PERSONAL DATA PROTECTION CHARTER
1. What is the purpose of this charter?
The purpose of this charter (the “Charter”) is to inform users (“You”, “Your”) of the terms and conditions under which SILVER RESORTS (“SILVER RESORTS” or “We”) processes their Personal Data (as defined below) in connection with their use of the website (the “Website” and the “Processing”).
For the purposes of this Charter, the term “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
We invite You to read this Charter carefully before continuing to browse the Website.
2. Data Controller: SILVER RESORTS
SILVER RESORTS, a simplified single-shareholder joint-stock company with share capital of €15,000, registered under number 979 724 457 00010 R.C.S PARIS, with its registered office at 30/32 boulevard Sébastopol, Paris 75004, reachable at +33 9 70 44 99 88 – email: [email protected], determines the purposes and means of the Processing and therefore acts as data controller. The representative of SILVER RESORTS is Mr Farès Bouslama, in his capacity as Chairman.
When carrying out the Processing, SILVER RESORTS undertakes to comply with the “Regulations”, meaning all applicable legal provisions on the protection of personal data, including in particular (i) Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (ii) Directive 2002/58/EC of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, and (iii) applicable French legal and regulatory provisions, including Law No. 78-17 of 6 January 1978, as amended.
3. How does SILVER RESORTS collect Your Personal Data in the context of Processing?
SILVER RESORTS collects Your Personal Data when (i) You browse the Website and (ii) You complete the various forms available on it, namely the “Contact” form and the “Receive our brochures” form.
4. What Personal Data is collected for Processing?
In connection with the processing of online forms, the Personal Data processed comprises Your identity data (surname, first name), Your personal email address, Your telephone number, and any information You wish to share with us. In this context, You agree not to communicate any health data to SILVER RESORTS, as defined by the Regulations[1].
With regard to the cookies used on the Website, these process Your connection data, Your preferences saved during previous sessions (authentication, choice and interface personalisation trackers), data enabling audience measurement by SILVER RESORTS, and Your device information.
We invite You to regularly update Your data by notifying Us in writing of any changes, as set out in the dedicated section “What are Your rights and how can You exercise them?“.
5. Purposes, legal bases, and retention periods for Personal Data
SILVER RESORTS processes Your Personal Data only to the extent strictly necessary to achieve the purposes pursued, on the following legal bases and for the following retention periods:
Purposes
Legal bases
Retention period
Website operation
Our legitimate interest in ensuring the proper functioning of the Website
1 year and 2 months from the date of Your last visit to the Website
Website operation, including offering You personalised features/services based on Your expectations and analysing Your connection data
Our legitimate interest in offering You personalised features/services on the Website and analysing Your connection data
Certain cookies may require Your consent via the information banner displayed when You connect to the Website
1 year and 2 months from the date of Your last visit to the Website
Processing of “Contact” and “Receive our brochures” forms
Our legitimate interest in developing our client base
Three (3) years from the date of submission of the relevant form
Compliance with Our legal obligations
Compliance with Our legal obligations
The period necessary until the relevant legal obligation has been discharged
SILVER RESORTS will only use Your Personal Data for the purposes set out above.
Providing Your Personal Data is mandatory and necessary to enable SILVER RESORTS to fulfil the aforementioned purposes; failing this, You will not be able to use the Website under normal conditions, the Website will not be able to offer You the best possible experience, nor will You be able to receive the information requested via the forms.
Focus on cookies
Cookie
Functionalities
Characteristics
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Preventing a modal window from being displayed multiple times on the Website
Necessary
cookieyes-consent
Remembering Your consent preferences so that they are respected during subsequent visits to the Website
Necessary
_GRECAPTCHA
Identifying bots in order to protect the Website against malicious attacks
Necessary
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Calculating visitor, session, and campaign data and tracking Website usage for analytical reporting.
Analytical
6. Who are the recipients of Your Personal Data?
SILVER RESORTS only shares Your Personal Data with the following parties, who need access to it for the purposes of fulfilling the aforementioned objectives and the tasks entrusted to them. The recipients of Your Personal Data are:
- Internal recipients: SILVER RESORTS staff in charge of “Customer/Sales” and “IT” departments;
- External recipients: SILVER RESORTS subcontractors, including the subcontractor responsible for the IT system (data hosting), and the owners and managers of the residences/care homes.
SILVER RESORTS ensures that these recipients are required to implement appropriate security measures to comply with the Charter and are not authorised to process Your Personal Data for any purpose other than those provided for in Article 5.
7. Are Your Personal Data transferred outside the European Union?
Personal Data relating to the processing of “Contact” and “Receive our brochures” forms are transferred to countries outside the European Union (EU), including Tunisia and Morocco. These transfers are governed by measures ensuring a level of protection equivalent to the Regulations, in particular the standard contractual clauses adopted on 4 June 2021 by the European Commission.
8. What security measures are in place?
SILVER RESORTS implements technical and organisational measures to protect Your Personal Data against accidental or unauthorised destruction, alteration, loss, or disclosure.
9. What are Your rights and how can You exercise them?
In connection with the Processing, You have the following rights:
- to be informed: You have the right to be informed of the Personal Data SILVER RESORTS holds about You, as well as of the Processing. This is precisely the purpose of the Charter;
- to access: You have the right to access all Personal Data concerning You that SILVER RESORTS holds. You may exercise this right by sending a simple request to SILVER RESORTS at the contact details provided below;
- to rectify: Should You consider that such Personal Data is incomplete or inaccurate, You may ask SILVER RESORTS to rectify it, which SILVER RESORTS will do as soon as possible;
- to restrict: In certain cases listed in Article 18 of the GDPR, You may ask SILVER RESORTS to restrict the Processing of Your Personal Data;
- to transfer: You have the right to data portability of Your Personal Data and may request their transfer to the recipient of Your choice;
- to erase: You may request SILVER RESORTS to erase Your Personal Data (“right to be forgotten”);
- to lodge a complaint: You always have the right to lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL);
- to object: You may in some cases object to the Processing: SILVER RESORTS will cease the Processing unless it is legally required to continue it or there are legitimate and compelling grounds justifying the Processing;
- to define post-mortem instructions: These instructions, which may be revoked at any time, may concern the storage, erasure, or communication of Your Personal Data by designating a person responsible for their execution:
- where they are general instructions, You may transmit them to a digital trusted third party certified by the CNIL;
- where they are specific instructions, You may transmit them directly to SILVER RESORTS;
If You wish to exercise any of Your rights or obtain further information, You may at any time send a request to SILVER RESORTS, accompanied by a copy of proof of Your identity, which will allow Us to verify Your identity:
- by email: [email protected]
- by post: 30/32 boulevard Sébastopol, Paris 75004
10. Amendments to the Charter
The Charter may be amended and updated at any time by SILVER RESORTS, and such amendments will be communicated to You by any means SILVER RESORTS deems appropriate.
We recommend that You always consult the most recent version of the Charter before using the Website and/or interacting with Us.
[1] Data relating to the physical or mental health, past, present, or future, of a natural person (including the provision of healthcare services) that reveals information about the health status of that person. For example, information concerning an illness or certain data from which it is possible to deduce information about a person’s state of health.
Last updated on 30/07/2023.