PRIVACY AND PERSONAL DATA PROTECTION CHARTER FOR THE MILLÉSIME GROUP AND ITS HOUSES

Established pursuant to French Data Protection Act no. 78-17 of 6 January 1978, as amended by European Regulation 2016/679 of 27 April 2016 on the protection of Personal Data, which came into force on 25 May 2018.

The Millésime Group and its online store place the protection of personal data at the heart of the services offered to you.

The Millésime Group includes the following Houses, as well as any that may be added to them due to their presence on the www.millesime-collection.com website:

The Domaine de Raba: www.domainederaba-talence.fr
The Grand Hôtel du Soleil d’Or, Megève : https://www.lesoleildor-megeve.fr/
La Palmeraie: www.lapalmeraie-labaule.fr
The Château de sacy: www.chateaudesacy-reims.fr
La Course: www.lacourse-bordeaux.fr
Aux Vins des Pyrénées: www.vinsdespyrenees.com
Le Manège: www.lemanege-leognan.fr
Cocorico: cocorico-porto.pt

By using the website www.millesime-collection.com and its online store (millesime-maison.com), as well as the websites of its Houses www.domainederaba-talence.fr, www.hoteldebouilhac-montignac.fr, www.lapalmeraie-labaule.fr, www.chateaudesacy-reims.fr, www.lacourse-bordeaux.fr, www.vinsdespyrenees.com, www.lemanege-leognan.fr, www.cocorico-porto.pt, you unreservedly accept the collection and use of your Personal Data as described in this Personal Data Protection Charter.

This Charter sets out the principles and guidelines for the protection of your Personal Data and aims to inform you about: the Personal Data that the Millésime Group collects and the reasons for this collection, the way in which these Personal Data are used, and your rights around the Personal Data concerning you. This Charter applies to all the services of the Millésime Group, excluding those offered by partner sites that are not part of the Millésime Group.

Data Controller

The data controller is the person responsible for the processing of personal data, the purpose and means of which it shall determine. The Website www.millesime-collection.com and its online store (millesime-maison.com), as well as the sites www.domainederaba-talence.fr, www.lesoleildormegeve.fr, www.lapalmeraie-labaule.fr, www.chateaudesacy-reims.fr, www.lacourse-bordeaux.fr, www.vinsdespyrenees.com, www.lemanege-leognan.fr, www.cocorico-porto.pt, are responsible for all the Processing of your Personal Data.

How does the Millésime Group take into account the protection of Personal Data?

The Millésime Group undertakes to take into account the protection of your Personal Data and your privacy starting from the design of the services offered. To guarantee the security, respect and proper exercise of your rights, technical and organisational measures to ensure the protection of your Personal Data are implemented.

What rights do you have regarding your personal data?

The Millésime Group undertakes to collect only that data strictly necessary for the performance of the services agreed:

Your first name, last name, address, e-mail, telephone,
Your billing and/or shipping address,
Your financial information (e.g. bank card number),
IP/Mac address,
Your connection data and navigation data.

Mandatory data that are essential to the processing of your requests is indicated to you during its collection by an asterisk. Personal Data is collected directly from you and is only used for purposes of which you have been made aware.

Why is your Personal Data collected and used by the Millésime Group?

For the following purposes, we request your consent:

Online bookings (hotels, restaurants, various services),

Online purchases,

Informational communications about events, evenings, concerts, etc.,

Newsletter.

For the following purposes, your data are processed as part of the performance of the contract binding you to the website www.millesime-collection.com and its online store (millesime-maison.com), as well as to the websites of its Houses www.domainederaba-talence.fr, www.lesoleildor-megeve.fr, www.lapalmeraie-labaule.fr, www.chateaudesacy-reims.fr, www.lacourse-bordeaux.fr, www.vinsdespyrenees.com, www.lemanege-leognan.fr, www.cocorico-porto.pt:

Management of your online bookings (hotels, restaurants, various services), Management of your online purchases (delivery, invoicing), Management and monitoring of the customer relationship, complaints and your requests, in particular the right of access, query, rectification and opposition for legitimate reasons and to oppose commercial prospecting.

For the following purposes, your data are necessary for the purposes of the legitimate interests pursued:

To prevent and detect possible threats to the security of our visitors and our products or services,

To prevent fraud or any other illegal action and comply with our legal obligations.

How is the Personal Data collected?

When booking online (hotels, restaurants, various services) and purchasing online, data may be collected directly on our website www.millesime-collection.com and its online store (millesime-maison.com), as well as on the websites of its Houses www.domainederaba-talence.fr, www.lesoleildor-megeve.fr, www.lapalmeraie-labaule.fr, www.chateaudesacy-reims.fr, www.lacourse-bordeaux.fr, www.vinsdespyrenees.com, www.lemanege-leognan.fr, www.cocorico-porto.pt.

This data may be collected through forms that you will have to complete, or automatically.

How is the collection of the Personal Data of minors carried out?

Minors must obtain the consent of their parents or legal guardians.

Recipients of your Personal Data

Your Personal Data may be sent to the following Recipients:

Internal departments of the Millésime Group and its Companies, in particular those responsible for performing the services requested,

Service providers outside the Millésime Group and its Companies: technical service providers, including subcontractors.

We do not disclose your Personal Data to other companies for marketing purposes.

We are committed to ensuring appropriate security measures are in place to protect your Personal Data from any foreseeable danger.

Can your Personal Data be transferred outside the European Union?

The Millésime Group and its Companies carry out all the Processing of your Personal Data within the territory of the European Union (EU).

If, for certain specific services, the Millésime Group and/or its Companies use subcontractors established outside the EU, certain Personal Data may then be communicated to them for the strict purposes of fulfilling their missions. In this case, in accordance with the applicable regulations in force, the Millésime Group and/or its Companies require its subcontractors to provide the guarantees necessary to manage and secure these transfers, specifically by signing standard contractual clauses from the European Commission.

How long does the Millésime Group keep your Personal Data?

Your Personal Data is retained for the time period necessary to achieve the objective for which they were collected. It will then be archived with restricted access for an additional period in connection with the limitations on legal retention periods for reasons that are strictly limited and authorised by law. It will then be deleted.

Is your Personal Data protected?

The Millésime Group and its Companies undertake to implement all appropriate technical and organisational measures to ensure the security and confidentiality of Personal Data and in particular to prevent it from being damaged, erased or accessed by unauthorised third parties.

In the event of a security incident affecting your Personal Data (destruction, loss, alteration or disclosure), the Millésime Group and its Companies undertake to comply with the obligation to disclose Personal Data Breaches, in particular to notify the CNIL.

Managing your Personal Data

In accordance with Law no. 78-17 of 6 January 1978 on data protection, as amended by European Regulation 2016/679 of 27 April 2016 on the protection of Personal Data, you have several rights when it comes to the management your data.

You have the option at any time to exercise the rights provided for by the regulations in force that are applicable to personal data held by the Millésime Group and its Companies, subject to meeting the following conditions:

Right of access: you may be provided with your Personal Data that is subject to Processing by the Millésime Group and its Companies,

Right to rectification: you may update your Personal Data or have your Personal Data that is processed by the Millésime Group and its Companies rectified,

Right to object, in particular to receiving commercial communications: you may express your wish to no longer receive commercial communications from the Millésime Group and its Companies or request that your Personal Data no longer be subject to Processing,

Right to erasure: you may request the deletion of your Personal Data,

Right to restriction of Processing: you may request the suspension of the Processing of your Personal Data,

Right to portability: you may ask the Millésime Group and/or its Companies to recover your Personal Data in order to have access to it,

The right to define guidelines relating to the fate of your Personal Data after death: in the absence of instructions from you, after a certain period of inactivity, your Personal Data is deleted. Notwithstanding, your heirs may, after your death, exercise rights over your data,

The right to file a complaint with the CNIL. You may file a complaint if you consider that the Processing of personal data concerning you constitutes a breach of the regulations. For additional information on your rights, and more specifically regarding this last right, visit to the website of the Commission Nationale de l’Informatique et des Libertés (/www.cnil.fr).

Contact to exercise your rights

For any question relating to this Charter or to the exercise of your rights, you may send us, in accordance with the regulations, a request accompanied by valid proof of identity:

Either to BIRD : 28, rue Etienne Marcel – 75002 Paris, indicating your surname, first name, and e-mail address.

Or to the postal and/or electronic address provided to you when subscribing to a service or collecting your Personal Data.

Any request must be accompanied by proof of identity. The Millésime Group and its Companies undertake to respond to your requests to exercise your rights as soon as possible, and in any event within the legal deadlines.

Cookies

Users of the www.millesime-collection.com website and its online store (millesime-maison.com), as well as the sites of its Houses www.domainederaba-talence.fr, www.hoteldebouilhac-montignac.fr, www.lapalmeraie-labaule.fr, www.chateaudesacy-reims.fr, www.lacourse-bordeaux.fr, www.vinsdespyrenees.com, www.lemanege-leognan.fr, www.cocorico-porto.pt, and, where applicable, the sites of other Houses that may be added to these, are informed of the use of Cookies that have been designed to be used by the Millésime Group and its House.

For example, each time you log in, Cookies allow us to save the following information: the type and version of the user’s browser, the dates and times of the visit, the history and content of the orders, including in the event of a purchase that is not finalised. Thus, when you log in next time, you no longer need to enter certain information again.

Users may object to the use of all or some of these Cookies. In fact, most Internet browsers make it possible to configure the Internet and security options or user preferences in order to refuse or disable Cookies, or to obtain a message that will notify the User when Cookies have been sent.

Cookies that are necessary for the operation of the sites: they allow you to use the main features of the sites (e.g. use of the shopping cart, access to personal and reserved spaces). Without these Cookies, you will not be able to use the Site normally. These are Cookies that only relate to the operation of the Website. If your browser is configured to refuse all Cookies, you will not be able to make purchases or take advantage of essential functions of the sites, such as storing items in your basket or receiving personalised recommendations.

Analytical cookies

These are Cookies that enable the Millésime Group and its Brands to establish statistics on the volume of visits and the use of the various elements comprising the Website (sections and content visited, user pathways) in order to improve the appeal and usability of its services.

Functional cookies

These are Cookies that allow the Millésime Group and its Houses to:

(i) adapt the presentation of their sites, spaces and advertising content to the display preferences of your device (language used, display resolution, operating system used, etc.), if applicable based on the localisation data transmitted by your device with your prior agreement, and your personal data;

(ii) personalise your experience on the sites (for example, remind you of the sections you have visited and/or the latest products you have consulted, remembering the items in your basket before continuing your purchases).

Cookies and social media plug-ins (social buttons)

The Millésime Group and its Brands may include on their websites apps from third parties, which allow you to share the content of the site with other people or to inform these other people of your visit or your opinion concerning content on the Site. This is specifically the case for “Share” and “Like” buttons from social networks such as Facebook, Twitter, etc.

The social network providing these types of app button may identify you using this button, even if you did not use this button during your consultation of the Site. This type of app button can enable the social network concerned to track your browsing on the Site, simply because your account on the social network concerned is activated on your device (session opened) during your browsing of the site. If you do not want social networks to publish your plug-in actions on your social network accounts, you must log out of your social networks before visiting the Site.

The Millésime Group and its Companies have no control over the process used by social networks to collect information relating to your browsing on the site and associated with the personal data that they have.

We invite you to consult the privacy policies of these social networks in order to become aware of the purposes of the use of the browsing information that they can collect through these application buttons, notably advertising. These protection policies should notably enable you to exercise your right to choose with these social networks, specifically by configuring your user accounts for each of these networks.

GLOSSARY

Each term of the Charter beginning with a capital letter is understood ads having the meaning listed below.

“Privacy and Personal Data Protection Charter”: refers to this Charter describing the measures taken regarding the processing, use and management of your Personal Data and your rights as a data subject.

“Personal Data”: means any information relating to you that directly or indirectly identifies you.

“Processing”: means any operation or set of operations applied to your Personal Data.

“Personal Data Breach”: means a breach of security leading to the accidental or unlawful destruction, loss, alteration, disclosure or unauthorised access to your Personal Data.

“Recipient”: means the department or company that receives communication(s) and can access your Personal Data.