Article 1. Purpose

CLUB DES SPORTS DE COURCHEVEL attaches great importance to the protection and respect of privacy and personal data (" Personal Data ") of the users of its website https://www.ineosclubhouse.com and the persons whose data it collects in the course of its activities (the " Person(s) concerned ").

CLUB DES SPORTS DE COURCHEVEL undertakes to implement adequate measures for the protection, confidentiality and security of personal data and to comply with a Personal Data processing policy that complies with the regulations in force in France and the European Union, in particular the General Regulation on the Protection of Personal Data EU 2016/679 of 27 April 2016 and the rules of national law taken for its application.

This Privacy Policy (the " Policy The purpose of the "Privacy Policy" is to inform the Data Subjects of the practices and processing inherent in the collection and use of Personal Data that CLUB DES SPORTS DE COURCHEVEL is required to carry out as data controller and of the means available to them to control this use and to exercise their rights with regard to their Personal Data.

By browsing the https://www.ineosclubhouse.com website, users accept this Privacy Policy and the general conditions of use. Consequently, CLUB DES SPORTS DE COURCHEVEL invites users to read this document carefully in order to know and understand its practices regarding the processing of Personal Data.

Article 2. Personal data collected

CLUB DES SPORTS DE COURCHEVEL may collect and process Personal Data provided in the context of comments left on its website and in the comment form.

CLUB DES SPORTS DE COURCHEVEL may also collect the IP address and browser user agent of the Data Subjects to assist in the detection of unwanted comments.

a. Principles applicable to the collection of Personal Data

CLUB DES SPORTS DE COURCHEVEL applies the principle of minimization and protection of Personal Data from the design (" privacy by design ") and by default (" privacy by default "). Only Personal Data that is relevant, adequate and limited to what is necessary for the purposes of the processing, and in particular for the following purposes, is collected:

• Inserting comments or images on the site ;
• Sale of products ;
• Participation in surveys or analyses to improve customer relations and the customer experience implemented by CLUB DES SPORTS DE COURCHEVEL;
• Sending of newsletters ( newsletters") or informational or commercial email alerts;
• Guarantee of access and navigation of users on the Site ;
• Improving the efficiency and functionality of the Site.
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b. Information communicated by the user of the Site

Users can browse the Site without having to provide any Personal Information about themselves. However, users may be asked to provide personal information when this is necessary to provide certain services, such as filling in a contact form to obtain more information on the services offered.

In this case, the personal information required from users is: (i) Name(s) and (ii) E-mail address(es).

This Personal Data is then kept for the time necessary to fulfil the users' request. If the request is not fulfilled, it is deleted within the timeframe recommended by the CNIL, i.e. after three years from the date of its collection by the Site.

b. Browsing information of the users of the Site

When using the Site or certain services linked to the Site, certain user data is collected automatically: (i) IP address, (ii) reference of the navigation software used, (iii) navigation data (date, time, content consulted, etc.), (iv) operating system reference.

Among the technologies used to collect this information, CLUB DES SPORTS DE COURCHEVEL may use "sessions". php "These php sessions store data in memory only for the duration of the browsing session. These php sessions keep data in memory only for the duration of the browsing session.

The data collected during the navigation of users on the Site is deleted when the user's browser closes, or, if applicable, within a maximum period of thirteen months from the date of collection.

Article 3. Basis for the collection and processing of personal data

Personal Data are processed by CLUB DES SPORTS DE COURCHEVEL in the cases authorised by the regulations in force, and in particular in the following conditions:

• The Data Subject has given free, specific, informed and unambiguous consent to the processing of his/her Personal Data (it is specified that for minors under 18, consent must be given by the legal representative) ;
• The processing is necessary for the performance of a contract or pre-contractual measures at the request of the Data Subject;
• The processing is necessary to comply with legal and/or regulatory obligations imposed on CLUB DES SPORTS DE COURCHEVEL (such as the fight against fraud);
• The processing is justified by the protection of legitimate interests of CLUB DES SPORTS DE COURCHEVEL (such as the protection of the security of its computer network).

Article 4. Link to other websites

The Site may occasionally contain links to the websites of partners or third-party companies that have their own privacy and data protection policies.

Articles on this site may include embedded content (e.g. videos, images, articles). Embedded content from other sites behaves in the same way as if the Data Subject visited that other site.

An anonymised string created from the email address (also known as a hash) can be sent to the Gravatar service to check whether it is being used. The Gravatar service privacy policy is available at: <https://automattic.com/privacy/>. After validation of the comment, the profile picture of the Person concerned will be publicly visible next to the comment.

CLUB DES SPORTS DE COURCHEVEL invites the users of its site to take note of the personal data protection policies implemented by the publishers of these sites before transmitting any personal information concerning them.

These websites may collect data, use cookies, embed third-party tracking tools, track Data Subjects' interactions with such embedded content from the account logged onto their website.

CLUB DES SPORTS DE COURCHEVEL has no control over the content of these sites and declines all responsibility for the use made by these sites of information collected when users click on these links.

Article 5. Duration of data storage

CLUB DES SPORTS DE COURCHEVEL shall keep the Personal Data that it processes under the conditions detailed in this Policy for the time necessary to achieve the purposes pursued, subject to the possibilities and legal obligations in terms of archiving, obligations to keep certain data and/or anonymisation.

Certain Personal Data collected via the Site are kept for the period indicated in Article 2.

Article 6. Recipients of the personal data collected

Only duly authorised CLUB DES SPORTS DE COURCHEVEL staff may have access to the Personal Data collected and be required to process them, without prejudice to their possible transmission to the bodies in charge of a control or inspection mission in accordance with the legislation and/or regulations in force or for the purposes of responding to a judicial or administrative decision.

Authorised personnel are subject to an obligation of discretion and confidentiality.

CLUB DES SPORTS DE COURCHEVEL undertakes not to market the Personal Data collected to third parties.

Article 7. Transfer of data

The Personal Data collected from users of the Site are kept exclusively in France and are not transferred within or outside the European Union.

In the event of recourse to affiliates or service providers located outside the European Union, CLUB DES SPORTS DE COURCHEVEL undertakes to verify that appropriate measures have been put in place to ensure that the Personal Data of the Persons concerned benefit from an adequate level of protection.

Article 8. Data security

CLUB DES SPORTS DE COURCHEVEL collects and processes users' Personal Data with the utmost confidentiality and in compliance with applicable laws. Users are protected against unauthorised access, modification, disclosure or destruction of their Personal Data.

Where disclosure of Personal Data to third parties is necessary and permitted, COURCHEVEL SPORTS CLUB ensures that these third parties guarantee the same level of protection for the Personal Data concerned as that offered by CLUB DES SPORTS DE COURCHEVEL, and requires contractual guarantees so that, in particular, the Personal Data is processed exclusively for the purposes accepted by the Person Concerned, with the required confidentiality and security.

CLUB DES SPORTS DE COURCHEVEL has put in place technical and organisational measures to ensure that the storage of Personal Data is secure and for the period necessary to fulfil the purposes pursued in accordance with applicable law.

The attention of the Persons Concerned is drawn to the fact that no transmission or storage technology is totally infallible.

Also, and in accordance with the applicable regulations, in the event of a proven breach of Personal Data likely to give rise to a high risk for the rights and freedoms of the Data Subjects, CLUB DES SPORTS DE COURCHEVEL shall communicate this breach to the competent supervisory authority and to the Data Subjects when required by the said regulations, and in accordance with the methods provided for by the said regulations.

It is the responsibility of Data Subjects to exercise caution to prevent unauthorised access to their Personal Data and in particular to their computer and digital terminals (computer, smartphone, tablet in particular).

CLUB DES SPORTS DE COURCHEVEL advises the Persons concerned not to upload images to the Site containing EXIF data of GPS coordinates because of the downloading and extraction of location data from these images.

Article 9. Users' rights

It is recalled that the Data Subjects have the following rights, subject to the limitations provided for by the laws and/or regulations in force

a. Right to information on the processing of Personal Data

CLUB DES SPORTS DE COURCHEVEL shall use its best endeavours to provide concise, transparent and accessible information on the conditions of processing of the Personal Data of the Data Subjects.

b. Right of access to Personal Data

Each Data Subject shall have the right to obtain confirmation that Personal Data relating to him/her is being processed by CLUB DES SPORTS DE COURCHEVEL and to receive a copy of such data in electronic form (for any additional copy, CLUB DES SPORTS DE COURCHEVEL shall be entitled to demand payment of a fee based on the administrative costs incurred).

c. Right to erasure ("right to be forgotten") and rectification of Personal Data

Each Data Subject has the right to request the deletion of Personal Data concerning him or her, and the right to request the rectification of Personal Data concerning him or her when such data is erroneous or obsolete.

CLUB DES SPORTS DE COURCHEVEL undertakes to ensure that this right is respected as soon as possible and, by default, within 30 days of the request being made in sufficiently clear and unequivocal terms.

It is specified that CLUB DES SPORTS DE COURCHEVEL may retain certain Personal Data when required to do so by law or for legitimate reasons.

c. Right to object

The Data Subjects may object at any time and for reasons relating to their particular situation or for legitimate reasons to the processing of their Personal Data for direct marketing purposes or to the re-use of their Personal Data for other purposes, except in the case of the fulfilment by CLUB DES SPORTS DE COURCHEVEL of one of its legal obligations.

e. Right to limit the processing of Personal Data

The Data Subjects have the right to request the limitation of the processing of their Personal Data. This right is applicable only :

• if the Data Subject disputes the accuracy of his/her Personal Data;
• if the Data Subject can establish that the processing of his or her Personal Data is unlawful and requires restriction of use rather than erasure;
• if CLUB DES SPORTS DE COURCHEVEL no longer requires the Personal Data relating to the Data Subject but the Data Subject still needs it for the establishment, exercise or defence of legal claims;
• if the Data Subject objects to the processing being based on the legitimate interest of the controller, during the verification as to whether the legitimate grounds pursued by the controller prevail over those of the Data Subject.

f. Right of complaint to a supervisory authority

If they consider that the efforts made by CLUB DES SPORTS DE COURCHEVEL to preserve the confidentiality of Personal Data do not guarantee the respect of their rights, Data Subjects may lodge a complaint with the competent supervisory authority (CNIL or any other authority mentioned on the list available from the European Commission).

g. Right to the portability of Personal Data

The Data Subjects have a right to the portability of their data, allowing them to obtain from CLUB DES SPORTS DE COURCHEVEL the Personal Data concerning them in a structured, commonly used and machine-readable format and to request that this Personal Data be transmitted to another data controller.

h. Right to decide on the fate of Personal Data after death

The Data Subjects have the right to organise the fate of their Personal Data after their death by adopting general or specific directives which CLUB DES SPORTS DE COURCHEVEL undertakes to respect.

In the absence of such directives, CLUB DES SPORTS DE COURCHEVEL recognises the possibility for heirs to exercise certain rights, in particular the right of access if it is necessary for the settlement of the deceased's estate and the right of opposition.

i. Conditions for the exercise of rights

In order to exercise their rights, Data Subjects are invited to contact CLUB DES SPORTS DE COURCHEVEL in accordance with the procedures described in Article 10.

To help them exercise their rights, the CNIL provides model letters on its website (<www.cnil.fr>).

Before processing the request(s) of the Persons concerned, CLUB DES SPORTS DE COURCHEVEL may verify the identity of the Persons concerned by asking them for proof of identity.

CLUB DES SPORTS DE COURCHEVEL shall reply to the request as soon as possible and in any event within one (1) month of the proof of identity to reply.

If necessary, this period may be extended by two (2) months taking into account the complexity and number of requests addressed to CLUB DES SPORTS DE COURCHEVEL, CLUB DES SPORTS DE COURCHEVEL undertaking to inform the Person Concerned of the extension and the reasons for the postponement.

Article 10. Contact

For any questions relating to this Policy for the purpose of rectification, supplementation or updating, Data Subjects are invited to contact CLUB DES SPORTS DE COURCHEVEL :

• by sending a letter to the following address CLUB DES SPORTS DE COURCHEVEL 83 Rue Park City - Ineos Club House, Courchevel 1850 - 73120 Courchevel
• by sending an e-mail to contact@sportcourchevel.com

or by filling in the online contact form at https://ineosclubhouse.com/contact/