ADRT DE LA SOMME

IP / IT & Data protection

RGPD Policy

Personal data protection policy for customers, prospects and partners.

1. GENERAL PROVISIONS

1.1. CONTEXT AND DEFINITIONS

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, otherwise known as the General Data Protection Regulation (hereinafter GDPR) sets out the legal framework applicable to the processing of personal data.

The RGPD strengthens the rights and obligations of data controllers, processors, data subjects and data recipients.

This policy is implemented by the ADRT de la Somme (hereinafter referred to as “Somme Tourisme”), whose main activities include developing the tourism offer, promoting tourist destinations and marketing the Somme department’s tourism offer.

In the course of its business, Somme Tourisme processes personal data relating to its customers, partners and prospective customers.

For a better understanding of the present policy, it is specified that :

• Customers are understood to be any natural or legal person who has entered into a contract of any kind with Somme Tourisme, it being understood that Somme Tourisme works with tourism professionals, local authorities or the general public;
• Partners are understood to be all natural or legal persons involved in the tourism sector and maintaining relations with Somme Tourisme in this respect, such as, in particular, tourism professionals in the département, project sponsors and internal and external investors, holiday distributors, local authorities and their associations, and institutional partners;
• Prospects are understood to be any potential customer or any contact recipient of Somme Tourisme promotional messages whose data has been collected directly via contact forms, events or indirectly via any Somme Tourisme partner.

1.2. PURPOSE AND SCOPE

The present personal data protection policy is intended to apply to the processing of personal data of Somme Tourisme’s customers, partners and prospects.

The purpose of this policy is to meet Somme Tourisme’s obligation to provide information and to formalize the rights and obligations of customers, partners and prospects with regard to the processing of their data.

This policy applies only to data processing for which Somme Tourisme is responsible and to data qualified as “structured”.

The processing of personal data may be managed directly by Somme Tourisme or through a subcontractor specifically appointed by it.

This policy is independent of any other document that may apply within the contractual relationship between Somme Tourisme and its customers, partners and prospects.

No processing is implemented by Somme Tourisme concerning data from customers, partners and prospects if it does not concern personal data collected by or for its services or processed in relation to its services and if it does not comply with the general principles of the RGPD.

Any new processing, modification or deletion of existing processing will be brought to the attention of customers, partners and prospects by means of an amendment to this policy.

2. CUSTOMER DATA

2.1. TYPES OF DATA COLLECTED

Non-technical data

(as applicable) – Identity and identification (surname, first name, date of birth, pseudonym, customer number)

• Contact details (e-mail, postal address, telephone number)
• Work-life balance when necessary

Technical data

(depending on use) – Identification data (IP address)

• Connection data (logs, tokens, etc.)
• Acceptance data (click)
• Location data.

2.2. SOURCE OF DATA

Somme Tourisme collects customer data from :

• data supplied by the customer (paper form, order form, contract, business card);
• electronic forms completed by the customer ;
• data entered online (website, social networks, etc.) ;
• registration for events organized by Somme Tourisme (e.g. trade fairs, workshops, etc.);
• rental or acquisition of databases on an exceptional basis ;
• communication of contacts through specialized companies or Somme Tourisme partners.

2.3. PURPOSES

Depending on the case, Somme Tourisme processes customer data for the following purposes:

• customer relationship management (CRM) ;
• sale of tourist stays directly or through distribution partners;
• management of events organized by Somme Tourisme (trade fairs, workshops, etc.) ;
• sending newsletters or information feeds;
• customer account management ;
• answers to questions that may be asked by telephone or online ;
• improvement of Somme Tourisme services;
• meeting Somme Tourisme’s administrative obligations;
• community management ;
• statistics.

2.4. RETENTION PERIODS

The length of time Somme Tourisme retains customer data is defined by Somme Tourisme with regard to legal and contractual constraints and, failing that, according to its needs and in particular according to the following principles:

Treatment Shelf life

Customer data For the duration of the contractual relationship with Somme Tourisme, plus 3 years for promotional and canvassing purposes, without prejudice to retention obligations or limitation periods.

Technical data 1 year from collection

Cookies 13 months

Once this period has elapsed, the data is either deleted or kept after being anonymized, notably for statistical purposes. Data may be kept for pre-litigation and litigation purposes.

Customers are reminded that deletion or anonymization are irreversible operations and that Somme Tourisme is subsequently unable to restore them.

2.5. LEGAL BASIS

The purposes of the processing described above are based on the following conditions of lawfulness:

Customers Pre-contractual or contractual performance

3. PARTNER DATA

3.1. TYPES OF DATA COLLECTED

Non-technical data

(as applicable) – Identity and identification (surname, first name, date of birth, pseudonym, customer number)

• Contact details (e-mail, postal address, telephone number)
• Personal/professional life when necessary

Technical data

(depending on use) – Identification data (IP address)

• Connection data (logs)
• Acceptance data (click)
• Location data

3.2. SOURCE OF DATA

Somme Tourisme collects data from its partners from:

• information gathered directly from partners;
• electronic forms completed by partners ;
• registrations or subscriptions to our online services (newsletter, social networks, etc.);

3.3. PURPOSES

Depending on the case, Somme Tourisme processes the data of its partners for the following purposes:

• partner relationship management ;
• labeling of sites and facilities for sectors entrusted by the Somme department;
• tourism engineering operations (diagnostics and feasibility studies, support in setting up projects and grant applications);
• networking and consultation operations involving the various partners ;
• marketing support operations for partner service providers ;
• management of events organized by Somme Tourisme (trade shows, workshops, etc.);
• answers to questions that may be asked by telephone or online ;
• training operations for partner service providers ;
• operations to find distribution partners ;
• statistics.

3.4. RETENTION PERIODS

The length of time Somme Tourisme retains partner data is defined by Somme Tourisme with regard to legal and contractual constraints and, failing that, according to its needs and in particular according to the following principles:

Treatment Shelf life

Data relating to partners For the duration of the contractual relationship with Somme Tourisme, plus 3 years for the purposes of monitoring the relationship, without prejudice to retention obligations or limitation periods.

Cookies 13 months

Technical data 1 year from collection

Once this period has elapsed, the data is either deleted or kept after being anonymized, notably for statistical purposes. Data may be kept for pre-litigation and litigation purposes.

Partners are reminded that deletion or anonymization are irreversible operations and that Somme Tourisme is no longer able to restore them.

3.5. LEGAL BASIS

The purposes of the processing described above are based on the following conditions of lawfulness:

Partners Pre-contractual or contractual performance

4. PROSPECT DATA

4.1. TYPES OF DATA COLLECTED

Non-technical data

(as applicable) – Identity and identification (surname, first name, date of birth, pseudonym, customer number)

• Contact details (e-mail, postal address, telephone number): in particular for sending newsletters and delivering newspapers.
• Professional life (function) when necessary

Technical data

(depending on use) – Identification data (IP address)

• Connection data (logs)
• Acceptance data (click)
• Location data

4.2. SOURCE OF DATA

Somme Tourisme collects the data of its prospects from :

• data supplied by the prospect (paper form, business card, etc.) ;
• electronic forms completed by the prospect ;
• data entered online (website, social networks, etc.) ;
• registration or subscription to our online services (website, social networks, …) ;
• registration for events organized by Somme Tourisme (e.g. trade fairs, workshops, etc.);
• list provided by the organizers of events or conferences in which we participate;
• exceptional rental of databases by Somme Tourisme ;
• communication of contacts through specialized companies or Somme Tourisme partners.

4.3. PURPOSES

Depending on the case, Somme Tourisme processes the data of its prospects for the following purposes:

• prospect relationship management (PRM) ;
• management of events organized by Somme Tourisme (trade fairs, workshops, etc.) ;
• sending our newsletters or information feeds;
• answers to the questions we receive (by telephone or online) ;
• animation of websites in partnership with our partners ;
• operation to promote Somme Tourisme and tourism in the Somme department on social networks (Facebook, Twitter, YouTube, Instagram, etc.);
• behavioral analysis of prospects ;
• community management ;
• statistics.

4.4. RETENTION PERIODS

The length of time that prospective customers’ data is kept is defined by Somme Tourisme in the light of the legal and contractual constraints it is subject to and, failing that, according to its needs and in particular according to the following principles:

Treatment Shelf life

Data relating to contacts and prospects 3 years from their collection by Somme Tourisme or the last contact from the prospect/contact.

Cookies 13 months

Technical data 1 year from collection

Once this period has elapsed, the data is either deleted or kept after being anonymized, notably for statistical purposes. Data may be kept for pre-litigation and litigation purposes.

Prospects are reminded that deletion or anonymization are irreversible operations and that Somme Tourisme is no longer able to restore them.

4.5. LEGAL BASIS

The purposes of the processing described above are based on the following conditions of lawfulness:

Prospects – Pre-contractual measures

• Legitimate interest
• Consent when required by law (e.g. newsletter)

5. DATA RECIPIENTS

Somme Tourisme ensures that data is only accessible to authorized internal or external recipients.

The recipients of personal data of customers, partners and prospects within Somme Tourisme are subject to an obligation of confidentiality.

Somme Tourisme decides which recipients will have access to which data, based on an authorization policy.

Somme Tourisme is in no way responsible for damages of any kind that may result from illicit access to personal data.

All accesses concerning processing of personal data of customers, partners and prospects are subject to traceability measures.

In addition, personal data may be communicated to any authority legally empowered to deal with it. In this case, Somme Tourisme is not responsible for the conditions under which the personnel of these authorities have access to and use the data.

Internal recipients External recipients

• Authorized Somme Tourisme staff (marketing, customer relationship management, service providers and prospects, administrative staff, IT staff) and their line managers;
• Service providers or support services (e.g. IT service provider, etc.) ;
• Authorized staff from auditing departments (statutory auditors, departments responsible for internal audit procedures, etc.);
• Administration, court officer where applicable.
• Fédération Nationale des Gîtes de France
• Clévacances France

6. PERSONAL RIGHTS MANAGEMENT

6.1. RIGHT OF ACCESS (RIGHT TO COPY)

Customers, partners and prospects traditionally have the right to ask Somme Tourisme to confirm whether or not data concerning them is being processed.

Customers, partners and prospects also have a right of access, which is exercised provided that the request comes from the person himself and is accompanied by a copy of an identity document, up to date and that it is formulated in writing to the following address: 54 rue Saint Fuscien 80 000 AMIENS or to the email address accueil@somme-tourisme.com.

Customers, partners and prospects have the right to request a copy of their personal data being processed from Somme Tourisme. However, in the event of a request for an additional copy, Somme Tourisme may require customers, partners and prospects to bear the cost of this.

If customers, partners and prospects submit their request for a copy of data electronically, the information requested will be supplied in a commonly used electronic form, unless otherwise requested.

Customers, partners and prospects are hereby informed that this right of access does not apply to confidential information or data that may not be disclosed by law.

The right of access must not be exercised in an abusive manner, i.e. on a regular basis with the sole aim of destabilizing Somme Tourisme.

6.2. UPDATE – UPDATING AND RECTIFICATION

Somme Tourisme satisfies requests for updates:

• automatically for online changes to fields that can be technically or legally updated;
• upon written request from the person concerned, who must provide proof of identity.

6.3. RIGHT TO ERASURE

The right to erasure of customers, partners and prospects will not apply in cases where processing is carried out to meet a legal obligation.

Apart from this situation, customers, partners and prospects may request the deletion of their data in the following limited cases:

• the personal data is no longer required for the purposes for which it was collected or otherwise processed;
• when the data subject withdraws the consent on which the processing is based and there is no other legal basis for the processing;
• the data subject objects to processing that is necessary for the purposes of the legitimate interests pursued by Somme Tourisme and there is no compelling legitimate reason for the processing;
• the data subject objects to the processing of his/her personal data for canvassing purposes, including profiling;
• personal data has been processed unlawfully.

In accordance with legislation on the protection of personal data, customers, partners and prospects are informed that this is an individual right that can only be exercised by the person concerned in relation to his or her own information: for security reasons, the department concerned will therefore need to verify your identity in order to avoid any communication of confidential information about you to anyone other than yourself.

6.4. RIGHT TO RESTRICTION

Customers, partners and prospects are informed that this right is not intended to apply insofar as the processing carried out by Somme Tourisme is lawful and that all personal data collected is necessary for the implementation of the purposes of the processing thereof.

6.5. RIGHT TO DATA PORTABILITY

Somme Tourisme grants the right to data portability in the particular case of data communicated by customers, partners and prospects themselves, on online services offered by Somme Tourisme and for purposes based solely on the consent of individuals and the execution of a contract. In this case, data will be communicated in a structured, commonly used and machine-readable format.

6.6. RIGHT TO OBJECT

Customers, partners and prospects have the right to object at any time to the processing of personal data concerning them based on the legitimate interests of Somme Tourisme. Somme Tourisme will then no longer process the data, unless it can be demonstrated that there are compelling and legitimate grounds for the processing which override the interests and rights and freedoms of the persons concerned. Customers, partners and prospects may object at any time to the processing of their personal data for prospecting purposes.

6.7. AUTOMATED INDIVIDUAL DECISION-MAKING

Somme Tourisme does not make automated individual decisions.

The tools offered on the Somme Tourisme website are only intended to help customers and prospects and should not be considered otherwise.

6.8. POST-MORTEM RIGHTS

Customers, partners and prospects are informed that they have the right to formulate directives concerning the conservation, deletion and communication of their post-mortem data. The communication of specific post-mortem directives and the exercise of their rights can be made by e-mail to accueil@somme-tourisme.com or by post to 54 rue Saint Fuscien 80000 AMIENS, accompanied by a copy of a signed identity document.

7. ADDITIONAL PROVISIONS

7.1. OPTIONAL OR MANDATORY NATURE OF ANSWERS

Customers, partners and prospects are informed on each personal data collection form of the compulsory or optional nature of the answers by the presence of an asterisk. Where answers are mandatory, Somme Tourisme explains to customers, partners and prospects the consequences of not answering.

7.2. RIGHT OF USE

Customers, partners and prospects grant Somme Tourisme the right to use and process their personal data for the purposes set out above.

However, enriched data resulting from processing and analysis by Somme Tourisme, otherwise known as enriched data, remains its exclusive property (usage analysis, statistics, etc.).

7.3. SUBCONTRACTING

Somme Tourisme informs its customers, partners and prospects that it may involve any subcontractor of its choice in the processing of their personal data.

In this case, Somme Tourisme ensures that the processor complies with its obligations under the RGPD.

Somme Tourisme undertakes to sign a written contract with all its subcontractors and imposes the same data protection obligations on subcontractors as it does. In addition, Somme Tourisme reserves the right to audit its subcontractors to ensure compliance with the provisions of the RGPD.

7.4. TREATMENT REGISTER

Somme Tourisme is implementing a data processing register.

8. SAFETY

8.1. SAFETY MEASURES

It is the responsibility of Somme Tourisme to define and implement the physical or logical technical security measures it deems appropriate to prevent the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of data.

These measures include the following:

• data access authorization management ;
• internal and external safeguards with our subcontractors
• identification process for building and data accesss

In any event, Somme Tourisme undertakes, in the event of a change in the means used to ensure the security and confidentiality of personal data, to replace them with means of superior performance. No change may lead to a reduction in the level of security.

In the event of subcontracting all or part of the processing of personal data, Somme Tourisme undertakes to contractually impose security guarantees on its subcontractors by means of technical data protection measures and appropriate human resources.

8.2. DATA BREACH

In the event of a personal data breach, Somme Tourisme undertakes to notify the Cnil under the conditions prescribed by the RGPD.

If the said violation poses a high risk to customers, partners and prospects and the data has not been protected, Somme Tourisme:

• will notify the customers, partners and prospects concerned;
• communicate the necessary information and recommendations to the customers, partners and prospects concerned.

9. CONTACTS

9.1. SOMME TOURISME CONTACT

The contact details of our personal data referent are as follows:

• Name: Somme Tourisme – Rémi Desaintjean
• E-mail address: r.desaintjean@somme-tourisme.com
• Tel: 03 22 71 22 71

9.2. DPO CONTACT

Somme Tourisme has appointed a data protection officer whose contact details are as follows:

• Name: Me Eric BARBRY, Cabinet Racine
• E-mail address: dpo-adrtsomme@racine.eu
• Address: 40, rue de Courcelles, Paris 75008 FRANCE

9.3. RIGHT TO LODGE A COMPLAINT WITH CNIL

Customers, partners and prospects concerned by the processing of their personal data are informed of their right to lodge a complaint with a supervisory authority, namely the Cnil in France, if they consider that the processing of personal data concerning them does not comply with European data protection regulations, at the following address:

Cnil – Complaints department

3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

Tel: 01 53 73 22 22

10. EVOLUTION

The present policy may be modified or amended at any time in the event of changes in legislation, case law, CNIL decisions and recommendations or usage.

Any new version of the present policy will be brought to the attention of customers, partners and prospects by any means chosen by Somme Tourisme, including electronic means (distribution by e-mail or online, for example).

11. FOR FURTHER INFORMATION

For further information, please contact us at accueil@somme-tourisme.com.

For more general information on the protection of personal data, please visit the Cnil website at www.cnil.fr.