Privacy Policy
- Introduction
- About this policy
- Your rights and preferences: choice and control
- How do we collect your personal data?
- What personal data do we collect about you?
- How do we use your personal data?
- Sharing your personal data
- Data retention and deletion
- Links
- Data security
- Children
- Changes to this privacy policy
- Contact us
1. Introduction
Thank you for joining the program!
We want to provide you with the best possible experience to ensure you enjoy our best offers, deals, benefits, and events, today, tomorrow, and in the future. To do this, we need to manage your rewards and the rights you have acquired or been granted by the shops and partners participating in the program, to inform you about offers reserved for you, and to understand your interests and preferences in order to offer you an outstanding, customized service specifically designed for you. The privacy and security of your personal data is, and will remain, one of our highest priorities. We therefore wish to explain to you in a transparent manner why we collect, store, share, and use your personal data. We will also outline the controls and choices available to you to determine when and how your personal data is shared.
This is our goal, and this Privacy Policy (« Policy ») specifies and details our commitments and actions below.
2. About this Policy
This Policy sets forth essential information regarding the use of your personal data under the Pass'Partout program, developed by EPIC Corbier Tourisme and the La Toussuire Tourist Office, and designed and operated by the company SMARTFIDELIS. The Policy applies to all services accessible under your membership in the program and through the use of your account and cards in participating shops and associated services (referred to as the « Program »). The terms governing your use of the Program are defined in our General Terms and Conditions of Use (the « General Terms and Conditions of Use »).
We occasionally develop and offer new services or additional offers. If the introduction of these new or additional services results in a change to the way we collect and process your personal data, we will provide you with further information as well as supplementary terms or policies. Unless otherwise stated, any new or additional services added will be subject to this Policy.
The purpose of this Policy is to:
- Explain to you what personal data we collect, for what purpose we gather and use it, and with whom we share it;
- Detail how we use the personal data you share to offer you an optimal experience when using the Program; and
- Define your rights and choices regarding the personal data we collect and process, and explain how we protect your privacy.
We hope this Policy helps you understand our commitments to protecting your confidentiality and privacy. For more information on the terms used in this Policy, visit our Privacy Center. To contact us in case of questions or problems, please see section 13 « Contact us » below. If you do not agree with the content of this Policy, you are free to decide whether you wish to use the Program.
3. Your rights and preferences: choice and control
As you may know, a European Union regulation, known as the General Data Protection Regulation or « GDPR », grants individuals certain rights regarding their personal data. Consequently, we have implemented additional access controls and transparency measures within our privacy policy and in your Program account privacy settings to help users benefit from these rights. Subject to limitations set by applicable law, the following rights are granted to individuals as available:
- Right of access: the right to be informed of and request access to the personal data we process;
- Right to rectification: the right to request that we modify or update your personal data when it is inaccurate or incomplete;
- Right to erasure: the right to request that we permanently delete your personal data;
- Right to restriction: the right to request that we temporarily or permanently stop processing all or part of your personal data;
- Right to object:
- the right to object at any time to the processing of your personal data for personal reasons;
- the right to object to the processing of your personal data for direct marketing purposes;
- Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit this personal data for use by a third-party service; and
- Right not to be subject to automated decision-making: the right not to be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
To allow you to easily exercise these rights and save your preferences regarding the use of your personal data by EPIC Corbier Tourisme and the La Toussuire Tourist Office within the framework of Pass'Partout, we grant you access to the following settings via the Personal Data page of your account. You will be able to:
- Manage your privacy settings
- Define your notification preferences,
- Update or delete your data in connection with the Program services,
- Download your personal data
- Close your account
The Program's new privacy policy allows you to control how the Program processes your personal data. You will be able to implement and configure your rights, identify what happens if you change your settings, and see how to choose not to receive certain messages from the Program on the Account Settings page. If we send you electronic marketing messages with your consent or in any other manner permitted by applicable law, you may, at any time, either withdraw your consent or signal your refusal (« Opt out ») at no cost. The electronic marketing messages you receive from the Program (by email, for example) also include an opt-out option (i.e., an unsubscription link in the sent emails).
If you have questions about your privacy, your rights, or how to exercise them, please contact us using the « Contact us » form in the Privacy Center. We will respond to your request within a reasonable timeframe, following verification of your identity. If you are not satisfied with the way we use your personal data, you can also contact the French data protection authorities, and you are free to file a complaint with them.
4. How do we collect your personal data?
We collect your personal data in the following ways:
- When you register for the Program: when you sign up for the Program, we collect certain personal data, such as your email address, date of birth, title, and address, to enable you to use the Program.
- Through your use of the Program: when you use the Program, we collect personal data relating to your use of this service, such as the offers and shops you have viewed and the preferences you have mentioned.
- Personal data collected to provide you with additional functions/features: you may occasionally provide us with additional personal data or give us your permission to collect other personal data, for example, to enjoy additional functions or features. As described below, we do not collect any photos, voice data, or contacts from your device without your prior consent. You will always have the option to change your mind and withdraw your permission at any time.
- From third parties: we receive personal data about you and your activity from shops and service providers participating in the Program and potentially from third parties, including advertisers and partners with whom we work to provide you with the Program (please see Section 7 below, Sharing your personal data). We will use this personal data if you have given your permission for this data to be shared with a third party or with EPIC Corbier Tourisme, or if EPIC Corbier Tourisme or the La Toussuire Tourist Office has a legitimate interest in using this personal data to provide you with the Program services.
We use aggregated and anonymous information, notably for the purposes of conducting research, analyzing data, creating marketing and promotional models, improving the Program, and developing new functions and features within the Program.
5. What personal data do we collect about you?
We have outlined in the tables below the categories of personal data that we collect and use:
Personal data collected when you register for the Program
| Personal data categories | Category description |
|---|---|
| Account registration data |
This is the personal data you provided or that we collected to enable you to register and use the Program. It includes your email address, date of birth, title, and address. Certain required personal data is necessary to create your account. You have the option to provide us with additional personal data to further customize your account. The exact personal data we collect depends on the services and benefits you request in the Program you subscribe to and whether or not you use a Third-Party Service (as defined in the General Terms and Conditions of Use, such as Facebook) to register and use the Program. If you use a Third-Party Service to create an account, we will receive personal data through that Third-Party Service, but only if you have authorized that Third-Party Service to share your personal data with us. |
Personal data collected through your use of the Program
| Personal data |
|---|