Personal data (“Personal Data” or “Data”) means any information relating to an identified or identifiable natural person:

• directly (last name, first name, email address)
• or indirectly (IP address).

This Policy applies to all our services (the “Services”), i.e. our consulting and management services, dedicated to the luxury hotel industry, as presented via our website www.lph-group.com (the “Site”).
Our Policy is intended to inform any person using our Services or visiting the Site (the “User” or the “Customer”).

The Data Controller, within the meaning of the RGPD, is the simplified joint stock company SAS Luxury Places & Hotels, represented by Isaac DAYAN.

Luxury Places & Hotels collects your Data online (including by e-mail), on paper or orally (during a physical appointment, by videoconference or by telephone) and this Policy applies regardless of the method of collection or processing.

The Personal Data that the User agrees to communicate to us, regardless of the method of collection (online, paper or oral), are subject to the provisions of this Policy.

Some of your Data is necessary for the processing and provision of our Services. Failure to provide this information will prevent our Services from functioning properly.
For your information, you will find below a list of the categories of data collected corresponding to the purposes pursued by our collection as well as the legal basis for this collection.

To answer your contact request :

• Categories of Data collected: identity data (surname, first name), contact data (e-mail address, telephone number).
• Legal basis: legitimate interest in offering you our Services.

To respond to your request for a quote :

• Categories of Data collected: identity data, contact data, quotation number, professional data.
• Legal basis: pre-contractual measures taken at your request.

To enable you to subscribe to and use our Services:

• Categories of Data collected: identity data, contact data, customer data (order form, billing address), professional data.
• Legal basis: contractual measures taken at your request.

To manage customer and supplier invoicing :

• Categories of Data collected: identity data, contact data, customer data, professional data, economic and financial data.
• Legal basis: contractual measures taken at your request.

To subscribe to our newsletter :

You can subscribe to our newsletter via the link provided on our Site.

• Categories of Data collected: identity data (surname, first name) and contact data (email address).
• Legal basis: your consent by checking the appropriate box when you subscribe to our newsletter.

You can unsubscribe from this newsletter at any time by clicking on the link provided in each newsletter.

To process your response to a job offer :

• Categories of Data collected: identity data (surname, first name), contact data (e-mail address, telephone number), information contained in the curriculum vitae and covering letter (photograph, professional background).
• Legal basis: pre-contractual measures taken at your request.

To carry out statistical operations on the number of visitors to our website:

• Categories of Data collected: browsing data (IP address).
• Legal basis: your consent when you accept the deposit of statistical cookies.

When you request a quote, some of your personal and contact data must be processed. Indeed, we cannot draw up a quotation without processing this Data.

Please note that when you give your consent to the processing of your Personal Data, you have the option of withdrawing this consent at any time via the unsubscribe links present in each promotional email.

Subject to compliance with the legal obligations imposed on Luxury Places & Hotels in the course of its business, each individual may exercise the following rights:

• Request a copy of your Data – Right of access
• Correct inaccurate personal data – Right of rectification
• Request the deletion of certain Data concerning you – Right of deletion
• Oppose our processing of your Data; we draw your attention to the fact that this request is incompatible with the processing of your subscription to our Services – Right of opposition
• Decide at any time to withdraw your consent, for example via the unsubscribe link in each newsletter – Right of withdrawal
• Request to limit the use of your Data – Right to limit processing
• Oppose profiling of your Data – Right to oppose profiling
• Exercising your right to portability

You may formulate directives concerning the retention, deletion and communication of your Data after your death, in accordance with Article 40-1 of the French Data Protection Act.

These rights and instructions can be exercised by writing to us at :

• by post to the following address LPH Group, 53 avenue Victor Hugo, 75 116 PARIS or
• electronically: contact@lph-group.com

To enable us to identify you quickly and respond to your request, please attach to your request any information that may help us establish your identity (in particular your customer number or a request made directly via your account). A reply will be sent to you within 1 month of receipt of the request. In certain cases, due to the complexity of the request or the number of requests, this deadline may be extended by 2 months.

We only keep your Data for as long as is necessary to carry out the operations for which it was collected, except where the law provides for a different retention period.

For example, in the context of sending newsletters or commercial prospecting, we keep your Data for a period of 3 years from the date of our last contact.

You acknowledge that the Data you communicate to us and which are stored in our information systems are accurate and constitute proof of your identity.

The Data collected are shared, according to their respective needs and in accordance with the purposes mentioned above, with :

• LPH staff.
• staff of external hosting services for our Website
• external accounting staff

We may share some of your Data outside the European Union with service providers located outside the European Union.

We undertake to implement all the technical and organizational measures necessary to protect your Personal Data.

For example, we apply the principle of data minimization.

However, Luxury Places & Hotels shall not be held liable in the event of total or partial non-compliance with an obligation and/or failure of the operators of the transport networks to the Internet world and in particular of its access provider(s) or its computer equipment.

We may update this Policy by posting a new version on our Site. We undertake not to lower the level of confidentiality of your Data substantially without informing you and obtaining your consent where appropriate.

If you have any questions about our Data Protection Policy, please contact us:

• by post to the following address: 53 avenue Victor Hugo, 75 116 PARIS; or
• electronically: contact@lph-group.com