The privacy and protection of our customers’ personal data is a central focus for the Monte-Carlo Société des Bains de Mer Group.
1. PERSONAL DATA COLLECTED BY MONTE-CARLO SOCIETE DES BAINS DE MER
The personal data we may collect comes from 3 different sources:
- Data collected from customers
- Data collected automatically
1.1 Data collected directly:
This data is collected:
- when you subscribe to our Newsletters;
- when you make a quotation request or a callback request.
This data may include the following:
1. Identity (title, surname, first name, company name etc.);
2. Addresses and contact details (email address, telephone number, country etc.);
3. Time and location information (activity tracking, cookies, logs, geolocation etc.);
4. Generic information about the request (type of event, dates, number of participants etc.);
5. Other information that you can provide when requesting a quote or a callback (additional information specific to your needs and/or attached document).
Some of this information will be required to process your request. If these are not communicated, this may delay or make it impossible to process your request, answer your questions or provide the products or services.
1.2 Data collected automatically:
Personal data may be collected automatically when you use our websites or online platforms. These are mainly electronic identification data (customer identification number, IP address, location data, MAC address, etc.)
2. USE OF DATA
We use your data on several legal bases:
- Your prior consent, which may be revoked at any time;
- The processing is necessary for the execution or preparation of a contract (purchases, reservations, etc.);
- Processing is necessary for the pursuit of legitimate interests of SBM (improvement of customer relations, adaptation of services, etc.)
- The processing is imposed by legal or regulatory texts;
- Your personal data is used by SBM to:
- Provide desired products or services;
- The management of offers, the monitoring of services and, more generally, the entire commercial relationship that binds us;
- verify your identity;
- Evaluate and improve our online services and perform statistical analysis;
- Manage the entire business relationship
- Carry out loyalty, prospecting, survey and promotion actions
- Carry out commercial prospecting. With your consent, you may receive offers from Monte-Carlo Société des Bains de Mer or its commercial partners.
- To comply with our legal obligations to respond to requests from public and governmental authorities.
3. PERSONAL DATA ACCESS AND CUSTOMER RIGHTS
In accordance with Regulation (EU) 2016/679 of 27 April 2016 and amended (Monegasque) Law No. 1.165 of 23 December 1993, you have a right of access to and a right to the rectification, erasure and portability of your personal data as well as a right to object and restrict the processing of this personal data. You may also define the instructions for the outcome of your personal data after your death. With proof of your identity, you may exercise your rights by contacting the Data Protection Officer (DPO) by email at data‑[email protected]. If, after contacting the DPO, you do not feel that your rights have been observed, you may make a claim with the French Data Protection Authority (CNIL – Commission Nationale de l'Informatique et des Libertés) or the Monegasque authority, the Commission for Control of Personally Identifiable Information (CCIN.mc – Commission de Contrôle des Informations Nominatives). The data which Monte-Carlo Société des Bains de Mer needs for the purpose for which they were collected, necessary for compliance with a legal obligation and/or for the establishment, exercise or defence of rights in court, may not, however, be deleted.
4. SUBCONTRACTING PROCESSING OF PERSONAL DATA
Your personal data is processed by:
- Employees of Monte-Carlo Société des Bains de Mer who are authorized to process them for the aforementioned purposes and who undertake to respect their confidentiality.
- Its subcontractors and partners, for the purposes of managing and performing the services you have requested or authorized. These subcontractors and partners of Monte-Carlo Société des Bains de Mer may be located outside the European Union. When this subcontractor or partner is located in a country which has not been recognized as providing an adequate level of protection, Monte-Carlo Société des Bains de Mer requires it to comply with its security and confidentiality requirements for your personal data and to only process your data for the purposes it has determined. Such subcontractors and partners will have previously signed the European Commission's Standard Contractual Clauses.
- On request, they can also be transferred to persons and authorities whose right of access to personal data is recognized by law, regulations or provisions issued by authorities empowered by law.
5. PERSONAL DATA RETENTION
Your personal data is stored in our databases in Monaco or in those of our subcontractors :
- For the period necessary to fulfill the purposes for which it was collected;
- To meet legal and regulatory obligations to which SBM is subject;
- To respond to requests from public and governmental authorities;
- For as long as necessary to exercise or defend legal claims;
- With regard to commercial prospecting, personal data will be kept for a maximum of three years from the end of the commercial relationship or following the last contact with SBM;
In any event, we regularly review the relevance of the information we hold. When their conservation is no longer justified by commercial requirements or related to the management of your customer account or if you have made use of a right of modification or deletion, we will delete them in a secure manner (with the exception of data necessary to establish proof of a right or a contract).
6. PERSONAL DATA SECURITY
Monte-Carlo Société des Bains de Mer implements the necessary measures to protect the personal data it processes. Your data is processed electronically and/or manually, and in any case, in such a way to ensure its security, protection and privacy appropriate for its sensitivity level, through administrative, technical and physical measures to prevent loss, theft and unauthorised use, disclosure or changes. In case of breach of your personal data liable to pose a high risk to your rights and freedoms, Monte-Carlo Société des Bains de Mer shall inform you as soon as possible and take all necessary measures to limit the risks related to this breach. Whether your data is processed by Monte-Carlo Société des Bains de Mer or by its subcontractors and partners, the same security and privacy requirements apply to your personal data.
In particular, we have:
- appointed a data protection officer;
- established a unit dedicated to information system security;
- raised awareness of privacy requirements among our employees who need to access your personal data;
- secured access to our premises and IT platforms;
- implemented a general IT security policy for the company;
- secured data access, sharing and transfer;
- and we maintain high standards for data protection when selecting our subcontractors and partners.
7.COOKIES AND OTHER TRACKERS
9. MONTE-CARLO SOCIETE DES BAINS DE MER GROUP
SOCIETE ANONYME DES BAINS DE MER ET DU CERCLE DES ETRANGERS A MONACO (SBM) with capital of 24,516,661 euros, registered in the Monaco Trade and Industry Registry under the number 56 S 523 and with intra-community VAT no. FR 07 0000 1 5486.
Headquarters: Monte Carlo Société des Bains de Mer, Place du Casino – MC 98000 Monaco.
The Monte-Carlo Société des Bains de Mer group includes SBM and its subsidiaries: SOCIETE ANONYME MONEGASQUE GENERALE D’HOTELLERIE (SOGETEL), SOCIETE ANONYME MONEGASQUE DES THERMES MARINS MONTE-CARLO (STM), Société Civile Immobilière de l’Hermitage, Société Anonyme d’Entreprises de Spectacles (SAMES), SARL CAFE GRAND PRIX.