Preamble

SMIX Gaillac, Cordes sur ciel and the medieval cities processes personal data (hereinafter the “Personal Data”) concerning you in the context of the use of this website (hereinafter the “Site”).

As data controller, we respect privacy and protect the personal data of users of our Site.

This policy aims to inform you of the methods of collection, processing and use of Personal Data and of your rights in terms of protection of personal data with regard to the applicable provisions in this matter, in particular Law 78-17. of January 6, 1978 relating to data processing, files and freedoms known as "Data processing and freedoms" in its latest version and with France's General Data Protection Regulations, in force since May 25, 2018.

Article 1 - Scope of this personal data protection policy

This Policy sets out the principles and guidelines for the protection of Your Personal Data, which includes Personal Data collected on - or through - the Site.

SMIX Gaillac, Cordes sur ciel and the medieval cities, management entity of the La Toscane Occitane tourist office, collects Personal Data (online, including by e-mail, or offline); this policy applies regardless of the method of collection or processing.

The notion of Personal Data refers to any information relating to an identified or identifiable natural person. A person is “identifiable” when they can be identified, directly or indirectly, in particular by reference to an identification number, or to one or more elements which are specific to them.

“Non-Personal Data” corresponds to information that does not allow a person to be identified.

Article 2 - Places of storage of Personal Data

All Personal Data is stored exclusively in France, by our web hosting provider:

OVH SAS 2, rue Kellermann, 59100 Roubaix

Article 3 - Data controller

The controller of Your Personal Data is: SMIX Gaillac, Cordes sur ciel et les cités médiévales, 14 rue des écoles, 81140 Castelnau-de-Montmiral; certain technical services are entrusted to our technical service providers. In accordance with Article 28 of the GDPR, these service providers are bound by a strict confidentiality clause which prohibits any use of the data entrusted to them that is not provided for in the service contract and which requires them to implement technical and organizational measures that meet the security and personal data protection requirements.

Our technical service providers

Our payment providers: Consonnance web, Alliance Réseau, DGFIP, COSOLUCE, Payzen-Lyra

Our external web service providers: Iris Interactive and Webitics

Our subcontractors and hosting, storage, maintenance and site security services: OVH and Iris Interactive

Our feed analysis services: Google Analytics, Google Search Console, Google Tag Manager

Our advertising and retargeting services: Google Adwords, Meta

Our GRM and newsletter sending service providers whose head office is located in France: Proximit, Brévo

Article 4 - Data collected

Personal data

Personal Data may include the following:

Last name First Name
Address
E-mail
Phone Number
Connection data
Navigation data
IP adress
Banking transactions
Booking History
Newsletter subscription

And any other Personal Data that may be relevant for the purposes set out below.

Note to visitors and users of the Site: certain functionalities and features of the Site can only be used if You communicate to SMIX Gaillac, Cordes sur ciel and the medieval cities certain Personal Data when You visit or use the Site. You are free to provide or not, all or part of Your Personal Data.

However, if you choose not to provide them, such a decision could prevent the achievement or satisfactory achievement of the objectives described below, certain services and certain features of the Site may not function properly and / or You will be refused the access to certain pages of the Site.

Cookies and other trackers

The Site may use cookies or other technologies likely to collect or store Personal Data. Cookies are text files stored and used to record Personal and Non-Personal Data concerning browsing on the Site.

Cookies can be permanent (and remain after the user has disconnected from the Site, in order to be used during subsequent visits to the Site) or temporary (and disappear as soon as the user disconnects from the Site).

SMIX Gaillac, Cordes sur ciel and the medieval cities uses cookies to improve your user experience, in particular by:

  • allowing a service to recognise an individual user's equipment, so that person will not have to provide the same information several times in order to perform the same task;
  • recognizing the username and password have already provided so that the user does not have to re-enter them on each web page that requests them.

SMIX Gaillac, Cordes sur ciel and the medieval cities uses cookies to analyze traffic and data on the Sites in order to:

  • measure the number of users of the services, thus making them easier to use and ensuring their ability to respond quickly to requests;
  • help SMIX Gaillac, Cordes sur ciel and medieval cities to understand how users interact with services in order to improve them.

SMIX Gaillac, Cordes sur ciel and the medieval cities may also use the services of third-party providers for the purpose of performing services on its behalf and in particular for:

  • analyse individual browsing habits and measure the audience of the Sites and Applications;
  • analyse an individual's areas of interest and offer targeted marketing or advertising offers;
  • allow an individual to share the content of the Applications' Sites with other people on social networks or to let these other people know what a user is watching or what they think (eg the "Like" button on Facebook)

In this case, invisible "pixels" and cookies provided by these third-party providers may be used and stored. When transmitting the information generated by these cookies, the cookie settings ensure that the IP address is made anonymous before geolocation and before storage. Our service providers will use this information for the purposes of evaluating Your use of the Site, writing reports on the Site's activity for the La Toscane Occitane Tourist Office, and offering You better services and advertising targeted to Your needs. They will not associate your IP address with any other of their data.

When you browse the Site, cookies are enabled by default and data can be read or stored locally on your device. You will be notified the first time you receive a cookie and you can decide whether to accept or reject it. By continuing to use the Sites, you expressly accept the use of such cookies by SMIX Gaillac, Cordes sur ciel and the medieval cities.

Any individual can also configure their browser to systematically refuse cookies (including cookies used for audience measurement purposes). However, if this were the case, certain functionalities and features of the Site may not function properly and that individual may not be able to access certain parts or services of the Site.

If any individual wishes to modify or delete information, please refer to Article 9: Your rights.

It's possible to access the cookie management panel to configure the storage and reading of cookies.

Data retention

By type of data:

  • Civil status data (name, first name, postal address, etc.): 3 years max. ;
  • Connection data: 3 years max. ;
  • Location data = 48h;

We only keep Personal Data for a period of time necessary and proportionate to the purpose for which it was collected, namely for a maximum period of 3 years from the last exchange you had with us and carried out at your initiative.

Beyond the aforementioned periods, your data will be purely deleted or anonymised.

Article 5 - Purposes of the collection of personal data

As indicated above, You provide Your Personal Data on a voluntary basis.

Personal Data is generally collected for the needs of the activity of SMIX Gaillac, Cordes sur ciel and the medieval cities such as the improvement of the marketing and advertising efforts of the La Toscane Occitane Tourist Office, a better adaptation of the Tourist Office's products and services to the needs of customers or compliance with the reporting obligations provided for by law, and other similar activities.

SMIX Gaillac, Cordes sur ciel and the medieval cities collects and uses Personal Data concerning You for the needs of its activity and in particular for the following purposes:

We process a user's data in whole or in part for the purposes of:

  • Sending newsletter
  • Requests for information
  • Buy your tickets
  • Marketing

Subject to applicable local law, by providing Your email address, You expressly authorize the La Toscane Occitane Tourist Office to use it with other useful Personal Data to send You commercial or marketing messages.

La Toscane Occitane Tourist Office may also use Your email address for administrative or other non-marketing purposes (for example, to notify You of important changes to the Site).

Article 6 - Conditions for processing and storing personal data

The "processing" of Personal Data includes in particular the use, conservation, recording, transfer, adaptation, analysis, modification, declaration, sharing and destruction of Personal Data depending on what is necessary in view of the circumstances or legal requirements.

All Personal Data collected is kept for a limited period depending on the purpose of the processing and only for the period provided for by the applicable legislation.

All Personal Data collected is stored in mainland France.

Article 7 – Links to websites not controlled by SMIX Gaillac, Cordes sur ciel and medieval cities 

The Site may provide links to third party websites that may be of interest to its users.

SMIX Gaillac, Cordes sur ciel and the medieval cities has no control over the content of third-party sites or over the practices of these third parties regarding the protection of Personal Data that they may collect. Consequently, SMIX Gaillac, Cordes sur ciel and the medieval cities declines all responsibility concerning the processing of Your Personal Data by these third parties. It is your responsibility to inform yourself about the personal data protection policies of these third parties.

Article 8 - Transfer of personal data

In the event of access to the Site from a country which is not a member of the European Union whose legislation relating to the collection, use and transfer of data differs from those of the European Union, we draw the individual's attention to the fact that by continuing to use the Site, which is governed by French law, the corresponding Terms of Use and this Policy, Personal Data is transferred to the European Union and the user consents to this transfer.

Your Personal Data may be disclosed within SMIX Gaillac, Cordes sur ciel and the medieval cities for the purposes set out in Article 3 of this Policy.

SMIX Gaillac, Cordes sur ciel and the medieval cities may transfer Your Personal Data outside the European Union, provided that it ensures, before transferring them, that the entities outside the European Union offer an adequate level of protection, in accordance with the European legislation in force.

If SMIX Gaillac, Cordes sur ciel and the medieval cities learns that a third party to whom SMIX has communicated Personal Data for the purposes set out in Article 3 above is using or disclosing Personal Data without complying with this Policy or in violation of applicable legislation, SMIX will take all reasonable measures to prevent or put an end to such use or disclosure.

You also have the right to authorize or not the La Toscane Occitane Tourist Office to use Your Personal Data for a purpose other than those for which these Personal Data were initially collected. You can oppose this use by referring to Article 9 below.

SMIX Gaillac, Cordes sur ciel and the medieval cities may also be required to transfer Your Personal Data to third parties if SMIX considers that such a transfer is necessary for technical reasons (for example, for hosting services by a third party) or to protect its legal interests (for example, in the event of a sale of assets to a third-party company, a change of control or total or partial liquidation of SMIX).

In addition, SMIX Gaillac, Cordes sur ciel and the medieval cities may share Your Personal Data with the reseller on whom You depend or assigned to the territory in which You are located for the needs of the SMIX activity may also share Your Personal Data with commercial partners when SMIX and the commercial partner jointly sponsor an event or participate together in a marketing promotion in which You engage.

SMIX Gaillac, Cordes sur ciel and the medieval cities may communicate Your Personal Data if required to do so by law or if SMIX believes in good faith that such disclosure is reasonably necessary to comply with legal process (for example, a warrant, subpoena or other court order) or to protect the rights, property or personal safety of SMIX, our customers or the public.

If the applicable legislation allows it, SMIX Gaillac, Cordes sur ciel and the medieval cities may also share Your Personal Data with third parties in order to offer You targeted marketing or advertising offers.

These transfers may take place via the Internet or by any other method deemed appropriate by SMIX Gaillac, Cordes sur ciel and the medieval cities in accordance with applicable legislation and the internal security policies of SMIX.

Article 9 - Your rights

Your right to access and rectify your data

You have the right to access and have your personal data corrected.

You can ask us that your personal data be, depending on the case, rectified, completed if they are inaccurate, incomplete, equivocal or out of date.

Your right to have your data deleted

You can ask us to erase your personal data when one of the following reasons applies:

  • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw the consent previously given;
  • you object to the processing of your personal data for legitimate reasons;
  • the processing of personal data does not comply with the provisions of applicable law and regulations.

Nevertheless, the exercise of this right will not be possible when the conservation of your personal data is necessary with regard to the legislation or the regulations and in particular for example for the establishment, the exercise or the defence of rights in court.

Your right to limit data processing

You can request the limitation of the processing of your personal data in the cases provided for by law and regulation.

Your right to object to data processing

You have the right to object to the processing of personal data concerning you when the processing is based on the legitimate interest of the controller.

Your right to the portability of your data

Since May 25, 2018, you have the right to the portability of your personal data.

The data on which this right can be exercised are:

  • only your personal data, which excludes anonymised personal data or data that does not concern you;
  • declarative personal data as well as the personal operating data mentioned above;
  • personal data which does not infringe the rights and freedoms of third parties, such as those protected by business secrecy.

This right is limited to processing based on consent or on a contract as well as personal data that you have personally generated.

This right does not include derived data or inferred data, which are personal data created by SMIX Gaillac, Cordes sur ciel and the medieval cities.

Your right to withdraw your consent

When the data processing that we carry out is based on your consent, you can withdraw it at any time. We then stop processing your personal data without the previous operations for which you had consented being called into question.

Your right to lodge an appeal

You have the right to lodge a complaint with the CNIL on French territory, without prejudice to any other administrative or judicial appeal.

Your right to set post-mortem guidelines

You have the possibility to define guidelines relating to the conservation, erasure and communication of your personal data after your death and this with a trusted third party, certified and responsible for ensuring that the will of the deceased is respected in accordance with the requirements of the applicable legal framework.

How to exercise your rights

All the rights listed above can be exercised:

  • by post to the following address: SMIX Gaillac, Cordes sur ciel et les cités médiévales, 14 rue des écoles, 81 140 Castelnau-de-Montmiral, enclosing a copy of your identity card and proof of address;
  • via our email address [email protected]. A procedure will then be sent to you in order to validate your identity.

Note: the documents sent within the framework of this procedure will be destroyed, and the data potentially collected during the procedure will be definitively deleted, at the end of the latter.

Also note that any requests that do not meet these guidelines will be ignored.

We undertake to respond to these requests within 1 month of receipt of the request. This period may be extended by 2 months depending on the complexity and the number of requests received, i.e. 3 months in total.

If you have an account, you can exercise Your rights of access and rectification by logging into your account.

However, with regard to the exercise of the right to information, we may not have the obligation to act on it if:

  • you already have this information;
  • the recording or communication of your personal data is expressly provided for by law;
  • communication of information proves impossible;
  • providing information would require disproportionate effort.

Article 10 - Data security and recipients

SMIX Gaillac, Cordes sur ciel and the medieval cities ensures that the Personal Data that You have chosen to communicate to it is protected and secured, in order to ensure their confidentiality and prevent them from being distorted, damaged, destroyed or disclosed to unauthorized third parties.

SMIX Gaillac, Cordes sur ciel and the medieval cities has taken physical, electronic and organizational protection measures to prevent any loss, misuse, unauthorized access or dissemination, alteration or possible destruction of this Personal Data. Among these protection measures, SMIX Gaillac, Cordes sur ciel and the medieval cities integrates technologies specially designed to protect Personal Data during their transfer. However, despite the efforts of SMIX to protect Your Personal Data, SMIX Gaillac, Cordes sur ciel and the medieval cities cannot guarantee the infallibility of this protection due to unavoidable risks that may arise during the transmission of Personal Data.

All Personal Data being confidential, their access is limited to the employees and service providers of SMIX Gaillac, Cordes sur ciel and the medieval cities who need it as part of the execution of their mission. All persons having access to Your Personal Data are bound by an obligation of confidentiality and are exposed to disciplinary measures and/or other sanctions if they do not respect these obligations.

However, it is important that all users exercise caution to prevent unauthorized access to Personal Data. An individual is responsible for the confidentiality of passwords and the information contained in their account. Consequently, they must ensure that they close their session in the event of shared use of the same computer or the same terminal.

Article 11 - Conflict resolution

Although SMIX Gaillac, Cordes sur ciel and the medieval cities has taken reasonable measures to protect Personal Data, no transmission or storage technology is completely infallible.

However, SMIX Gaillac, Cordes sur ciel and the medieval cities is concerned with ensuring the protection of Personal Data. If You have reason to believe that the security of Your Personal Data has been compromised or that it has been misused, You are invited to contact SMIX Gaillac, Cordes sur ciel and the medieval cities at the following address: [email protected].

SMIX Gaillac, Cordes sur ciel and the medieval cities will investigate complaints regarding the use and disclosure of Personal Data and attempt to resolve them in accordance with the principles contained in this Policy.

Unauthorised access to Personal Data or its misuse may constitute an offence under local law.

Article 12 - Contact

For any questions regarding this Policy, to no longer receive information from SMIX Gaillac, Cordes sur ciel and the medieval cities or for any request for rectification, addition, update or deletion of Your Personal Data, You can send an email to the following email address: [email protected] 

Article 13 - Date of entry into force and revisions of the personal data protection policy

This Policy may be updated according to the needs of SMIX Gaillac, Cordes sur ciel and the medieval cities and circumstances or if required by law. We therefore invite you to regularly read the updates.

Last modification: March 6, 2025 

Information regarding the use of personal data from the EnQuête(s) application

La Toscane Occitane undertakes, within the framework of its activities and in accordance with the legislation in force in France and in Europe, to ensure the protection, confidentiality and security of the personal data of the users of its services, as well as to respect their privacy.

This notice informs you about how La Toscane Occitane, its subcontractors and its possible partners process your personal data in the context of the use of the mobile application “Survey(s)” (the “Application”) and the service accessible via this mobile application (the “Service”).

Why does La Toscane Occitane process your data?

La Toscane Occitane only processes personal data for specific, explicit and legitimate purposes. La Toscane Occitane does not process this data in a manner incompatible with these purposes.

La Toscane Occitane processes your data as part of the execution of a contract (the general terms and conditions of use ("GCU") of the Application and the Service that you accept prior to any use). To this end, the purposes pursued by La Toscane Occitane are as follows:

Allow access to the Application and the Service

Manage the features of the Application and the Service

As part of its legitimate interests, La Toscane Occitane also carries out data processing within the framework of the provision of the Service, and this for the following purposes:

  • Evaluate the audience of the Service and the content viewed on the Application
  • Improve the Service and the Application

La Toscane Occitane may also be required to process your data to meet its legal or regulatory obligations.

What data is processed?

Depending on the case, La Toscane Occitane processes your personal data, directly collected from you or resulting from the use of the Application and the Service. La Toscane Occitane may also be the recipient of data that has been collected from you by a third party for the use of the Service.

La Toscane Occitane only processes data or a category of data if it is strictly necessary for the purpose pursued.

La Toscane Occitane processes the following categories of data in connection with the use of the Application and the Service:

Identification data: technical identification data

Geolocation data

For how long is your data kept?

Your personal data is strictly confidential and kept for the period necessary to fulfill the purposes mentioned above.

Who are the recipients of your data?

The data collected is intended for the internal services of La Toscane Occitane and its subcontractors.

The processed data may finally be transmitted to the competent authorities, at their request, within the framework of legal procedures, within the framework of judicial research and requests for information or in order to comply with other legal obligations.

Is your data processed outside the European Union?

In order to provide you with a quality service, La Toscane Occitane relies on the expertise of its subcontractors, some of whom perform their services outside the European Union. In this case, La Toscane Occitane takes the necessary steps with its subcontractors to guarantee an adequate level of protection of your data and this in full compliance with the applicable regulations.

If the subcontractors concerned are not located in a country with legislation considered to offer adequate protection, they will then have previously signed the European Commission's "standard contractual clauses" or will be subject to binding internal rules approved by the authorities.

What are your rights?

You have the right to access, rectify and delete data concerning you. You can request the portability of the latter. You also have the right to object to the processing carried out or to request its limitation.

You can issue instructions on the retention, deletion or communication of your personal data after your death.

How can you exercise your rights?

You can exercise your rights at any time, as well as contact La Toscane Occitane at the following address: SM La Toscane Occitane, 42 GR RAIMOND VII 81170 CORDES-SUR-CIEL.

A response will be sent to you within one month of receipt of your request.

Possibility of contacting the CNIL: If your exchanges with La Toscane Occitane have not been satisfactory, you have the possibility of filing a complaint with the National Commission for Information Technology and Civil Liberties (CNIL), the supervisory authority responsible for compliance with obligations regarding personal data in France.

How is your data secured?

La Toscane Occitane ensures that your data is processed securely and confidentially, including when certain operations are carried out by subcontractors.

For this purpose, appropriate technical and organizational measures are put in place to prevent the loss, misuse, alteration and deletion of personal data concerning you. These measures are adapted according to the level of sensitivity of the data processed and according to the level of risk presented by the processing or its implementation.

Use of tracking technology.

La Toscane Occitane uses a software development kit ("SDK") allowing the implementation of analysis necessary for the operation of the Service and giving rise to the production of anonymous statistics. In accordance with the regulations in force and the use of the SKD, this mechanism is not subject to your prior consent.

Modification of the personal data protection policy

This personal data protection policy may be subject to change.

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