Alfred | Privacy Policy

1- General Purpose

These Terms and Conditions will define the terms under which Customers, Users and/or Customers are permitted to use the Website and the terms of access to and operation of the Services offered by Alfred on the Website.

www.alfred.travel is an online platform that offer services to individuals who would like information about their trip to Paris, and/or products and services that facilitates their stay in Paris. Only Alfred general terms and conditions shall apply in the valid online version at the time of the order (https://www.alfred.travel). Alfred may accept variant clauses only in the case of explicit written agreement.

The Website offers online booking and payment of these services.

2- Definitions

This privacy policy contains all the information applicable to the treatment of personal data collected on the website or through other alternative means used to contact Alfred Travel.

This Privacy Policy does not apply to third-party products and services or third-party websites that can be accessed through the links on our website for the user's convenience and/or information. Regarding access to third party links, you should consult our Terms and Conditions in advance.

3- Responsible for the Treatment of Personal Data

Within our organisation, a contact person is dedicated to answer or clarify your doubts in this field and, as well, exercise the rights that are recognised to you, whenever you feel this need. Please email the address above or at the Headquarter address.

Email address: we-are-alfred@alfred.travel

4- Principles followed by the Responsible, Security and Protection of Personal Data

As Responsible for Processing, Alfred Travel processes your personal data lawfully, always collecting your free, specific, informed, and explicit consent whenever required under the law. The purpose(s) for which your data is collected is(are) solely, and exclusively the one(s) described here.

The collection of personal data is carried out based on the Principle of Minimization. Alfred Travel only collects data considered essential for the pursuit of the purpose in question

6- Personal data collected and Purposes

6.1 General Conditions

Customers agree, for each of the specific applicable conditions, to comply with regulations on the processing of personal data and in particular, the General Data Protection Regulations (EU regulation 2016/679 of the European Parliament and Council of 27 April 2016).

6.2 Purpose of Data collection

Alfred must process personal data to provide the services they offer.
The personal data processed through the website will only be used for the following purposes:

• Service scheduled by Clients;
• Communication with Users and clarification of doubts;
• Processing of information requests;
• Complaints processing;
• Statistical analysis activities;
• Monitor, maintain and develop systems and statistical analysis;
• Direct marketing communications, namely the newsletter (if the User has consented to the processing of their data);
• Request for comments on services provided by Alfred Travel
• Conducting satisfaction surveys.

The website has a chat available 24 hours a day, in which Users can ask the questions they want if they do not find the answers on our page. However, if the Users provide personal data to Alfred Travel through chat or even through other forms of contact, they will not be used for any purpose other than what is requested by the User.

6.3 Data collected

The minimum characteristics of this data-processing are as follows :

The objective of processing personal data
Type of personal data processed : Name, First name
Email address
Telephone number
Postal address
Bank account details

Categories of people concerned : Customers
Location where the data is processed : European Union

Subsequently, depending on the type of interaction or service contracted with Alfred Travel, Alfred’s team may request other data to formalise the process and conclusion of the respective contract or partnership agreement.

Alfred is responsible for data processing and will comply with the obligations of the applicable regulations above, notably the obligation to inform the required persons, maintain a data-processing log, and in general adhere to the principles of the regulation.
The data supplied by Customers to Alfred for the purposes of service provision remain the property and responsibility of Customers. Alfred operates exclusively as a personal data processor.

6.4 Obligations of Alfred to Customers

Data processing
Alfred agrees to process data only with the objective of operating services and in compliance with the written instructions of the Customer, including with regards to the transfer of data outside of the European Union. Alfred agrees to inform the Customer if, in its opinion, an instruction constitutes a violation of applicable regulations.

Security and confidentiality of data
Alfred commits to implementing appropriate technical and organisational measures to ensure the security and integrity of personal data, its backup and restoration if a physical or technical incident occurs. Consequently, Alfred guarantees the Customer against fraudulent or illegal use of their data, against destruction, partial loss, total loss or theft of their data. Alfred ensures that persons authorised to work with their data are subject to the obligation to keep them confidential. Alfred commits to not divulging or passing on personal data, whether for free or paid, directly or indirectly, and to not reproducing, copying, communicating, or making personal data accessible to any third-party in any form or by any means.

Data storage
Alfred commits to storing data inside the European Union.
Other data processors
Alfred agrees not to subcontract the processing of personal data to any other data processors without the prior, specific, or general written agreement of the Customer. Where the authorization is general, Alfred agrees to inform the Customer of any expected change or addition of subcontractor and the Customer has the right to object to such changes.

Supplier information
Alfred agrees to respond to any request for information made by the Customer, whether exercising their right to request information, as part of an impact analysis, a request by data protection authorities or the mandated data protection representatives of the Customer.

Notification of data breaches and complaints
Alfred agrees to notify the Customer of any breaches of the security of personal data or of any complaints made by anyone about the data within 48 hours of being informed of such. Where the Customer themselves declares a data breach to data-processing authorities, Alfred agrees to provide the Customer with all relevant information and contact details. In general, Alfred agrees to inform the Customer as soon as possible of any dereliction of their duty, by its employees, service providers or by third parties of which it may have knowledge and inform the Customer as soon as possible of any request concerning their (personal) data.

Cooperation with data protection authorities
Alfred agrees to cooperate with data protection authorities at the request of the Customer, notably on information requests which may be made to either party as part of an inspection. If Alfred should receive a request from administrative or judicial authorities, then Alfred agrees to inform the Customer immediately

Data conservation
Alfred agrees to delete personal data six months after the expiry of the contract, no matter the reason for contract termination and not to retain a copy of the personal data. By extension, data may be deleted before this date on explicit request by the Customer.

Register and documentation
Alfred maintains a register of data processes carried out on behalf of Customers. The register contains information on data processes executed. Alfred agrees to provide the Customer, on request, with all information to demonstrate that it complies with its obligations.

6.5 Personal information

All data provided by customers during the rental and usage of the Alfred equipment will be protected corresponding to the relevant terms of privacy regarding customer data. All customer provided data saved by Alfred, will be explicitly used for purposes of contractual fulfillment and to inform the customer about products related to their contractual agreement. In this regard the customer agrees explicitly, that they approve and agree to the mailing of such information, also for marketing purposes and in electronic form, e.g. via email.

A revocation of consent may be served at any time, but must be made in writing to Alfred, stating the affected email addresses. Any such data is is protected by French law “Loi N° 78-17 Informatique et libertés du 6 Janvier 1978” that states that the customer can access, modify, or delete any personal data, and that he could use this right by writing to: Guz Biz International, 8 route de Samois, 77210 Avon – France.

You have a right to access, modify, rectify and delete your personal data held by Alfred. This data is for the use of Alfred and may be disclosed to third parties to confirm your services booking. To exercise your rights or if you do not wish your personal data to be disclosed, please contact Alfred Customer Service.
6.6 Limitation of Alfred’s Liability

If you come to interact with Alfred Travel social networks in particular, please be aware that we collect personally identifiable data and any other information that you provide when interacting with us. Each of the aforementioned social networks has its privacy policies, which Alfred Travel is unrelated to. For this reason, the User, from the moment he decides to interact through these channels, is the only and exclusively responsible for what the prior consultation is advisable for such documents.

7- Period of retention of personal data

The period of retention of data varies according to the purpose for which the information is processed.

Personal data collected based on consent are kept for five years from the last date on which your permission was obtained unless previously requested by the respective holder to be deleted.

The data collected based on pre-contractual diligence and execution of the service provision contract will be kept until the contract is in force. Due to legal imposition or compliance with a legal obligation, the processing is necessary for a legal obligation time more extended.

At any time, you may cancel periodic direct communications previously consented to by Alfred Travel and stop receiving them. To do so, just in the communications you receive, click on the option “unsubscribe”, as a rule, available in them.

8- Treatment of Minors' Personal Data

As a rule, data is not collected or processed, by any means, under the age of 18. If, for any circumstance, this occurs, know that the treatment is only lawful if and to the extent that consent is given or authorised by the holders of parental responsibilities.

In that case, Alfred Travel will make every effort to verify that consent has been given or authorised by the holder of parental responsibility, taking into account the available technology.

9- Transmission of Data to Third Parties

Personal data collected from your interaction will not be transmitted to third parties other than Alfred Travel unless legally imposed or by an investigation by the competent authorities.

Concerning the data of the Users, considered as Client, Keepers or Partners, these, for the execution of the respective contract, may be transmitted to third parties subcontracted by Alfred Travel which will, in due course, be known by the respective owners.

Please note that Alfred Travel may also, anonymously, transmit the personal data of its Users to:

• Payment and billing processors and facilitators;
• Security verification service providers;
• Cloud Storage providers;
• Google and/or AWS servers;
• Data analysis providers;
• Encrypted communication service providers, to be used during the provision of services;
• Partners that help Alfred Travel improve the security of our website.

10- Confidentiality

The confidentiality of all information that the User transmits is guaranteed.

Alfred Travel undertakes to protect the information disclosed with great care and, to that end, has adopted the necessary measures to prevent the use and dissemination of the data by any person other than itself, unless it consents in writing to such disclosure, which will be done on the agreed terms.

The information disclosed on the website is the sole and exclusive property of the disclosing entity or the property of those who have authorised such disclosure. Alfred Travel does not have any right over any type of information that may be transmitted to it to which it had access.

11- Security of Personal Data

Alfred Travel uses several technical and organisational measures to protect the personal data of data subjects, depending on what is appropriate for the specific case:

• Pseudonymization and encryption of personal data;
• Ability to ensure the confidentiality, integrity, availability and permanent resilience of treatment systems and services;
• Ability to restore availability and access to personal data promptly in the event of a physical or technical incident;
• Implementation of a process to test, assess and regularly evaluate the effectiveness of technical and organisational measures to ensure treatment safety, among other actions considered appropriate and relevant on a case-by-case basis.

In the case of subcontracting service providers, they will have to guarantee the same level of protection.

The violation, or attempted breach, of the personal data for which Alfred Travel is responsible will be reported to the judicial authorities, as well as to control and supervision. If the breach involves a high risk for the holders of personal data, they will be informed of the incident.

12- Cookies Policy

Alfred Travel uses cookies and other identification technologies on the website for the following purposes:

• Authenticate Users;
• Remember Users' preferences and settings;
• Discover the popularity of a content;
• Disseminate and measure the effectiveness of marketing campaigns;
• Analyse trends and traffic to understand online behaviours and the interests of people who interact with services. It may also allow other entities to provide measurement and analysis services to Alfred Travel showing advertisements on the Internet on behalf of the brand and monitoring the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify their device when they visit the website and use the Alfred Travel services and when they visit different websites and online services.

Cookies are files with a small amount of data that are usually used as unique anonymous identifiers. These are sent to your browser from the user visits and stored in your device's internal memory.

This service does not use "cookies" explicitly. However, the page may use third party code and libraries that use "cookies" to collect information and improve its services. The User can accept or refuse these cookies and know when a cookie is being sent to his device. If you choose to decline Alfred Travel cookies, you may not be able to use some parts of the proposed service. This Cookie Policy is periodically reviewed, so its content may be updated.

13- Exercise of rights

Following the provisions of Law No. 58/2019 and the GDPR, the User can exercise his rights of access, rectification, deletion, limitation, opposition, and portability at all times by requesting any of the following means:

E-mail: we-are-alfred@alfred.travel

If the User wishes, at any time, to stop being part of the Alfred Travel database, he can exercise this right through these contacts, providing the respective identification for this purpose.

14- Changes to the Privacy Policy and applicable legislation

This privacy policy can be frequently updated whenever it is justified by Alfred Travel and without prior notice, informing you of the date of the last update, so it is advisable to read it periodically.

The use of the site assumes that you know and accept this Privacy Policy and the Terms and Conditions of Use of the same.

Last Updated: 1fst of February 2023

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