Privacy policy
(Version 1.0, May 2018)
When you write a review about Aube en Champagne or use our Website, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, for what purposes we use it and the rights you have regarding your personal data.
When we use the terms “Aube en Champagne”, “we” and “our”, we mean the Comité Départemental du Tourisme de l’Aube and our affiliated activities. We also use the term “Policy” to refer to this Privacy Policy and “Website” to refer to our applications and all Aube en Champagne websites, such as http://www.aube-champagne.com, http://www.congres-champagne.com, http://www.champagne-breaks.com, http://www.bienvenue-en-champagne.com etc
The Comité Départemental du Tourisme de l’Aube is responsible for processing your personal data.
1 Personal data: what we collect and for what purposes
1.1 Master data
When you create a profile or write a review on the Website, we automatically create a personal account for you (“Account”) and collect the following personal data about you (the “Master Data”):
- Your username (it will be public)
- Your travel situation (Single, couple, family, business friends)
- Your period of stay and consumption of the tourist service (month and year)
- Your e-mail address.
This information is mandatory, which means that it is not possible to write a review on the Website without it.
You can choose to add additional personal data to your profile. The additional data you can add are your name, profile description, photo, gender, city, country and language. This additional information will become part of your public profile and Master Data.
Aube en Champagne Tourisme is a tourism promotion platform and allows the collection of open reviews. When we post your review, we will connect it to your profile so that people can see who wrote the review. So be aware that depending on the information you add to your profile and the username you choose, you may or may not be anonymous.
1.2 Information contained in notices and appraisals
When you write a review about a company and post it on our Website, we also collect the information you include in your review. This includes:
- The company concerned by your notice
- The type of shopping or service experience to which your review relates (see the definition of “Service Experience” in our Terms of Use),
- The title and content of your review
- Your assessment of your service experience with the company (1 to 5 in terms of satisfaction)
- The date of your notice and, if you are updating it, the date on which it was modified
Please do not share sensitive documents or personal information with us, either about yourself or about others.
1.3 Notifications
If you notify us of a notice that you believe violates our Terms of Use, we will collect the information you provide in your notice to us. This includes the notice of which you have informed us, the reason for and date of your notification, etc.
1.4 Cookies
Our website uses cookies. Cookies identify your computer but do not identify you as an individual user. They are used for various purposes.
You can find out more about the cookies used by the Website, as well as the purposes for which they are used below(section 8).
1.5 Your IP address, browser settings and geographical location
When you visit the Website, we record your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to consult the Website. Browser settings may include the type of browser you use, the browser language and the time zone. We collect this information so that we can track the computer used in the event of abuse or illicit action in connection with visits to or use of the Website. We also use IP addresses to establish your approximate geographic location (your city) and to determine which of our Terms and Conditions apply to your use of our Website.
1.6 Newsletters and summary e-mails
We collect the information you provide when you sign up to receive our newsletters, daily e-mails or similar (we collect your first name, last name, e-mail address, country and city and newsletter preferences). If you no longer wish to receive our newsletters, you can unsubscribe by following the unsubscribe link provided in each communication.
1.7 Chat and conversation
We collect information such as IP address, origin, browser type, browsing time and page within the framework of our chat conversations. This information is used exclusively to optimize the response we can provide you with, as well as for statistical purposes.
1.8 What do we use your personal information for?
We will use the information you provide us :
- To provide you with our services, including the display of proposals based on your profile and, more generally, to give you access to our Website.
- To identify you as a registered user when you connect to the Website and when you return to it
- To improve the Website and our services
- To answer your questions and provide you with the associated customer service
- To send you our newsletters
- To enable social sharing functionality, including the ability to connect to members of your network who are users of l’Aube en Champagne and one or more Social Networks.
- For various internal business purposes, including data analysis, auditing, fraud control and prevention, development of new products and services, improvement or modification of the Website or our services, identification of usage trends, determining the effectiveness of our promotional campaigns and the operation and development of our business activities.
- To comply with legal provisions and court proceedings, requests from public authorities, relevant industry standards and our internal policies
- To enforce our General Terms and Conditions
- To protect our operations or those of our affiliates
- To protect our rights, privacy, security or property and/or those of our affiliates, as well as yours or those of third parties
- To enable us to pursue available remedies or limit the damages we suffer
- We will also use information in other ways, in which case we will provide specific information at the time of collection.
1.9 On what legal basis do we process your personal data?
We need to process your personal information in order to :
To implement our contract with you (see Article 6.1.b of the RGPD).
Comply with our legal obligations (see Article 6.1.c of the RGPD) and operate an online review platform in a manner that complies with, for example, the Unfair Commercial Practices Directive, the ICPEN Guidelines on Online Reviews and Endorsements, the Consumer Protection from Unfair Commercial Practices Regulations 2008, the Competition and Markets Authority Guidelines on Online Reviews and Endorsements, the Danish Consumer Ombudsman Guidelines on the publication of user reviews, the French Trade Practices Act, etc.
To pursue our own legitimate business interests related to the operation of the Website and the provision of our services or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override these interests (see Article 6.1.f of the GDPR).
For the establishment, exercise or defence of legal claims, if necessary (see Article 9.2.f of the RGPD).
Some of these reasons for processing your personal data overlap, so there may be several reasons why we process your personal information.
In the limited cases where you have expressly granted your consent for us to process your personal data (see Article 6.1.a of the GDPR), for example, when you subscribe to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may be entitled to continue processing your information if this can be justified under any of the legal bases mentioned above.
You have the right to object to the way we process your personal information, or to ask us to restrict the way we process it. To find out more, please see section 11 below.
If you would like more information about the legal basis on which we process your personal information, please contact our Data Protection Officer – see section 13 below.
2 Disclosure of personal information
2.1 Disclosure of personal information on the Website
We are an open travel information and review platform, and we share your reviews on our Website so that others can learn about your experience with a particular business. When you write a review, we will disclose it along with your username and other information you have chosen to attach to your public profile. Remember that if you have chosen to use your name as a username, this may reveal all or part of your identity, unless you use a pseudonym.
We recommend that you exercise caution when deciding what information to make available for disclosure on the Website. Please note that depending on the level of information provided, you may or may not be anonymous.
Master data and other information
When you write a review on our Website and create an Account, your username, your review, your location and the number of reviews you have written will be visible on the Website. The companies involved in your review may also receive information about your review.
Geolocation
When you post a review on the Website, we use your computer’s IP address (see section 1.7 of this Policy) to approximate your geographic location to the nearest city. This information is made available to other users of the Website.
Social networking
If you connect to a Social Network, information such as your profile photo, name, date of birth and approximate geographic location will be collected from your Social Network profile and used to identify you on the Website. Subject to the privacy settings and level of information available on the Social Network, users of the Website may use this information to identify reviews you have written.
If you have chosen to preserve your anonymity by using a pseudonym for your Aube en Champagne username, you should be aware that your social network information may reveal your identity, in whole or in part, and allow the reviews you have written to be identified.
2.2 Disclosure to other services, websites and companies
One of Aube en Champagne’s main objectives is to increase the visibility and availability of reviews on the Website. We therefore allow other services to show reviews created on the Website. This increases the potential audience for your reviews.
Other similar tourism websites on which Aube en Champagne believes it would be relevant for users to search for reviews (local Tourist Office websites, Comité Régional du Tourisme websites).
Once you have submitted your review, it is published on the Website. This means that the following information is disclosed:
Your opinions (see point 1.2 above)
Your username and any additional data you choose to add to your profile, such as your name, profile description, city, country and language.
If we need to verify your review, we will contact you and ask for documentation to prove that you have had a Service Experience with the company you reviewed. We therefore recommend that you keep these documents for 12 months from the date of your review.
We do not share the documents you send us with third parties, including the company that has been evaluated. However, if you have a reference number or order ID, we may share it with the company, unless you ask us not to.
3 Data controller
3.1 Information for which we are the data controller
We are responsible for processing the Master Data that you enter in connection with the creation and management of your profile, including, but not limited to, your name, your e-mail address and the recording of your IP address.
We are also responsible for data processing in respect of information disclosed on other services (see point 2.3). French data protection legislation governs our collection of your data.
3.2 Information for which you are the data controller
You are responsible for data processing with respect to the content you choose to disclose on the Website, as well as for data disclosed when you link your Social Network profiles to your profile on the Website.
4 Website links
Our website contains links to other websites. Our inclusion of such links does not imply our endorsement of those websites. We have no control over the content of these third-party websites and accept no responsibility for their policies or practices.
We encourage you to consult the privacy policies of these third-party websites as their procedures for collecting and processing your personal data will differ from ours.
5 Subcontractors and transfer of personal information outside the EU
We use external companies to manage the technical operation of the Website and our services. These companies are the subcontractors with respect to the personal data for which we are responsible for processing. By accepting this Policy, you agree that we may also allow the data for which you are responsible to be processed by these subcontractors.
We have data processing agreements with data processors and as such, they must act in accordance with our instructions. By accepting this Policy, you authorize us to give such instructions to processors to process data in accordance with the Policy and for the purposes of using the Website.
Subcontractors have taken reasonable technical and organizational measures to prevent accidental or unlawful destruction, loss or deterioration of data, and to prevent disclosure to unauthorized persons, misappropriation or processing in breach of data protection legislation.
At your request, and potentially in return for payment at the applicable hourly rate to subcontractors at any time for this work, subcontractors must provide you with sufficient information to demonstrate that the aforementioned technical and organizational security measures have been taken.
6 Data retention
We retain the Master Data and other personal data you provide, including your notices, for as long as you have an Account and as long as necessary to provide our services to you. If you choose to delete your Account, please note that all your notices will also be deleted. We will delete this information at your request and will only record a log with the following information: your name, e-mail address and the date your Account was deleted. We will keep the log for 3 years. All other information will be deleted.
If you only use our Website to search for companies, including companies for which reviews have been published, we will retain your information and will not close your account until you decide to close it. In some cases, even if you close your account, we may choose to retain certain information (e.g. visits to our Website) in an anonymized or aggregated form.
7 Safety measures
We implement reasonable organizational, technical and administrative measures to protect your personal information within our company, and we regularly monitor our system for possible breaches. However, as the Internet is not a 100% secure environment, we cannot guarantee the security of any information you transmit to us. E-mails sent via the Website are not encrypted, and we therefore recommend that you do not include any confidential information in the e-mails you send to us.
To find out more about our current security practices and policies, and for further information, please consult our security practices. We are constantly striving to improve our security practices, and will update this information as they evolve.
8 Cookies
The Website uses cookies and similar technologies (“Cookies”). By using our Website, you agree to our use of Cookies as described below.
8.1 What types of cookies do we use?
Cookies are small information files that the Website places on the hard disk of your computer, tablet or smartphone. Note that HTML5 has introduced Web Storage functionality, which is similar in nature to Cookies. We will therefore consider this feature to be a Cookie in what follows.
Cookies contain information that the Website uses to make communication between you and your browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, permanent cookies, and HTML5 sessionStorage and HTML5 localStorage session cookies, as well as HTML5 sessionStorage objects that are temporary in nature and are deleted when you exit your web browser. Permanent cookies are small, durable information files that are stored and remain on your computer until they are deleted. Permanent cookies expire or are deleted after a certain period of time, but they are renewed each time you visit the Website. HTML5 localStorage objects are permanent in nature and remain on your computer until they are deleted.
8.2 Why do we use cookies?
We use Cookies :
To generate statistics
To measure traffic on the Website, in particular the number of visits to the Website, the domain from which visitors come, the pages they consult on the Website and the approximate geographical area in which they are located.
Monitoring website performance and your use of our website
To monitor the performance of the Website, our applications and the way in which you use our Website, applications and functionalities (chat, tourist basket, search around me).
To ensure authentication and improve the functionality of our Website
To optimize your experience on the Website, which involves storing your user name and information about your browser and preferences (e.g. your preferred language).
To connect to Social Networks
We give you the option of connecting to social networks such as Facebook.
Quality control
To ensure the quality of reviews and to prevent any misappropriation or irregularities in connection with the drafting of reviews and the use of the Website.
Targeted advertising
To display targeted advertisements on the Website, including advertisements based on your interests, which we believe may be of interest to you. We use third parties to provide these advertisements when you visit the Website and other websites. These third parties may use Cookies alone or in conjunction with Web beacons or other tracking technologies to collect information about you when you use our Website and other websites.
8.3 Third-party cookies
Third-party Cookies are installed by third-party sites and not by our Website. When you visit our Website, the following third-party Cookies may be installed:
Facebook cookies, set when you connect to our website via Facebook
Google cookies, installed when you connect to our website via Google
Google AdSense cookies, installed when relevant and targeted advertisements are displayed on our Website. Some cookies may be installed as DoubleClick, part of Google
8.4 Deleting cookies
You can delete cookies that are already on your device. Generally speaking, you can delete cookies from the Privacy or History sections of your browser’s Settings or Options menu. In most browsers, the same menu can be accessed using the keyboard shortcut Ctrl+Shift+Delete, or Command+Shift+Delete if you’re on a Mac.
If you do not accept cookies from our Website, you may experience certain difficulties in using the Website and be unable to access some or all of its functions.
9 Access to and information about the personal data we hold about you
If you have an Account with Aube en Champagne as a result of submitting a review, you can log in to your Account in the link in the email message you receive and see what information we hold about you, including your reviews, and why we hold this information.
If you do not have an Account, you can send an e-mail to privacy@Aube-Champagne.com and request information about your personal data. Upon receipt of your request, we will inform you of the nature of the personal information we hold about you, how we collect the information, the purpose for which we process your personal data, and with whom we share your personal information.
10 Rectification and deletion of your personal data
If any Master Data or other personal information we hold about you as data controller is incorrect or misleading, you can rectify most of this information yourself on your Account. We recommend that you make any corrections yourself. Otherwise, we are at your disposal to help you rectify your information.
You may at any time correct or delete content and personal information on the Website for which you are the data controller (see point 3.2). If your personal information changes, or if you no longer wish to appear on the Website, you may update or delete the information by writing to us at privacy@aube-champagne.com
When your Account is deleted, all data associated with your Account is deleted, including your Master Data and notices on the Website.
We reserve the right to block access to your Account and/or delete your Account if it or the content associated with it or your opinions on the Website are, in our opinion, discriminatory, racist, sexual, unethical, threatening, offensive, harassing or otherwise contrary to applicable law, the rights of third parties, the Terms of Use, or are contrary to the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending you an e-mail to the address you provided when you created your Account.
11 Other rights
In addition to the rights indicated above concerning your personal data, you also have the following rights:
You also have the right to object to the processing of your personal data and to have it restricted.
In particular, you have an unconditional right to object to the processing of your personal data for marketing purposes.
If we process your personal data on the basis of your consent, you have the right to withdraw it at any time. Such withdrawal will not affect the lawfulness of the data processing that took place prior to the withdrawal of your consent. You can withdraw your consent by sending us an e-mail to privacy@aube-champagne.com
In some cases, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.
12 Children’s information
Our Website is not intended for children. If you become aware that a child under the age of 13 has provided us with personal information, please contact us.
13 Our data protection officer
We have a data protection officer. If you have any questions about our data processing activities, please contact our data protection officer by e-mail at : privacy@aube-champagne.com
14 Changes to this Policy
We reserve the right to make changes to this Policy. The date at the beginning of this Policy indicates when it was last updated. If we make material changes to this Policy, we will notify you on our Website or by other means, so that you have an opportunity to review the changes before they become effective. If you object to our changes, you may terminate your Account. By continuing to use our Web Site after we post or send notice of changes to the Policy, you accept and agree to the modified Policy.
15 Contact details and where to address your questions or complaints
If you have any questions or concerns about our Policy, how we handle your personal information, or if you would like us to correct your personal information, please contact us at privacy@aube-champagne.com.
You can also send us a letter.
If, after contacting us, your complaint remains unresolved, you have other options. For example, you can always lodge a complaint with a supervisory authority responsible for data protection.
Our contact details:
Aube en Champagne Tourist Board
34 quai Dampierre
10000 Troyes – France
Travel and holiday operator registered under n°IM010110008
VAT identification: FR 68304787922
RC: Assurance GAN / n° AO1006 – 021 222 450 – 25, place Jean Jaurès – 10000 Troyes
Guarantor Banque Populaire Lorraine-Champagne n°111747 – Place de la Libération – 10000 Troyes
You can also find additional resources on data privacy here