The website accessible at the URL https://www.cowleymanor.com/ (hereinafter the “Website”) is published by the company Experimental Group, a société par actions simplifiée, with a share capital of €20,085,900 register in the Paris Trade and Companies Register under number 524 095 064, whose registered office is located at 104, rue d’Aboukir, 75002, Paris, France (hereinafter “Experimental Group).
The persons who can access the Website are referred to as “Users”.
- Collection of Personal Data
Experimental Group is required to collect and process, on its own behalf, the User’s personal data which (i) have been communicated to it by the User following the sending of a collection form available on the Website, (ii) subsequently in the context of its various exchanges with Experimental Group and (iii) though the mere use of the Website provided a valid consent has been given by the User.
- Legal Basis for Processing
In accordance with the applicable legislation on the protection of personal, the processing of personal data implemented by Experimental Group is based on one of the following legal bases.
- The performance of the contractual relations of Experimental Group with the Users
In order to use the Website and benefit from the services it offers, Users must accept the general terms and conditions available at https://www.cowleymanor.com/privacy-policy/.
These documents formalize a contractual relationship between each of the Users and Experimental Group.
The personal data collected and processed by Experimental Group in this context are necessary for the performance of these contracts, the purposes of which are specified in Article 4 – “Purposes of the processing” hereunder.
- User’ consent
When Users browse the Website, Experimental Group may read and/or write trackers on their device (e.g., computer, mobile device).
Before installing cookies on the User’s device, Experimental Group collects the User’s consent through a “cookie banner”.
- Compliance with a legal obligation to which Experimental Group is subject
The processing of User’s personal data implemented by Experimental Group may be imposed by a legal obligation (e.g., Decree No. 2011-219 of February 2011 on the retention of the data identifying any person who has contributed to the creation of online content).
- Legitimate interest of Experimental Group
Experimental Group may have a legitimate interest authorizing it to collect and process the personal data of Users who visit the Website (e.g., implementation of commercial prospecting operations with its prospects).
In this context, Experimental Group ensures that the processing implemented is necessary for the achievement of its legitimate interest and that it does not infringe the interests and fundamental rights of Users.
- Categories of Personal Data Collected and Processed
Experimental Group may collect, store and process the following categories of personal data:
- identification data (e.g., name, surname, date of birth);
- contact data (e.g., phone number, e-mail address, postal address);
- economic and financial information (e.g., card number, transaction details);
- personal life and lifestyle data;
- Experimental Group may collect information related to the User’s meal preferences, which could indirectly give indications regarding the User’s religious beliefs, ethnic origin or health status and thus qualify as sensitive data under Article 9 of the GDPR. Such data would only be gathered when the User willingly decides to formulate a specific request in this respect;
- data related to professional life (e.g., curriculum vitae);
- location data (e.g., GPS);
- connection data (e.g., IP address, logs).
Experimental Group does not collect any information relating to political opinions, morals, sexual orientation or genetic characteristics.
- Purpose of the Processing
The processing of User’s personal data by Experimental Group is necessary to enable it to accomplish the following purpose.
- Processing for the purpose of online booking
- optimization of the Website for the Users’ browsing;
- creation of a customer account by Users on the Website;
- confirm and process the User’s reservation in one of the Experimental Group establishments;
- process the payment of the reservation in one of the Experimental Group establishments;
- sending confirmation or message prior to the arrival of the User;
- conduct a customer satisfaction survey.
- Processing for the purpose of managing applications
The processing of personal data of the User by Experimental Group is necessary if the User access the job application service :
- receipt of job applications;
- recruitment of a candidate.
- Processing for the purpose of sending the newsletter and marketing communication
- sending Experimental Group newsletter, the User may unsubscribe at any time from any marketing message by clicking on the unsubscribe link at the end of said message;
- measurement statistics and marketing analysis;
- communication with a User who fills in a contact form on the Website;
- constitution of a file of customers and prospects;
- informing Users in the event of changes affecting the services offered via the Website.
- Processing for the purpose of rights management
- prevention and fight against fraud during the payment of the order;
- management of disputes;
- to comply with a legal requirement or in the context of legal proceedings or litigation;
- informing Users in the event of changes affecting the services offered via the Website;
- management of requests to exercise the rights.
- Rights of the Data Subjects
Users have a right of access, modification, opposition, limitation, portability, rectification to define guidelines for the fate of their data after their death and deletion of their personal data, the latter being subject to compliance with the following rules:
- The request is made by the person concerned and is attached to a copy or a current identity document;
- The request must be made in writing to the following address: firstname.lastname@example.org
For the purpose of the right to data portability, the information requested by the User will be provided to him/her in electronic form, unless expressly requested otherwise.
With regard to the right to the deletion of the User's personal data, this will not be applicable in cases where the processing is implemented to meet a legal obligation.
- Data Retention
The User’s personal data in relation to a request for information on the services offered by Experimental Group (e.g., name, surname, email address) are kept for a period of three (3) years from their collection.
The statistical data of audience measurements are not kept for a period longer than thirteen (13) months.
In the event of litigation, all information, documents, and exhibits containing the User’s personal data tending to establish the disputed facts may be kept for the duration of the proceedings, including for a period longer than those indicated above.
Some data may be archived beyond the periods provided for the needs of research, the establishment and prosecution of criminal offenses for the sole purpose of providing the judicial authority with these data as necessary.
Archiving implies that these data are anonymized and can no longer be consulted online but are extracted and stored on an independent and secure support.
- Data Recipient
The User’s personal data collected and processed by Experimental Group are communicated to the following recipients for the sole purpose described above.
- Internal services of Experimental Group
Experimental Group shares Users’ Personal Data with its internal departments, solely for the purpose defined in Article 4 above for which they are authorized.
The members of the internal department who process Users’ personal data are subject to an obligation of confidentiality regarding such data.
- Affiliates of Experimental Group
Experimental Group shares Users’ personal data with its affiliates, strictly for the purpose of:
- Managing reservations, privatization requests and group reservations in each establishment managed by a subsidiary;
- Managing applications for job vacancies in each establishment managed by a subsidiary.
In accordance with European and French legislation on the protection of personal data (European Regulation No. 2016/679 of April 27, 2016, on the protection of personal data, and the French Data Protection Act No. 78-17 of January 6, 1978), the subsidiaries of the Experimental Group process User’s personal data.
- Third party suppliers and service providers
Experimental Group may transfer temporarily and securely to third parties some of the User’s personal data when necessary:
- the operation and maintenance of the Website (e.g., Influence Society);
- partners with whom Experimental Group have contracted to enable the execution of its contacts with Users (e.g., Synxis, Zenchef, OTAs);
- partners with whom Experimental Group have contracted to enable it to manage its customers and prospects (e.g., advertising platforms, Sendethic, Influence Society);
- some regulated professionals such as accountants, auditors or lawyers.
As such, when the third party concerned is located outside the European Union, or in a country that does not have adequate regulation within the meaning of the GDPR, Experimental Group provides a framework for its contractual relationship with third party by implementing an appropriate contractual arrangement.
- Administrative and judicial authorities
Only in cases where such disclosure is required by a legal obligation, Experimental Group will disclose user’s personal data to the administrative or judicial authorities that require it.
Experimental Group also uses web analytics cookies to better understand User behavior. These tools collect information and generate reports on Website usage statistics without Users necessarily being personally identified by the third party providing the cookie (e.g., Google).
In addition to generating reports on Website usage statistics, these audience analysis cookies also make it possible, in combination with certain other advertising cookies (placed by third-party website and/or content when accessed by the User), to display more relevant ads on the Website.
Each User has the possibility of refusing cookies by configuring their Internet browser:
- InternetExplorer™: http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11
- Safari™: http://support.apple.com/kb/PH11952;
- Chrome™: https://support.google.com/chrome/answer/114836? ;
- Firefox™: https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister;
- Opera™: http://help.opera.com/Windows/12.10/fr/notrack.html;
- Edge™: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy.
- Statistical Use of Anonymous Data
As part of its activity, Experimental Group collects, processes and stores statistical data relating to the use of the Website and relating to the activities of Users.
This utilization data which may be transmitted to third parties, is anonymous and does not allow for the identification of Users, even indirectly.