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Privacy Policy.

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Noémie Boyer Poulin
route des Ormonts 14
1854 Leysin

manages the hotel: Hôtel-Restaurant Tour d'Aï and is the operator of the website:
and thus responsible for the collection, processing and use of your personal data as well as
the compliance of data processing with applicable data protection legislation.
We attach great importance to your trust, which is why we take the protection of
data very seriously and ensure appropriate security. We obviously respect the
legal provisions of the Federal Data Protection Act (LPD), the Ordinance on
Federal Data Protection Act (OLPD), the Federal Telecommunications Act (LTC) and
other data protection provisions from Swiss or EU law
possibly applicable, in particular the General Data Protection Regulation (GDPR). For
that you know what personal data about you we collect and for what purposes
we use these, please read the information below carefully. Address of
our representative in the EU in terms of data protection legislation is: [Noémie Boyer
Poulin, route des Ormonts 14, 1854 Leysin, Switzerland,].

Visiting our website

When you visit our site, our server temporarily records each access in a file
newspaper. The following technical data are then entered, in principle as for any connection with
a web server, without any intervention on your part and stored by us until their deletion
automatic at the latest after [12] months:
- the IP address of the computer accessing the site,
- the name of the owner of the IP space (generally your Internet access provider),
- the date and time of access,
- the website from which you accessed our site (original URL) and possibly
the search keywords used,
- the name and URL of the file consulted,
- the status code (e.g. error message),
- the operating system of your computer,
- the browser you are using (type, version and language),
- the communication protocol used (e.g. HTTP / 1.1)
- possibly your username resulting from a registration / authentication.
The purpose of collecting and processing this data is to enable the use of our website.
(establishing a connection), to ensure the long-term security and stability of the system and
allow the optimization of our online offer, as well as for internal statistical purposes. These treatments
are based on our legitimate interest under Art. 6 para. 1 let. f GDPR. The IP address is also analyzed
with other data for reconnaissance and defense purposes in the event of attacks on the infrastructure of
network or other unauthorized or abusive uses of the website, and possibly used in the
within the framework of criminal proceedings for the purposes of identification and civil and criminal action against the user in
question. This processing is based on our legitimate interest under Art. 6 para. 1 let. f GDPR.
Use of our contact form
You have the option of using a form to contact us. For this, we
we necessarily need the following information:
- first
and last name
- e-mail address
- message
We only use this data, together with your optional telephone number, to
be able to respond to your contact request in the best possible way and in a personalized way. The treatment of these
data is therefore necessary for the execution of pre-contractual measures in accordance with Art. 6 para. 1 let.
b GDPR or is based on our legitimate interest in accordance with Art. 6 para. 1 let. f GDPR, respectively.
Subscribe to our newsletter
You have the possibility to subscribe to our newsletter on our site. For this you must
enter and provide the following data: title first name and last name email address The above data is
essential for data processing. You can also provide other data
optional (date of birth and country [A2]). We process this data exclusively for the purpose of
personalize the information and offers we send you and better tailor them to your interests. Through
your registration, you consent to the processing of the data you have provided in this context, with a view to
the regular sending of the newsletter to the address you provided, but also for statistical analysis
your user behavior and the optimization of the newsletter. This consent represents
our legal basis for processing your email address under Art. 6 para. 1 let. a GDPR.
We are entitled to use third parties for the technical realization of advertising campaigns and
are entitled to transmit your data for this purpose (see section 13 below). At the end of each
newsletter, you will find a link to unsubscribe at any time. As part of your
unsubscribe, you can optionally tell us the reason. Your personal data
are deleted following your unsubscription. Further processing takes place only in a form
anonymous for the purpose of optimizing our newsletter.
Creation of a customer account
To make reservations on our site, you can order as a visitor or
open a customer account. When you register for a customer account, we must collect the
following data:
- title
- first and last name
- address
- Date of Birth
- phone number

- e-mail address
- password
This data, as well as other optional information (e.g. company name), is collected in
the aim of providing you with direct and password-protected access to your master data stored in
our system. You can view your previous and current reservations there, or manage or
modify your personal data. Your consent according to art. 6 para. 1 let. a GDPR constitutes the
legal basis for data processing for this purpose.
Reservation on site, by correspondence or by phone
If you make reservations through our site, by correspondence (email or post) or by
telephone, we require the following data for the execution of the contract:
- title
- first and last name
- address
- Date of Birth
- phone number
- tongue
- information relating to your credit card

- e-mail address
We use this data, as well
as other optional information you provide (e.g. time
expected arrival, motor vehicle license plate, preferences, remarks), only for
performance of the contract, unless otherwise provided in this privacy policy or where you have
separately consented. We will process this data in particular in order to enter your reservation
in accordance with your request, to provide the reserved services, to contact you in the event of
uncertainties or problems, and to ensure that payment is made correctly. Running a
contract according to art. 6 para. 1 let. b GDPR is the legal basis for data processing in this
There are many ways in which cookies make your visit to our site easier, more
pleasant and more useful. Cookies are files containing information that your web browser
automatically saves to your computer's hard drive when you visit our site. We
use cookies, for example, to temporarily store your selected services and
information entered when you fill out a form on our site so that you do not have to enter it again.
second time when viewing a subpage. In addition, cookies can also be used to
identify you as a registered user following your registration on our site. This therefore saves you from
need to log back in when you visit another subpage. Most web browsers
automatically accept cookies. However, you can configure your browser so that it does not
does not store any cookies on your computer or that a message appears each time you receive a
new cookie. On the following pages you will find explanations on how to configure the treatment.
cookies for the most commonly used browsers:
- Microsoft Windows Internet Explorer
- Microsoft Windows Internet Explorer Mobile
- Mozilla Firefox
- Google Chrome for desktop
- Google Chrome for mobile
- Apple Safari for desktop
- Apple Safari for mobile [A5] Disabling cookies may prevent you from using
all the features of our site.
Monitoring tools

For the proper presentation and continuous optimization of our website, we use the
Google Analytics audience analysis service. Thus, we create pseudonymized usage profiles
and use small text files stored on your computer ("cookies"). Information generated by
the cookies concerning your use of this site are transmitted to the servers of the providers of these
services, then stored and processed for us. In addition to the data indicated in ch. 1 below, we
we receive the following information, if applicable:
- navigation route taken by a visitor to the site,
- duration of the visit to the site or to the page,
- the page from which the visitor leaves the site,
- the country, region or city from which access takes place,
- device (type, version, color depth, resolution, width and height of the
navigation) and recurring visitor or new visitor.
The information is used in order to analyze the use of the website, to compile reports on
activities of the site and to provide other services related to the use of the site and the use of the Internet to
for market research and appropriate presentation of this site. This information can also be
transmitted to third parties insofar as this is prescribed by law or insofar as third parties are
mandated to process this data.
Google analytics
The provider of Google Analytics is Google Inc., a company of the holding company Alphabet Inc., whose registered office is
in the United States. Before data transmission to the provider, the IP address is shortened by activating
IP anonymization ("anonymizeIP") on this website within the Member States of the European Union
or in other states signatory to the Agreement on the European Economic Area. Google does not aggregate
together with other data the anonymized IP address transmitted by your browser within the framework of Google
Analytics. Exceptionally, the full IP address is transmitted to a Google server in the United States.
before being abbreviated. In this case, we ensure through contractual guarantees that Google Inc.
respects a sufficient level of data protection. According to Google Inc., the IP address will not be
case associated with other data concerning the user. You will find additional information
on the audience analysis service used on the Google Analytics website. To find out how
prevent the processing of your data by the audience analysis service, please consult the address
next Data processing to respond to
legal obligations to inform
Data processing related to your stay
When you arrive at our hotel, we need the following information about you as well
that concerning the people who accompany you:
- first and last name
- postal address and canton
- Date of Birth
- Place of birth
- Nationality
- official ID and number
- day of arrival and departure
- room number
We collect this information to meet legal obligations to inform arising from
particularly police and hotel legislation. To the extent that we have to
according to the applicable provisions, we forward this information to the competent police authority.
We have a legitimate interest under Art. 6 para. 1 let. f GDPR to fulfill the legal provisions.
Entry of services provided Insofar as you receive additional services in the
during your stay (e.g. use of the mini bar or our pay TV offer), we enter
for invoicing purposes the object of the service as well as the date on which you received it. Treatment of
this data is necessary for the performance of your contract with us under Art. 6 para. 1 let. b GDPR.
Booking platforms If you make bookings through a third-party platform, the operator of the
platform in question sends us various personal information. In principle, these are
data indicated in ch. 5 of this privacy policy. In addition, requests concerning
your reservation may be sent to us. We process this data in particular to enter
your reservation in accordance with your request and provide the reserved services. Running a
contract according to art. 6 para. 1 let. b GDPR is the legal basis for data processing in this
goal. Finally, the platform operators potentially inform us of disputes related to a
reservation. They then also send us data concerning the reservation process,
for which a copy of the booking confirmation can serve as proof of the effective closing of
this one. We process this data for the protection and respect of our rights. For these treatments we
we are based on our legitimate interest under Art. 6 para. 1 let. f GDPR. Please also take
knowledge of the privacy policies of the respective providers. Centralized storage and
data relation We record the data indicated in ch. 2-5 and 8-10 in a system of
centralized electronic data processing. Your data is then systematically
entered and grouped together for the processing of your reservations and the performance of services
contractual. To do this, we use software from the company D-EDGE, 14-16 Bd Poissonnière - 75009
Paris ]. The processing of this data by the software is based on our legitimate interest under Art. 6 para.
1 let. f GDPR to customer-friendly and efficient customer data management. Duration
retention We only store personal data for as long as this is
necessary for the use of the aforementioned follow-up services as well as for further processing based on
our legitimate interest. We keep the contractual data for a longer period as soon as
this is prescribed by legal retention obligations. Obligations to keep that oblige us
to keep data derive from the provisions relating to the right to notify the authorities, to the
financial and tax law. In accordance with these provisions, commercial communication, contracts
concluded and the accounting documents must be kept for up to 10 years. Insofar as we have
These data are no longer needed for the performance of the services, they will be blocked. This means that these
data may only be used for accounting and tax purposes. Transmissions of
data to third parties We only pass on your personal data if you have
expressly consented, if we are under a legal obligation to do so or if this is necessary
to assert our rights, in particular to assert our rights arising from the contractual relationship. Furthermore,
we pass your data on to third parties insofar as this is necessary for the use of the site
Internet and contract performance (including outside the website), in particular for the processing of
your reservations. Our web host [OVH] is a service provider to which we transmit the data to
personal character collected through the website, or who has access or may have access to them. The site
Internet is hosted on servers in [FRANCE]. The purpose of data transmission is to provide and
maintain the functionality of our site. This processing is based on our legitimate interest under Art. 6
al. 1 let. f GDPR. Finally, we send the issuer and the acquirer of your credit card the
information relating to this when paying by credit card on our site. If you choose to
pay by credit card, you must enter all the necessary information. Execution of a contract
according to art. 6 para. 1 let. b GDPR is the legal basis for data transmission. Regarding
the processing of your credit card information by these third parties, please also read the
terms and conditions as well as the privacy policy of your credit card issuer. Please
moreover, take note of the indications in ch. 7-8 and 10-11 concerning the transmission of
data to third parties. Transmission of personal data abroad We are
also entitled to transmit your personal data to third-party companies (service providers
mandated services) abroad for the data processing specified in this privacy policy.
confidentiality. These companies are subject to the same level of data protection as us. If the
level of data protection in a given country does not correspond to the Swiss or European level,
we ensure by contractual means that the protection of your personal data
corresponds to that of Switzerland or the EU. You have the right to obtain information on request
relating to the personal data concerning you that we record. In addition, you have the
right to the rectification of erroneous data and the erasure of your personal data from
as long as there is no legal retention obligation or any legal basis allowing us to
processing the data does not object. You also have the right to demand the return of data that
you have transmitted to us (right to data portability). On request, we also send the
data to a third party of your choice. You have the right to obtain the data in a standard format. You
can contact us for the aforementioned purposes at the following email address: He is
we may ask you, at our sole discretion, for proof of identity for the processing
of your requests. Data security
Data security
We use appropriate technical and organizational security measures to protect
personal data concerning you that we save against any manipulation, partial loss or
total and against unauthorized access by third parties. Our security measures are constantly being improved by
according to technological progress. You must always keep your access data confidential and
close the browser window when you have finished your communication with us, in particular if
you are not the only person using the computer. We also take the
data protection within our company. Our employees and the service providers that
we mandate are subject to secrecy and compliance with legal provisions for the protection of
Note on data transmissions to the United States
For the sake of completeness, we inform users whose domicile or registered office is in Switzerland that
the United States is subject to surveillance measures by the United States authorities. These
generally allow the recording of all personal data of persons whose
data was transmitted from Switzerland to the United States. This is done without differentiation, limitation or
exception based on the aim pursued and without objective criteria making it possible to limit the access of the authorities
to the data and their subsequent use for very specific and strictly limited purposes
likely to justify the infringement implied by the access to these data as well as their use. Furthermore,
we inform you that in the United States, there is for data subjects from Switzerland
no recourse allowing you to have access to the data concerning you and to obtain their
rectification or erasure, nor effective legal protection against general access rights of
US authorities. We explicitly draw the attention of the person concerned to this situation
legal and factual so that she can make an informed decision about consent to
the use of their data. We inform users domiciled in an EU Member State that
according to the EU, the United States
- in particular because of the subjects mentioned in this part
- do not have a sufficient level of data protection.
Insofar as we have explained in this privacy policy that certain recipients of
data (eg: Google) have their headquarters in the United States, we will ensure either through provisions
contractual with these companies, or through their certification according to the protection shield
EU-US or Swiss-US data, whether your data has a level of protection
reasonable with our partners.
Right to lodge a complaint with a supervisory authority responsible for overseeing the protection of
You have the right to lodge a complaint with a protection supervisory authority

Datas. Version: [2018]


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