Privacy Policy
Privacy Policy
CONCIERGERIE NAYA, concerned about the rights of individuals, particularly with regard to automated processing and in a desire for transparency with its customers, has implemented this privacy policy covering all of this processing, the purposes pursued by the latter. as well as the means of action available to individuals so that they can best exercise their rights.
The Privacy Policy (hereinafter “the Policy”) is established in compliance with the following guidelines:
European Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as “GDPR”;
Law n°78-17 of January 6, 1978 relating to information, files and modified freedoms, hereinafter called “LIL”;
Law n°2018-493 of June 20, 2018 relating to the protection of personal data.
Article 1 – Definitions
Charter
means the operation by which the CONCIERGERIE NAYA concludes, on behalf of a Client, a transport contract with an Operator who is responsible for carrying out the Flight with the Aircraft.
Personal data
Or “Data”
means any information relating to an identified or identifiable natural person (data subject); is deemed to be identifiable a person who can be identified, directly or indirectly, in particular by reference to a name, an identification number or to one or more specific elements, specific to his physical, physiological, genetic, psychological, economic, cultural or social.
Operator
designates the legal person offering the Charter of its aircraft and being able to carry out the flight(s), in accordance with the transport contract concluded with the CONCIERGERIE NAYA according to the criteria of the Customer’s order
Passenger
designates the persons benefiting from the Services provided by the CONCIERGERIE NAYA.
Services
refers to all the services offered by the CONCIERGERIE NAYA via its website as defined in the General Conditions of Sale.
Article 2 – About the CONCIERGERIE NAYA
2.1 The CONCIERGERIE NAYA as data controller:
The data controller is defined by the GDPR, in article 4.7, as being the person who determines the purposes and means of the processing of Personal Data.
The CONCIERGERIE NAYA has the status of data controller for all data processing relating to the Services it offers, as well as the management of its Clients, from the first Request for quotation.
For any request concerning the processing of Personal Data collected by the CONCIERGERIE NAYA as data controller via the website https://www.conciergerienaya.com Customers can contact the data controller via the following address: contact @conciergerienaya.com
2.2 The CONCIERGERIE NAYA as co-controller
The co-controller, defined in article 4.7 of the GDPR, is the person who determines jointly with another data controller, the purposes and means of the processing of the Personal Data collected.
The CONCIERGERIE NAYA has the status of co-controller for all data processing relating to transport contracts that it concludes on behalf of the Customer with the Operator when they jointly collect Personal Data relating to the Customer for the performance of the Services provided for in the Contract.
2.3 CONCIERGERIE NAYA as a subcontractor
The processor, defined in article 4.8 of the GDPR, is the person who processes Personal Data on behalf of a data controller, and under the authority and instructions of the latter.
This Policy concerns both the data processing carried out by Access Air in its capacity as data controller or joint controller or subcontractor.
Article 3 – collection and origin of Data
As part of the provision of its Services, La CONCIERGERIE NAYA collects Personal Data relating to its Customers. This data may come directly from Customers, or may have been collected from Passengers. The personal information that can be collected on the site is mainly used by the CONCIERGERIE NAYA for the management of relations with the Customers, and if necessary for the processing of orders placed.
In all cases, Customers are informed of the purposes for which their data is collected by the CONCIERGERIE NAYA via the various online data collection forms, in particular the Request for quotation, the emails sent, the notifications on the site, by SMS , by instant messages on the various social networks of the CONCIERGERIE NAYA, by telephone interviews, or even via our Charter for the use of cookies.
In all cases, Customers are informed of the purposes for which their data is collected by the CONCIERGERIE NAYA via the various online data collection forms, in particular the Request for quotation, the emails sent, the notifications on the site, by SMS , by instant messages on the various social networks of the CONCIERGERIE NAYA, by telephone interviews, or even via our Charter for the use of cookies.
Article 4 – Data processed
CONCIERGERIE NAYA informs its Customers that it may process the following Data:
Data relating to your identity: title, surname, first name(s), address of your company or personal address, telephone number, date of birth, email addresses;
Data collected during the use of the Services: travel preferences, dietary habits;
Data collected via cookies and other tracers present on our site;
Payment data: means of payment used
Data relating to the payment of invoices: terms of payment, discounts granted, receipts, balances and unpaid bills, information necessary for invoicing
In any event, La CONCIERGERIE NAYA undertakes to process all the Data collected in accordance with the GDPR and the Data Protection Act.
Article 5 – Uses/Purposes and legal basis of processing
The legal basis of the processing is the execution of the contract concluded between the Clients and LA CONCIERGERIE NAYA.
The Personal Data collected from Customers is intended to provide the Services on the site, improve them and maintain a secure environment.
The processing is necessary for the performance of the services provided for in the Charter Quote, then the contract concluded between the Customer and the CONCIERGERIE NAYA on behalf of the Passenger(s).
Specifically, the uses are as follows:
The proper performance of the CONCIERGERIE NAYA Services;
Customer management ;
Carrying out marketing operations;
Accounting management and the carrying out of associated operations;
Proper access to and use of the site;
Management of the operation and optimization of the site;
The implementation of customer assistance;
Verification, identification and authentication of data transmitted by Customers;
Management of requests for rights arising from the GDPR and the amended Data Protection Act;
The personalization of services by displaying advertisements based on the Customer’s browsing history, according to their preferences;
Prevention and detection of fraud, malware (malicious software or malicious software) and management of security incidents;
Management of any disputes with Customers;
Sending commercial and advertising information, according to the Customer’s preferences; organization of the conditions of use of the Payment Services.
Article 6 – Duration of data retention
CONCIERGERIE NAYA retains the Data of its Customers only for the time necessary to provide them with its Services or assistance as described in Article 5, and in compliance with the legal retention periods.
To the extent reasonably necessary or required to meet legal or regulatory obligations, settle disputes, prevent fraud and abuse or apply our terms and conditions, CONCIERGERIE NAYA may also retain certain information of its Customers, if necessary after the end of the business relationship.
More precisely :
For the proper functioning and continuous improvement of the site, its functionality and the Services:
Data allowing the identification of Customers are kept for the duration of the commercial relationship.
Cookies and other commercial tracers according to the Cookies Use Charter can be placed on the Customer’s terminal with their consent, for a maximum period of 13 months. Beyond this period, the raw traffic data associated with an Identifier is either deleted or anonymized.
For Customer management:
The Data used in the context of the management of the Customer relationship are kept for the duration necessary for the execution of the contract.
This Data is then archived for a period of 5 years for probative purposes. Invoices and accounting data issued are kept for 10 years from their issue.
In the absence of conclusion of the contract, the Data of a prospect are kept for a period of 3 years from their collection or from the last positive contact with the CONCIERGERIE NAYA.
For the realization of marketing operations:
The Data used in the context of marketing operations are kept for a period of 3 years from the end of the commercial relationship as a Customer or from the last contact if it is a prospect.
In the event that the Client has not purchased Services from the CONCIERGERIE NAYA or has not used his account for 27 months and the Client is not subscribed to the CONCIERGERIE NAYA newsletter will no longer retain the Data of the latter’s personal nature for commercial purposes.
For accounting management and carrying out related operations:
It is recalled that for payments by bank card, in accordance with article L.133-24 of the Monetary and Financial Code, this data may be kept for the purpose of proof in the event of any dispute of the transaction or complaint, in intermediate archives, for a period of 13 months following the debit date (duration extended to 15 months for deferred debit payment cards).
The accounting record of payments is kept for a period of 10 years in intermediate archiving from the effective completion of the payment (see article L.123-22 of the Commercial Code).
Litigation and pre-litigation actions
As part of the management of a pre-litigation, the Data is deleted as soon as the dispute is settled amicably or, failing that, as soon as the corresponding legal action expires.
The Data collected and processed in the context of litigation must be deleted when the decision is rendered as res judicata.
For the management of requests for rights arising from the GDPR and the amended Data Protection Act:
Data relating to the management of rights requests is kept for the duration necessary to process the request. They are then archived for the applicable limitation period in intermediate archiving.
Article 7 – Customers’ rights
In accordance with the GDPR and the LIL, CONCIERGERIE NAYA Clients have the following rights:
Right of access and information (article 15 GDPR): Customers can exercise their right of access and information to know the Data that concerns them;
Right of rectification (article 16 GDPR): Customers may request the updating and completeness of the Data concerning them if they are inaccurate;
Right to erasure of Personal Data (Article 17 GDPR): Customers may request the deletion of their data when they are inaccurate, incomplete, ambiguous, outdated, or when their collection, use, communication or storage is prohibited;
Right to limitation of processing (article 18): Customers may ask the site to limit the processing of Data when they are inaccurate, incomplete, ambiguous, outdated, or when their collection, use, communication or storage is prohibited;
Right to oppose the processing of data (article 21 GDPR): Customers may object at any time to the processing of their data, for reasons relating to their particular situation;
The right to portability (article 20): Customers may request that CONCIERGERIE NAYA hand over their Personal Data provided to transmit them to another company;
The right not to be the subject of a decision based on exclusively automated processing (article 22 GDPR): no decision-making of this type is currently applied by the CONCIERGERIE NAYA;
Right to define the fate of the data after death and to choose whether the Data is communicated (or not) to a previously designated third party (article 85 LIL). In the event of death and in the absence of instructions from you, the CONCIERGERIE NAYA undertakes to destroy the Data, unless their retention proves necessary for evidentiary purposes or to meet a legal obligation.
Customers can exercise their rights by contacting us at the following addresses:
By email, at: contact@conciergerienaya.com
These rights can be exercised by simple request by justifying your identity and a legitimate reason when this is required by law.
The CONCIERGERIE NAYA undertakes to send a response within one month of receiving the request. This one-month period may be extended by two months if the complexity of the request and/or the number of requests so requires.
Customers can also lodge a complaint with the supervisory authorities, in particular the CNIL on its website: https://www.cnil.fr.
La CONCIERGERIE NAYA recommends contacting it first before filing a complaint with the CNIL, because La CONCIERGERIE NAYA is at your entire disposal to resolve this problem.
Article 8 – Sharing of personal data with third parties and transfer outside the European Union
Within the limits of their attributions and for the purposes mentioned in article 5, the main people who will be likely to have access to the Data are the following:
Authorized personnel from our marketing, sales, administrative, logistics, legal and IT departments, responsible for improving our services, customer relations and prospecting and quality control.
The authorized personnel of our subcontractors
The authorized personnel of our co-controller
Les données personnelles peuvent être partagées avec des sociétés tierces exclusivement dans l’Union européenne, dans les cas suivants :
Quand le Client utilise les services de paiement : pour la mise en œuvre de ces services, la CONCIERGERIE NAYA est en relation avec des sociétés bancaires et financières tierces avec lesquelles elle a passé des contrats ;
When the CONCIERGERIE NAYA uses the services of service providers to provide Customer assistance, advertising and payment services. These service providers have limited access to Customer data, as part of the performance of these services, and have a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of Personal Data. personal ;
If required by law, the CONCIERGERIE NAYA may transmit data to respond to complaints against the site and to comply with administrative and legal procedures.
Certain categories of subcontractors have access to the data collected, in particular:
The following financial institutions: (banks)
If applicable, the courts concerned, mediators, accountants, auditors, lawyers, bailiffs, debt collection companies;
Third parties likely to place cookies on your terminals (computers, tablets, mobile phones, etc.) when you consent (For more details, see our Cookies Policy).
Customers’ personal data is not communicated, exchanged, sold or rented without the prior express consent in accordance with the applicable legal and regulatory provisions.
The CONCIERGERIE NAYA has taken appropriate measures to ensure its Customers that their Data is kept securely via the contractualization of standard clauses approved by the European Commission (art. 46 GDPR) or via the so-called “Privacy Shield” mechanism.
Customers may request access to documents providing appropriate contractual guarantees by sending a request by email to contact@conciergerienaya.com
Article 9 – Minors
The CONCIERGERIE NAYA Services and website are not intended for minors.
The CONCIERGERIE NAYA does not voluntarily collect Personal Data from minors under the age of 15.
Article 10 – Social networks
When browsing the CONCIERGERIE NAYA website, Customers have the option of clicking on the icons dedicated to the social networks Twitter, Facebook, Instagram and LinkedIn appearing on our site.
Social networks improve the user-friendliness of the site and help promote it through sharing.
When Customers use these buttons, CONCIERGERIE NAYA may have access to personal information that Customers have indicated as public and accessible from their Twitter, Facebook, Instagram and LinkedIn profiles. However, CONCIERGERIE NAYA does not create or use any database independent of Twitter, Facebook, Instagram and LinkedIn and does not use any data relating to the privacy of its Customers in this way.
Article 11 – Security
Access to the site and its use are reserved for strictly personal use.
Customers undertake not to use this site and the information or data contained therein for commercial political and advertising purposes and for any form of commercial solicitation and in particular the sending of unsolicited e-mails.
The CONCIERGERIE NAYA complies with the GDPR and the Data Protection Act in terms of data security and confidentiality.
The CONCIERGERIE NAYA implements all the technical and organizational measures necessary to ensure the security of the processing of Personal Data and the confidentiality of the Data it collects.
As such, the CONCIERGERIE NAYA takes all useful precautions, with regard to the nature of the Data and the risks presented by the processing, to preserve its security and, in particular, to prevent the data from being distorted, damaged, or that third parties not have access to it (physical protection of premises, authentication procedures for people accessing data with personal and secure access via confidential identifiers and passwords, secure https protocol, logging and traceability of connections, encryption of certain data, etc.).
Article 12 – Responsibilities
For the proper management of the site, the CONCIERGERIE NAYA may at any time:
Suspend, interrupt or limit access to all or part of the site, reserve access to the site, or to certain parts of the site, to a specific category of Internet users;
Delete any information that could disrupt its operation or contravene national or international laws;
Suspend the site in order to make updates.
The responsibility of the CONCIERGERIE NAYA cannot be engaged in the event of failure, breakdown, difficulty or interruption of operation, preventing access to the site or to one of its functionalities.
The site connection equipment that Customers use is under their sole responsibility. Customers must take all appropriate measures to protect their equipment and their own data, in particular from viral attacks via the Internet.
The CONCIERGERIE NAYA cannot be held responsible in the event of legal proceedings:
Due to the use of the site or any service accessible via the Internet;
Due to the non-compliance by its Customers with this Policy.
The CONCIERGERIE NAYA is not responsible for damage caused to its Customers, to third parties and/or to their equipment as a result of your connection or their use of the site.
Article 13 – Intellectual property
All trademarks, photographs, texts, comments, illustrations, animated or still images, video sequences, sounds, as well as all computer applications that could be used to operate this site and more generally all elements reproduced or used on the site are protected by the laws in force under intellectual property.
They are the full and entire property of the CONCIERGERIE NAYA or its partners. Any reproduction, representation, use or adaptation, in any form whatsoever, of all or part of these elements, including computer applications, without the prior written consent of CONCIERGERIE NAYA, is strictly prohibited.
The fact that the CONCIERGERIE NAYA does not initiate proceedings upon becoming aware of these unauthorized uses does not constitute acceptance of said use and waiver of prosecution.
Article 14 – Commercial offers
Customers are likely to receive commercial offers from CONCIERGERIE NAYA. If Clients do not wish this, they can click on the following link: contact@conciergerienaya.com.
The Data is likely to be used by the CONCIERGERIE NAYA partners for commercial prospecting purposes, if the Customers do not wish this, they can click on the following link: contact@conciergerienaya.com.
If, during the consultation of the site, a Customer accesses Personal Data, he must refrain from any collection, any unauthorized use and any act that may constitute an invasion of the privacy or reputation of the people.
The CONCIERGERIE NAYA declines all responsibility in this regard.
Section 15 – Cookies
The use of cookies by the CONCIERGERIE NAYA is indicated in the Cookies Use Charter. It should be referred to. It should be referred to.
Article 16 – Modification of the privacy policy
The CONCIERGERIE NAYA may need to change its Services and change its Privacy Policy. Where applicable, Customers are notified by email of any significant changes to the Privacy Policy.
The version currently online is the only one opposable for the duration of use of the site and until a new version replaces it.
Article 17 – Applicable law
The policy is governed by French law.
Article 18 – Contact us
For any questions, information on the products presented on the site, or concerning the site itself, you can leave a message at the following address: contact@conciergerienaya.com