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 supplied by third parties (partners or service providers)
- Data collected automatically
This data includes the following:
1. Identity and family status (title, surname, first name, status, etc.)
2. Address and contact details (email address, postal address, mobile no., etc.)
3. Education and career (qualifications, jobs, etc.)
4. Financial details (bank card no., payment methods)
5. Consumption of goods and services, preferences and areas of interest (transactions; date, place and amount of expenditure; activities, etc.)
6. Electronic identification data (customer identification no., IP address, location data, MAC address, etc.)
7. Time and location information (monitoring of activities, cookies, logs, geolocation, etc.)
8. Loyalty programmes of the Group and its partners, loyalty programme membership no., etc.)
9. Health information provided by the customer (allergies, disabilities, etc.)
2. USE OF DATA
Your personal data is used by Monte-Carlo Société des Bains de Mer for the purpose of managing and delivering the services provided to you and without which Monte-Carlo Société des Bains de Mer would be unable to provide or render these services.
This use covers, firstly, the management of offers, the monitoring of services and, more generally, our entire business relationship (subscription to the Group’s newsletter or communication materials – MC Society; visits to our channels; quotes; reservations; orders; subscriptions; loyalty accounts; Wi-Fi or home automation services; reviews; surveys; information and marketing communications through all the means of communication you have provided for this use; and your contributions and posts on the Group’s accounts, social media or mentioning hashtags, brands, events, places, offers, services, products, Group channels, etc. (including through third parties)).
Monte-Carlo Société des Bains de Mer may also use your data to evaluate and improve its services and to develop new ones, as well as to run loyalty campaigns, target potential customers, conduct surveys and carry out promotional activities. Unless you object, you may receive offers from Monte-Carlo Société des Bains de Mer or its business partners through all the means of communication you have provided for this use for services similar to those offered by Monte-Carlo Société des Bains de Mer.
With your express consent, Monte-Carlo Société des Bains de Mer may,through all the means of communication you have provided for this use, send you marketing information for services that are not similar to those already provided.
This data will be stored for as long as is necessary for these purposes and for a maximum of three years from the date of the end of the business relationship with regard to direct marketing. Monte-Carlo Société des Bains de Mer may also use your data to meet its legal requirements (in particular the fight against fraud and money laundering) and/or in response to requests from public and governmental authorities.
3. ACCESS TO PERSONAL DATA AND THE RIGHTS GRANTED TO CUSTOMERS
You may, at any time, access your data, correct it, request for it to be deleted, oppose its processing on legitimate grounds due to personal circumstances or exercise your right to the portability of your data by sending an email and proof of your identity to the address [email protected], or by sending a letter and proof of your identity to: Monte-Carlo Société des Bains de Mer – Marketing Department – Place du Casino – BP 139 – 98000 Monaco (Principality of Monaco). However, data needed by Monte-Carlo Société des Bains de Mer for the purpose for which it was collected, to comply with a legal requirement and/or to assert, exercise or defend its rights in court may not be deleted.
You may also set guidelines for what happens to your personal data after your death. If Monte-Carlo Société des Bains de Mer has not given you a satisfactory response to a complaint, you can contact the Supervisory Commission on Personal Data (CCIN) – 12 Avenue de Fontvieille, 98000 Monaco (Principality of Monaco) – which is responsible for enforcing compliance with data protection requirements.
4. SUBCONTRACTING OF PERSONAL DATA PROCESSING
Your personal data is processed by Monte-Carlo Société des Bains de Mer, its subcontractors or partners for the purpose of managing and delivering the services you have requested or authorised. Your data may also be transferred to third-party service providers who provide services or support and advice to Monte-Carlo Société des Bains de Mer. On request, data may also be transferred to persons and authorities whose right to access personal data is recognised by the law, regulations or provisions issued by the legally competent authorities. Subcontractors and partners of Monte-Carlo Société des Bains de Mer may be located outside the European Union. When a subcontractor or partner is located in a country that has not been recognised as having an adequate level of protection, Monte-Carlo Société des Bains de Mer requires it to comply with its own requirements on the security and privacy of your personal data and to process your data only for the purposes it has identified. These subcontractors and partners will have previously signed the standard Contractual Clauses of the European Commission.
5. PERSONAL DATA STORAGE
Your personal data will be stored on our database located in Monaco or on those of our subcontractors. In some cases, mainly for technical reasons, your data may be stored on servers located outside the European Union.
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 event, in such a way as to guarantee security, protection and privacy appropriate to the sensitivity level, through administrative, technical and physical measures to prevent loss, theft, or unauthorised use, disclosure or changes. Whether it is processed by Monte-Carlo Société des Bains de Mer or by subcontractors and partners of Monte-Carlo Société des Bains de Mer, the same security and privacy requirements apply to your personal data.
8. MONTE-CARLO SOCIÉTÉ DES BAINS DE MER GROUP
SOCIETE ANONYME DES BAINS DE MER ET DU CERCLE DES ETRANGERS (SBM), with capital of 24,516,661 euros, registered in the Trade and Industry Register of Monaco under no. 56 S 523 and with intracommunity VAT no. FR 07 0000 1 5486.
Head office: Monte-Carlo Société des Bains de Mer, Place du Casino – MC 98000 Monaco.
The Monte-Carlo Société des Bains de Mer Group is made up of 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.
Customer Data Protection Policy – Version 2.0 updated on 5/07/2018