PRIVACY POLICY

Who are we?

The company TROPICAL HOTEL & BEACH registered in the RCS of Basse-Terre under the number 821 773 553, whose head office is located at Saint-Jean Tropical Hôtel 97133 Saint-Barthélemy, is responsible for processing personal data for the purposes described below.

Data Protection Officer369° Hotels & Maisons has appointed a Data Protection Officer (DPO) who can be contacted:by email at dpo@369degres.compar by post at the following address: 369 - Parc d'activités GAROSUD - 130 rue de la Jasse Maurin - Immeuble le NEOS II - 34070 Montpellier.

This cookie management policy (hereinafter the "Management Policy") is offered by TROPICAL HOTEL & BEACH, a simplified joint stock company with a share capital of €1,000, registered with the Montpellier Trade and Companies Register under number 821 773 553, with the following intra-Community VAT number : FR 36879166395 and whose registered office is located at Ld Saint Jean Tropical Hotel, 97133 Saint Barthelemy France (hereinafter referred to as the "Company").

This Cookie Management Policy informs you of your rights and of the choices you can make regarding the deposit of cookies when using the website https://www.tropical-saintbarth.com (hereinafter the "Site") published by theCompany.

1. Object

In accordance with article 82 of the French Data Protection Act (Loi Informatique et Libertés) of January 6, 1978, as amended, and in application of the provisions of Directive 2002/58/EC of the European Parliament and of the Council of July 12, 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, your consent as a user must be obtained prior to any action aimed at storing information or accessing information stored in your terminal equipment.

Pursuant to the provisions of Articles 4(11) and 7 of the RGPDrelating to the conditions applicable to consent, the CNIL adoptedDeliberation no. 2020-091 of September 17, 2020 adopting guidelines relating to the application of Article 82 of the amended Act of January 6, 1978 to read and write operations in a user's terminal (in particular to "cookies and other trackers"), as well as Deliberation no. 2020-092 of September 17, 2020 adopting a recommendation proposing practical methods of compliance in the event of recourse to "cookies and other tracers", presenting in particular examples and best practices of concrete methods of collecting consent and implementing tracers not subject to consent.

2. What is a cookie?

Cookies are small files containing textual information, generally consisting of letters and numbers. They are deposited on your terminal (computer, tablet, smartphone...) via your browser, by the websites you visit.

This operation enables your devices to be recognized as soon as a connection is established between the Site's server and your browser. The main purpose of a cookie is simply to enable the Site's server to adapt the content of Internet pages to your personal preferences, in order to personalize your visit to the Site.

LeSite may use several types of cookies:

- Session cookies: these are temporary cookies stored in your browser's cookie file until you close it. These cookies are required for certain applications or Site features to function correctly.

- Persistent cookies: the Site may use persistent cookies to improve your experience (e.g. by providing optimized navigation). These cookies remain in the cookie file of your browser for a longer period of time, depending on your browser's configuration choices. Persistent cookies enable information to be transmitted to a web server each time someone visits the Site, and can be used in particular to remember your preferences and choices for a website, or to target advertising. Persistent cookies are also known as tracking cookies.

- Internal cookies: these cookies are installed by the Site at the time of your visit in order to improve your experience.

- Third-party cookies: these cookies are installed by third parties who may be the Company's partners. A third-party cookie is a file embedded in a browser by a site other than the one you are visiting, in order to store information locally and track your visit across several sites. These cookies are not hosted on theSite.

These cookies are classified according to several types: necessary cookies used for technical purposes, audience measurement cookies, advertising cookies, social network sharing cookies, and so on.

3. What are cookies for?

Cookies are used for various purposes:

- Strictly necessary cookies: these are essential to the operation of the site and enable you to access secure areas such as your shopping cart, your personal space, etc.

- Analytical or performance cookies: these cookies enable the Company to understand the use and performance of the Site and to improve its operation, for example by identifying the pages of the Site that are most frequently consulted.

- Functional cookies: these are used to remember the choices you make in order to improve your experience on the Site.

For example, they are used to recognize you when you return to the Site, to keep track of the choices you have made, the items you have put in your shopping cart, etc., and to provide enhanced and personalized information about your preferences and shopping habits.

- Advertising cookies: these cookies collect information about your browsing habits in order to present you with advertising tailored to your interests. These cookies record your visit to the Site, the pages you have visited and the links you have followed, as well as your navigation outside the Site. They are also used to limit the number of times you see the same advertisement and to measure the effectiveness of advertising campaigns.

They are generally placed on the Site by third parties with the Company's permission.

4. What cookies are present on the Site?

The cookies placed on the Site by the Company are the following:

Analytical cookies

• _ga (Persistent cookie - 13 months - Domain: Tropical Hotel & Beach)
  Used to distinguish users and collect analytical data on site usage.
• _ga_id*(Persistent cookie - 13 months - Domain: Tropical Hotel & Beach)
  This cookie is used to maintain session status and track user interactions on the site.
• _gcl_au (Persistent cookie - 3 months - Domain: Tropical Hotel & Beach)
  Used by Google AdSense to measure the effectiveness of advertising campaigns on different websites.
• __hp2_id.* (Persistent cookie - 6 months - Domain: Namastay)
  This cookie is used to track user interactions.
• cee (Persistent cookie - 3 months - Domain: Stape)
  Enables the collection of analytical data on users' interactions with the site.

Advertising cookies

• _fbp (Persistent cookie - 3 months - Domain: Tropical Hotel & Beach)
  Used by Facebook to store and track website visits for targeted advertising purposes.
• test_cookie (Session cookie - end of session - Domain: Google)
  This cookie is used to check whether the browser accepts cookies.

Functional cookies

• axeptio_cookies, axeptio_authorized_vendors, axeptio_all_vendors (Persistent cookies - 1 year - Domain: Axeptio)
  These cookies are used to store the user's consent to the use of cookies on the site, and to list potential service providers.
• __cf_bm (Session cookie - 30 minutes - Domain: Cloudflare)
  Used to identify and mitigate automated traffic to protect the site from malicious bots.

Strictly necessary cookies

• _cfuvid (Session cookie - end of session - Domain: Cloudflare)
  Used to maintain user sessions and manage site security settings.

The Company cannot guarantee that the above list of cookies is exhaustive.

The Company undertakes, insofar as possible, to update it on a regular basis and to alert you in the event of any major change concerning the deposit of cookies on the Site.

5. What personal data is collected by cookies?

The cookies used on the Site collect the following personal data:

- IP address ;

- Web browser ;

- Date and time of visit ;

- Operating system ;

- Internet service provider.

6. How long are the personal data collected by cookies stored?

Personal data collected through cookies on the Site is kept for a maximum of 13 months.

Cookies are kept for a maximum of 13 months.

Your choice of whether or not to accept cookies on the Site will be retained by the Company for a maximum period of 12 months.

7. What are your choices?

7.1 Cookies banner

At your first connection to the Site, a banner will inform you of the use of cookies and invite you to accept or refuse their use.

Acceptance or refusal of the use of cookies has no effect on your navigation on the Site, with the exception of cookies strictly necessary for the operation of the Site or for an online communication service that you have requested.

TheSite uses cookies in order to guarantee access and important functions of the Site (necessary cookies).

These cookies do not require your consent. You are hereby informed that acceptance of these cookies is a necessary condition for access to and use of the Site, and that refusal to accept them may have potentially negative effects (normal browsing of the Site not guaranteed).

The information banner includes :

- the identity of the person in charge of processing ;

- the precise purpose of the cookies used ;

- the possibility of withdrawing your consent at any time.  

In accordance with the deliberation n°2020-092 of September 17, 2020 concerning the adoption of a recommendation proposing practical methods of compliance in the event of recourse to "cookies and other tracers" of the CNIL, you must be able toaccept or refuse the use of cookies with the same degree of simplicity.

To this end, you can click on a button to refuse the deposit of all cookies, which has the same format and is placed at the same level as the button to accept the deposit of all cookies.

You can also choose whether or not to accept (except for necessary cookies) each cookie deposited on your browser.

To ensure that your consent is free, informed and unequivocal, the banner will not disappear until you accept or refuse the cookies.

No unnecessary cookies will be deposited on your browser unless you accept or reject them.

Unless you give your prior consent, cookies will not be deposited or read: 

- if you go to the Site (home page or directly to another page of the Site) and do not continue browsing: a simple absence of action cannot be assimilated to an expression of will on your part;

- or if you click on the link in the banner allowing you to configure cookies and, if so, that you refuse the deposit of cookies. 

You can change your mind at any time by clicking on the information banner on the Site.

7.2. Settings via your web browser

You can accept the use of cookies or choose to deactivate them at any time. This is usually done from your browser.

You can set your browser to notify you when cookies are placed on your terminal and ask you to accept them or not.

Each browser's configuration is different.

It is described in your browser's help menu, which will tell you how to modify your cookie preferences.

7.2.1. Ifyou are using Mozilla's Firefox browser

Cookies - information that websites store on your computer | Firefox Support

- Click on the menu button and select "Options".

- Select the "Privacy" panel .

- Set the "Retention rules" menu to "Use custom settings for history".

- Uncheck the "Accept cookies" box.

- Any changes you've made will be automatically saved.

 7.2.2. If you use Microsoft Internet Explorer

Delete and manage cookies

- Click on the Tools button, then on "Internet Options".

- Click on the "Privacy" tab, then under "Settings", move the cursor up to block all cookies or down to allow all cookies, then clickOK.

7.2.3. Ifyou use Google's Chrome browser

Delete, allow and manage cookies in Chrome- Android - Google Chrome Help

- Select the Chrome menu icon.

- Select "Settings".

- At the bottom of the page, select "Show advanced settings".

- In the "Privacy" section, select "Content settings".

- Select "Prohibit all sites from storing data".

- Select OK.

7.2.4. If you use Apple's Safari browser

Legal - Use of Cookies

- Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data".

Delete history and cookies saved inSafari on your iPhone, iPad or iPod touch and Manage cookies and website data inSafari on Mac

7.2.5. If you use the Opera browser from Opera Software

Opera Web preferences - Opera Help

8. Modification of this Management Policy

This Management Policy is subject to change. The Company therefore advises you to consult this page regularly. In the event of a material change to the Management Policy, the Company will notify you of such changes.

9. More information

For more information on the use of cookies, please consult the CNIL website.

10. Contact us

If you have any questions about this Management Policy or the use of cookies on the Site, you can contact the Company at the following e-mail address: dpo@369degres.comou at the following postal address: Société 369°, Le Néos II, 130 rue de la Jassede Maurin, 34070 - Montpellier.

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Purposes of the processing

Legal basis

Commercial prospecting Our legitimate interest or your consent if required by regulation

Our legitimate interest Management of questions and contact requests

Our legitimate interest Tracking of interests Our legitimate interest or your consent if required by regulation Recruitment The performance of pre-contractual obligations and our legitimate interest

Supplier management

Fulfillment of contractual obligations and our legitimate interest Supplier evaluation Compliance with regulatory obligations (Sapin 2) Litigation management Our legitimate interest and the fulfillment of our contractual relationship

Management of customer reviews and satisfaction surveys

Our legitimate interest Categories of data collected and sources: TROPICAL HOTEL & BEACH processes the following categories of personal data: identification data (surnames, first names, dates of birth, etc.), contact data (email addresses, postal addresses, telephone numbers, etc.), data relating to professional life (company name, position in the company, etc.) as well as data relating to the diplomas and experience of job applicants.

The information collected by TROPICAL HOTEL & BEACH and which is essential to meet the above-mentioned purposes is identified by an asterisk on the collection forms. If you do not fill in these mandatory fields TROPICAL HOTEL & BEACH may not be able to provide the service concerned.

Your data is collected directly by TROPICAL HOTEL & BEACH or may have been transmitted to us by our business partners (in particular, companies in which TROPICAL HOTEL & BEACH directly or indirectly holds a majority stake).

If certain Third Parties are located in countries whose regulations do not necessarily offer the same level of protection as those of the European Union Member States, TROPICAL HOTEL & BEACH will ensure that these transfers are carried out in accordance with the provisions imposed by French regulations (such as the implementation of contractual clauses adopted by the European Commission or adherence to the PRIVACY SHIELD in the USA). You may contact our DPO to obtain further information on these matters and a copy of the relevant documents.

Retention period: The personal data collected are kept by TROPICAL HOTEL & BEACH in accordance with the regulations relating to data protection and according to the legal requirements. For example: data relating to commercial prospecting are kept for three years from the last contact; data relating to the management of contracts are kept for the duration of the contractual relationship increased by the statute of limitations (in general, the statute of limitations is 5 years); data relating to the management of recruitment are kept for 24 months.

Your rights: You have rights in accordance with the applicable regulations: You have the right to request access to and correction of your personal data.

You have the right to request the restriction of the processing of your personal data, (i) if you contest the accuracy of your data during the period of time required for us to verify the accuracy of your data, (ii) if you consider that we are processing your data unlawfully and you demand a restriction of its use rather than its deletion (iii) if we no longer need your data for the above-mentioned purposes but it is still necessary for the establishment, exercise or defence of your legal rights, (iv) if you exercise your right to object to the processing of your data for the duration of the verification of whether our legitimate reasons prevail over yours.

You have the right to request the deletion of your personal data. If you request the deletion of your data, TROPICAL HOTEL & BEACH may nevertheless keep it in an intermediate archive for the time necessary to meet its legal, accounting and tax obligations.

You have the right to ask to exercise your right to object to the processing used for reasons relating to your particular situation.

You also have the right to object to commercial prospecting, without having to provide a reason.

You have the right not to be subject to a decision based exclusively on automated processing and producing legal effects concerning you or significantly affecting you.

You have the right to exercise your right to data portability, which gives you the right to obtain a copy of your data or to transfer it to a third party in a structured and commonly used machine-readable format.

You have the right to withdraw your consent to the processing of your data at any time, where the processing requires your consent.

You also have the right to formulate directives concerning the conservation, deletion and communication of your personal data post-mortem.

These rights can be exercised at any time by email at dpo@369degres.com and by post at the following address: 369 - Parc d'activités GAROSUD - 130 rue de la Jasse Maurin - Immeuble le NEOS II - 34070 Montpellier.

You may also - if you wish - file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL). Further information is available on its website www.cnil.fr.