Privacy Policy & Cookie Policy

The purpose of this privacy policy (hereinafter the ‘Policy’) is to explain the rules governing the various types of personal data processing that may be carried out when you use our website, accessible at the URL: www.ltsw.be (hereinafter the ‘Site’). The processing of personal data carried out from the Site is the responsibility of two joint controllers. The controllers of your personal data are:

Amenitiz Solutions (hereinafter ‘Amenitiz’), which manages bookings for the 11 Francs website

Amenitiz is registered under number CIF B67096750 in Barcelona, Spain. Its registered office is located at 4, Plaza d'Urquinaona, 08010 Barcelona, Spain.

Amenitiz supports accommodation professionals by offering them a SaaS-hosted digital platform that allows them to manage bookings for their accommodation business.

11 Francs

This company is registered with the Belgian administration in Mons under number 0799516461 (hereinafter ‘the Establishment’). Its registered office is located at 20 place de Vannes.

Email address of the data protection officer within the establishment: info@ltsw.be

Amenitiz and the Establishment are hereinafter jointly referred to as the ‘Data Controller’. The terms ‘we’, “us” and ‘our’ in this privacy policy refer to the Data Controller.

As the Data Controller of your Personal Data, we make every effort to protect your privacy when you visit the Website.

This Policy provides you with information about the origin and use of your Personal Data and your browsing information processed when you visit our Website.

For the purposes of this Policy, the term ‘Personal Data’ refers to any data that relates solely to you and allows you to be identified directly or indirectly, regardless of the Device you use.

The term ‘Device’ refers to the hardware (computer, tablet, smartphone, telephone, etc.) that you use to view and browse the Website.

The term ‘Regulations’ refers to regulations relating to personal data, in particular Regulation No. 2016/679 known as the General Data Protection Regulation, the French Data Protection Act No. 78-17 of 6 January 1978 and French Law No. 2018-493 on the protection of personal data.

By using our Website, you agree to the terms of this Policy in their entirety.

If you disagree with any of these terms, you are free to stop using our Website.

This Privacy Policy is regularly updated. In order to ensure that you are properly informed of any significant changes in advance, we will notify you via notifications on the relevant services or by email, as appropriate.

The Website will always display the most recent version of this privacy policy.

Protection of your personal data

In accordance with the Regulations, we record all processing operations in a processing register that we make available to the competent authorities.

All information that you may have provided to us during your visits to the Website is strictly confidential. This information is necessary for the purposes of processing.

What personal data is collected and processed?

The information that may be collected and processed is as follows:

  • Identification and contact details: your first name, surname, gender, postal address, telephone number, email address, language and the country from which you interact with us;
  • Financial and payment data: your bank details (in this regard, we inform you that all payment transactions are encrypted by the receiving bank or accredited storage centre and that we do not store any credit card numbers), information about your bookings, etc.;
  • Connection, geolocation (only with your consent) and browsing data; and
  • Personal preferences: this includes your cookie preferences.

When we ask you to enter your personal data to access a feature, some data is mandatory as it is data we need to enable you to access that feature (for example, to register your booking, we need your first and last name).

It is important that the personal information shared about you is correct and up to date.

We do not process any personal data that could be classified as ‘sensitive’ (information concerning racial or ethnic origin, political, philosophical or religious opinions, trade union membership, health or sex life) within the meaning of the Personal Data Regulations.

In this regard, it is specified that our Website is not intended for children and that we therefore do not process any data relating to them.

We undertake not to transfer your personal data to third parties, except in the cases listed below in Article 1.3.

For what purposes are your Personal Data collected and processed?

  • The Personal Data listed above may be collected and processed for the following purposes:
  • Managing a booking: The processing of your data is necessary to keep you informed of the status of your booking, to provide you with a summary of your booking, to accept your payment, etc.
  • Access to customer service: We process your Personal Data as part of our customer service in order to respond to your requests, in particular via the contact form.
  • Improvement of our services: We process your browsing and booking data for analysis and statistical purposes. This data allows us to analyse how you use our Website and to improve its usability and quality.
  • Marketing: When you subscribe to our newsletter, we process your data in order to manage your subscription and send you targeted information by email or SMS, depending on your preferences. We may also contact you via push notifications if you subscribe to this service. Processing for marketing purposes requires your consent. You can therefore unsubscribe from our communications at any time. If you have given us your consent to receive our communications, whether via our newsletter or via push notifications, we may use the information you have provided to us for the following purposes:
    • Sharing information about our events, products, services and current offers;
    • Recommendations on certain products or services that may be of interest to you; and
    • Customer surveys to better understand your expectations regarding the products and services offered by our Site.

Who are the recipients of your Personal Data?

When using our Site, you may receive information from third parties with whom we collaborate in order to offer you certain services. These may include:

  • Accredited financial institutions and storage centres;
  • Fraud detection and prevention entities; and
  • Marketing, communication and advertising service providers.

Personal Data collected from the Site is mainly processed by the Data Controller's internal departments.

However, we may share your information with the third parties listed above for the following reasons, among others:

  • to process payments in the case of financial institutions and accredited storage centres;
  • to verify your credit and identity in the case of fraud detection and prevention entities; and
  • to optimise your experience on our Website and improve our services in the case of marketing, communication and advertising service providers.

We require third parties receiving your personal data to agree to comply with the Personal Data Regulations. The third parties listed above may only use your personal information in accordance with our instructions and not for their own purposes.

Your connection and browsing data may also be transferred to Google Analytics.

We may also disclose your Personal Data in response to a court order.

How long is your Personal Data kept?

We will keep your data for a period of ten (10) years following your last booking in order to respond to any questions or complaints or to maintain all data necessary to meet legal, accounting or analysis requirements (Article L.123-22 of the French Commercial Code).

We may also retain your data for research or statistical analysis purposes; in such cases, the data will be anonymised.

If you subscribe to our newsletter, we will not contact you again if you have not opened our newsletters for more than twelve (12) months.

Any changes to this Policy will be made on this page and, in the event of a substantial change, you will be notified by email.

The Data Controller may also retain your data for research or statistical analysis purposes. As this data is anonymised, no retention period is imposed by the Regulations, since it is no longer possible to ‘re-identify’ you afterwards.

Hosting of your Personal Data

Your Personal Data is hosted by Heroku Inc. The Landmark @ 1 Market St., Suite 300, San Francisco, CA, 94105, United States.

The servers on which your Personal Data is stored are located in Frankfurt, Germany.

In any event, the Data Controller has implemented appropriate technical measures to maintain the security of your Personal Data.

What are your rights?


Consent: Your consent must be given clearly and unambiguously. That is why, when you agree to fill in the contact form on the Website:

you are explained how your Personal Data will be used;

  • you must tick a box to confirm your consent; and
  • children under the age of 13 cannot give their consent.
  • Other rights: In accordance with the Regulations, you have the following rights over your Personal Data:

- Right of access to data: this right allows you to receive a copy of the Personal Data we hold about you;

- Right to rectification: this right allows you to request the correction of inaccurate or incomplete Personal Data concerning you;

- Right to erasure of your Personal Data: this right allows you to request that we erase your Personal Data if one of the legal grounds is met:

  • the Personal Data is no longer necessary for the purposes of the processing;
  • you have withdrawn your consent on which the processing is based;
  • you have objected to the processing through your right to object;
  • the processing of your Personal Data is unlawful; or
  • your Personal Data must be erased in accordance with a legal obligation.

- Right to restriction of processing of your Personal Data; this restriction of processing may be carried out when:

  • you contest the accuracy of your Personal Data;
  • you do not object to the erasure of your Personal Data in the context of unlawful processing but require that it be restricted;
  • your Personal Data is no longer used by our services but its retention is necessary for the establishment, exercise or defence of legal claims; or
  • you object to our use of your Personal Data through your right to object.

- Right to the portability of your Personal Data: you may contact us to provide you, or directly to another data controller, with your Personal Data in a structured, commonly used and machine-readable format;

- Right to object: you may contact us when

  • the processing is carried out to fulfil a public interest mission or for the purposes of our legitimate interests; you may object to this only for reasons relating to your situation; or
  • the processing is carried out for commercial prospecting purposes; you may object to this at any time without providing us with any explanation.

- Right to determine the fate of your Personal Data after your death (e-Will): one of the specific features of French regulations is that they allow you to send us your instructions on how we should process your Personal Data after your death. As such, you can choose to have it deleted or transferred to one of your relatives.

Regardless of the purpose or legal basis on which we process your data, you can therefore, at any time and at no cost, send us an email to exercise your rights at the following address: info@ltsw.be

Or send us a letter to the following address:

20 place de Vannes - 7000 Mons

Please note, however, that we are not always able to respond favourably to your request for legal reasons, which we will inform you of, if applicable, after receiving your request.

In any event, we remind you that you have the right to lodge a complaint with the competent administrative authority.


What are the legal grounds for processing?

We process your data on legal grounds that depend on how you interact with our Site.

When you purchase products from our Website, we collect and process your personal data in order to perform the contract between us. For example, we need your postal address to deliver your order and your bank details to process the payment.

We also rely on other legal bases such as your legitimate interests. For example, we consider it to be in your interest that your identity cannot be used for fraudulent purposes, that our customer service staff have access to your order information in order to serve you better, or that we can better understand your use of our Site in order to improve its usability and the services we offer you.

Finally, when it comes to the processing of Personal Data for marketing purposes, the legal basis for processing is your consent (see Article 1.6.1. above).

Internet browsing security

Integrity of your data on the Internet

The Site has appropriate security measures in place to prevent any loss, unauthorised use or access, modification or disclosure of your Personal Data.

All personal data collected is stored on secure servers. The Data Controller has also implemented procedures to manage any personal data breaches.

Malicious use

We recommend that you only connect to secure networks, preferably private networks. Be aware of the risks involved in using public Wi-Fi networks.

Regardless of the Data Controller to whom you have voluntarily provided your Personal Data, and given the nature of the Internet, other operators, unrelated to the Data Controller, may be able to capture this data without your consent, particularly when you are browsing the Internet. We therefore recommend that you install anti-virus and anti-spyware software on your computer and update it regularly.

Identity theft/Phishing

The Data Controller will never contact you by email to request personal information.
If you receive an email on behalf of the Data Controller asking you to provide sensitive personal information (bank details, information relating to your private life, etc.), please do not reply and forward the email to us so that we can take the necessary action.

You should only provide information relating to your account after logging in to the Website directly via your browser.

Cookie policy

A cookie is a connection token, i.e. a text file that may be stored in a dedicated area of your Device's hard drive when you visit a website. A cookie allows its issuer to identify the Device on which it is stored for the duration of the cookie's validity or storage.

When you visit the Website, information relating to your device's browsing activity (computer, tablet, smartphone, etc.) may be stored in cookies installed on your device, subject to the choices you have made regarding cookies, which you can change at any time.

What are the cookies issued on our Website used for?

Only the issuer of a cookie can read or modify the information contained therein.

When you connect to the Website, the Data Controller may, subject to your choices, install various cookies on your Device to recognise your Device's browser during the period of validity of the cookie concerned. The cookies we issue are used for the purposes described below.

The cookies we issue enable us to:

  • conduct studies and compile statistics and traffic volumes and usage of the various elements that make up our Website (sections and content visited, paths taken), enabling the Data Controller to improve the interest and ergonomics of its services;
  • adapt the presentation of the Website to the display preferences of your Device (language used, display resolution, operating system used, etc.) during your visits to the Website, depending on the hardware and software used to view or read the Website on your Device; and
  • implement security measures, for example when you are asked to log in again to access content or a service after a certain period of time.

Your choices regarding cookies

There are several ways to manage cookies. Any settings you may make may affect your Internet browsing and your access to certain services that require the use of cookies.

You can choose at any time to express and modify your preferences regarding cookies, using the methods described below.

In particular, you can configure your browser software so that cookies are stored on your device or, conversely, are rejected, either systematically or depending on their issuer.

You can also configure your browser software so that you are asked to accept or refuse cookies on a case-by-case basis, before a cookie is likely to be stored on your device. For more information, see the section ‘How to exercise your choices, depending on the browser you use’ in Article 4.2.3. below.

Agreement on cookies

The storage of a cookie on a device is essentially subject to the device user's consent, which they can express and modify at any time and free of charge through the choices offered by their browser software.

If you have accepted the storage of cookies on your Device in your browser software, the cookies embedded in the pages and content you have viewed may be stored temporarily in a dedicated area of your Device. They will only be readable by their issuer.

Refusing cookies

If you refuse to accept cookies on your Terminal, or if you delete those that are already stored there, the quality of the services offered by the Website will not be affected.

However, you will no longer be able to benefit from a number of features that may be necessary to navigate certain areas of the Website. This would be the case if you attempted to access content or services for which the use of cookies is strictly necessary (e.g. booking a holiday). This would also be the case if the Data Controller - or its service providers - could not recognise, for technical compatibility purposes, the type of browser used by your Device, its language and display settings, or the country from which your Device appears to be connected to the Internet.

Where applicable, the Data Controller declines all responsibility for the consequences related to the functioning of its services resulting from its inability to record or consult the cookies necessary for their functioning and which you have refused or deleted.

Please note that certain cookies cannot be deleted as they are strictly necessary for the technical functioning of the Website.

How to exercise your choices, depending on the browser you use?

Each browser has different settings for managing cookies and your choices. These are described in your browser's help menu, which will allow you to find out how to change your cookie preferences.

Deleting your cookies

You can delete all your cookies or only those you want. Deleting cookies does not prevent browsing or their reinstallation during browsing. This allows you to control your browser's cookie library at any given time. Technical cookies, which are necessary for browsing, will be reinstalled if you visit the Site.

Below, we explain the procedure to follow depending on your browser.

Chrome

  • In the Chrome menu, select ‘Settings’.
  • Display the advanced settings.
  • Go to the ‘Privacy’ section.
  • Click on ‘Content settings’.
  • In the ‘Cookies’ section (first section), click on ‘Cookies and site data’.
  • Find the cookies you want to delete and click ‘OK’. You can also choose to delete all your cookies.

Firefox

  • In the Firefox menu, go to ‘Tools’ and then ‘Options’.
  • On the ‘Privacy’ tab, click ‘Show Cookies’.
  • Find the cookies you want to delete and click ‘Delete Cookies’.

Safari

  • In the Safari menu, select ‘Preferences’.
  • In the window that opens, go to the ‘Security’ tab.
  • Click on ‘Show Cookies’.
  • In the window that opens, find and select the cookies you want to delete, and click on ‘Delete’.
     

Private browsing

The ‘Private browsing’ mode, now offered by all browsers, mainly allows you to browse the Internet without keeping a history of the pages you have visited or downloads you have made. As for cookies, all those that have been stored during your browsing will be deleted when you close your browser. This is therefore not a solution for refusing cookies; however, their lifetime is limited to the duration of your browsing session.

Disabling third-party cookies

Disabling third-party cookies allows you to accept only cookies placed by the Website, which you can also disable, delete or limit. Here is the procedure to follow, depending on your browser, if you wish to refuse third-party cookies:

Chrome

  • In the Chrome menu, select ‘Settings’.
  • Display the advanced settings.
  • Go to the ‘Privacy’ section.
  • Click on ‘Content settings’.
  • In the ‘Cookies’ section (first section), tick the box ‘Block cookies and third-party site data’.
  • Save the changes by clicking on ‘OK’.

Firefox

  • In the Firefox menu, go to ‘Tools’ then ‘Options’.
  • On the ‘Privacy’ tab, tick the box ‘Accept cookies’.
  • For the ‘Accept third-party cookies’ setting, select ‘Never’.
  • Save the changes by clicking on ‘OK’.

Safari

  • In the Safari menu, select ‘Preferences’.
  • In the window that opens, go to the ‘Security’ tab.
  • Under ‘Accept cookies’, select ‘Only from sites I visit’.

Your choices expressed online directly to us

If you do not want:

  • us to collect data about your browsing,
  • us to be able to identify the original special offer when you register via a special offer,

you can choose to disable all third-party cookies that are not essential for browsing the Website.

We will then store a cookie on your Device for the sole purpose of disabling the storage of these cookies on your computer. This cookie will be valid for twelve (12) months.

Please note that your preference is stored in a cookie. If you delete all cookies stored on your device (via your browser), the Data Controller or its service providers will no longer know that you have chosen this option.