1. General
Comme des Français SAS (head office located at 191 rue des Cinq Voies, 59200 Tourcoing, France) ("Comme de Français," "we" and "our"), as the role of responsible for processing, attaches great importance to the protection and respect of your privacy. This policy is intended to inform you of our practices regarding the collection, use and sharing of information that you are required to provide to us through our platform (the "Platform") accessible from the www.commedesfrancais.com website or our mobile applications.
This policy (as well as our Terms and Conditions of Use and Services and any document referred to in it, as well as our Cookies Charter) outlines how we process the personal data we collect that has been provided to us. We invite you to read this document carefully to learn and understand our practices regarding the processing of your personal data that we implement.
2. Types of information collected
We are likely to collect and process the following data:
2.1. The information you give us directly
By using our Platforms, you are required to provide us with information, some of which may identify you ("Personal Data"). This is especially the case when you fill out forms (such as the registration form), when you participate in one of our games, contests, promotional offers, studies or surveys, when you contact us - whether by phone, email or any other means of communication - or when you inform us of a problem.
This information includes:
2.1.1. The data necessary to register for the service we provide on our Platforms or access to any other service provided by us. This data includes your first and last name, email address, date of birth, gender, phone number (landline and/or mobile), password, professional guide card number, legal status and registered number (company, self-employed, association, other,...), This information is mandatory. Otherwise, Comme des Français will not be able to provide you with the services offered by our Platforms and you will not be permitted to create an account on our Platform;
2.1.2. A photograph (as a French Friend);
2.1.3. A postal address;
2.1.4. Information regarding your experience in the services proposed (as a French Friend) in the advertisements you published or in the form of media content (texts, photo, video) in relation to the French way of life, previously validated by Comme des Français;
2.1.5. Your mini-biography (as a French Friend);
2.1.6. A copy of all the exchanges between you and Comme des Français;
2.1.7. A copy of all bookings or publications made on our Platforms;
2.1.8. Details of financial or accounting transactions on our Platforms or by any other means, including information relating to your credit card payment, your bank details, information about Reserved Activities or for which you have posted an advertisement on our Platforms;
2.1.9. Details of your visits to our Platforms and the content you have accessed;
2.1.10. If applicable, your responses to our surveys and questionnaires and the comments you left to assess a trip with another member of our community, including the information that could be used in research and analysis of user behaviour;
2.1.11. The data we may ask you to provide when you report a problem with our Platforms or services, such as the purpose of your request for assistance;
2.1.12. Your location data when you agreed to have us collect and process this data;
2.1.13. A copy of your passport, driver's license, ID card or other similar documents that you have agreed to provide to us.
2.2. The data we collect automatically
2.2.1. In the case when you connect to our services using the social networking features available to you, Comme des Français will have access to some of the data (including your first name, last name, photography, email address and number of Facebook friends) of your account on that social network in accordance with the General Terms of Use of the social network concerned . We are also likely to collect some of your Personal Data when you interact with features of these networks such as "Like" features.
2.2.2 On each of your visits, we may collect, in accordance with applicable legislation and with your consent, any information about the devices on which you use our services or the networks from which you access our services, such as your IP addresses, login details, types and versions of internet browsers used, types and versions of plugins in your browser, operating systems and platforms, data about your browsing path on our Platforms, including your passage on the various URL pages of our Platforms, the content you access or view, the search terms used, the download errors, the viewing time of certain pages, the advertising ID of your device, interactions with the page as well as any phone number used to contact us. Among the technologies used to collect this information, we use cookies (to learn more about this, please refer to our Cookies Charter).
2.2.3. We also collect information about your use of our Platform (such as the number of advertisements published, your response rate, your registration date, your average of reviews received, etc.) that are likely to be displayed on your public profile.
2.3. How long your data is stored
2.3.1. With the exception of the personal data categories covered in Articles 2.3.2. and 2.3.3. below, your Personal Data is archived at the end of the following periods:
2.3.2. The following personal data categories may be retained for different durations:
2.3.3 In the event of your account being suspended or blocked, we will keep your data for a period of 2 to 10 years from the date of suspension, to avoid any circumvention by your part of the rules in force on our Platforms.
3. Using collected data
We use the data we collect to:
3.1. execute contracts between you and us and provide you with the information and services requested;
3.2. send you information about our services (such as booking confirmations) via email, SMS or any other means of communication;
3.3. collect your payment information
3.4. allow you to customize your profile on our Platforms;
3.5. allow you to communicate and interact with other members of our community, including our services or the Experiences you have already performed or are planning to perform;
3.6. give you access and allow you to communicate with our Member Relations Service;
3.7. ensure compliance with (i) applicable legislation, (ii) our terms and conditions of use, (iii) our privacy policy and (iv) our charter of good conduct. In the event of any breaches on your part, we may have to suspend your account on our Platforms;
3.8. send you, in accordance with applicable legal provisions and with your consent when required by law, marketing, advertising and promotional messages and information relating to the use of our services, booking arrangements, or suggesting and advising you on goods or services that may be of interest to you. We may also use your data to send you advertisements that may be of interest to you on social networking platforms or third-party sites. If you would like more information on this, please read the contractual documents of these platforms;
3.9. to inform you of changes to our services;
3.10. check the information contained in your passport, driver's license, ID card or any other identity document that we collected when you registered or used our Platforms;
3.11. manage our Platforms and perform internal technical operations in the context of problem solving, data analysis, testing, research, analysis, studies and surveys;
3.12. improve and optimize our Platforms, including ensuring that our content is displayed correctly on device you use;
3.13. allow you to use the interactive features of our services if you wish;
3.14. help us preserve a safe and healthy environment on our Platforms; and
3.15. assess the effectiveness of the advertising messages we send and adapt them to our members.
4. Recipients of the information collected and justification for its transmission
4.1. As part of the use of our services, some of your information is passed on to other members of our community, either through your public profile or as part of the booking process (for example, we provide your phone number to the people with whom you will participate in an Activity).
4.2. We are also likely to share information about you, including Personal Data, with other entities of the Comme des Français group as part of this policy.
4.3. We also work closely with third-party companies that may have access to your Personal Data, including:
4.4. We only share your data with the third parties mentioned in 4.3. above in the following cases:
4.4.1. When we use a service provider to carry out any contract between you and us or to provide or improve our services (for example, as part of payments made through our Platforms);
4.4.2. As part of the booking process, in order to provide the requested services, we are required to post on our Platforms or to pass on to another member certain details of your Personal Data such as your first name, photograph, mobile phone number or email address;
4.4.3. We publish the comments you write as part of our review system on our Platforms. These comments, which contain your first name and the first letter of your last name as well as your photograph, are visible to all visitors to our Platforms;
4.4.4. When we use search engine and analytics providers to improve and optimize our Platforms;
4.4.5. When you specifically request it (for example, when using authentication methods provided by social networks);
4.4.6. When we publish, on the websites of our business partners, certain parts of our Platforms (including trips you posted) through APIs or widgets. In this case, certain information from your public profile may also be displayed on these sites;
4.4.7. Where we have a legal obligation to do so or if we believe in good faith that it is necessary to (i) respond to any claim against Comme des Français, (ii) comply with any judicial request, (iii) enforce any contract with our members, such as the General Terms of Use and this Privacy Policy (iv) in the event of an emergency involving public health or the physical integrity of a person, (v) in the context of an inquiry or investigation, or (vi) to guarantee the rights, property and security of Comme des Français, its members and more generally any third party;
4.4.8. In the event that we sell or acquire a business or assets, in which case we reserve the opportunity to share your Personal Data with the potential seller or buyer of that business or assets.
4.4.9. If Comme des Français or all or part of its assets are bought by a third party, the data in our possession will, if necessary, be transferred to the new owner.
4.4.10. In accordance with applicable legislation and with your consent when required, we may aggregate data that concerns you and that we receive or send to our business partners, including all or part of your Personal Data and information collected through cookies. This aggregated information will only be used for the purposes described above.
4.4.11. We draw your attention to the fact that if you decide to allow us access to some of your information, including your Personal Data, through connection services made available by our business partners, their privacy policies are also enforceable. We have no control over the collection or processing of your data implemented by our business partners on their platform.
5. Use and Moderation of Messages
5.1. We can read the messages you exchange with other members of our community through our Platforms for fraud prevention, service improvement, user support, verification of our members' compliance with our contracts with us and in particular our Terms of Use. For example, in order to prevent a member from bypassing our online booking system, we allow ourselves to browse and analyze messages exchanged on our Platforms to ensure that they do not contain any contact information or reference to other websites.
5.2. We never become aware of your communications with other members of our community for promotional or advertising purposes. Where possible, we use automated systems to moderate messages sent between members via our Platform.
6. Targeted advertising, emails and SMS
In accordance with applicable legislation and with your consent when required, we may use the data you provide us on our Platforms for commercial prospecting purposes (e.g. to (i) send you our newsletters, (ii) send you invitations to our events or any other communication that may be of interest to you and (iii) display targeted advertisements on social media platforms or third-party sites).
Regarding promotional emails: You can withdraw your consent at any time by (i) unticking the relevant box in your account, (ii) clicking on the link de-registration provided in each of our submissions or (iii) by contacting us according to the details described in article 14 below.
Regarding targeted advertising:
7. Data retention and transfer
We keep your Personal Data in the European Union. However, the data we collect when you use our Platform or as part of our services may be transferred to other countries, some of which may have less protective data protection legislation than that in the country where you live.
This is particularly the case with regard to data transmitted to our subcontractors located outside the European Union, particularly in the United States. We can use their services to respond to your requests, moderate photographs published on our Platforms, provide online payment tools, provide us with commercial and advertising services or email and SMS services.
This is also the case for companies affiliated with Comme des Français located outside the European Union to whom we can transfer some of your data as part of the provision of our services in those countries.
In the event of a transfer of this type, we ensure that the treatment is carried out in accordance with this policy and that it is framed by the standard contractual clauses of the European Commission which ensure a sufficient level of protection of the privacy and fundamental rights of individuals.
On request, we can provide you with a list of the countries where we keep your data and where it passes occasionally.
8. What are your rights to your personal data?
8.1. Where required by applicable law, you have the right to obtain a copy of the personal data about you that we hold. Before responding to your request, we may (i) verify your identity and (ii) ask you to provide us with more information to respond to your request.
8.2. We will endeavour to respond to your request within a reasonable time frame and, in any event, within the statutory time frame. If you wish to exercise this right, contact us as required in section 14 below.
As a member of our Platforms, you also have the option to access the Personal Data we hold through your account to correct, modify or delete any incorrect information. You are committed to providing us with complete, accurate, valid and up-to-date information. You can also close your online account at any time.
You can also edit or delete this information by contacting us directly (see article 14 below).
Please note that we may retain certain information about you when required by law or when we have a legitimate reason to do so. This is the case, for example, if we believe that you have committed a fraud or violated our Terms of Use and we want to prevent you from circumventing the rules applicable to our community. 8.3. You also have the right to set guidelines regarding your Personal Data after your death.
9. Cookies and similar technologies
For more information, check out our Cookies Charter
10. Privacy of your password
You are responsible for the confidentiality of the password that we have chosen for you in order to access your account on our Platforms.
You agree to keep this password secret and not to share it with anyone.
11. Links to other websites and social networks
Our Platforms may occasionally contain links to the websites of our partners or third-party companies. Please note that these websites have their own privacy policies and we do not accept responsibility for the use of the information collected when you click on these links. We invite you to review the privacy policies of these sites before handing over your Personal Data.
12. General Data Protection Regulations
We guarantee the retention and confidentiality of data collected on secure servers in accordance with the recommendations of the General Data Protection Regulations (GDPR). (EU Regulation 2016/879 -27th April 2016).
We guarantee the right to delete and the right to portability of Personal Data to anyone registered in one of our files at their first request.
We undertake to notify the national data leak or data breach protection authority without delay so that those affected can take all measures to protect the data.
We are committed to ensuring that our potential subcontractors are able to comply with these measures.
Certain information collected and held under the GTCUS may give rise to the exercise of the right of access and rectification under the conditions provided by The amended Computer, File and Freedoms Act No. 78-17 of 6 January 1978. Our files are reported to the CNIL, under the number XXXXXXXX.
Our CNIL correspondent and data protection delegate is Mr François Xavier LUYCE who can be contacted by email at: contact@commedesfrancais.com or at the following address: Comme des Français - Personal Data - 191 rue des Cinq Voies 59200 TOURCOING
13. Modification of our privacy policy
We may occasionally change this privacy policy. When necessary, we will inform you and/or seek your approval. We advise you to check this page regularly for any changes or updates to our privacy policy.
14. Contact
If you have any questions about this privacy policy or any request for your personal data, you can contact us by email atcontact@commedesfrançais.com or by sending us a letter to the address mentioned at the top of this document.
Updated 8th February 2018
