Privacy Policy

Privacy Policy

Posted on 05/05/2021

Your personal privacy is of crucial importance to us. Your trust in us is our top priority and that is why we apply this Privacy Policy to our website
(hereinafter the “Website”) and to all relationships existing or not between Les Clés Secrètes and its customers as well as its partners.
We take the protection and the privacy of the users of our website seriously and take the necessary steps to ensure they benefit from such protection.
Les Clés Secrètes protects users’ personal data in accordance with the provisions of the
General Data Protection Regulation (GDPR: 2016/679).

What is a Privacy Policy? This document informs users of our Website about their personal data we collect when they visit our Website. We, therefore, undertake to comply with the confidential
nature of the personal data we collect as described below. This Privacy Policy sets out the personal data we collect about users, the reason why we collect such data,
the means used to collect the data, the recourse available to users to prevent the collection and the security measures taken to protect users’
personal data. Personal Data refers to any information that identifies a user, such as last names, first names, postal and email addresses, telephone numbers, etc.

Les Clés Secrètes may collect the personal data of any person visiting the Website who submits a question to Les Clés Secrètes via the Contact section of the Website
or who makes a booking online or who signs up to the Website newsletter. The collection and processing of personal data submitted by users to Les Clés Secrètes
are subject to the provisions of the General Data Protection Regulation (GDPR: 2016/679).

The Website makes a form available to users enabling them to exercise their rights to privacy protection. Click on the following link to access this form:

Please read this « Privacy Policy » in conjunction with the « Cookie Policy » of Les Clés Secrètes.

1 – Collection of personal data

Les Clés Secrètes can collect and process personal data (see personal data types below), when filling out a contact form,
or other forms, on our Website.

  • Last name
  • First name
  • Civility
  • Professional category
  • Company name
  • Job position
  • Address
  • E-mail address
  • Landline/mobile number
  • Information about your use of the Website such as the browser type, software, hardware, location data and the web page you visited when you access the website.

In addition, Les Clés Secrètes automatically collects anonymous information about the use you make of our Site and its services.
For example, Les Clés Secrètes will automatically record which parts of the Website you visit, which web browser you are using and which website you visited
when you received access to the website. We cannot identify you based on these data, but they allow Les Clés Secrètes to compile statistics about the use of the website,
website traffic and enables more targeted communication with users. The personal data we collect is gathered using the means described below in section « 2 – How we collect your personal data ».

2 – How we collect your personal data

Your personal data is collected by the following means:

  • A collaboration with Les Clés Secrètes
  • Website visit to
  • When a user creates a customer account
  • The contact form(s)
  • The request forms
  • The use you make of Les Clés Secrètes
  • Identity checks
  • Registration for communications and newsletter (on the Website)
  • Correspondence exchanged with and from Les Clés Secrètes
  • The exchange of business cards
  • Reception and exchanges with the staff of the establishment
  • Opinion polls
  • Cookies (for more information: « Cookie Policy »)
  • Contests

The personal data collected by Les Clés Secrètes are therefore specifically and voluntarily provided by you.

3 – Use of personal data may process all or part of the data collected in order to:

  • Allow Website navigation, management and traceability of services and services ordered by users.
  • Optimize the user experience, quality, management, navigation and content of the Les Clés Secrètes Website.
  • Set up a customer account and confirm this.
  • Track customer/prospect relationships when booking.
  • Provide Les Clés Secrètes goods and services.
  • Improve customer service and your support needs.
  • Contact you by email and/or by telephone.
  • Conduct satisfaction surveys, studies, and optional surveys on the Website.
  • Send targeted marketing campaigns and advertisements from Les Clés Secrètes, updates and promotional offers based on your preferences and your communication consent.
  • Provide personalised ad content.
  • Send you quotes, receipts and invoices.
  • Collect statistical elements.
  • Develop an offer.
  • Administer a contest.
  • Perform a contract entered into with Les Clés Secrètes.
  • Prevent and fight against computer fraud (spamming, hacking,…).

4 – Confidentiality of personal data

Les Clés Secrètes is the only owner of the information collected on the Website. Your personal data will not be sold, exchanged, transferred, or given to third parties
for any reason, without your consent, apart from that required to respond to a request and / or transaction in the framework of our customer relationship management,
the provisions of Les Clés Secrètes services and the optimisation of such services.

5 – The data protection officer

The data protection officer in charge of collecting and processing users personal data upon setting up their account and when they browse on the Website is Laura Giralt.

As a data controller responsible for the processing of the personal data it collects, undertakes to respect the framework of the current legal
requirements. It is incumbent on it to establish the purposes of the data processing, to provide prospects and customers, from the time they provide their consent,
with full information on the processing of their personal data and to maintain a record of processing that is consistent with the reality.

Whenever the Website processes personal data, Les Clés Secrètes takes all reasonable measures to ensure the personal data is accurate and relevant with
regard to the purposes for which the Site processes such data.

6 – Disclosure of personal data to third parties shall refrain from processing, hosting or transferring the data collected about its
customers to a country located outside the European Union or recognised as unsuitable by the European Commission without first informing the customer.
However, the Site remains free to choose its technical and commercial data processors on condition it presents sufficient guarantees with regard to
the requirements of the General Data Protection Regulation (GDPR: 2016/679).

The Website doesn’t sell your personal data which are therefore only used when required or for statistical purposes and analyses. We will not sell, trade,
or transfer your personally identifiable information to third parties. If it is necessary for Les Clés Secrètes to disclose your personal data to third parties,
the third party concerned will be required to use your personal data in accordance with the provisions of this « Privacy Policy ».
We believe that it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, alleged fraud,
situations involving potential threats to the physical security of any person, violations of our Terms and Conditions, or when the law compels us to do so.

Notwithstanding the foregoing, however, it is possible that Les Clés Secrètes may disclose your personal data:

  • To the competent authorities when Les Clés Secrètes is bound to do so by law or in the context of legal proceedings or future legal proceedings and to protect and defend our rights.
  • When Les Clés Secrètes or most of its assets are taken over by a third party, in which case your personal data, which Les Clés Secrètes has collected, will be among the transferred assets.

The Website undertakes to take all necessary precautions to secure your data and in particular to ensure they are not communicated to unauthorised persons.
However, if an incident affecting the integrity or confidentiality of the customer’s data is brought to the attention of,
it will promptly inform the customer and indicate the corrective measures taken. In addition, the Website does not collect any « sensitive data ».

The User’s personal data may be processed by the Website’s subsidiaries and data processors (service providers), exclusively for the purposes of this « Privacy Policy » such as:

  • The service provider in charge of the booking and payment system(s) in order to manage and validate your request.
  • The service provider who develops and maintains the Website, Diadao Productive, a digital agency.

Within the limits of their respective attributions and for the purposes mentioned above, the principal persons likely to have access to data of users are mainly the agents in our customer service.

In all other cases Les Clés Secrètes will not sell, rent or transmit your personal data to third parties, except when it has obtained your authorisation to do so
and has entered into a contract with the third party concerned, data processing, which contains the necessary guarantees regarding the confidentiality and
compliance of your personal data with the protection of your private and professional life. If you do not wish your personal data to be shared with third parties,
you may object to it when this data is collected or at any time thereafter, as mentioned in section « 8 – Rights relating to the protection of your privacy ».

7 – Storage of personal data

Except when a longer retention period is required or justified by law or by compliance with another legal obligation such as the 10 year period required to retain accounting documents,
Les Clés Secrètes will retain your personal data
for a period of 18 months from the time of the last contact with the hotel for a prospect and
for a period of 24 months for Les Clés Secrètes’s customers in order to achieve the objectives set out in the « Privacy Policy », under the heading « 3 – Use of personal data ».

8 – Rights relating to the protection of your privacy

In accordance with the provisions of the General Data Protection Regulation (GDPR: 2016/679),
users of the Website may exercise their rights relating to the protection of privacy, as stipulated below:

  • Right to access (Article 15 GDPR) and rectify (Article 16 GDPR), update, complete user data, right to lock or delete users personal data (Article 17 GDPR)
    when such data are inaccurate, incomplete, equivocal, out of date, or whose collection, use, communication or retention is prohibited.
  • Right to withdraw consent at any time (Article 13-2c GDPR).
  • Right to restrict the processing of user data (Article 18 GDPR).
  • Right to object to the processing of user data (Article 21 GDPR).
  • Right to the portability of the data that the users have provided, when this data is the subject of automated processing based on their consent or on a contract (Article 20 GDPR).
  • Right to define the fate of the user’s data after their death and to choose to whom will have to communicate (or not) its data to the third party it will have first designated.

As soon as the Website becomes aware of the death of a user and in the absence of instructions from the said user, Les Clés Secrètes undertakes to destroy this person’s data,
unless these data must be retained for probative purposes or to comply with a legal obligation.

If a user wishes to exercise their rights on the Website, they can send us a notice telling us which rights they wish to exercise with respect to their personal data.
This is free of charge and is performed by contacting Laura Giralt, as Manager, by e-mail at,
or by post Les Clés Secrètes, 11 Quai de la République, specifying in the subject of the email or letter « Rights relating to the protection of your privacy »
or by completing the application form located at the following address:

In this case, the user must indicate the personal data he/she would like to correct, update or delete on
The user must provide proof of their identity by providing a copy of their identity papers (identity card or passport).
Requests to delete personal data will be subject to the obligations imposed on Les Clés Secrètes by law, particularly as regards the preservation or archiving of documents.

In addition, you can always update, modify and/or check, through your account, the personal data you had to submit when you set up your account.
If you no longer wish to receive newsletters about our services or advertisements, you can unsubscribe at any time by clicking on the « unsubscribe » button
provided in the lower part of any email from Les Clés Secrètes.

9 – Protection of personal data

Les Clés Secrètes undertakes to take reasonable, physical, technological and organisational precautions to prevent unauthorised access to your personal data, as well as the loss,
misuse or alteration of your personal data. We use state-of-the-art encryption to protect sensitive information transmitted online.
We also protect your offline information. Only employees who need to perform specific work (for example, billing or customer service) have access to personally identifiable information.

The data collected and stored via the Website is hosted by an external company, Thaïs-Soft, which provides Thaïs is a complete management software for hotels.
It is also a CHR accounting firm (cafe, hotel, restaurant).

Your data is secure in France & Action traceability

Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot, therefore, guarantee absolute security.

If we become aware of a security breach, we will notify the affected users so that they can take appropriate action. Our incident reporting procedures take into account our legal obligations, whether at the national or European level. We are committed to fully informing our customers on all matters relating to the security of their account and providing them with all the information they need to help them meet their own regulatory reporting requirements.

No personal data belonging to users of the Website are published without the knowledge of the user, nor are they exchanged, transferred, assigned or sold on any media whatsoever to third parties.

10 – Update to the « Privacy Policy » statement

Les Clés Secrètes reserves the right to make changes to this « Privacy Policy » statement by placing a new version on the Website.
Therefore, users are advised to regularly check the relevant page on the Website on which the « Privacy Policy » is published so they are fully aware of the new terms.

11 – Hyperlinks to other websites

The Site may contain hyperlinks that lead to other websites.
In any case, Les Clés Secrètes cannot be held liable for any third party’s « Privacy Policy » or any third party’s practices relating to privacy.

12 – Consent

When using our Website, you are obliged to accept this « Privacy Policy » and the « Terms & Conditions »
by checking the checkboxes present when we collect information if you wish to benefit from Les Clés Secrètes.

13 – Claims

If you have any complaints about the manner in which Les Clés Secrètes collects, uses and/or processes your personal data, you can contact us,
in the first place, to resolve the issue(s). If this is not sufficient, Website users may file a complaint with the supervisory authorities at the following link:

14 – Contact Les Clés Secrètes

If you have any questions about the « Privacy Policy » or how Les Clés Secrètes collects, uses or processes your personal data,
please contact us by e-mail at, or by post to Les Clés Secrètes, 11 Quai de la République.