Privacy Policy Protection of Personal Data
This Personal Data Policy is established by the company UN HUIT HOTELS, acting as data controller.
The "TO COMPLETE” Site is published by SRL UN HUIT HOTELS Limited Company, whose registered office is located at Rue du Béguinage 38 1000 Bruxelles, registered with the “Banque Carrefour des Entreprises” under number BE: 0440.041.587, VAT BE 0440.041.587, owner of the Site, https://www.maisonarya.com/ E-mail address: TO COMPLETE (Telephone: +32 (0) TO COMPLETE). If you have any questions about the management and use of your personal data, you can contact UN HUIT HOTELS by e-mail at the above address or obtain further information on the website of the Belgian Data Protection Authority: www.autoriteprotectiondonnees.be.
UN HUIT HOTELS undertakes at all times and in all circumstances to respect the following principles: (i) the User is and remains the owner of his/her personal data and (ii) the User's data is processed in a transparent, secure and confidential manner.
This Personal Data Policy supplements the general terms and conditions of sale and services offered by UN HUIT HOTELS and applies to all personal information and browsing data collected and processed during contacts between UN HUIT HOTELS and Users on the Website and via mobile applications offered elsewhere by UN HUIT HOTELS.
1 - UN HUIT HOTELS'S COMMITMENTS
UN HUIT HOTELS's Personal Data Policy complies with the following principles:
Collection and use: the collection of personal data depends on the expression of the User's explicit and prior consent for a clearly defined use.
Consent: With the explicit consent of the User according to the purpose, UN HUIT HOTELS will offer the User information, offers and services corresponding to his/her declared interests and projects or that UN HUIT HOTELS will have deduced from the analysis of personal data collected with the explicit consent of the User.
Web browsing cookie: With the explicit consent of the User depending on the purpose (except where necessary for IT security reasons), web browsing data and the IP address are stored. UN HUIT HOTELS gives the User all the means to accept or refuse the conservation of his/her IP address or the installation of cookies and other tracers on his/her terminal.
Storage: the site is hosted in Belgium.
Retention period: personal data will only be kept for as long as is necessary for the purposes of processing or providing the specified service.
Sharing and transfer to third parties: UN HUIT HOTELS may share certain information with other companies in order to improve the quality of its services or to offer Users a more personalized experience.
Personal data may be communicated to external partners for the purposes set out in article 4. Any communication by external partners must be subject to the explicit and informed consent of the User.
UN HUIT HOTELS will only send commercial solicitations after having obtained the explicit and informed consent of the User or after having already sold him a similar service.
Rights management: The User will have the necessary means to access, rectify, update and delete his/her personal data. Users may withdraw their consent, restrict the processing of their data and object to the processing of their data. The User has the right to the portability of the data provided and the right to define the fate of his/her data after his/her death.
Security: UN HUIT HOTELS will ensure the protection of all Users' personal data.
Notification: The User will be informed as quickly and accurately as possible in the event of a breach of their personal data.
In Belgium, personal data is protected in particular by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, (RGPD) as well as by the Act of 30 July 2018 on the protection of individuals with regard to the processing of personal data, transposing the aforementioned European Regulation. When using the Site, such data may be collected (in particular, the URL of the links through which the user accessed the Site, the user's access provider, the user's Internet Protocol (IP) address, etc.).
In any event, UN HUIT HOTELS only collects personal information from the User for the purposes of certain services offered by the Site. The User therefore provides such information with full knowledge of the facts and is invited to read the present personal data protection policy, which provides him with the information required to enable him to express his consent with full knowledge of the facts.
2 - DEFINITIONS
Mobile Application: refers to mobile applications accessible from a terminal and to which the User has access in order to use the Services offered by UN HUIT HOTELS.
Personal Data: refers to any data of a personal nature, any information relating to a natural person who is identified or who can be identified, directly or indirectly, by reference to an identification number or to one or more elements that are specific to him, and entrusted by the User to UN HUIT HOTELS. To determine whether a person is identifiable, it is necessary to consider all the means to which the data controller or any other person may have access.
User: refers to the natural person or legal entity who may (i) reserve the Services offered by UN HUIT HOTELS on a private or professional basis and who may be, depending on the nature of the Service offered, an Internet user, a client, a subscriber, (ii) either offer Services on a professional basis, (iii) or be requested by UN HUIT HOTELS or its Partners to provide Services, or (iv) or purchase one or more UN HUIT HOTELS Services identified or selected on the Site.
Partners: refers to any person not employed by UN HUIT HOTELS and with whom UN HUIT HOTELS maintains commercial relations with a view to offering Users Services and/or managing and/or optimizing said Services.
Payment Service Provider or PSP: refers to the entity with banking authorization entitled to provide payment services.
Site: refers to the website to which the User has access in order to use the Services offered by UN HUIT HOTELS with a view to acquiring its Services.
E-commerce site: refers to the website to which the User has access in order to use the Services offered by UN HUIT HOTELS and in particular to obtain services from UN HUIT HOTELS.
Services: refers to all services offered by UN HUIT HOTELS to Users via its Site and in particular the sale of catering and event services via the Site.
Terminal: refers to all electronic devices that enable data to be exchanged and processed (touch tablets, mobile phones, computers, etc.).
3 - LEGAL BASES
Depending on the purposes set out under this heading, UN HUIT HOTELS processes the User's data according to different legal bases.
3.1 Obtaining consent
UN HUIT HOTELS only collects Personal Data from the User after having obtained his/her consent, i.e. the expression of free, specific, informed and unambiguous will, and for a specific, precise use which is strictly necessary for the purpose pursued.
To ensure that the User is aware of and unreservedly accepts this Personal Data Protection Policy, established by UN HUIT HOTELS, the User gives his/her consent in several ways:
by transmitting his/her Personal Data orally to an UN HUIT HOTELS employee during a commercial relationship for the provision of services, a telephone reservation or any other relationship covered by general conditions;
by communicating Personal Data in writing in digital correspondence or on a contact form;
on acceptance of the general terms and conditions applicable to the services concerned;
by ticking a box or using forms;
when accepting web browsing cookies (for further information, UN HUIT HOTELS invites the User to visit the "Cookies" section).
3.2 Managing and monitoring reservations and invoices
For processing relating to the management of bookings, the monitoring of event projects on the Site and the preparation of invoices, the legal basis is contractual in that the processing is necessary for the performance of a contract or pre-contractual measures.
3.3 - Maintaining the proper functioning and improving the Site and its functionalities
Processing for the purpose of ensuring the proper functioning and ongoing improvement of the Site and its functionalities is based on the legitimate interest of UN HUIT HOTELS in guaranteeing the best level of functioning and quality of its Site thanks in particular to visit statistics as well as on the consent of the User when required.
4 - INFORMATION GATHERED AND PURPOSES
4.1 - Management of the commercial relationship in the context of orders placed on the UN HUIT HOTELS Site
For this purpose, UN HUIT HOTELS processes the User's data on the basis of the performance of the sales contract, so that the processing of such data is necessary for the performance of said contract as well as for that of pre-contractual measures.
4.2 Purchase of UN HUIT HOTELS Services by the User
The User communicates certain information to UN HUIT HOTELS when making purchases on a private or professional basis. This information concerns :
Identification details: title, surname, first name, email address, landline or mobile telephone number, home postal address, customer number;
personal data relating to its domicile or registered office for invoicing purposes, etc.
personal data concerning some of its banking data: the number of the payment card used, the expiry date, the cryptogram, the R.I.B., it being specified that UN HUIT HOTELS does not store these data.
for a legal entity, Personal Data relating to its professional life, its sector of professional activity, sector of activity, VAT number and intra-Community VAT number;
information of an economic and financial nature: the number of the bank card used, the expiry date, the cryptogram, the R.I.B.
This Personal Data is collected for the following sub-purposes: the creation and management of Customer bookings, web assistance, the management of services offered in the Mobile Applications and the sending of push notifications (alert messages).
These sub-finalities also concern the guarantee of technical monitoring and, where applicable, the establishment of contact between the User and UN HUIT HOTELS and its Partners, as part of the fight against fraud involving means of payment and in particular bank card fraud.
In the case of a subscription taken out by the User, this data is intended to meet the following sub-purposes:
answer any questions asked by the User via the "Contact us" tab;
make direct debits in settlement of a contract ;
to improve and optimize the services provided to the User by UN HUIT HOTELS ;
obtain payment of any sum owed by the User to UN HUIT HOTELS.
4.3.- The User may receive a refund from UN HUIT HOTELS
The User may also be required to provide UN HUIT HOTELS with certain information when using the UN HUIT HOTELS service for a refund:
Identification data: title, surname, first name, email address, fixed or mobile telephone number, home postal address, customer number;
economic and financial information: IBAN number, full bank details and proof of purchase reimbursement.
Personal Data is collected for the following purposes:
reimbursement of the User following cancellation of a Reservation;
payment following the signing of a memorandum of understanding in connection with a dispute on the Site;
4.4 - Communication of personalized Offers
This is based on UN HUIT HOTELS's legitimate interest in offering its Services and on the User's consent to receive personalized commercial offers from UN HUIT HOTELS.
UN HUIT HOTELS may collect the following data:
Data required for loyalty-building, canvassing, research, surveys, product testing and promotional activities;
Data relating to the User's browsing on the Site via Cookies.
This data is collected for the following purposes:
sending newsletters, text messages and other alerts to Users who have requested them,
adapting advertising messages and content to Users' interests.
4.5 - Managing the proper running of the Site
It is based on UN HUIT HOTELS's legitimate interest in guaranteeing the best level of operation and quality of the Site, in particular through the management of visit statistics, and on the User's consent when required.
Depending on the Terminal used by the User and the Services used by the User through his/her Terminal, UN HUIT HOTELS may collect different types of technical information:
Technical Personal Data: IP address, internet connection, browser type, terminal identifiers, connection identifiers, and information relating to the User's browsing path in the software they use;
Personal Data collected using Cookies (for further information, UN HUIT HOTELS invites the User to visit the COOKIES section).
This Personal Data is collected for the following purposes: the operation and optimization of the Site and/or Mobile Applications and for web support.
5.- PERSONALISED OFFERS
UN HUIT HOTELS wishes to offer a User’ experience geared towards their satisfaction and fully adapted to their needs and expectations. UN HUIT HOTELS wishes to get to know each User better in order to be able to meet or even anticipate their needs.
5.1 - Personalized Offers proposed by UN HUIT HOTELS
In order to improve the quality of its Services and to propose personalized offers to each User, UN HUIT HOTELS may analyze all the Personal Data collected directly from the User and may send him/her relevant commercial solicitations taking into account the evolution of his/her needs.
UN HUIT HOTELS will only send commercial solicitations after having obtained the explicit and informed consent of the User for this purpose.
Users are free to withdraw their consent at any time.
5.2.- Personalization of online advertising for the benefit of third-party advertisers with a view to extending the audience
UN HUIT HOTELS may use the User's data to personalize the advertising displayed on its Site or, where applicable, on external sites, such as social networks, on behalf of third-party advertisers. However, no personal data is transmitted to the advertisers concerned.
To this end, UN HUIT HOTELS relies on its legitimate interest in improving its knowledge of Users in order to establish a personalized profile and target advertisements more effectively by combining browsing data and data provided during interactions between the User and UN HUIT HOTELS.
The User may object to this data processing by writing to the e-mail address: TO BE COMPLETED
UN HUIT HOTELS also relies on the consent expressed by the User via advertising Cookies to trigger the display of targeted advertising according to the profile of the User, who will also have expressed certain preferences. Users may withdraw their consent to Cookies at any time using the consent management module.
6.- RETENTION PERIOD FOR PERSONAL DATA
Use of Personal Data
Associated shelf life
For :
Access to the Site
Reservation(s)
Management of personalized communications of goods and services requiring specific consent
5 years maximum from the last commercial or contractual contact with the User.
Invoices and accounting data are kept for 10 years.
Payment for Services
The User's payment details are deleted once the transaction has been completed and then archived/stored for a period of 13 months after the transaction date.
For payments made by bank card, such data may be stored in temporary files for thirteen (13) months (or fifteen (15) months if the payment is deferred) from the date on which the debit is made, to be used as evidence if the transaction is disputed.
In all cases, the visual cryptogram is not affected by this storage, and the bank details are deleted on expiry of the date indicated above.
During the User's browsing on the Site (other than connection information, pages viewed and IP addresses)
25 months maximum from the last navigation.
When the User uses dedicated applications and platforms (other than connection information, pages viewed and IP addresses)
5 years maximum from the last commercial contact with the User.
When the User exercises his/her right to object
5 years maximum from the date of exercising the right to object.
When the User makes a request to exercise a right (other than the right to object)
Maximum 5 years from exercise of rights
7 - DATA RELATING TO THE USE OF BANK CARDS
To ensure the security of transactions, UN HUIT HOTELS uses several "Payment Partners".
When paying in shop, the User inserts his bank card on a payment terminal, operated and maintained by one of UN HUIT HOTELS's Payment Partners. The bank card data is encrypted directly on the Payment Partners' Terminal and then transmitted in unintelligible form to the Payment Partner, who alone is capable of decrypting it.
In order to pay for an Order by bank card, the Customer is hereby informed that he/she must provide a certain number of bank details, such as the name of the cardholder, the card number and, depending on the type of card, the expiry date and the cryptogram number. All bank details entered are subject to secure processing and are immediately encrypted: they are automatically encrypted and sent in secure mode to the secure payment server of the banking organizations concerned, without passing through UN HUIT HOTELS. The Client is, in particular, invited to ensure that the payment is secure.
These processes ensure that no banking data is entered or stored on UN HUIT HOTELS's information systems. In addition, as the exchange flows are based on the HTTPS protocol (encryption sub-layer on the HyperText Transfer Protocol), all bank data is transmitted in encrypted format over the Internet or mobile telecommunications networks.
8.- COOKIES
UN HUIT HOTELS makes use on its Site of connection data (date, time, Internet address, protocol of the visitor's computer, page consulted) and of Cookies (small files recorded on the User's computer) enabling the User to be identified, to memorize his consultations, and to benefit from measurements and statistics of the Site's audience, in particular relating to the pages consulted.
By browsing the Site, the User accepts that UN HUIT HOTELS installs this type of so-called "technical" Cookies, the sole purpose of which is to enable or facilitate electronic communication between the User's terminal equipment and the Site, by facilitating management and browsing thereof.
All other purposes for which Cookies are used are subject to the User's express consent, i.e. the following purposes:
audience measurement and statistics;
personalization of content and services;
advertising tailored to Users' interests;
For further information, UN HUIT HOTELS invites the User to visit the "COOKIES" section.
If the browser allows, the User may deactivate these Cookies at any time by following the procedure indicated by the browser. However, UN HUIT HOTELS informs the User that such deactivation may result in slowing down and/or disrupting access to the Site.
To find out more about Cookies (how to manage them, delete them, identify them), Users can consult the PLATFORM of the French Data Protection Authority: www.autoriteprotectiondonnees.be.
8.1 - Measuring audiences and the performance of advertising campaigns on Facebook or Instagram
UN HUIT HOTELS uses the social networking platform Facebook or Instagram as a medium for some of its advertising campaigns. In order to measure the audiences and interactions on its website as well as the relevance of these advertising campaigns, UN HUIT HOTELS uses the measurement service offered by Facebook, the Facebook Pixel and Instagram.
For the purposes of running this service, UN HUIT HOTELS defines the interactions that this service can measure (visits to a page, for example) and is therefore jointly responsible for processing this service with Facebook Ireland Limited (5/7, Hanover Quay - Grand Canal Dock - Dublin 2 - Ireland), which collects the data and implements the resources required to monitor the interactions and audiences generated on the https://UN HUIT HOTELSbrussels.wixsite.com/UN HUIT HOTELSweb/fr website, following the various advertising campaigns broadcast on the Facebook group's network platform or Instagram page.
The conditions of use of the data by Meta Platforms, Inc, as well as all the information relating to the processing carried out by Meta Platforms, Inc (legal basis, means of exercising the rights of individuals, etc.) are available at the following address: www.facebook.com/about/privacy
The conditions for the use of data by Instagram, as well as all information relating to the processing carried out by Facebook Ireland (legal basis, means of exercising individual rights, etc.) are available at the following address: https://privacycenter.instagram.com/policy
Under the terms of the Joint Responsibility Agreement, it is agreed that Meta Platforms, Incis responsible for activating the rights of data subjects under Articles 15 to 20 of the GDPR with respect to personal data stored by Meta Platforms, Inc as a result of the joint processing.
You can send your requests to exercise your aforementioned rights to Facebook using the request form available at the following address:
https://www.facebook.com/help/contact/540977946302970
8.2 - Other services
8.2.1 - Geolocation (for mobile applications)
This function enables UN HUIT HOTELS to indicate to the User from his Mobile Terminal the useful route for a delivery, or to send personalized information and commercial offers. The User may choose not to authorize geolocation by refusing it when downloading or using the Mobile Application for the first time.
8.2.2.- Facebook, Twitter, Pinterest, Instagram
UN HUIT HOTELS is the publisher of information pages and the UN HUIT HOTELS account on the following social networks and in particular: Facebook, Twitter, Pinterest, Instagram.
If the User wishes to oppose the collection by UN HUIT HOTELS of personal information that is published on his/her profile on these social networks, the User may refer to the personal data policies of these networks.
9.- UN HUIT HOTELS'S COMMITMENTS TO ITS PARTNERS
9.1 Identification of UN HUIT HOTELS Partners
When the Personal Data collected is intended for UN HUIT HOTELS Partners, UN HUIT HOTELS undertakes to inform the User of their identity.
UN HUIT HOTELS ensures that the Partner respects commitments as binding as its own in terms of security and compliance with legislation on personal data. To this end, UN HUIT HOTELS ensures in advance, within the limits of the means of control available to it, that the Partner offers appropriate guarantees to protect the privacy of the User.
9.2.- Collection of Personal Data by UN HUIT HOTELS Partners
When Personal Data is collected directly by one or more Partner(s), the Partner shall inform the User of its identity and the purpose of the processing, prior to any collection of the User's Personal Data by the Partner.
To this end, UN HUIT HOTELS shall in particular alert its Partners to the obligations of formality, keeping a register of processing and/or requests for authorization relating to the processing of Users' Personal Data from the Personal Data Protection Authority or any other competent authority.
9.3.- The transfer of data to Partners for the purposes of providing Services and personalized offers
With the explicit agreement of the User, UN HUIT HOTELS may communicate his/her details to its Partners in order to propose offers of services corresponding to his/her expectations and interests. In such a case, the Partner becomes responsible for processing the User's personal data.
9.4 - Liability of Partners
In any event, UN HUIT HOTELS is not responsible for the actions of its Partners and strongly recommends that the User carefully read the general conditions specific to each Partner before accepting them, in order to know exactly what their policy is with regard to personal data. The User remains free to accept or refuse the Partner's personal data policy.
10 - SUBCONTRACTING
UN HUIT HOTELS ensures that its subcontractors respect commitments as binding as its own in terms of security and compliance with Belgian and European legislation on the protection of personal data.
UN HUIT HOTELS does not subcontract the User's Personal Data to subcontractors located outside the European Union.
11.- RECIPIENTS OF THE USER'S PERSONAL DATA
UN HUIT HOTELS only transmits the User's Personal Data to recipients who are strictly necessary to ensure that it is processed in accordance with the purpose for which it was collected.
In this context, Personal Data can only be accessed :
authorized personnel of UN HUIT HOTELS and/or its Partners and subcontractors, subject only to proven necessity;
to the Payment Service Provider ;
technical service providers responsible for managing the Site, hosting or communication
where applicable, to the courts concerned, mediators, chartered accountants, statutory auditors, lawyers, bailiffs, debt collection agencies, police authorities in the event of theft or judicial requisition;
third parties likely to place Cookies on the User's terminals (computers, tablets, mobile phones, etc.) when the User consents (for more details, see "Cookies").
12 - SECURITY OF PERSONAL DATA
12.1 - Physical security of data
UN HUIT HOTELS and any subcontractors undertake to implement all technical and organizational measures to ensure the security of the processing of personal data and the confidentiality of Users' data.
In this respect, UN HUIT HOTELS takes the necessary precautions, with regard to the nature of the Users' data and the risks presented by the processing, to preserve the security of the data and, in particular, to prevent them from being altered or accessed by unauthorized third parties (physical protection of the premises, authentication process for our customers with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data, etc.).
However, UN HUIT HOTELS does not control the risks associated with the operation of the Internet and draws the attention of the User to the existence of possible risks in terms of occasional loss of data or breach of confidentiality of data transiting via this network. In addition, the information offered on the Site may be interrupted in cases of force majeure or beyond the control of UN HUIT HOTELS or due to events beyond the control of UN HUIT HOTELS.
UN HUIT HOTELS recommends that the User carefully read the physical and logical data security measures specific to each Partner before agreeing to entrust his/her Personal Data to the Partners. UN HUIT HOTELS is not responsible for the physical and logical security measures for Personal Data implemented by its Partners on their websites or applications or as part of the provision of services.
UN HUIT HOTELS also recommends that the User choose an identifier with a sufficient level of security as well as a strong password, which should be changed regularly, when creating his Client Account.
12.2. Notification in the event of a breach of Data security
In the event of a breach of security and/or confidentiality of the User's Personal Data collected during consultation and browsing of the Site, the User will be notified of the breach as soon as possible.
13 - HOSTING PERSONAL DATA
The User's Personal Data is preferably hosted in Belgium.
14 - TRANSFERS OUTSIDE THE EUROPEAN UNION
UN HUIT HOTELS prefers to host data and processing in Belgium.
In the event of a transfer, UN HUIT HOTELS ensures that it is governed by a contract including the European Commission's standard contractual clauses and by technical and organizational measures guaranteeing a high level of data security and confidentiality, similar to that required within the European Union.
15.- HOW CAN USERS EXERCISE THEIR RIGHTS?
In accordance with the RGPD, the User has the following rights:
Right of access (art.15 RGPD), rectification (art.16 RGPD), updating and completeness of data
The right to block or erase personal data (art.17 RGPD), if it is inaccurate, incomplete, ambiguous, out of date, or if its collection, use, communication or storage is prohibited.
Right to withdraw consent at any time (art.13-2c RGPD)
Right to limit data processing (art. 18 RGPD)
Right to object to data processing (art. 21 RGPD)
The right to portability of data provided by the User, where the data is processed automatically with the User's consent or on the basis of a contract (art. 20 RGPD).
The right to define the fate of his/her data after his/her death and to choose whether or not UN HUIT HOTELS communicates his/her data to a third party that he/she has previously designated.
In the event of death and in the absence of instructions from the User, UN HUIT HOTELS undertakes to destroy the User's data, unless it is necessary to keep it for evidential purposes or to comply with a legal obligation.
Users may exercise their rights by sending an e-mail TO COMPLETE to, or by contacting the DPO at Rue du Béguinage 38 1000 Bruxelles
To find out more about your rights, you can also consult the Personal Data Protection Authority's platform, which can be accessed at the following address: www.autoriteprotectiondonnees.be.
16 - RIGHT TO MAKE A CLAIM
The User has the right to lodge a complaint with the Personal Data Protection Authority, which can be accessed at the following address: www.autoriteprotectiondonnees.be.
17.- PERSONAL DATA POLICIES FOR MINORS
The Site is not intended for minors. However, access to the Site is not restricted to adults, as it does not contain any content that is forbidden to minors under the age of 18.
If information is collected on a minor by the Site, the minor's legal representative may contact UN HUIT HOTELS to rectify, modify or delete this information.
18 - AUTOMATED DECISIONS
UN HUIT HOTELS does not implement any decision-making processes based on automatic processing of User data within the meaning of Article 4 § 4 of the RGPD.
19.- USE OF DATA IN THE EVENT OF A CHANGE OF CONTROL OF THE COMPANY
Personal Data collected by UN HUIT HOTELS may be transferred to third parties in the event of a change of control of the company, an acquisition, bankruptcy proceedings or a sale of the company's assets.
20 - UPDATE OF THE PERSONAL DATA PROTECTION POLICY
UN HUIT HOTELS may modify the Personal Data Policy. If UN HUIT HOTELS wishes to use the User's Personal Data in a manner different from that stipulated in the Personal Data Policy in force at the time of collection, these modifications will be notified in a visible manner on the Site or the Mobile Applications.
21 - QUESTIONS - CONTACTS
UN HUIT HOTELS's Data Protection Officer is on hand to respond to all requests from Users, including requests to exercise their rights, relating to personal data.
The contact details for the Data Protection Officer are as follows:
UN HUIT HOTELS
Data Protection Officer
Place Fontainas 18-20 1000 Bruxelles
E-mail: TO COMPLETE
