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Privacy policy

We attach great importance to safeguarding the personal data entrusted to us by our customers or partner establishments as part of our Services. The purpose of this Privacy Policy is to inform you about our personal data policy, and in particular about the data we collect, how we process it, for what purposes we use it and with whom we share it.

More specifically, this Policy describes how we use your personal data when you use our websites, when you purchase and use the Services provided or offered by COWOLIDAY, or when you interact with us via other channels (contact form, hotline, social networking platforms).

By simply using one of the services provided or offered by COWOLIDAY (hereinafter "the Services"), you confirm that you have read and understood this Privacy Policy in its entirety and that you accept it.

In accordance with current legislation on the protection of personal data, we consider that COWOLIDAY is acting as a Data Controller for certain processing operations and purposes.

Personal data (hereinafter referred to as "Data" or "Personal Data") means "any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity".

Data processing (hereinafter "Processing" or "Data Processing") means "any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction".

Information we collect

We declare that Personal Data has been collected fairly and lawfully, for specified, explicit and legitimate purposes.

  • Collection of Personal Data from consumer customers

As part of the reservations made by the customers, via the Secureholiday Reservation Interface that we use, we collect Personal Data from them at the time of their reservation and then transmit them to the Establishment (via its PMS management software if a PMS gateway is installed) via a technical means that it -the Establishment- determines and for which it is responsible, in particular with regard to the safety and security of the Personal Data. We then host these Personal Data in the database of the Secureholiday system of SAS CTOUTVERT. The Data collected are the first and last names of customers, their dates of birth, their addresses (street, postcode, town, country), their telephone numbers, their email addresses, the place and dates of their bookings.

As part of the contact form filled in by customers via the cowoliday.com website, we collect the Personal Data provided. We then send these Personal Data by email to contact@cowoliday.com, which we then host in the COWOLIDAY system database. The Data collected are the first and last names of the customers, the name of their companies, their telephone numbers and their email addresses.

Within the framework of the form allowing to join the network, filled in by the establishments wishing to become partners, via the cowoliday.com website, we collect the Personal Data filled in. We then send these Personal Data by email to contact@cowoliday.com, which we then host in the COWOLIDAY system database. The Data collected are the name of their establishments, their addresses, the first and last names of their managers, their telephone numbers and their email addresses.

Within the framework of the registration to the newsletters, filled in by the customers, via cowoliday.com website, or any other digital or paper support, we collect their email addresses which we then host in the COWOLIDAY system database.

As part of the "Cowoliday" application provided to customers, they will fill in their coworker profiles in which they will enter their email addresses, their choice of language, their professions, the name of their companies and also, afterwards, their consumer opinions. Customers will be able to choose whether or not to include a photo in their coworker profiles. We then integrate this Personal Data into the COWOLIDAY system database.

  • Collection of Personal Data from partner establishments

Within the framework of partnerships with Establishments, we collect Personal Data from the Establishments, mainly at the time of contracting the business relationship. The Data collected includes the name of their Establishments, their addresses, their company names, their telephone numbers, the addresses of their websites, their intra-Community VAT numbers, their email addresses, as well as the first and last names of the managers of their Establishments or of the signatories.

How we use the information we collect

  • Processing of Personal Data of consumer customers

We Process Personal Data for the sole purpose of providing the Services to the Establishment and in particular for the following purposes:

  • Processing of customer reservations and management of the Coworking Service
  • Subsequent commercial communication for similar products or services
  • Statistical studies
  • Profiling purposes

In this respect, Personal Data may not be the subject of any operation other than those provided for in these provisions.

  • Processing of Personal Data of partner Establishments

We Process Personal Data for needs relating to the performance of the partnership between the parties and to legal requirements, in particular for the following purposes:

  • Processing Service Orders placed by customers
  • To meet the legal requirements arising from the law of 21 June 2004 in terms of the retention of Publishers' data.

We may also use the information detailed above, including any Data relating to consumer customers and any Data relating to partner Establishments, for the following purposes:

  • To comply with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanctions screening). This may include checking the information provided to us against Data from other sources.
  • Enforce any contract between you and us relating to our partnership
  • Notify all of our partners of changes to our Services or to our terms and policies
  • Improve the experience and quality of service

Information we share

We may share Personal Data with service providers that we use for the Services for essentially technical purposes, including the host of our servers (Microsoft Azure). When service providers are involved in the Services provided or offered by COWOLIDAY, all measures are taken to ensure a high level of security for the protection of Personal Data and all Processing is carried out in accordance with our instructions. They may not, under any circumstances, make any other use of the Personal Data transmitted to them than that expressly required, nor disclose to any other third party the Personal Data concerning COWOLIDAY's partner Establishments or consumer clients booking via Secureholiday. In particular, technical service providers are not authorized to use your data for commercial prospecting on their behalf.

In any case, the only other occasions on which Personal Data may be transmitted to a third party are the following:

  • We have obtained your prior consent to do so
  • The information is processed via a trusted commercial partner in compliance with the Confidentiality Charter, respect for privacy and security levels, on the basis of the contract concluded between the said commercial partner and the Establishment.
  • We use third-party service providers for technical subcontracting purposes
  • We have aggregated data, which does not personally identify data subjects, to be used for segmentation, statistical modelling, general studies or trend analysis purposes
  • We have a duty to disclose or communicate Personal Data in order to comply with our legal obligations, to enforce our terms of sale and other agreements, and to protect our rights, property or safety, that of our customers or others. This includes exchanging information with other companies or organisations in order to prevent fraud and reduce credit risk.

Retention of Personal Information

We retain Personal Data for as long as is necessary to pursue and achieve the above purposes in the manner indicated and to comply with our legal obligations.

Accuracy of information

We endeavour to ensure that Personal Information held is accurate, current and complete. We will respond to customer requests to rectify inaccurate information in a timely manner. Consequently, any person about whom we hold Personal Data has the opportunity to let us know.

Security

We have put in place a number of technical and organisational measures to ensure the security and protection of the Personal Data we process. However, if Personal Data is transmitted to us via an Internet-enabled means of communication, we cannot guarantee that such data is completely secure.

Transfers outside the EEA

The Personal Data we process is hosted exclusively in the European Union and we do not transfer any Personal Data outside the European Union.

Your rights and preferences

At any time and in accordance with current legislation on the protection of personal data, you have the right to access, rectify and delete your data, as well as the possibility of objecting to the processing of your data, by sending a request by post to the following address: COWOLIDAY 10 Place Alfonse Jourdain 31000 Toulouse (France) Email address: cnil@cowoliday.com

You also have the possibility of lodging a complaint at any time with the competent supervisory authority, i.e. the CNIL.

You are reminded that if you exercise any of these rights, we may no longer be able to provide you with all or part of the Services.

Updates

This Personal Data Protection Policy may be modified without prior notice. In order to keep you informed of any changes, we invite you to consult our Policy regularly.

Last updated: 09/03/2023