Privacy Policy
Introduction :
Thanks for joining the program! We want to give you the best possible experience to make sure you get our best deals, deals, benefits and events, today, tomorrow and in the future. To do this, we need to manage your earnings and the rights that you have acquired or that have been granted to you by the businesses and partners who are members of the program, to inform you about the offers reserved for you, to understand your centers of interest and preferences so that we can provide you with exceptional and personalized service, tailored just for you. The privacy and security of your personal data is, and will remain, a top priority for us. We therefore want to explain to you in a transparent way why we collect, store, share and use your personal data. We will also introduce you to the control and choice tools 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.
About this Policy
This Policy sets out essential information relating to the use of your personal data under the Pass'Partout program, developed by EPIC Corbier Tourisme, designed and operated by SMARTFIDELIS. The Policy applies to all services accessible by irtue of your membership in the program and through the use of your account and cards in member businesses and associated services (referred to as the "Program"). The terms governing your use of the Program are set out in our Terms of Service (the “Terms of Service”).
We sometimes develop and offer new services or additional offers. If the introduction of these new additional services or offerings results in a change in the way we collect and process your personal data, we will provide you with urther information and additional terms or policies.
Unless otherwise specified, new services or additional offerings 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 collect and use it, and with whom we share it; Detail how we use the personal data you share to provide you with the best experience when using the Program; and Define your rights and choices relating to the personal data we collect and process, and explain how we protect your privacy.
We hope this Policy will help you understand our commitments to protecting your confidentiality and privacy. For more information about the terms used in this Policy, visit our Privacy Center. To contact us with questions or concerns, ee Section 13 "Contacting Us" below. If you do not agree with the content of this Policy, you are free to decide whether you want to use the Program.
Your rights and preferences: choice and control
As you may know, a new European Union regulation called the General Data Protection Regulation or “GDPR” grants individuals certain rights in relation to their personal data. Accordingly, we have implemented additional ccess controls and transparency measures under our privacy policy and in the privacy settings of your account on the Program, to help users benefit from these rights. Except as limited by applicable law, the following rights are granted as available to individuals:
- Right of access: the right to be informed and to request access to the personal data we process;
- Right of rectification: the right to ask us to modify or update your personal data when it is inaccurate or incomplete;
- Right to erasure: the right to ask us to permanently delete your personal data;
- Right of restriction: the right to ask us to temporarily or permanently stop processing all or part of your personal data;
- Right of refusal: 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, in the event that the decision would have a legal effect on you or would produce a similar significant effect. In order to allow you to easily exercise these rights and to record your preferences related to the use of your personal data by EPIC Corbier Tourisme within the framework of the Pass'Partout, we give you access to the following parameters via the Personal data page of your account . You will be able to: Manage your privacy settings Set your notification preferences, Update or delete your data in connection with the services of the Program, Download your personal data Close your account.
The Program's new privacy policy gives you control over how the Program handles 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 as otherwise permitted by applicable law, you may, at any time, either withdraw your consent or indicate your refusal (“Opt-out”) without charge. The electronic marketing messages you receive from the Program (by e-mail for example) also include an opt-out (i.e. an unsubscribe link in the e-mails sent).
If you have any questions about your privacy, your rights or how to exercise them, contact us using the "Contact Us" form in the Privacy Center. We will respond to your request within a reasonable time, after verifying 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.
How do we collect your personal data?
We collect your personal data as follows:
When you register for the Programme: When you register for the Programme, we collect certain personal data, such as your e-mail address, date of birth, title and address, to enable you to use the Programme. 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 businesses you have consulted and the preferences you have mentioned. Personal data collected for the purpose of providing you with additional functions/functionalities: you may sometimes provide us with additional personal data or give us your authorization for the collection of other personal data, for example to take advantage of additional functions or functionalities. As described below, we do not collect any photos, voice data or contacts from your device without your prior consent. You will always be able to change your mind and withdraw your permission at any time.
From third parties: we receive personal data about you and your activity from merchants and service providers who are members of the Program and possibly from third parties, including advertisers and partners with whom we work in order to provide you with the Program (please see below Section 7, Sharing your personal data). We will use this personal data if you have given your authorization for the sharing of this data with a third party or with EPIC Corbier Tourisme or if EPIC Corbier Tourisme has a legitimate interest in using this personal data in order to provide you with the services of the Program.
We use aggregated and anonymous information for purposes such as conducting research, analyzing data, creating marketing and promotional models, improving the Program, and developing new features and functionality within the Program.
What personal data about you do we collect?
We have defined in the tables below the categories of personal data that we collect and use:
Personal data collected when you register for the Program
| Categories of personal data | Category Description |
|---|---|
| Account Registration Data | This is the personal data that you have provided or that we have collected to allow you to register and use the Program. They include your e-mail address, your date of birth, your civility, your address. Some required personal data is needed to create your account. You have the option of providing us with additional personal data to further personalize your account. The exact personal data we collect depends on the services and benefits you will request in the Program to which you subscribe and whether or not you use a Third Party Service (as defined in the Terms of Service, 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 person |
Personal data collected through your use of the Program
| Categories of personal data | Category description |
|---|---|
| Program usage data | This is personal data collected when you use the Program. They may include: Information on your earnings, benefits, rights, participation in good plans, activities and Program events. Information on your interactions with the Program, such as the date and time of each transaction, the amounts, quantities, rights acquired or consumed under the advantages of the Program, consultations of offers and tips, your articipation in games of lottery, draw, instant winners, in particular in connection with your presence in a point of sale. It may also include details of your use of Third Party Applications, advertising and Program-related communications you receive. In-store presence data such as day and time by localized identification of your Smartphone by wifi and/or bluetooth as part of your explicit agreement to participate in games and lotteries, benefit services or new services offered by the Program. Messages you send and/or receive through the Program and your interactions with the Program's Customer Service team. Technical Data which may include URL information, cookie data, your IP address, the types of devices you use to access or connect to the Program, unique device IDs, device attributes, connection type network (e.g. Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, digital rights management information, operating system. You can find more details about the technical data we process in our Cookies Policy. |
Personal data collected with your permission and enabling us to provide you with additional features or functionality
| Categories of personal data | Category Description |
|---|---|
| Voluntary mobile data | In addition to the mobile data we collect to provide you with the Program (described above), you may also consent to the collection of additional personal data from your mobile device to take advantage of features/functionality that will enhance your experience of the Program. We will not access the personal data listed below without first obtaining your consent: The precise location of your mobile device: if you allow us to access your precise location, this will allow us to access your GPS or Bluetooth to use the geolocation functionality of the Program. Your contacts: If you allow us to access your contacts, you are giving us individual access to the contacts stored on your device to help you find friends who use the Program. Your photos: If you give us permission to access your photos or camera, we will only access the images that you specifically choose to share with us and metadata about those images, including file format and image size. We will never be able to scan or import your photo library or camera roll; Your voice data: If you give us permission, this allows us to access voice commands entered through your device's microphone, to allow you to use the Program by voice. Please note that you will always have the option to disable the microphone functionality; and, We may collect this personal data if you subscribe to a service (as defined in the Terms of Service) or if you perform other actions through the Program. The personal data collected may vary depending on the service. |
| Data relating to competitions, lotteries and sweepstakes | This personal data is used to allow you to register and participate in these types of operations. The exact personal data collected varies by operation. |
| Marketing data | This personal data is used to enable the Program and its partners/service providers to send you marketing communications, either: by e-mail, SMS, notifications while using the Program and/or directly from a third party. You can learn more about the personal data collected and the controls you have over the marketing communications you receive through the Privacy Center. |
How do we use your personal data?
When you use or interact with the Program, we use different technologies to process the personal data we collect about you for various reasons. We have set out in the table below the purposes for which we process your personal data, he associated legal standards we rely on to lawfully process your personal data, and the categories of personal data (identified in section 5 “What personal data about you do we collect?”) used for these purposes:
| Description of why the Program is processing your personal data (“purpose of processing”) | Legal basis of the purpose of the processing | Categories of personal data used by the Program for the purpose of processing |
|---|---|---|
| Provide, personalize and improve your experience of the Program and other services and products offered by SMARTFIDELIS on behalf of the Program, for example by providing tailored, personalized or localized content, benefits, deals, unctions and advertising on the Program or outside, on behalf of merchants who are members of the Program, including for third-party products and services. |
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| Understand how you access and use the Program to ensure the technical functionality of the Program, develop new products and services, and analyze your use of the Program, including your interaction with applications, advertisements, products and services that are offered, associated or provided by the Program. |
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| Communicate with you for Program-related reasons. |
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| Process your payments and prevent or detect fraud, including fraudulent payments and fraudulent use of the Program. |
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| Communicate with you, either directly or through one of our partners, to: -marketing, the research, participation in contests, surveys and sweepstakes, for promotional purposes, via emails, notifications or other messages, in accordance with the authorizations you have given us (on the Account Settings page, for example). |
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| To provide you with features, information, advertising or other content based on your specific location. |
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If you would like further information regarding the balancing test EPIC Corbier Tourisme has put in place to substantiate its claim to the legal basis of legitimate interest under the GDPR, see Section 13 Contact Us for our contact details.
Sharing your personal data
We have established categories of recipients for the personal data collected or generated by your use of the Program.
Publicly accessible information None of your personal data is publicly accessible.
Information with restricted access Only personal data related to your use of the Program, including your name and/or card number, your contact details, your profile photo (if registered), the history of your transactions in connection with a merchant or a service provider, the history of your interactions with its offers, benefits, events, games and lotteries are accessible by the merchant or service provider concerned.
The recipients of your personal data are our own management teams (EPIC Corbier Tourisme and SMARTFIDELIS), our technical service providers and our partners the Tourist Offices of the Toussuires, Saint Jean de Maurienne, Saint Jean d’Arves, Saint Sorlin d’Arves and Corbier. The Tourist Offices mentioned above are in charge of data qualification operations, enrichment of customer knowledge and management of customer relations for non-commercial purposes (information on events in the valley, new , ...).
Personal data you may choose to share The following personal data will only be shared with the categories of recipients described in the table below if: + you choose to use a specific functionality of the Program for which the sharing of particular personal data is necessary for the proper use of said functionality from the program ; or + you give us your permission to share the personal data, for example by selecting the appropriate setting in the Program.
| Categories of recipients | Reason for sharing |
|---|---|
| Third-party applications that you connect to your account on the Program | If you connect your Program account to a Third Party Application, such as social networks, the Program may share your identification and service usage data in order to connect you to your Program account. |
| Third-party application you use to log in to your account on the Program | If you sign in to a Third Party Application using your Program account credentials, then the Third Party Application may have access to certain service usage data, such as your interests and preferences. You will receive a notification before logging into the Third Party Application telling you what personal data will be shared/accessible for that Third Party Application. |
| Support Services | When you request assistance in the use of the Program, we will give access to your personal data in connection with your request for assistance to the service mandated to carry out this assistance. |
To learn more about managing notifications, publicly available information, and what you share with other users, see Section 3 “Your Rights and Preferences: Choice and Control” of this Policy and the Privacy Center. Information We May Share
| Categories of recipients | Reason for sharing |
|---|---|
| Service providers and other partners | We use the services of technical service providers who can operate the technical infrastructure we need to provide the services of the Program, in particular the service providers who host, store, manage and maintain the Program website, its content and the data we process. We use technical service providers to help us communicate with you as described in section 6 of this Policy. We use marketing and advertising partners to show you more personalized content or better understand your use of the Program in order to provide you with better service. We may also share personal data with certain marketing and advertising partners to send you promotional communications about the Program, or with service providers in charge of providing user assistance. |
| Merchants and service providers participating or partners of the Program | If you apply for membership in the Program through a participating Program merchant or service provider or Program partner, we share your personal registration data and general activity data with that third party regarding your use. of the Program to find out if you have used the offer that triggered your membership, if you have activated an account on the Program or if you have actively used the Program. We may also share your personal data under a pseudonym with our public or economic partners to help them understand how the content to which they give us access is used and the impact on the development of the services associated with the Program. We also share your personal data under a pseudonym with marketing partners who support our promotional efforts and with advertisers who allow us to offer you services of advantages, freebies and good deals. |
| University researchers | We share your personal data for activities such as statistical analysis and academic study, but only under a pseudonym. |
| Data protection and law enforcement authorities | We share your personal data when we have a good faith belief that disclosure is necessary to comply with legal obligations under applicable law or to respond to valid legal process, such as a search warrant, court order, or subpoena. We also share your personal data when we have a good faith belief that disclosure is necessary for our own or a third party's legitimate interests of national security, law enforcement, litigation, criminal investigation, protection the safety of a person or to prevent death or any imminent bodily harm, if we judge that this interest overrides your interests or freedoms and fundamental rights requiring the protection of your personal data. |
Program Designer and Operator |
The designer and manager of the SMARTFIDELIS Program is in charge of all processing and protection of all personal data related to the Program. As such, it is of course mandated to share all personal data and has undertaken to comply with all the terms and conditions related to the protection of your personal data and compliance with the general conditions of the program. You will be informed of any transfer of your personal data in the event of a change of manager or any application of new privacy policies. |
Retention and deletion of data
We retain your personal data only as long as necessary to provide you with the Program and for legitimate and essential business purposes, such as maintaining a performing Program, making data-based business decisions about new features and offers, compliance with our legal obligations and dispute resolution. We keep some of your personal data as long as you are a user of the Program. For example, we keep the history of your transactions, rights, benefits, your interactions with the program and its partners as well as all the information related to your account.
At your request, we will delete or anonymize your personal data so that you can no longer be identified, unless the law authorizes or requires us to retain certain personal data, in particular in the following situations:
If there is an unresolved issue with your account, such as an unresolved complaint or dispute, we will retain necessary personal data until the issue is resolved;
If we are required to retain personal data due to legal, tax, auditing and accounting obligations, we will retain necessary personal data for the period required by applicable law; and order
If this data is required for our legitimate business interests, such as fraud prevention or the safety of our users.
Connections :
We may display third-party advertisements and other content that redirects to third-party websites, including the sites of merchants and service providers who are partners of the Program. We cannot control or be responsible for the content and privacy practices of third parties. If you click on a third-party advertisement or link, you will leave the Program and any personal data provided will not be covered by this Policy. Please read that third party's privacy policies to learn how your personal data is collected and processed.
Security of personal data
We are committed to protecting the personal data of our users. We implement appropriate technical and organizational measures to protect the security of your personal data. However, please note that no system is completely secure. We have various policies in place, including pseudonym, encryption, access and retention policies to prevent unauthorized access and unnecessary retention of personal data in our systems.
Your password protects your user account, so we encourage you to use a secure and unique password, limit access to your computer and browser, and log out after using the Program.
Minor children
The Program is not intended for minors under the age of 18.
We do not knowingly collect personal data from minors under the age of 18 or the legal age limit. If you are under the Legal Age Limit to be of legal age, please do not use the Program and do not provide any personal data.
If you are the parent of a minor under the Age Limit and become aware that your child has provided personal data to the Program, contact us using the "Contact Us" form in the Privacy Center and ask to apply your rights described in Section 3 Your Rights and Preferences: Choice and Control of this Policy. If we learn that we have collected the personal data of a minor under the age of 18, we will take reasonable steps to delete that personal data. We will be obliged to delete the account of this minor on the Program.
Changes to this Privacy Policy
We may make changes to this Policy. If this Policy changes, we will notify you by means of appropriate notices, for example, by displaying a notice in the Program or by sending you an e-mail. We may notify you of such changes in advance. Be sure to read these notices carefully.
Contact us
Thank you for reading our Privacy Policy. If you have any questions about this Policy, contact our Data Protection Officer using the contact form in the Privacy Center or by writing to us at:
SMARTFIDELIS – 48 avenue du lac du Bourget – BP 304 – 73377 LE BOURGET DU LAC CEDEX
SMARTFIDELIS is the data controller with regard to personal data processed under this Policy.