Privacy Policy

PALAZZO EVENTS attaches particular importance to protecting the privacy and personal data of its clients, prospective clients, partners and the users of the lepalaismichelange.com website.

This Privacy Policy describes the personal data that may be collected, the purposes and legal bases of the related processing activities, the recipients of the data, their retention periods, and the rights available to data subjects.

It applies to the processing carried out by PALAZZO EVENTS in connection with the use of the website, contact or quote requests, the preparation and organisation of events, and the commercial and contractual relationship.

These processing activities are carried out in accordance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (GDPR) and the French Data Protection Act (loi Informatique et Libertés).

1. Data controller

The controller for the processing of personal data is:

PALAZZO EVENTS — Le Palais Michel Ange

Single-member private limited company (EURL)
Share capital: €1,000

Registered office:

Résidence Le Grand Hôtel
45 boulevard de la Croisette
06400 Cannes — France

Place of operation:

Le Palais Michel-Ange
3 rue Michel-Ange
06400 Cannes — France

SIREN: 102 761 681
RCS: 102 761 681 R.C.S. Cannes

Telephone: 07 83 59 56 41
Email: lepalaismichelange@gmail.com

The person responsible for these processing activities is Mrs Souad ARNAUD, in her capacity as manager of PALAZZO EVENTS.

As at the date of this Policy, PALAZZO EVENTS has not designated a Data Protection Officer (DPO). Should a DPO be appointed at a later date, their contact details will be added to this Policy.

2. Personal data that may be collected

Depending on the nature of your request and your relationship with PALAZZO EVENTS, the following categories of data may be collected.

2.1. Identification data

• surname and first name;
• company, organisation or business;
• job title or professional role;
• postal address, where necessary.

2.2. Contact details

• email address;
• telephone number;
• postal address;
• professional contact details.

2.3. Information relating to your event

• nature of the event;
• desired date;
• timings;
• number of guests;
• services requested;
• layout or specific requirements;
• budget or information provided voluntarily;
• information necessary for the preparation and organisation of the event.

2.4. Commercial and contractual data

• contact and quote requests;
• quotations, contracts and special terms;
• correspondence by email, telephone or any other means of communication;
• documents provided for the organisation of the event;
• information relating to invoicing and payments;
• complaints, requests and correspondence relating to the performance of the contract.

2.5. Technical data

When browsing the website, certain technical data may be processed where necessary for the proper functioning and security of the site, including:

• IP address;
• data relating to the browser and device used;
• connection data;
• information relating to the choices expressed regarding cookies and other trackers.

As at the date of this Policy, the website does not use any advertising cookies or profiling trackers. Detailed information on cookies and other trackers is set out in the Cookie Policy.

2.6. CCTV data

Individuals who may be filmed in the relevant areas of the Palais Michel-Ange may have their image captured as part of the CCTV system installed on the premises. The arrangements applicable to this system are set out in Section 14 of this Policy and in the signage displayed on site.

3. How data is collected

Personal data may be collected when you:

• complete a contact or quote request form;
• contact us by telephone;
• send us an email;
• correspond with PALAZZO EVENTS about an event;
• request a visit to the Palais Michel-Ange;
• accept a quotation or sign a contract;
• provide documents required for the organisation of the event;
• correspond with PALAZZO EVENTS in connection with the performance of a service;
• browse the website, where certain data is necessary for its functioning or security;
• are present in areas covered by the CCTV system.

PALAZZO EVENTS collects only the data necessary for the purposes pursued. Where information is requested through a form, mandatory fields are indicated where relevant.

4. Purposes of processing

Personal data is processed for the following purposes.

4.1. Handling contact and quote requests

• responding to requests for information;
• assessing the needs expressed;
• preparing and issuing a quotation;
• arranging a visit to the Palais Michel-Ange;
• corresponding with the enquirer about their project.

4.2. Preparing and organising events

• preparing the service;
• organising the provision of the spaces;
• coordinating the information necessary for the smooth running of the event;
• communicating with the client, its representatives and, where necessary, authorised contractors;
• providing follow-up before, during and after the event.

4.3. Managing the contractual relationship

• preparing and managing quotations, contracts and special terms;
• managing bookings;
• monitoring the performance of services;
• handling requests, complaints and any disputes;
• issuing invoices and tracking payments.

4.4. Administrative, accounting and tax management

• maintaining accounting records;
• complying with tax, accounting and administrative obligations;
• retaining the documents necessary to evidence transactions;
• responding to requests from competent authorities.

4.5. Security of persons, property and premises

• preventing intrusions, damage and unauthorised access;
• ensuring the safety of persons and the security of property;
• recording and documenting incidents;
• providing relevant footage or information to the competent authorities where necessary.

4.6. Operation and security of the website

• ensuring access to and operation of the website;
• remembering the user's cookie choices;
• preventing fraudulent use;
• ensuring the technical security of the website and its services.

4.7. Commercial prospecting

PALAZZO EVENTS may use the contact details of its clients or prospective clients to send them commercial information where such use is permitted under applicable regulations.

Anyone may object at any time to the use of their data for commercial prospecting purposes, in particular by using the unsubscribe link where one is provided, or by contacting PALAZZO EVENTS using the contact details set out in this Policy.

PALAZZO EVENTS does not sell, rent or transfer personal data to third parties for commercial purposes.

5. Legal bases

The processing of personal data relies, depending on the circumstances, on one of the following legal bases:

Where processing is based on the performance of a contract or on pre-contractual measures, providing the necessary data may be essential in order to respond to a request, prepare a quotation or organise a service.

Where processing is based on a legal obligation, a refusal to provide the necessary data may prevent PALAZZO EVENTS from complying with its obligations, particularly in relation to invoicing and accounting.

Where processing is based on consent, that consent may be withdrawn at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

6. Mandatory or optional nature of data

The data requested in connection with a contact request, a quotation or a booking is required only where it is essential to respond to the request, prepare the quotation, conclude the contract or perform the service.

Where certain data is optional, its absence does not necessarily prevent the request from being processed. However, the absence of necessary information may prevent PALAZZO EVENTS from responding fully or providing the service requested.

Information provided voluntarily by the user should be limited to what is necessary for their request. It is recommended not to send sensitive data or confidential information that is not necessary for the processing of the request, whether via the website or by email.

7. Recipients of data

Personal data may be accessible, within the limits of their respective duties and authorisations, to:

• PALAZZO EVENTS;
• authorised individuals involved in managing requests, bookings or events;
• technical service providers involved in hosting, maintaining or securing the website;
• administrative, accounting or professional service providers acting on behalf of PALAZZO EVENTS;
• service providers required for the preparation or performance of the event, where such disclosure is necessary and permitted;
• administrative or judicial authorities and legally authorised bodies where required or permitted by law.

Service providers processing data on behalf of PALAZZO EVENTS are selected with care and must provide sufficient guarantees in terms of confidentiality and security. Where necessary, their obligations are governed by a contract compliant with applicable regulations.

PALAZZO EVENTS never sells, rents or transfers personal data for commercial purposes.

8. Retention periods

PALAZZO EVENTS retains personal data for no longer than is necessary for the purposes for which it is processed, subject to legal obligations and the applicable time limits relating to evidence, limitation periods and the defence of rights.

Once the applicable retention periods have elapsed, data is deleted or anonymised. It may be retained in archived form where such retention is necessary to comply with a legal obligation or to establish, exercise or defend a right before the courts.

9. Data security

PALAZZO EVENTS implements appropriate technical and organisational measures to preserve the security, confidentiality and integrity of personal data.

These measures may include, in particular:

• restricting access to authorised individuals;
• managing access rights according to the needs of each role;
• protecting the accounts and tools used;
• securing electronic communications where possible;
• limiting access to documents containing personal data;
• retaining data for a limited period;
• raising awareness among authorised individuals regarding data confidentiality.

PALAZZO EVENTS takes reasonable measures to prevent the loss, destruction, alteration, disclosure of, or unauthorised access to, personal data.

In the event of a personal data breach likely to result in a risk to the rights and freedoms of data subjects, PALAZZO EVENTS will take the measures provided for by applicable regulations, in particular regarding notification to the CNIL and, where necessary, informing the data subjects concerned.

10. Transfers outside the European Union

Wherever possible, PALAZZO EVENTS favours service providers located within the European Union or the European Economic Area.

Where certain service providers or technical tools involve a transfer of data to a country outside the European Union or the European Economic Area, such a transfer is carried out solely in accordance with the conditions set out in the GDPR.

The safeguards applied may include, in particular:

• an adequacy decision of the European Commission;
• standard contractual clauses adopted by the European Commission;
• appropriate safeguards provided for by the GDPR;
• any other legally recognised mechanism.

Further information regarding the service providers concerned may be provided on request, subject to applicable confidentiality and security obligations.

11. Your rights

In accordance with the GDPR and the French Data Protection Act, and subject to the conditions and limits set out in applicable regulations, you have the following rights.

11.1. Right of access

You may request confirmation as to whether personal data concerning you is being processed and obtain a copy of that data, together with the information provided for by applicable regulations.

11.2. Right to rectification

You may request the correction of inaccurate or incomplete data.

11.3. Right to erasure

You may request the deletion of your data where the conditions set out in applicable regulations are met. This right is not absolute. PALAZZO EVENTS may in particular be required to retain certain data in order to comply with a legal obligation or to establish, exercise or defend a right before the courts.

11.4. Right to restriction of processing

You may request the temporary restriction of processing in the cases provided for by the GDPR, in particular where the accuracy of the data is contested or where you have objected to processing.

11.5. Right to object

You may object to processing based on the legitimate interest of PALAZZO EVENTS for reasons relating to your particular situation. You may object at any time to the use of your data for commercial prospecting purposes.

11.6. Right to data portability

Where this right applies, you may receive the personal data you have provided in a structured, commonly used and machine-readable format, or request that it be transmitted to another controller.

11.7. Right to withdraw consent

Where processing is based on your consent, you may withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

11.8. Post-mortem directives

In accordance with applicable regulations, you may issue directives regarding the retention, erasure and disclosure of your personal data after your death.

12. Exercising your rights

You may exercise your rights by sending a request to:

PALAZZO EVENTS

By email: lepalaismichelange@gmail.com

Or by post:

PALAZZO EVENTS
Résidence Le Grand Hôtel
45 boulevard de la Croisette
06400 Cannes — France

Where necessary, the request should specify the right being exercised and be sufficiently precise to enable it to be processed.

In order to protect personal data, PALAZZO EVENTS may request proof of identity where necessary to verify the identity of the person making the request. Such proof is used solely for this purpose and is not retained beyond the period necessary for verification, save where a legal obligation requires otherwise.

PALAZZO EVENTS responds to requests within one month of receipt. This period may be extended by two months where the request is complex or where a large number of requests need to be handled. In such cases, PALAZZO EVENTS will inform the data subject of this extension within the initial one-month period.

13. Complaint to the CNIL

If, after contacting PALAZZO EVENTS, you consider that your rights are not being respected or that the processing of your personal data does not comply with applicable regulations, you may lodge a complaint with the:

Commission nationale de l’informatique et des libertés (CNIL)

3 place de Fontenoy
TSA 80715
75334 Paris Cedex 07
France

You may also obtain information and lodge a complaint via the CNIL website: www.cnil.fr

Every data subject also has the right, subject to the conditions set out in applicable regulations, to lodge a complaint with the CNIL.

14. CCTV at Le Palais Michel-Ange

Le Palais Michel-Ange is fitted with a CCTV system located inside the premises.

14.1. Purposes

The system is intended to:

• ensure the safety of persons;
• protect property and premises;
• prevent and record intrusions;
• prevent and record damage;
• monitor unauthorised access;
• help establish the facts in the event of an incident.

The system is not intended to permanently monitor guests, clients or contractors during events.

14.2. Legal basis

The processing of footage is based on the legitimate interest of PALAZZO EVENTS in ensuring the security of persons, property and premises, in accordance with applicable regulations.

14.3. Access to images

Access to footage is restricted to individuals authorised by PALAZZO EVENTS and, where necessary, to the competent administrative or judicial authorities. Footage is not disclosed to unauthorised third parties.

14.4. Retention period

Footage is retained for a maximum of seven (7) days from recording, after which it is deleted. In the event of an incident, strictly necessary footage may be extracted and retained for the period necessary to establish the facts, transmit it to the competent authorities, or establish, exercise or defend the rights of PALAZZO EVENTS.

14.5. Informing individuals

Individuals who may be filmed are informed of the existence of the system by means of visible signage displayed on the premises. This signage indicates, in particular, the existence of the system, its purpose, and the means available for obtaining further information or exercising applicable rights.

14.6. Exercising rights regarding footage

Rights relating to footage may be exercised by contacting PALAZZO EVENTS using the details set out in Section 12 of this Policy. Any request should specify, as far as possible, the date, approximate time and location concerned, in order to allow the footage to be identified.

The exercise of the right of access may be limited where disclosure of the footage would infringe the rights and freedoms of other individuals, or where a restriction is necessary to prevent an offence, protect an investigation or comply with a legal obligation. For certain professional or private events requiring particular confidentiality, the Client may request further information about how the system operates. Any request for temporary deactivation remains subject to the agreement of PALAZZO EVENTS and to applicable security requirements.

15. Cookies and other trackers

The website may use cookies or other trackers that are necessary for its operation, as well as to remember the user's cookie choices. As at the date of this Policy, no advertising cookies or profiling trackers are used.

Information relating to cookies and other trackers, their purposes, their retention periods and how to manage preferences is set out in detail in the Cookie Policy available on the website.

Where consent is required, the relevant cookies and trackers are placed or read only after the user's consent has been obtained.

16. Changes to this Policy

PALAZZO EVENTS may amend this Privacy Policy to reflect:

• changes to the website;
• the services offered;
• the data processing activities implemented;
• changes to the technical tools used;
• legal or regulatory obligations;
• CNIL recommendations.

The version published on the website is the version applicable as at the date of consultation. The date of the last update is shown at the top of this Policy.

In the event of a substantial change affecting the rights of data subjects or the arrangements for processing personal data, PALAZZO EVENTS may inform data subjects by any appropriate means where necessary.

17. Contact

For any question concerning this Privacy Policy, the processing of personal data or the exercise of your rights, you may contact:

PALAZZO EVENTS — Le Palais Michel-Ange

Registered office:

Résidence Le Grand Hôtel
45 boulevard de la Croisette
06400 Cannes — France

Place of operation:

Le Palais Michel-Ange
3 rue Michel-Ange
06400 Cannes — France

Telephone: 07 83 59 56 41
Email: lepalaismichelange@gmail.com