Privacy Policy - KUBE Hotel Saint-Tropez

Preamble

Through this Privacy Policy, Les Hôtels de Paris informs Data Subjects about how their Personal Data is processed on the Sites and within the premises of the hotel establishments owned by Les Hôtels de Paris (hereinafter the "Hotel Establishments") and the restaurants owned by Les Hôtels de Paris (hereinafter the "Restaurants"), as well as the specific rights that may be exercised.

Definitions

The following terms, whether used in the singular or plural in this Privacy Policy, including its Preamble, shall have the following meanings:

Intermediate Archiving:

Refers to the movement of Personal Data that still holds administrative value for Les Hôtels de Paris (such as in the event of litigation and/or legal obligations) into a separate database, logically or physically isolated, and to which access is restricted in any event. This archive is an intermediate step before the deletion or anonymization of the Personal Data concerned;

Recipients

Refers to all subcontractors, joint controllers, and recipients of Personal Data processed by Les Hôtels de Paris;

Hotel Establishment Managers

Refers to the managers of the Hotel Establishments in charge of the management and operation of the various hotel sites owned by Les Hôtels de Paris, including their Restaurants;

Data Subject (You/Your)

Refers to any person who can be identified, directly or indirectly, whose data is processed by Les Hôtels de Paris as part of its business activities, including, but not limited to, visitors to the Sites and/or Hotel Establishments, job applicants, customers of the Hotel Establishments and Restaurants, suppliers, partners, and prospects.

Data Controller

Refers to the company Les Hôtels de Paris, a public limited company with a board of directors, registered with the Paris Trade and Companies Register under number 388 083 016, with its registered office at 256, rue Saint-Honoré, 75001, Paris (hereinafter "Les Hôtels de Paris" or "We" or "Our").

Personal Data Regulations:

Refers to Law No. 78-17 of January 6, 1978, on Information Technology, Data Files and Civil Liberties, regarding the protection of personal data, in application of the EU Regulation of April 27, 2016, published in the Official Journal of the European Union on May 4, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as "GDPR" for General Data Protection Regulation).

Sites

Refers to the websites published and operated by Les Hôtels de Paris and/or by subcontractors of Les Hôtels de Paris from which Personal Data is collected, specifically including the following websites:

For websites intended for booking rooms at the Hotel Establishments:

www.maison-eugénie.com

(hereinafter referred to as the "Hotel Establishment Sites")

‍

For sites used for restaurant table reservations:

(hereinafter referred to as the “Restaurant Websites”)

Description and purposes of processing

3.1 Personal Data collected directly from you

The Personal Data of Data Subjects is processed on the websites and at the premises of the hotel properties and restaurants to carry out the following processing activities:

Personal data processed (for all of the purposes below)

Identification data (surname, first name, title, postal address, e-mail address, telephone number);
Data required to assess the ability to hold a job, professional aptitudes, qualifications).
Financial data (bank card number, expiry date, security code, name of the cardholder);
Connection data;
Data relating to browsing on the Sites;
Data from the surveillance cameras present in the Hotel Establishments, relating to IT and physical security (CCTV images, connection to the Wifi of the Hotel Establishments.)

Personal data processed	Purposes	Legal bases
Identification data (surname, first name, title, postal address, e-mail address, telephone number); Data required to assess the ability to hold a job, professional aptitudes, qualifications). Financial data (bank card number, expiry date, security code, name of the cardholder); Connection data; Data relating to browsing on the Sites; Data from the surveillance cameras present in the Hotel Establishments, relating to IT and physical security (CCTV images, connection to the Wifi of the Hotel Establishments.)	Management of the booking of a hotel room and/or a restaurant table and sending of Our commercial offers/newsletter.	Performance of the contract between the Data Subject and Les Hôtels de Paris. Consent for the newsletter.
	Management and sending of invitations to Our events, seminars.	Legitimate interest.
	Management of the rental of event spaces within the Hotel Establishments.	Performance of the contract between the Data Subject and Les Hôtels de Paris.
	Access to the Wifi of the Hotel Establishments.	Legitimate interest.
	Sending hotel and/or restaurant promotions and offers from Our Hotel Establishments and Restaurants as part of Our advertising campaigns broadcast on social media.	Consent.
	Measuring the effectiveness of advertising campaigns broadcast on third-party websites in connection with your booking of a hotel room and/or a restaurant table on the Sites.	Consent
	Management of your contact/information request.	Legitimate interest.
	Management of the operations useful to the recruitment operations by the human resources department (receipt of CVs, sorting of CVs and cover letters sent by post and by e-mail), of the recruitment procedures in connection with the directors of the Hotel Establishments, of the analysis of applications and evaluation of candidates, of responding to job applicants, of completing the mandatory legal formalities, of creating the administrative file of the selected candidates, of maintaining a pool of unsuccessful applications.	Performance of the contract between the Data Subject and Les Hôtels de Paris, in particular the employment contract to be concluded. Legitimate interest in responding to the application.
	Management of the commercial relationship with the Data Subject.	Performance of the contract between the Data Subject and Les Hôtels de Paris.
	Carrying out operations relating to the physical security of the Hotel Establishments and the IT security of their servers.	Legitimate interest.
	Management of complaints.	Performance of the contract between the Data Subject and Les Hôtels de Paris.
	Development of commercial statistics, analyses and marketing tools (in particular classification, scoring, etc.)	Legitimate interest.
	Management of the exercise of specific rights.	Legal obligations.
	Management of unpaid invoices and disputes.	Performance of the contract between the Data Subject and Les Hôtels de Paris.

Les Hôtels de Paris may also collect information related to your stay or personal preferences in order to improve the quality of services provided, such as: your interests, your feedback on services provided, specific dietary restrictions or personal needs to ensure your well-being, preferred types of leisure or activities, special occasions (birthdays), etc. This information is collected and processed based on the legitimate interest of Les Hôtels de Paris to provide you with an experience best suited to your needs.

Furthermore, if you provide information about other people in this context, you guarantee that you have all the necessary rights and authorizations to do so.

Les Hôtels de Paris collects Personal Data directly from Data Subjects via the websites and/or during the Data Subject's visit to the hotel properties, restaurants, and through associated video surveillance recordings.

Les Hôtels de Paris also collects data related to cookies and other similar technologies, in accordance with section 9 of this Privacy Policy.

3.2 Personal Data collected indirectly from you

Les Hôtels de Paris may collect Personal Data from certain partners who offer room booking services and, where applicable, process reservations through their own websites and/or mobile applications.

These partners include, for example, Booking.com, Expedia.com, Agoda.com, Hotelbeds.com, Keytel.com, Hoteltonight.com, Infinitehotel.com (Gekko), Sunhotels.com, Webbeds.com, or Veepee.com.

Les Hôtels de Paris also collects Personal Data indirectly from the Hotel Property websites and Restaurant websites, as detailed in sections 6.2 and 6.3 of this Privacy Policy.

Les Hôtels de Paris may also collect other Personal Data when you apply for a job at one of its hotel properties, for example, through job search service partners such as LinkedIn or Teamtailor.

These partners may collect some of your Personal Data for their own purposes and within databases to which Les Hôtels de Paris does not have access. For this type of processing, we invite you to review their respective privacy policies to understand how your Personal Data is handled in that context.

Data Retention

4.1 Personal Data processed to fulfill contractual obligations is not kept longer than strictly necessary for managing the business relationship. However, Personal Data required to establish proof of a right or contract, or retained to comply with a legal obligation, may be subject to an intermediate archiving policy for a period not exceeding the time necessary for the purposes for which they are retained, in accordance with applicable regulations.

4.2 Personal Data processed for commercial prospecting purposes concerning:

a) a Data Subject who is a customer of Hôtels de Paris are kept for a period of three (3) years from the end of the business relationship;

b) a Data Subject who is not a customer of Hôtels de Paris are kept for a period of three (3) years from the date of collection or the last contact from the Data Subject.

4.3 Personal Data processed for hotel room reservation payments is kept only for the duration of the transaction.

4.4 Personal Data concerning successful candidates will be added to their personnel file and kept for the applicable retention period (i.e., up to five years after the end of the employment relationship). Personal Data concerning unsuccessful candidates is not retained and is permanently deleted.

4.5 Financial Personal Data subject to accounting and tax obligations (invoices and transaction amounts, as well as the date and time of these transactions) are kept for two (2) years in an active database from the end of the contractual relationship, followed by an additional eight (8) years in intermediate archives.

4.6 Personal Data used for video surveillance at the Controller's hotel establishments will not be kept for longer than 30 days.

Personal Data used for welcoming Data Subjects to the Controller's hotel premises or for providing Wi-Fi access to these Data Subjects will not be kept longer than necessary for the completion of said processing.

However, data required to establish proof of a right or contract, or retained to comply with a legal obligation, may be subject to an intermediate archiving policy for a period not exceeding the time necessary for the purposes for which they are retained, in accordance with applicable regulations.

Personal Data Storage

5.1 The Site is hosted by OVH, SAS, 2 rue Kellermann - 59100 Roubaix.

5.2 Every precaution has been taken to store the Personal Data of Data Subjects in a secure environment and to prevent it from being distorted, damaged, or accessed by unauthorized third parties. Information provided by the Data Subject will never be shared with third parties for commercial purposes, nor will it be sold or exchanged without their consent.

Recipients or categories of recipients

6.1 Personal Data processed on the Sites is accessible to certain employees (Les Hôtels de Paris Digital Department, Communications Department, etc.) in order to best fulfill the aforementioned purposes, in particular the managers of the hotels concerned by the reservations made by the Data Subjects, as well as to authorized external recipients for the provision of the service.

Recipient's Name	Country where the data recipient is established	Nature of the data	Purpose	Categories of data recipient	Level of protection offered by the third country or exception provided for by the Personal Data Regulations
OVH SAS	France	Identification data	Hosting of the Sites	Processor	N/A
MM Création	France	Identification data	Maintenance of the Sites of the Hotel Establishments, provision of the contact form and newsletter subscription, cookie management.	Processor	N/A
Zenchef	France	Identification data	The booking by any means of communication of a restaurant by the Data Subjects and the internal use for marketing analysis and statistical purposes of the Sites of the following Restaurants: www.montijo.fr ; www.pomoli-restaurant.com ; www.kraft-hotel-paris.com/fr/page/kraft-hotel-paris-la-bonne-table.20006.html ;	Joint controller	N/A
Mews	Czech Republic	Identification data Financial data	Provision of the room booking platform for the Hotel Establishments and management of the bookings made from this platform via the Sites of the Hotel Establishments.	Processor	Standard Contractual Clauses
Google Tag Manager	United States	Connection data (IP address), approximate location, information relating to the booking (reference ID, total cost, arrival and departure dates, time of the booking), information relating to the search (dates, other search criteria), e-mail	Provision of the tool for analysing and tracking advertising campaigns in connection with the bookings made on the Sites via the placement of pixels	Processor	Standard Contractual Clauses
Triptease	United States	Connection data (IP address), approximate location, information relating to the booking (reference ID, total cost, arrival and departure dates, time of the booking), information relating to the search (dates, other search criteria), e-mail	Analysis and tracking of advertising campaigns via access to Google Tag Manager (number of clicks, views, bookings and booking price in euros) then anonymised reporting.	Processor	Standard Contractual Clauses
Hotjar	Malta	IP address of the device (stored in a de-identified format), screen resolution of the device, type of device (unique identifiers), operating system and browser type, preferred language used to display the Site(s), events related to the mouse (movements, locations and clicks), keystrokes, referring URL and domain, pages visited, date and time of access to the pages of the website.	Analysis and feedback tool revealing the online behaviour of Data Subject visitors on the Sites.	Processor	Standard Contractual Clauses
Atelier Business Food (BookingShake)	France	Identification data Professional data	Platform for managing the booking of event spaces within the Hotel Establishments.	Processor	N/A
SiteMinder	Australia	Data relating to the booking of rooms with the Hotel Establishments	Technical management of the gateway between the partner sites for booking rooms and Les Hôtels de Paris, in accordance with article 3.2 of this Privacy Policy.	Processor	Standard Contractual Clauses

Personal Data processed via Hotel Websites

The room reservation module accessible from the hotel websites is published and operated by Mews.

Mews, acting as a data processor, provides Les Hôtels de Paris with a secure platform for managing incoming and outgoing reservation data, allowing hotel managers to handle reservations for Data Subjects for the duration necessary to carry out this Personal Data processing.

Personal Data processed via Restaurant Websites

The restaurant table booking module accessible from the Restaurant Websites is published and operated by Zen Chef.

Zen Chef provides Les Hôtels de Paris with an online booking service on the Restaurant Websites. Bookings are managed under the responsibility of the Hotel Establishments; Zen Chef has no knowledge of booking requests made by Data Subjects, nor of the availability of the Hotel Establishments.

Zen Chef and Les Hôtels de Paris act as joint controllers regarding processing for the following purposes:

the booking of a restaurant by Data Subjects, via any means of communication;
internal use for marketing analysis and statistical purposes.

Data Subjects can view how Zen Chef processes Personal Data by clicking here.

Specific rights

9.1 Right of access

The Data Subject has the right to obtain from Les Hôtels de Paris confirmation as to whether or not Personal Data concerning them are being processed, and, where that is the case, access to said Personal Data as well as the following information:

a) the purposes of the processing;

b) the categories of Personal Data;

c) the recipients or categories of recipients to whom the Personal Data have been or will be disclosed;

d) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;

e) the existence of the right to request from Les Hôtels de Paris rectification or erasure of Personal Data, or restriction of processing concerning the Data Subject, or to object to such processing;

f) the right to lodge a complaint with the CNIL;

g) where Personal Data is not collected from the Data Subject, any available information as to its source;

h) the existence of automated decision-making, including profiling, and, at least in such cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject.

Where Personal Data is transferred to a third country or an international organization, the Data Subject has the right to be informed of the appropriate safeguards relating to such transfer.

Les Hôtels de Paris shall provide a copy of the Personal Data undergoing processing.

Les Hôtels de Paris may charge a reasonable fee based on administrative costs for any further copies requested by the Data Subject.

Where the Data Subject makes the request by electronic means, the information shall be provided in a commonly used electronic form, unless otherwise requested by the Data Subject.

The Data Subject's right to obtain a copy of their Personal Data must not adversely affect the rights and freedoms of others.

9.2 Right to rectification

The Data Subject has the right to obtain from the Data Controller, without undue delay, the rectification of inaccurate Personal Data concerning them. They also have the right to have incomplete Personal Data completed, including by providing a supplementary statement.

9.3 Right to erasure

The Data Subject has the right to obtain from the Data Controller the erasure of Personal Data concerning them without undue delay when one of the following grounds applies:

a) The Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed by Les Hôtels de Paris;

b) The Data Subject has withdrawn their consent for the processing of such Personal Data and there is no other legal basis for the processing;

c) The Data Subject exercises their right to object under the conditions set out below and there are no overriding legitimate grounds for the processing;

d) The Personal Data has been processed unlawfully;

e) The Personal Data must be erased to comply with a legal obligation;

f) The Personal Data was collected from a child.

9.4 Right to restriction

The Data Subject has the right to obtain from the Data Controller the restriction of the processing of their Personal Data when one of the following grounds applies:

a) Les Hôtels de Paris verifies the accuracy of the Personal Data following a challenge by the Data Subject regarding the accuracy of said Personal Data;

b) the processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests the restriction of their use instead;

c) Les Hôtels de Paris no longer needs the Personal Data for the purposes of processing, but they are still required by the Data Subject for the establishment, exercise, or defense of legal claims;

d) The Data Subject has objected to the processing under the conditions set out below, and Les Hôtels de Paris is verifying whether the legitimate grounds pursued override the grounds alleged.

9.5 Right to data portability

The Data Subject has the right to receive the Personal Data concerning them from Les Hôtels de Paris in a structured, commonly used, and machine-readable format when the processing of Personal Data is based on consent or a contract and is carried out by automated means.

When the Data Subject exercises their right to portability, they have the right to have the Personal Data transmitted directly by Les Hôtels de Paris to another Data Controller of their choosing, where technically feasible.

The right to portability of the Data Subject's Personal Data must not adversely affect the rights and freedoms of others.

9.6 Right to object

The Data Subject may object at any time, for reasons relating to their particular situation, to the processing of their Personal Data based on the legitimate interest of the Data Controller. The Data Controller will then no longer process the Personal Data, unless they demonstrate compelling and legitimate grounds for the processing that override the interests, rights, and freedoms of the Data Subject, or may retain them for the establishment, exercise, or defense of legal claims.

9.7 Post-mortem instructions

The Data Subject may provide Les Hôtels de Paris with instructions regarding the retention, deletion, and disclosure of their Personal Data after their death. These instructions may also be registered with a “certified digital trusted third party.” These instructions, a form of “digital will,” may designate a person to carry them out; failing this, the Data Subject's heirs will be designated.

In the absence of any instructions, the Data Subject's heirs may contact Les Hôtels de Paris to:

access Personal Data processing operations that allow for the organization and settlement of the deceased's estate ”;
receive communication of “digital assets” or data similar to family mementos, which may be passed on to heirs” ;
have the Data Subject's Personal Account closed on the website and object to the continued processing of their Personal Data.

In any event, the Data Subject has the option to inform Les Hôtels de Paris at any time that they do not wish for their Personal Data to be shared with a third party in the event of their death.

Cookies and opting out of cookies

10.1 Rights may be exercised at any time with Les Hôtels de Paris:

By email to the following address: info@machefert.com, specifying in the subject line “Personal Data Management – Groupe Machefert”

By post, specifying in the subject line “Personal Data Management – Groupe Machefert” at the following address:

Les Hôtels de Paris 256, rue Saint-Honoré 75001 Paris France

10.2 In order to exercise their rights under the conditions referred to above, and in the event that Les Hôtels de Paris has doubts regarding the identity of the requester, Les Hôtels de Paris may ask the requester to provide proof of identity by stating their surname, first name, email address, and by attaching a copy of a valid identity document to their request.

10.3 A response will be sent to the Data Subject within a maximum of one (1) month following the date of receipt of the request.

10.4 If necessary, this period may be extended by two (2) months by Les Hôtels de Paris, which will notify the Data Subject, taking into account the complexity and/or number of requests.

10.5 In the event that the Data Subject requests the deletion of their Personal Data and/or exercises their right to request the erasure of their Personal Data, Les Hôtels de Paris may nevertheless retain it in the form of Intermediate Archiving for the duration necessary to fulfill its legal obligations or for evidentiary purposes during the applicable limitation period.

10.6 The Data Subject may also lodge a complaint with the competent supervisory authority (the CNIL).

Exercising Data Subject Rights

11.1 Upon their first visit, the Data Subject is informed of the presence of the cookies referred to in Article 3.3 via a banner, which invites them to indicate their choice.

11.2 Information regarding cookies is collected and processed by Les Hôtels de Paris for the following purposes and durations:

Cookies	Purpose	Cookie lifespan	Retention period of the information
cdn.jsdelivr.net fonts.mmcreation.com hapi.mmcreation.com	Strictly functional cookies: Necessary for the proper functioning and security of the relevant Site.	These cookies are not kept beyond the duration of browsing on the relevant Site.	12 months
googletagmanager.com region1.google-analytics.com	Audience measurement: Statistics on visits and bookings on the Sites.	6 months	14 months
hotelpricexplorer.com api.hotelpricexplorer.com	Price comparator: Intended to offer in real time the best prices for a room on a given date, in order to compile statistics.	6 months	The information is not retained.

11.3 Cookies are only placed if the Data Subject consents.

11.4 The Data Subject may, at any time, obtain information about and configure cookies by clicking on "Cookie Preferences" located in the cookie banner at the bottom of each page of the Sites.

Last updated: July 7, 2026