We want you to understand the nature of the personal information we collect, how we use it, with whom we share it, how we strive to protect it, how you can access and/or correct it, and finally, how to contact us if you have any questions.
This document also aims to provide you with all the information required by Article 32 of the Data Protection Act and Article 13 of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR” General Data Protection Regulations).
Finally, please be aware that we may be obliged to make changes to this document, for example to comply with any new regulations or to adapt it to our practices.
Article 1– Data Controller
The information collected through the various forms for the collection of Personal Data on the Site is processed by O’Sullivans Development as the data controller.
Article 2– Collection of Personal Data by O’Sullivans Development
The concept of personal data refers to any information relating to an identified or identifiable natural person, i.e., a person who can be identified, directly or indirectly. O’Sullivans Development collects the Personal Data of Users, namely: their family name, first name, email, and telephone number.
While browsing the Site, O’Sullivans Development is also likely to collect connection data (IP address, logs, terminal identifiers, login identifiers, timestamp information…) and internet data (Cookies, trackers, browsing data, audience measurement…).
Article 3– Purpose(s) of Personal Data Processing and Legal Bases
O’Sullivans Development is a company that encompasses several brands, all belonging to the Cafés, Hotels, and Restaurants (CHR) sector.
The collection of Users’ Personal Data enables O’Sullivans Development to:
- Be better acquainted with the Users’ profiles and adapt its content accordingly.
- Measure the dissemination of its content on the website.
Thus, personal data may be used by O’Sullivans Development for the following purposes:
- To send newsletters by email, with the legal basis for this processing being legitimate interest and the right to object.
- To analyse User navigation and choices on the website for profiling purposes, for content personalization, with the legal basis for this processing being consent.
- To generate statistics, with the legal basis for this processing being legitimate interest.
- To handle all User inquiries/complaints, with the legal basis for this processing being legitimate interest.
- To manage requests to exercise individuals’ rights (right of access, rectification, erasure, objection, and portability), with the processing of Personal Data being mandatory by law.
- To justify, in case of dispute, compliance with our legal and regulatory obligations. The processing of your personal data as is mandatory by law.
Article 4–Communications sent by O’Sullivans Development
4.1 Categories of communications sent to the User
Users may receive the following communications:
- Service Emails
Upon registration on the website, you will receive a confirmation email. Receipt of this information is not related to your choices regarding reception of newsletters.
- O’Sullivans Development Newsletters
Following registration on the website, if you have not refused, you may receive newsletters from O’Sullivans Development by email. These communications keep you up to date about O’Sullivans Development. You can unsubscribe from these communications at any time.
- Surveys/Opinion Requests
We may also seek your opinion through surveys sent by email. You can decline these surveys or opinion requests directly in these emails or by informing us.
4.2 How to exercise your choices?
You can, at any time, object to the uses of your Personal Data described above:
- During your website registration via the checkbox or when entering your email address.
- By clicking on the “Contact Us” section on the website.
- By directly contacting O’Sullivans Development by email, phone, or postal mail.
- By clicking on the unsubscribe link for newsletters or notifications, which is included in every email sent.
Article 5– Recipients or Categories of Recipients of Personal Data
Your Personal Data is intended for O’Sullivans Development.
It may also be disclosed to subcontractors engaged by O’Sullivans Development to provide its services for the aforementioned purposes. O’Sullivans Development ensures compliance with data protection requirements for all its subcontracted companies.
O’Sullivans Development may also disclose your personal data when such disclosure is necessary in order to:
- Comply with the law (or a summons or court order).
- Comply with legitimate requests from public and government authorities.
- Prevent a crime or conduct an investigation, such as in cases of fraud or identity theft.
- Protect the rights, property, or safety of O’Sullivans Development, its users, or third parties.
Article 6 – Transfer of your data to a country outside the EU
It is understood that data transfer refers to any communication, copying, or movement of personal data intended to be processed in a third country or any data that a third party located outside of France may access.
Your data is not transferred outside the European Union by O’Sullivans Development.
In the event that your data were to be transferred to O’Sullivans Development partners located outside of the European Union, we guarantee that we:
have obtained all necessary authorisations from the competent authorities to carry out said transfer.
have framed this transfer with the standard contractual clauses of the European Commission or any other transfer safeguard mechanism recognized by the GDPR.
Article 7 – Individual Rights
You have the right to access, rectify, delete, and to the portability of your data. You can also request the restriction of the processing of your data or object to such processing.
You have the right to communicate to O’Sullivans Development your directives regarding what happens to your personal data in the event of your death.
You can exercise your rights with O’Sullivans Development by:
- Email at firstname.lastname@example.org
- Postal mail at 169 rue Montmartre, 75002 Paris, France
O’Sullivans Development reserves the right to request the payment of “reasonable fees” related to administrative costs incurred in providing information if your request is manifestly unfounded or excessive. We will endeavor to respond to your requests within the timeframes required by the GDPR.
To protect your privacy and ensure your security, we will also take appropriate measures to verify your identity before providing you access to your personal information or correcting, modifying, or deleting it. Therefore, any request may need to be accompanied by a copy of your identity card.
If your rights are not respected, you have the right to lodge a complaint with the CNIL.
Article 8 – Data Security and Confidentiality
Security of Your Data:
We implement organisational and technical security measures to ensure the confidentiality and veracity of your personal data.
To this end, administrative, organizational, technical, and physical precautions are taken to protect your personal data from loss, theft, unauthorized access, unauthorized transmission, alteration, or destruction. In any event, O’Sullivans Development will take security measures appropriate to the nature of the data collected.
The collected data is stored confidentially and protected at a very high level of security. The servers where this data is stored comply with the current security standards. They are protected against digital and physical attacks.
All pages of the website on which you are required to provide personal data are secured with HTTPS. However, despite all efforts, O’Sullivans Development cannot guarantee the infallibility of this protection due to inevitable risks that may arise during the transmission of personal data.Security of Data transmitted to our external service providers:
We always select our external service providers with the utmost care and attach great importance to the security of your data. These providers only act on O’Sullivans Development’s instructions and at no time use your data for any purpose other than the performance of the services entrusted to them.
A contract is systematically drawn up between O’Sullivans Development and the selected service providers, in which we require the implementation of appropriate technical, physical, logical, and organizational measures to ensure the confidentiality and security of personal data processed and so prevent distortion, damage, or unauthorized access by third parties.
Article 9 – Data Retention Period
O’Sullivans Development only retains your personal data for the time necessary for the operations for which they were collected and in compliance with current regulations and the following retention policy:
|Categories of personal data||Data storage duration|
|Identification data necessary to process various services offered on the website (e.g. website registration).||The time necessary to obtain the purpose sought during the collection of this data|
|Identification data for sending Newsletters/ Questionnaires.||Until withdrawal of consent, and no later than 3 years from the last activity.|
|Data relating to information and complaints.||3 years from their collection or the last contact or the end of the commercial relationship.|
|Data supporting the establishment of a right or contract.||5 years from their collection or from the last contact or the end of the commercial relationship.|
Some data may be kept for an additional period for the management of claims and/or disputes, as well as to meet our legal or regulatory obligations or to respond to any requests made by authorized authorities.
Data is deleted without delay when O’Sullivans Development becomes aware of the person’s death.
Article 10 – Cookies
When visiting the website, information related to your browsing may be stored in files called “cookies” installed on your device, subject to the choices you have expressed regarding cookies, which you can modify at any time.
Cookies allow the visited website to monitor, store, and retrieve information about your browsing habits, as well as obtain technical information about the site’s navigability.