Privacy policy

Clozeto is a brand of Hostay

HOSTAY

4 Quai Koch – 67000 Strasbourg – France

SIRET 95361625700010

gatien.sancho[at]qwenty.fr

Definitions The Publisher: The person, natural or legal, who publishes the online public communication services. The Site: All the sites, web pages, and online services offered by the Publisher. The User: The person using the Site and the services.

Nature of the data collected

As part of the use of the Sites, the Publisher may collect the following categories of data concerning its Users: personal identification data, identity, identification data…

Communication of personal data to third parties

No communication to third parties. Your data is not communicated to third parties. However, you are informed that it may be disclosed in application of a law, regulation, or by virtue of a decision of a competent regulatory or judicial authority.

Prior information for the communication of personal data to third parties in the event of merger/acquisition

Prior information and opt-out possibility before and after the merger/acquisition. In the event that we take part in a merger, acquisition, or any other form of asset transfer, we are committed to ensuring the confidentiality of your personal data and to informing you before it is transferred or subjected to new privacy rules.

Purpose of the reuse of personal data collected

  • Carry out operations related to customer management concerning contracts, orders, deliveries, invoices, accounting, and in particular the management of customer accounts.
  • A loyalty program within one or more legal entities.
  • Customer relationship monitoring such as satisfaction surveys, claims management, and after-sales service.
  • Selection of customers to carry out studies, surveys, and product tests (unless the persons concerned have given their consent under the conditions provided for in Article 6, these operations should not lead to the establishment of profiles likely to reveal sensitive data – racial or ethnic origins, philosophical, political, trade union, religious opinions, sexual life, or health of people).

Data aggregation

  • Aggregation with non-personal data. We may publish, disclose, and use aggregated information (information relating to all our Users or specific groups or categories of Users that we combine so that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other commercial purposes.
  • Aggregation with personal data available on the User’s social accounts. If you connect your account to an account of another service for cross-posting, the said service may provide us with your profile, login, and other information you have authorized disclosure of. We may aggregate the information relating to all our other Users, groups, accounts, personal data available on the User.

Collection of identity data

Free consultation. Consultation of the Site does not require registration or prior identification. It can be done without you providing any personal data concerning you (name, first name, address, etc.). We do not carry out any registration of personal data for the simple consultation of the Site.

Collection of identification data

Use of the user identifier only for connection proposal and commercial offers. We use your electronic identifiers to search for existing connections by connection, email address, or services. We may use your contact information to allow others to find your account, including through third-party services and client applications. You can upload your address book so that we can help you find acquaintances on our network or to allow other Users of our network to find you. We may offer suggestions to you and other Users of the network based on the contacts imported from your address book. We may partner with companies that offer incentive offers. To support this type of promotion and incentive offer, we may share your electronic identifier.

Collection of terminal data

No collection of technical data. We do not collect or store any technical data from your device (IP address, Internet service provider…).

Cookies

  • Cookie retention period. In accordance with the recommendations of the CNIL, the maximum duration of the retention of cookies is 13 months after their first deposit in the User’s terminal, just like the duration of the validity of the User’s consent to the use of these cookies. The cookie lifetime is not extended with each visit. Therefore, the User’s consent must be renewed at the end of this period.
  • Purpose of cookies. Cookies can be used for statistical purposes, in particular to optimize the services rendered to the User, from the processing of information concerning the frequency of access, the personalization of pages, as well as the operations carried out and the information consulted. You are informed that the Publisher may place cookies on your terminal. The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of the consultation…) that we can read during your subsequent visits.
  • User’s right to refuse cookies. You acknowledge that you have been informed that the Publisher may use cookies, and you authorize it. If you do not want cookies to be used on your terminal, most browsers allow you to disable cookies through the settings options. However, you are informed that some services may not function properly.
  • Possible association of cookies with personal data. The Publisher may collect browsing information through the use of cookies.

Retention of technical data

Retention period for technical data. Technical data is kept for the time strictly necessary to achieve the purposes mentioned above.

Retention period for personal data and anonymization

  • Retention of data for the duration of the contractual relationship. In accordance with Article 6-5° of Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms, personal data subject to processing is not kept beyond the time necessary to fulfill the obligations defined when the contract was concluded or the predefined duration of the contractual relationship.
  • Retention of anonymized data beyond the contractual relationship/after account deletion. We retain personal data for the duration strictly necessary to achieve the purposes described in these T&Cs. Beyond this period, they will be anonymized and kept exclusively for statistical purposes and will not be subject to any exploitation of any kind.
  • Deletion of data after account deletion. Means of purging data are put in place to provide for the effective deletion of data as soon as the retention or archiving period necessary to achieve the determined or imposed purposes is reached. In accordance with Law No. 78-17 of January 6, 1978, relating to data processing, files, and freedoms, you also have the right to delete your data, which you can exercise at any time by contacting the Publisher.

Deletion of the account

  • Deletion of the account on request. The User can delete their Account at any time, by a simple request to the Publisher OR through the account deletion menu present in the Account settings if applicable.
  • Deletion of the account in case of violation of the T&Cs. In the event of a violation of one or more provisions of the T&Cs or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict without prior notice and at its sole discretion, your use and access to services, your account, and all Sites.

Indications in case of security breach detected by the Publisher

  • User information in case of security breach. We are committed to implementing all appropriate technical and organizational measures to ensure a level of security appropriate to the risks of accidental, unauthorized, or illegal access, disclosure, alteration, loss, or destruction of personal data concerning you. In the event that we become aware of illegal access to the personal data concerning you stored on our servers or those of our service providers, or unauthorized access resulting in the realization of the risks identified above, we undertake to:
  • Notify you of the incident as soon as possible.
  • Examine the causes of the incident and inform you.
  • Take the necessary measures within reasonable limits to mitigate the negative effects and damages that may result from the said incident.
  • Limitation of liability. In no case can the commitments defined in the above point relating to the notification in the event of a security breach be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.

Transfer of personal data abroad

No transfer outside the European Union. The Publisher undertakes not to transfer the personal data of its Users outside the European Union.

Modification of the T&Cs and privacy policy

In case of modification of these T&Cs, we undertake not to substantially lower the level of confidentiality without prior information to the persons concerned. We undertake to inform you in case of substantial modification of these T&Cs, and not to lower the level of confidentiality of your data substantially without informing you and obtaining your consent.

Data portability

Data portability. The Publisher undertakes to offer you the possibility of having all your data returned to you upon simple request. The User is thus guaranteed better control over their data and retains the possibility of reusing them. These data must be provided in an open and easily reusable format.

Applicable law and methods of appeal

Arbitration clause. You expressly agree that any dispute that may arise from these T&Cs, particularly regarding their interpretation or execution, will be subject to arbitration under the rules of the arbitration platform chosen by mutual agreement, to which you will adhere without reservation.