your computer.

Only the sender of a Cookie is likely to read or modify the information contained therein. Different types of Cookies are used by LUXURY HOTELSCHOOL and its partners for different purposes.

• Types and purposes of cookies

Depending on their status and purpose, there are different  types of cookies These relate to our Site and/or the emails we send.

• Technical cookies and functionality cookie

These cookies are necessary for the operation of our Site and are essential to enable you to browse and use the functionalities of our Site like access to secure areas. These are mainly session cookies or connection cookies.

The cookies we issue allow us to :

• Store information relating to a form you have filled in on our Site (registration or access to an account) or to services or information you have chosen ;
• Give you access to reserved and personal areas of our Site, such as your account, using identifiers or data that you may have previously entrusted to us ;
• To deploy security measures, in particular when you are asked to reconnect to content or a service after a certain period of time.
• Analytical or audience measurement cookies 

These are mainly cookies relating to visits to the Site, cookies that analyse the origin of the visit, Site performance cookies and statistical or analytical cookies.

These cookies enable us to recognise and count the number of visitors and sources of traffic in order to measure and improve the performance of our Site. They help us to understand why you may be experiencing difficulties or receiving error messages on certain pages, where applicable; to determine which pages are most visited and which are least visited; to analyse visitors’ browsing on the Site; to adapt and improve our Site so that it is more useful and intuitive; and overall, to improve users’ visits.

• Social network sharing cookies

These cookies are required to manage external social networks (e.g. Facebook, Twitter, Pinterest, etc.). Their function is to control the interaction of web users with social widgets within a web page.

Our Site may contain buttons linked to social networks enabling you to share content on the Site or express your opinion (e.g. “like”, “retweet”, etc.). If you are connected to a social network while visiting our Site, your browser establishes a connection between the network and the Site. If you click on a social network button placed on the Site, plug-ins (small software programs) transmit the corresponding information to the social network, which publishes it on your account. If you wish to avoid any connection between a social network and the Site, you must disconnect from the social network before consulting our Site.

These cookies are placed directly by the social networks. The user’s choices concerning the deposit of these cookies must also be made with the social networks. To this end, LUXURY HOTELSCHOOL invites users to directly consult the websites of the social networks and their personal data protection policies.

• Behavioural advertising cookies

These cookies collect information about your browsing habits to identify your specific preferences and tastes. They are used to identify the user’s profile in order to display advertising targeted to your areas of interest in real time, via our email-sending programs and those of our partners, where applicable, and on other sites that you visit and on which our partner has deposited the same cookies. These cookies allow us to personalise advertising content according to your preferences. They may come from our partners or third parties and may be deposited either when browsing the Site or when consulting our emails.

The aim is to present you with the most relevant advertising possible and in keeping with your areas of interest. To this end, cookie technology makes it possible to determine which advertisements to display on a terminal based on recent browsing on one or more websites.

• Partner marketing cookies

Marketing cookies are held by partners and used to provide you with targeted advertising and offers throughout your online experience (web, email, applications, etc.). These cookies may be deposited either when browsing the Site or consulting our emails.

The issue and use of cookies by third parties are subject to the privacy protection policies of these third parties. We inform you of the cookies we are aware of and the means available to you to make choices with regard to cookies.

• Purpose of the cookies used on the Site and how to deactivate them

LUXURY HOTELSCHOOL uses its own cookies, as well as those issued by third parties, for the purpose of continuing and improving the activity of the Site and, where applicable, its email dispatches. Cookies are likely to be deposited when you browse our Site or open emails.

3.1 Purpose of the cookies stored by LUXURY HOTELSCHOOL

• To compile statistics and the volume of visits to and use of the elements making up the Site (sections and content visited, path taken), enabling us to improve the interest and ergonomics of our services,

• To count the number of advertisements or articles we display, to identify these advertisements or articles, the number of times they are displayed, the number of users who clicked on each advertisement or article and, where applicable, the subsequent actions taken by these users on the pages to which these advertisements or articles lead, in order to calculate the sums owed to the players in the advertising distribution chain (advertising agency, advertising network, distribution site/support) and to draw up statistics.

• To adapt the presentation of our Site to the display preferences of your Terminal (operating system used, language, display resolution, etc.) during your visits to our Site, depending on the hardware and the display and/or reading software that your Terminal has.

• To adapt the advertising areas to your terminal’s display preferences (language used, display resolution, operating system used, etc.) when you visit our Site, depending on the hardware and software that your terminal has,

• To store information relating to a form that you have filled in on our Site (registration or access to an account) or to products, services or information that you have chosen,

• To give you access to reserved and personal areas of our Site, such as your account, using identifiers or data that you may have previously entrusted to us,

• To deploy security measures, in particular when you are asked to reconnect to content or a service after a certain period of time.

Third-party applications integrated into our Site

We may include computer applications from third parties on our Site which enable you to share content from our Site with other people or to let these other people know that you have viewed or expressed an opinion about content on our Site. These include “Share” and “Like” buttons from social networks such as “Facebook”, “X – formerly known as Twitter”, “Google plus”, “LinkedIn”, etc.

The social network that provides such an application button is likely to identify you through this button, even if you did not use this button when visiting our Site. This type of application button may allow the social network concerned to track your browsing on our Site simply because your account with the social network concerned was activated on your Terminal (open session) during your browsing on our Site. We have no control over the process used by social networks to collect information relating to your browsing on our Site.

We invite you to consult the privacy protection policies of these social networks to find out how the information that these social networks may collect through these application buttons is used, particularly for advertising purposes. In particular, these protection policies should enable you to exercise your choices with regard to these social networks by configuring your user accounts for each of these networks.

Possible cases of third-party content displayed in our advertising spaces

The advertising content (graphics, animations, videos, etc.) displayed in the advertising areas on our Site may contain Cookies issued by third parties: either the advertiser (the originator of the advertising content in question) or a Company other than the advertiser (communications consultancy agency, audience measurement Company, targeted advertising service provider, etc.) which has associated a Cookie with the advertising content of an advertiser.

Where applicable, the Cookies issued by these third parties may enable them, during the period of validity of the Cookies, to:

• Record the number of times advertising content is displayed via the advertising areas on our Site, and identify the advertisements displayed and the number of users who clicked on each advertisement, enabling them to calculate the sums due as a result and to draw up statistics;

• Gather navigation information relating to terminals consulting our Site;

• To recognise your Terminal during subsequent browsing on any other site on which these Advertisers or these third parties also issue cookies and, where applicable, to adapt these websites or the advertisements they display to the browsing on your Terminal of which they may thus be aware.

• Managing your choices with regard to cookies

You may freely choose at any time to express and modify your wishes with regard to cookies by the means described in this Policy.

The registration of a cookie in a terminal remains subject to the expression of the terminal user’s wishes, which the user may express and modify at any time and free of charge by means of the choices offered to them by their browser software.

If you refuse to accept cookies on your terminal or if you delete the cookies stored on your terminal, you may no longer be able to take advantage of some functions which may nevertheless be necessary for browsing certain sections of our Site. This would be the case if you attempted to access our content or services that require you to be identified. This would also be the case if we and/or our service providers and/or partners were unable to recognise, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet.

Where applicable, we decline all responsibility for the consequences linked to the degraded operation of our services resulting from the impossibility for us to record or consult the cookies necessary for their operation, which you would have refused or deleted. If you choose not to accept cookies on your terminal’s hard drive, the Site may not function optimally on your terminal.

4.1.   Cookie Management solution : ” Privacy “

You can withdraw your consent at any time and put an end to targeting by refusing advertising cookies via the cookie banner, the cookie management tool in your browser or using the advertisement preference managers offered by partners or in the unsubscribe links in emails. 

It is the responsibility of each cookie issuer to respond to your wish to exercise your rights, such as your right to withdraw your consent to the deposit of cookies on your terminal.

If you do not wish LUXURY HOTELSCHOOL or its partners to store all or some of the cookies on your terminal, you can inform us of your choices :

• Either by refusing them in their entirety within the cookie banner,

• Or by configuring them in the cookie management module.

4.2.   Browser settings

To manage cookie activity, block them or delete them, you can manage the settings of the browser you are using to access the Site. Otherwise, browsing the Site implies your acceptance of the use of cookies, as indicated in this Cookie Management Policy. The configuration of each browser is different. By way of example, and without us being able to guarantee their correct operation, you can find the instructions on the following different browsers:

PC browsers :

• Internet Explorer™ 
• Mozilla Firefox™ 
• Google Chrome™ 
• Apple Safari™ 
• Opera™ 
• Others : if you do not use any of the browsers on this list, go directly to your browser’s help menu to find out how to configure it.

Browsers on mobile terminals :

• IOS :  https://support.apple.com/en-gb/HT201265
• Android :  https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en
• Windows Phone : : https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
• Others : if you do not use any of the browsers on this list, go directly to your browser’s help menu to find out how to configure it.

4.3.   Cookie Management Platform ” Your Online Choices “

You can also visit the Youronlinechoices website, set up by digital advertising professionals within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France, to modify the activity of your cookies, block them or delete them. This site offers you a cookie management platform shared by hundreds of professionals, allowing you to accept or reject their cookies in their entirety or on a case-by-case basis. Youronlinechoices can be found at:https://www.youronlinechoices.com/uk/

• Retention period

Cookies deposited on your terminal are kept for a maximum of 13 months from their 1^st deposit on your terminal equipment (following your expression of consent). The information collected via trackers must be kept for a maximum of 25 months. Once their retention period has expired, cookies will be deleted.

• Summary of the content of the agreement concluded between LUXURY HOTELSCHOOL and the issuers of third-party cookies on the Site

A contract for the provision of services has been concluded between LUXURY HOTELSCHOOL and each of its partners relating to the issue of cookies on this Site.

This contract reminds the Parties of the need to comply with the regulations in force relating to cookies and to respect the rights of Internet users (in particular, the right to information and to obtain the free, specific, informed and unambiguous consent of Internet users).

Within this contract, the Parties have taken care to define their respective obligations and responsibilities with regard to the placement of cookies on Internet users’ terminals.

In particular, it was agreed that the Partner, as the issuer of cookies, was obliged :

• To inform LUXURY HOTELSCHOOL about the categories of cookies used by the partner on its site;
• To advise LUXURY HOTELSCHOOL on the actions to be taken to ensure that the rights of individuals are respected with regard to the deposit of cookies deposited by the partner on their terminal ;
• To respond to any requests from Internet users concerning the deposit of cookies issued by the partner.

Finally, it was agreed that LUXURY HOTELSCHOOL, as publisher of the website, was responsible for :

• Informing Internet users about the categories of cookies placed on their terminal when they browse its website ;
• Obtaining their free, specific, informed and unambiguous consent prior to the deposit of cookies on their terminal  (e.g. : via the use of a banner);
• Responding to requests from Internet users wishing to exercise their rights, such as their right to withdraw their consent to the deposit of cookies on their terminal ;
• Ensuring that cookies are deleted once their retention period has expired ;
• Making available to Internet users on the Site the rules relating to cookies deposited on their terminal when they browse the Site.