Data Protection Policy

‘Hôtels Circuits France’ PRIVACY AND DATA PROTECTION POLICY

Last updated: 24/09/2026

Hôtels Circuits France is a network of independent French hoteliers and restaurateurs.

Hôtels Circuits SA in France is responsible, in particular, for publishing and operating the website hotels-circuits-france.com, as well as for communication and promotional activities on behalf of the network’s partner establishments.

Each hotel featured on the website is operated by a legally independent company, which retains its full autonomy and remains responsible for the accommodation, stays, services and other offerings it markets in its own name.

The presence of an establishment on the Hôtels Circuits France website shall not be interpreted as creating, between the various hoteliers or between the hoteliers and SA Hôtels Circuits en France, a joint venture or any other form of legal association other than that resulting from their membership of the network.

Hôtels Circuits France provides its customers (both private individuals and professionals) with specific services (website, newsletters, etc.).

In this context, Hôtels Circuits France has drawn up this policy in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/79), in force since 25 May 2018, and the amended French Data Protection Act.

The purpose of this Policy is to set out the personal data protection policy for users of the Hôtels Circuits France website; furthermore, by using our website, you expressly accept the provisions of this Policy.

Hôtels Circuits France’S COMMITMENT TO PRIVACY PROTECTION

We take your privacy seriously.

By using the services and the Hôtels Circuits France website, you are placing your trust in us, and we are committed to upholding that trust. To this end, we make every effort to protect and secure all the personal data you share with us. We act in the best interests of our website users.

This document explains, clearly and transparently, how we use and process your personal data, so that you can easily understand our approach.

Furthermore, we explain how to contact us if you have any questions about your personal data, and we would be happy to provide further clarification.

By ‘personal data’, we mean any information that allows a user to be identified, either directly or indirectly.

This may include personal details (surname, first name, address, email, date of birth, etc.) as well as data used to determine user profiles (interests, etc.) and thus send you personalised offers.

Hôtels Circuits France is committed to upholding the six fundamental principles of the European General Data Protection Regulation (GDPR), which form the main rules governing our processing of personal data:

1. Transparency: when collecting and processing your personal data, we will inform you of the purpose of the processing and the recipients of your data.

2. Data minimisation: personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.

3. Lawfulness: we will collect and process your personal data solely for the purposes described in this Policy.

4. Relevance and accuracy: we collect only the personal data necessary for the processing of data. We take all reasonable measures to ensure that the personal data we hold is accurate and up to date.

5. Retention: we retain your personal data for the period necessary for the purposes of data processing in accordance with the requirements laid down by law.

6. Access, rectification, objection, restriction, erasure, portability, consent: you have the right to withdraw your consent, to object to the processing of your personal data or to restrict such processing, as well as to access, amend, correct or delete your personal data. Information on exercising your rights is provided in paragraph 8, ‘Exercise your rights’

Hôtels Circuits France collects and processes data relating to you only for specific purposes and limited to what is necessary for you, namely:

1. Managing user relations (in connection with requests for quotes or information via the website hotelscircuitsfrance.com)

2. Managing commercial relations (newsletters, competitions, promotions, surveys, prospecting, contacts, online advertising, tailoring our communications to your interactions, etc.);

3. Compiling statistics on visitor numbers at establishments belonging to Hôtels Circuits France;

5. Improving our services by conducting surveys following the distribution of satisfaction questionnaires and the management of user reviews;

6. Managing any requests you may make to exercise your rights.

Other aspects of managing the commercial relationship are based on the legitimate interest in conducting commercial activities, offering promotional and personalised benefits to our users, providing solutions to respond to our users’ requests, or assessing the quality and satisfaction levels of the services provided.

Certain data processing activities take place at your request or upon your giving consent. This includes, in particular, entering your email address in the field provided for this purpose to subscribe to our newsletter, or when you make a request for commercial information or a holiday quote.

We collect and use the personal data necessary for our business activities, in particular to offer you personalised, high-quality products and services.

We may collect various types of personal data about you, including:

• contact details (e.g. surname, first name, telephone number, email address, etc.);
• personal information (e.g. day and month of birth (optional, may be used for personalised offers such as birthday promotions), nationality (enables us to send you emails in your preferred language and to send you personalised offers, etc.);
• your preferences and interests, so that we can send you personalised offers;
• your questions/comments.

We also collect data and pixel cookies from your computer, mobile phone, tablet or any other device you use to access our services. Please familiarise yourself with our cookie policy, which can be found via the ‘Cookie Policy’ link in our footer banner.

We do not wish to collect so-called ‘sensitive’ information. As such, please do not provide such information when communicating with our services (information such as health data, racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, sexual orientation, etc.).

Personal data may be collected on various occasions, both via our online tools and when you contact our services (by post or email), in particular:

1. Request for a quote for a stay at Hôtels Circuits France establishments via the website www.hotelscircuitsfrance.com:

• Request for a quote for a stay;
• Request for a catalogue or information.

2. Participation in Hôtels Circuits France marketing programmes or events:

• Registration in the Hôtels Circuits France ‘quote requests’ database;
• Completion of satisfaction surveys following stays at Hôtels Circuits France member establishments;
• Competitions organised by Hôtels Circuits France;
• Subscription to newsletters to receive offers and promotions by email.

3. Technical information:

• Your IP address;
• Information provided by your browser regarding the operating system and browser used;
• Cookies (Please refer to the rules regarding cookies in the “Cookie Policy” available at the bottom of the page).

Data is only retained for as long as is strictly necessary:

• To fulfil orders;
• To comply with legal and regulatory requirements, particularly regarding the management of disputes;
• To provide personalised services.

Our general data retention policy for the website is as follows:

• Identification data: 3 years from the date of your last visit to the website or your last contact with customer service;
• Order data: 3 years from the order date;
• Prospect data: 3 years after the last expression of interest (such as clicking on a link in the newsletter);
• Cookies / pixel tags: a maximum of 13 months from the date they are placed on your computer or device (Please refer to the rules regarding cookies in the “Cookie Policy” available at the bottom of the page).

It is our responsibility to define and implement technical security measures – whether physical or logical – in accordance with the applicable legal provisions, to protect your personal data against unlawful or accidental destruction, accidental loss or alteration, or unauthorised disclosure or access.

To this end, we have put in place technical measures (such as firewalls) and organisational measures (such as a username/password system, physical security measures, etc.).

• DATA BREACH:

In the event of a personal data breach, we undertake to notify the CNIL in accordance with the conditions laid down by the European Regulation.

If such a breach poses a high risk to customers and contacts and the data has not been protected:

- We will notify the affected users and contacts without delay;

- We will provide the affected users and contacts with the necessary information and recommendations.

We do not transfer any data to third-party companies for any reason other than one of the following:

• Provision of requested quotations and/or information: in order to provide you with the requested quotations and/or information, the data is transmitted to the hotels belonging to the relevant Hôtels Circuits France network, namely:
  • Establishments offering their services on the website www.hotelscircuitsfrance.com, in particular for quality monitoring purposes;
• Subcontracting: Hôtels Circuits France uses service providers to operate its website and supply you with the services and products on offer, including
  • IT subcontracting;
  • Marketing services: Marketing follow-up, sending out newsletters;
  • Collection of customer reviews

For all such data transfers, Hôtels Circuits France takes great care to work only with trusted companies and to ensure that its relationships with these companies are secure (through contracts, etc.).

Specific case for transfers outside the EU

Hôtels Circuits France’s policy is not to transfer data outside the European Union, except in the following cases:

• Microsoft Office 365 for office software;
• A newsletter tool;
• A Google solution for marketing and advertising tracking and website optimisation.

• 8.1 In accordance with the amended ‘Data Protection Act’ of 6 January 1978 and European Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, you have the right to access and rectify information concerning you, as well as the right to withdraw your consent, the right to restrict processing, the right to data portability and the right to erasure, to the extent permitted by the European Regulation and depending on the legal basis for the processing. In accordance with Article 85 of the French Data Protection Act, you may also set out instructions regarding the handling of your personal data following your death.

Please note that the exercise of these rights is not absolute and may be restricted on grounds of legitimate interest (customer disputes) or for legal reasons.

How can I exercise my rights?

You may exercise these rights by contacting Hôtels Circuits France:

• at the following email address: info@hotelscircuitsfrance.com;
• by post: Hôtels Circuits France, 49 Lices Georges Pompidou, 81000 Albi (France), tel. +33(0)5 63 43 09 09,

• info@hotelscircuitsfrance.com

We reserve the right to ask you to provide proof of your identity in the event of serious doubt.

Individuals may, if they deem it necessary and after contacting us, lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL).

8.2 As part of its business activities, Hôtels Circuits France collects telephone data. In accordance with the provisions of Article L.223-2 of the Consumer Code, Hôtels Circuits France informs you that you may register on the cold-calling opt-out list, available at www.bloctel.gouv.fr, in order to stop receiving unsolicited commercial telephone calls.

A cookie is a small text file placed on your computer, mobile phone, tablet or other device when you visit a website. The cookie will help us recognise your device the next time you visit our website.

Hôtels Circuits France uses cookies and other trackers on its website. To find out more about the use of these trackers, their retention periods and how to configure them, please see our cookie policy, which can be found in the footer of our website.