When using the https://www.grandluxuryhotels.com website and Grand Luxury mobile applications (the
"Service(s)"), we ("GRAND LUXURY", "We", "Our") may collect and process your personal data.
The purpose of this Protection of Personal Data and Privacy and Charter (the "Charter") is to inform the
users of the Services ("User(s)", "You", "Your") of the means used to:
It is very important to us to respect your privacy and protect your personal data.
By accessing and/or using the Services, You agree that Your personal data will be collected and
processed under the terms and conditions set forth below. If You do not agree to this Policy, You shall
cease all use of the Services.
We may amend the Charter, in order to comply with any legislative, regulatory, jurisprudential, editorial or
technical changes under the conditions described in the TOS. Therefore, before browsing, You should
refer to the latest version of the Charter.
The terms "personal data" ("Personal Data"), "process/processing", "data controller", "processor",
"recipient(s)", "consent", and "filing system", have the same meaning as in Article 4 of the GDPR.
The controller of Users’ Personal Data collected on the Services is GRAND LUXURY, a limited liability
company (SARL), registered in the Paris Trade and Companies Register under number 499330306, the
head office of which is located at 11 rue Saint-Florentin, 75008 Paris, and the contact details of which can
be found in Article “CONTACT INFORMATION”.
WHAT PERSONAL DATA IS COLLECTED?
During the collection of Personal Data, the User will be informed if certain Personal Data must be
provided or if they are optional. If Personal Data that is required is not provided, access to certain
features of the Services, such as the online partner hotel reservation service, and the use of such
Services by the User will be impossible.
In particular, GRAND LUXURY may be required to collect the following categories of Personal Data
relating to the User or the person with whom he or she intends to travel and relative to whom he or she
wishes to provide GRAND LUXURY, under his or her exclusive responsibility, Personal Data or
information relating to travel documents, which includes the following categories:
- Identity: title, nationality, surname, first names, postal address, telephone number (fixed and/or
mobile), e-mail address, date of birth, internal processing code for client identification (this
internal processing code is different from the registration number in the national directory of
identification of natural persons, and the credit card number), digitization and/or data on proof of
identity and/or passport data such as passport number, place of issue and expiration date;
- Identifiers and encrypted password;
- Payment data: transaction number, credit card details (credit card holder's details, number, expiry
date and cryptogram);
- Commercial relationship data: bookings made or in progress, wish lists, services subscribed,
amount, periodicity, billing address, booking history, purchases and purchase history, lists of
travellers, traveller preferences, user reviews and any problems encountered or reported by the
User in the provision of services, correspondence with the after-sales service, food and/or drink
preferences, and particular requests;
- Invoice payment data: terms of payment, discounts granted, payments received, payments due,
- Contact data: messages sent to the Services via contact forms or online chats, correspondence
that may be sent to Us;
- Newsletter registration data;
- Interests declared via a form or deduced from the use of the Services;
- Contacts and exchanges with Us;
- Technical navigation and interaction data: use statistics, IP address, cookies, for example, the
pages visited by the User, the date and time of visits;
- Location data, subject to Your free, specific and informed consent, which may be withdrawn at
any time using the settings of Your mobile device;
- Data on the conditions of mobility or access voluntarily provided by the User and making it
possible to adapt the services that may be provided relative to his or her specific situation,
including disabilities, support or care infrastructure. If applicable, the User shall acknowledge that
he or she provides this type of information voluntarily and freely and consents to data processing
by GRAND LUXURY at his or her request, particularly when such information constitutes
WHY DO WE COLLECT YOUR PERSONAL DATA?
Personal Data that You provide to Us relative to You or the persons with whom You intend to travel, as
well as data that is collected and/or processed in connection with Your use of the Services, is processed
in order to respond particularly to the following purposes:
|Contract between You and GRAND LUXURY (TOS and this Charter)
||- Put the Services at Your disposal, ensure their proper
functioning, especially in order to provide You with
information on reservations, treat Your requests, facilitate
Your navigation, etc.
- Allow You to create an account and join the Grand
|GRAND LUXURY's legitimate interest in improving its Services
||Improve the Services, in particular, to optimize or offer new
features to the Services, or offer You a simplified automatic entry
- Contract between You and GRAND LUXURY (TOS and this Charter)
- Legitimate interest of GRAND LUXURY
- Processing your reservations
- Customer Relationship Management
|GRAND LUXURY's legitimate interest in offering You services and offers that correspond to Your preferences and interests
||Adapt and optimize the display of the content of Services and
promotional offers, parameters or preferences, appetites and
interests, proven, assumed or deduced, of the User, which
may result from Your use of the Services, information.
You enter, Your navigation and Your interactions with the Services
- Legitimate interest of GRAND LUXURY to promote its services and propose You with offers and news
- Your consent to receive offers and news from GRAND LUXURY partners
|Inform You of GRAND LUXURY offers and news, unless not
consented to by You, as well as offers and news from GRAND
LUXURY's partners, if You have provided Your consent
|Your consent to activate the geolocation function
||Optimizing the Services using the geolocation function by
accepting or electing its activation allows You to be guided
when booking hotels and stays, to take advantage of hotel
reception services and other additional services, and to adapt
and optimize the display of the content of the Services and the
promotional offers to Your parameters or preferences,
appetites and centres of interest, proven, supposed or deduced. Disabling geolocation on Services blocks
WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?
The database of Personal Data created for Your use of the Services is strictly confidential. GRAND
LUXURY undertakes to take all the necessary precautions and organizational and technical measures in
order to preserve the security, integrity and confidentiality of Personal Data, and, in particular, to prevent
such data from being distorted or damaged, or unauthorized third parties having access thereto.
Data transferred to the authorities and/or public bodies
In accordance with the regulations in force, Personal Data may be forwarded to the competent authorities
upon request and also to public bodies, exclusively to satisfy legal obligations, officers of the law,
ministerial officers and debt collection bodies.
Third party access to data
Personal Data may be used by GRAND LUXURY, its subcontractors, affiliates and/or, if applicable, by its
business partners, for the purposes described in Article 4 above.
- GRAND LUXURY staff, the audit department (notably the auditor) and GRAND LUXURY’s
subcontractors will have access to the Personal Data collected as part of the use of the Services;
- GRAND LUXURY's business partners, such as hotels or restaurants, will have access to Users'
Personal Data for the purposes of managing their reservations and after-sales service;
- Social networks: if the User has an account on social network sites and accesses the Services,
GRAND LUXURY may receive information from such social networks in order to facilitate the
creation of an account on the Services, and the social network services may receive information
relating to the use of the Services by the User. When the User uses the Services via a social
network site, the User allows GRAND LUXURY to access certain information that he or she has
provided to the social network site, such as his or her username, his family name and first name,
profile picture, and Personal Data relating to the use of this service. By accessing the Services
via a social network site, the User authorizes GRAND LUXURY to collect, store and use all
information that the User has authorized the social network site to provide to GRAND LUXURY.
Transfer outside of the European Union
The User's Personal Data may be processed outside the European Union, including via remote access.
GRAND LUXURY undertakes not to carry out any transfer of Personal Data outside the European Union
without implementing the appropriate safeguards in accordance with the Applicable Regulations.
WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
In accordance with the Applicable Regulations, subject to an express request and justification of Your
identity with GRAND LUXURY, You have the right to access to Your Personal Data, a right of rectification,
a right to object, as well as a right to erasure, under the conditions of the Applicable Regulations.
Your right to the erasure of Your Personal Data applies subject to the necessities that may justify GRAND
LUXURY to store Personal Data, particularly with respect to its legal obligations.
In the event of exercise of the right to object, GRAND LUXURY will cease processing the Personal Data,
except in case of legitimate motive(s) and motive(s) imperative for the processing, or to ensure the
observation, the exercise or the defence of its rights in court, in accordance with the Applicable
Subject to the terms of the Applicable Regulations, You may also request a restriction to the processing
of Your Personal Data.
When the processing of Your Personal Data is based on Your consent, You have the right to withdraw
Your consent at any time.
You also have the right to the portability of some of Your Personal Data, allowing You to request, in a
readable and usable form, a computer copy of Your Personal Data that is processed by GRAND
LUXURY as part of Your contractual relationship with Us for the provision of products or services to which
You have subscribed, which excludes the Personal Data that GRAND LUXURY may have produced for
purposes specific to it or to meet its legal, accounting, social or tax obligations, as well as information
relating to booking history, any amounts paid or payable, as well as all the information that GRAND
LUXURY may have generated as part of the legitimate interests that it pursues.
You have the option to provide GRAND LUXURY with instructions regarding the use of Your Personal
Data after Your death.
If necessary, GRAND LUXURY will inform You of the reasons for which any rights you exercise cannot be
satisfied in whole or in part.
To exercise the rights mentioned in this Article, You may contact GRAND LUXURY at the location
indicated in Article “CONTACT INFORMATION” below, enclosing a copy of a valid ID with your request.
RETENTION PERIOD OF YOUR PERSONAL DATA
GRAND LUXURY undertakes not to keep Your Personal Data beyond the period strictly necessary for the
purposes for which it was collected, and in accordance with the Applicable Regulations.
GRAND LUXURY undertakes to anonymize or delete Your Personal Data as soon as the purpose and/or
the duration of their established retention expire.
Nevertheless, Personal Data may be archived beyond the applicable periods for the purposes of
researching, investigating, and prosecuting criminal offenses with the sole purpose of allowing, as
needed, the provision of such Personal Data to the judicial authorities, or for other retention obligations, in
particular for accounting or fiscal purposes. Archiving implies that this Personal Data will be subject to
access restrictions and will no longer be available online but will be retrieved and kept on a secure and
The maximum retention periods set out in the table below apply unless You request that your Personal
Data be erased before the expiry of these periods, in accordance with Article 7 above.
|Audience measurement and service
customization, management of cookies and other
||13 months from the receipt of the cookie or other
|Information relating to transactions carried out by
||Such data is not retained beyond payment, which
may include the regularization of any fees
applicable during a check-out, unless You have
consented to the saving of such data.
|Information about bookings made or services
||10 years from the date of the last purchase or the
last full payment of the last service provided
|User preference information
||5 years from full payment of the last service provided
|Personal Data processed as part of solicitations and promotional operations, sending offers and news
||3 years from the end of the relationship with the User or from the last interaction initiated by the User
|Personal Data relating to the management of requests for the exercise of rights and questions on Personal Data
||3 years from the last interaction initiated by the User
|Information about managing customer service interactions
||3 years from the last interaction initiated by the User
||Such data is not retained beyond the period of use of the feature by the User
PROTECTION OF THE PERSONAL DATA OF MINORS
The Services are generally not intended for minors under the age of 15. We do not collect or store
Personal Data on children under 15 years of age without obtaining verifiable parental consent, knowing
that the holders of parental authority will be able to request to receive information relating to their child
and ask for its removal.
When an adult User enters Personal Data relating to a minor under the age of 15, he or she undertakes
to have the verifiable consent of the holders of parental authority, and to provide upon request any
element of proof of such consent.
Given the evolution of technologies, the implementation costs, the nature of the Personal Data to be
protected as well as risks to the rights and freedoms of individuals, GRAND LUXURY implements the
appropriate technical and organizational measures to guarantee the confidentiality of Personal Data
collected and processed and a level of security adapted to the risk, in accordance with this Charter.
The information collected as part of the booking process is transmitted encrypted on the basis of the SSL
(Secure Socket Layer) protocol over the Internet. All necessary existing precautions will be taken, with
regard to the nature of Personal Data and the risks presented by processing, in order to preserve the
security of Personal Data and, in particular, to prevent it from being distorted or damaged, and from
unauthorized third parties having access thereto.
When using the Services, navigation information relating to Your computer, tablet, smartphone, etc.
("Terminal") may be stored in text files called "cookies" installed on your Terminal, subject to the choices
you have expressed about "cookies" and which You can change at any time (see Article 10.4 below).
What are cookies?
A "cookie" is a small text, image or software file that We may record on the hard disk of Your Terminal
through your Internet browser when You use the Services, subject to Your agreement and unless You do
not allow it.
During its period of validity, a "cookie" allows its issuer to recognize the relevant Terminal each time this
Terminal accesses digital content containing "cookies" of the same issuer.
Once installed, the "cookies" allow us to recognize you at each visit to the Services, and thus they allow
you to enjoy all of the features of the services, to save your visit to a particular page and to provide you
with additional services. They also allow us to improve your ease of browsing, securing your connection
or adapting the content of a page to your interests or usage preferences.
The information recorded by the "cookies", for a period of limited validity, include the pages visited, the
advertisements You click on, the type of browser you use and other data that Our online services
automatically process such as the identity of Your ISP, Your IP address or the information you enter on
the Services (in order to avoid re-entering).
"Cookies" are not active files, and therefore cannot host viruses. To learn more, You can visit
What are the "cookies" on the Services used for?
Only the issuer of a "cookie" may read or modify the information contained therein.
"Cookies" are used for the purposes described below, subject to Your choices that You may express and
modify at any time via the settings of the browser software used when browsing the Services.
Navigation "cookies" improve the performance of the Services in order to provide the User with a better
use of the Services. These "cookies" do not require the informing and the prior consent of the User to be
deposited on the User's Terminal.
More precisely, these navigation "cookies" make it possible:
- to adapt the presentation of the Services to the display preferences of Your Terminal (language
used, display resolution, operating system used, etc.) when You use the Services, depending on
the viewing or reading hardware or software that your terminal has;
- to allow access to a reserved area subject to username and password;
- to save information about the forms you completed when using the Services;
- to save Your usage preferences, display settings and readers you use to facilitate your navigation
during your next visit to the Services;
- to adapt the informational or promotional content of the Services according to Your assumed
interests and preferences, either declared or resulting from Your use of the Services, and
according to Your place of connection to the Services;
- to implement security measures, for example when a User is asked to reconnect to a Service
after a certain period of time.
The statistical "cookies" issued on the Services make it possible to establish statistics and measures of
visit frequency and use the various elements composing the Services (headings and content visited,
routes, etc.), allowing us to improve the use and the ergonomics of the Services.
The results of statistical "cookies" analyses are processed anonymously for exclusively statistical
Advertising "cookies" and third party "cookies"
Advertising "cookies" and third party "cookies" are primarily used:
- to determine, in real time, which advertising to display based on your recent browsing history in
order to limit the number of times an ad is displayed and to help measure the effectiveness of an
- to personalize Your browsing experience on the Services, to maintain and improve the quality of
Our Services and protect You from any fraudulent activity. When third party sites, such as social
networking sites, receive information contained in the "cookies" through the use of a specific
module of the Services, this information is anonymous and is only for the purpose of permitting
Your identification on the Services.
Period of validity of "cookies"
The "cookies" issued on the Services are session "cookies" (the duration of which is limited to the time of
a connection to the Services) and persistent "cookies" (the duration of which, however limited, is greater
than the duration of a connection).
Session cookies are only active for the duration of your visit and are deleted when you close your
browser. Persistent "cookies" remain stored on your Terminal's hard drive once Your browser is closed.
In accordance with the Applicable Regulations and the recommendations of the Commission Nationale
Informatique et Libertés ("CNIL"), "cookies" are kept for a maximum of 13 (thirteen) months after their first receipt. At the end of this period, Your consent must be obtained again for the collection of cookies
subject to consent.
Your choices regarding "cookies":
All User rights set forth in the Charter are also applicable to the use of "cookies".
Several possibilities are offered to you to manage cookies. The user understands that "cookies" improve
the ease of navigation on the Services. Any configuration that the User may undertake may modify his or
her browsing on the Services and his or her conditions of access to certain services requiring the use of
"cookies". GRAND LUXURY cannot be held responsible for the consequences of a less efficient
operation of the Services due to the impossibility to install or read the "cookies" necessary for their proper
functioning, to the extent that the User has not accepted or deleted them.
Users may configure their browsing software so that "cookies" are saved or rejected on their Terminal
either systematically or according to their issuer. Users can also configure their browsing software so that
the acceptance or rejection of "cookies" are proposed to them punctually, before a cookie is likely to be
registered on their Terminal.
The exercise of the right of opposition will not prevent the display of advertisements. Only advertisements
using the personalization services of the Services will cease. In other words, the User will no longer be
exposed to advertising adapted to his or her interests through the use of "cookies" on the Services but will
continue to be displayed advertisements the content of which will not necessarily be in line with his or her
centres of interest, or may even be questionable.
The help menu or the dedicated section of your browser will allow you to know how to express or modify
your "cookie" preferences:
For any questions concerning the treatment of Your Personal Data, You can address Your request or
Your complaint directly to GRAND LUXURY by contacting it at its headquarters at 11 rue Saint-Florentin,
75008 Paris or at the email address [email protected]
GRAND LUXURY will endeavour to find a satisfactory solution to ensure compliance with the Applicable
In the absence of a response from GRAND LUXURY or if the dispute persists, You have the possibility to
lodge a complaint with the CNIL or the supervisory authority of the Member State of the European Union
in which you habitually reside.