Privacy Policy

Last update : 01/07/2021

1. Preamble

Ubaye Tourisme attaches great importance to the protection and respect of your privacy and your personal data (hereafter "Personal Data" or "Personal Information").

Ubaye Tourisme is committed to implementing adequate measures for the protection, confidentiality and security of Personal Data in accordance with the regulations in effect in France and in the European Union, in particular the General Regulation on the Protection of Personal Data EU 2016/679 of 27 April 2016 and the rules of national law taken for its application.

The purpose of this "Privacy Policy" (hereinafter the "Policy") is to inform all natural persons concerned (hereinafter referred to as "You" or "Your") about the manner in which Ubaye Tourisme collects, uses and discloses Personal Data and about the means available to You to exercise your rights with regard to this information.

Consequently, Ubaye Tourisme invites you to read this Policy carefully in order to know and understand the processing of Personal Data.

In any event, we are committed to the following two (2) key principles:

the individual remains in control of his or her personal data
the data is handled in a transparent, confidential and secure manner

2. Identity of the data controller

2.1. Ubaye Tourisme as the data controller

Ubaye Tourisme, a registered association, with the SIREN number 823038344, whose registered office is located at OFFICE DE TOURISME - UBAYE TOURISME CHALET DE LA MONTAGNE, 04400, ENCHASTRAYES, will have the status of data controller for the processing related to a certain number of services provided via the website "praloup.com" (hereafter the "Website"). The treatments concerned are :

1. Cookies management
2. Management of information requests via the contact form
3. Management of subscriptions to newsletters and their sending
4. Newsletter unsubscribe management

2.2. Ubaye Tourisme as joint controller

Ubaye Tourisme will have the status of joint data controller with its professional partners for the processing relating to :

5. contact with service providers
6. contact with accommodations
7. online ticketing

3. Dedicated data protection contact

We have appointed a Data Protection Officer to deal with all your requests, including the exercise of your rights, relating to the processing of your personal data.

You can reach him :

○ By e-mail at the following address: dpo@ubaye.com
○ By mail: Ubaye Tourisme, ATTN DPO, Place Frédéric Mistral, 04400 Barcelonnette

4. Collection & origin of data

Through the website, Ubaye Tourisme and its partners process personal data about you. We consider that this data comes directly from you. In all cases, you are informed of the purposes for which your data is collected by us via the various online data collection forms or via our Cookies Policy.

Your personal data collected by Ubaye Tourisme is processed in accordance with the purposes for which it was collected, in compliance with the RGPD and the guidelines of the CNIL.

5. Purposes and legal bases of the processing

Below you will find details of the processing of your information, especially when you request information from our organization.

5.1. Cookie processing details

We use tools developed by third parties, including Google and Facebook, to improve the experience on our site, including measuring audience size and targeting ads. In this context, Google and Facebook may collect data about you via cookies. The "Cookie Policy" section of our site allows you to define, according to your preferences, the use of cookies.

5.1.1. Legal basis

The processing of data via cookies is based on your consent.

5.2. Details of the processing of requests received via the contact form

When you transmit your personal data to Ubaye Tourisme via the contact form, they will be processed for the following purposes :

○ Receive your requests
○ Put you in touch with the department concerned, and if necessary make contact by telephone
○ Respond to requests received electronically
○ Establish statistics

5.2.1. Legal basis

This processing is necessary to provide you with answers adapted to your request and thus the legitimate interest remains the legal basis of this processing.

5.3. Details of the processing of newsletter subscriptions and their dispatch

The execution of operations related to this processing covers the following objectives:

○ Maintenance of the mailing lists concerning the newsletters of Ubaye Tourisme and the good deals of Pra Loup
○ Sending newsletters
○ Establish statistics

5.3.1. Legal basis

This data processing is based on your consent, which is obtained with the checkboxes integrated below the web site form for registration.

5.4. Details of the processing of unsubscriptions from the Newsletter
This processing is set up in order to :

○ remove your email address from newsletters sent from the date of unsubscription
○ ensure that your unsubscription is respected

5.4.1. Legal basis

This data processing is based on the legitimate interest of Ubaye Tourisme in respecting your choice.

5.5. Details of the processing of the connection with the providers

Ubaye Tourisme has set up a process whose sole purpose is to transfer your personal data to a service provider of your choice so that the latter can contact you to respond to your request.

5.5.1. Legal basis

This data processing is based on the legitimate interest of Ubaye Tourisme in respecting your choice.

5.6. Details of the treatment of connection with the accomodation providers

Ubaye Tourisme has also set up a processing system whose sole purpose is to transfer your personal data to the accommodations of your choice so that they can contact you to answer your request. Moreover, we have the possibility to communicate your request to rental agencies in order to facilitate your search.

5.6.1. Legal basis

The transfer of your request to accommodations of your choice is based on the legitimate interest of Ubaye Tourisme. When you want your request to be transferred to rental agencies, this sharing will only be done with your explicit consent.

5.7. Details of online ticketing processing

When you submit your personal data to us in connection with this activity, it will be processed to accomplish the purposes of:

○ Registering you and confirming reservations
○ Set up the online payment
○ Transmit the reservation to the relevant service provider.

5.7.1. Legal basis

This treatment is necessary for the execution of the pre-contractual and contractual measures established for the confirmation of your reservation.

6. Processed data

The compulsory or optional nature of the personal data collected and the possible consequences of a failure to reply are indicated at the time of their collection on the associated forms.

You can consult the details of the personal data that we are likely to have on you below.

NB: the details of the information provided below are not intended to be exhaustive and aim above all to inform you about the categories of data that Ubaye Tourisme is likely to process.

6.1. For the management of cookies :

○ Informations électroniques (ex: adresses IP, MAC, historique des pages visitées etc,.)

6.2. For the management of requests received via the contact form :

○ Data relating to your identity: Civility, Birth name, Use name or spouse's name, First name,
○ Data relating to your professional activity: e-mail address
○ Information transmitted by the application

6.3. For the management of newsletter subscriptions and their sending :

○ Information about your identity: birth name, married name, first name, personal e-mail, postal code, country
○ Consent information that you provide to us using checkboxes
○ History of newsletters you have received following registration

6.4. For the management of the unsubscriptions of the Newsletter:

○ Your email address
○ Unsubscribe information, including the date you unsubscribed

6.5. To put you in touch with service providers

○ Identity data: Title, First name, Last name, Email, Phone number, Mobile number
○ Application - optional
○ Information about the provider you are applying to
○ Information regarding your desire to receive a copy of your request

6.6. For the connection with the providers

○ Data related to your identity: Title, First name, Last name, Email, Phone number, Mobile number
○ Start and end dates of the desired stay
○ Request - optional
○ Information about the accommodations you are applying to
○ Information regarding your desire to receive a copy of your application
○ Your acceptance or non-acceptance of sharing the request with rental agencies

6.7. For contact with providers

○ By default, the last name, first name, email address and phone number,
○ According to the needs of the event: the company, the date of birth, the postal address, a photo identifying the person,
○ For traceability purposes, the purchase IP address is also kept,
○ The payment reference from the bank payment provider

7. Recipients of your data

Within the limits of their respective attributions and for the purposes recalled in article 5, the main persons who will be likely to have access to your data are the following:

○ according to the purposes pursued, the authorized personnel of our internal services, in particular our reception desks, and in charge of partnerships with service providers and accommodations;
○according to the request, the service providers and the organizations managing the accommodations of your choice

Certain categories of subcontractors have access to the data collected :
○ The website development provider.
○ The website host.
○ The provider of the online ticketing solution.

For any additional information on our subcontractors, you can send a request for additional information to our Data Protection Officer by email at dpo@ubaye.com.

Other organizations that may have access to your data are:

○ If applicable, relevant courts, mediators, certified public accountants, auditors, lawyers, bailiffs, debt collection companies ;
○hird parties likely to deposit cookies on your terminals (computers, tablets, cell phones...) when you consent to it (For more details, see our Cookie Policy) ;

Your personal data is not communicated, exchanged, sold or rented without your prior express consent in accordance with applicable legal and regulatory provisions.

8. Transfer of data outside the European Union

In some cases, your personal information will be stored on servers located outside the EEA.

This is particularly the case when we transfer information to some of our partners, including via cookies to Facebook and Google, which may store it on servers in the United States. We have ensured that standard contractual clauses approved by the European Union Commission are in place to contractualize the security obligations and measures provided for in the GDPR, as set out in its Article 46.

You may request access to the documents ensuring the presence of appropriate safeguards by making a request to our Data Protection Officer by email at dpo@ubaye.com.

9. Data conservation period

We only keep your data for the time necessary for the purposes described in article 5 of the present policy, and if necessary increased by the duration of legal requirements. Nevertheless, personal information is not kept by Ubaye Tourisme in any case, when it concerns requests that you send to a partner or an accommodation of your choice.

9.1. For cookies management

When you visit our website https://www.praloup.com, the cookie managing your consent is stored for a maximum of 6 months. For more information, please consult article 10 and our Cookie Policy.

9.2. For the management of requests received via the contact form

The data used within the framework of the management of the requests for information are preserved until 2 years as from the last contact.

9.3. For the management of subscriptions to the Newsletter and their sending

The information collected in the context of this processing is kept until you unsubscribe from our newsletters, either by using our unsubscribe form or after your objection to our Data Protection Officer.

9.4. For the management of unsubscriptions from the Newsletter

The information collected in the context of this processing is kept for up to 3 years after the date of unsubscription.

9.5. To put you in touch with service providers

No personal data is kept by Ubaye Tourisme. Please contact the service provider directly or ask our Data Protection Officer for help in obtaining this information.

9.6. To put you in touch with the accommodations

No personal data is kept by Ubaye Tourisme. Please contact the service provider directly or ask our Data Protection Officer for help in obtaining this information.

9.7. For online ticketing

The personal data used in the management of reservations via the online ticketing service are kept for up to 2 years from the end of the event.

10. Individuals Rights

In accordance with the Data Protection Act and the RGPD, you have the following rights:

10.1. Right to information on the processing of Personal Data

Ubaye Tourisme undertakes to make every effort to provide concise, transparent and accessible information on the conditions under which your Personal Data is processed.

10.2. Right of access to Personal Data

You can access your Personal Data being processed by Ubaye Tourisme and have the right to receive a copy in electronic form (for any additional copy, Ubaye Tourisme will be entitled to demand payment of a fee based on the administrative costs incurred).

10.3. Right to erasure and rectification of Personal Data

You have the right to ask for the deletion and/or rectification of Personal Data when these are erroneous or obsolete.

It is specified that Ubaye Tourisme may retain certain Personal Data when required by law or for legitimate reasons. It is possible that if your Personal Data is deleted following your request and before the expiration of the valid retention period, this could prevent us from providing you with the services you expect from us.

10.4. Right of objection

You may object at any time, for legitimate reasons, to the re-use of your Personal Data for processing other than those notified, except in the case of the execution by Ubaye Tourisme of one of its legal obligations.

10.5. Right to limit the processing of Personal Data

You have the right to request that the processing of your Personal Data be limited to what is necessary. This right is applicable only:

○ if you dispute the accuracy of your Personal Data ;
○ if you can establish that the processing of your Personal Data is unlawful and request a limitation of its use rather than erasure ;
○ if Ubaye Tourisme no longer needs your Personal Data but it is still necessary for you to establish, exercise or defend legal rights;
○ if you object to processing based on a legitimate interest that we pursue as a Data Controller, having confirmed that the legitimate interests pursued by us prevail over yours.

10.6. Right to complain to a supervisory authority

If you believe that the efforts made by Ubaye Tourisme to preserve the confidentiality of Personal Data do not guarantee the respect of your rights, you have the possibility of lodging a complaint with the competent control authority (CNIL or any other authority mentioned on the list available from the European Commission).

You can exercise all your rights mentioned above by e-mail by contacting our data protection officer at his e-mail address dpo@ubaye.com.

11. Connection data and cookies

Ubaye Tourisme has set up a cookie manager via the Cookies Policy in order to inform you more specifically about their use.

If the browser allows it, you can also deactivate these cookies at any time, by following the procedure indicated by the browser. However, Ubaye Tourisme informs you that such deactivation may result in slowing down and/or disrupting access to certain sections of the website.

12. Minors

The Ubaye Tourisme website is not intended for minors. Ubaye Tourisme does not voluntarily collect personal data from minors under the age of 15.

13. Security

Ubaye Tourisme respects the RGPD and the French Data Protection Act in terms of the security and confidentiality of your data.

We implement all the technical and organizational measures necessary to ensure the security of our personal data processing and the confidentiality of the data we collect.

In this respect, we take all the necessary precautions, with regard to the nature of the data and the risks presented by the processing, to preserve its security and, in particular, to prevent the data from being deformed, damaged or accessed by unauthorized third parties (physical protection of the premises, secure https protocol, logging and traceability of the connections to the software deployed in-house).

14. Modification of the Policy

Ubaye Tourisme reserves the right to modify this policy at any time in order to comply with legislative and regulatory changes and/or to improve it.

In case of modification, a new version will be updated and put online with the date of "Last update".

15. Applicable law

This Policy is subject to French law, including the provisions applicable to the rules of private international law.