La Pélerine, a limited liability company registered in the Puy en Velay Trade and Companies Register under number 439 482 233 and whose registered office is located at 32 Place Limozin 43170 Saugues, (hereinafter "La Pélerine", "we", "us", "our") takes the protection of personal data very seriously. Voyageurs du Monde takes great care to ensure compliance with the provisions relating to the protection of personal data, and more specifically with the provisions of the amended French Data Protection Act of 6 January 1978, the General Data Protection Regulation 2016/679 ("GDPR") and the recommendations issued by the CNIL (hereinafter the "Legislation in force").

1) ABOUT THIS PRIVACY POLICY

As the party responsible for processing your personal data, La Pélerine wishes to use this privacy and cookies policy ("Privacy Policy") to explain how we may collect, use and process personal data ("Personal Data") submitted when users of the website(s) (the "Website") or our services (our "Services") by our customers or prospects.

2) HOW IS PERSONAL DATA COLLECTED?

We may collect your Personal Data directly from you:

- when you create a Customer Area on the Site or when you book a trip with La Pélerine ;

- when you contact our customer service department by email, during our telephone conversations or during appointments with our advisers in the branch.

We may obtain information about you from other sources. For example, we may ask a third party supplier to provide us with additional information about our existing customers, such as information from your profile or postings on a third party social network.

We may also collect information from your profile on a third-party social network (in particular Facebook) if you authorise the third-party social network to communicate it to us or if you post it publicly. This information may include your general account information (e.g. name, email address, profile picture, gender, date of birth, current city, username, list of friends, etc.) and any other information or activity that you allow the third party social network to share with us or that you post publicly on your profile. For example, we may receive your social network information (or some of it) when you download or interact with one of our applications on a social network site (such as Facebook). To find out more about how your social network information may be obtained by us, please consult the terms of use of the relevant third party social network.

3) WHAT PERSONAL DATA DO WE COLLECT?

Personal Data is any information about a person from which that person can be directly or indirectly identified.

The Personal Data we collect from users of the Site or customers or prospects using our Services are as follows:

- your surname(s) and first name(s),

- your date of birth,

- your type,

- your postal address,

- your e-mail address,

- your telephone number(s),

- a copy of your identity document only if you are requesting us to book your flights,

- your booking history,

- your hobbies and interests in order to offer you personalised trips, where applicable, special category data such as health data (disability, allergy or special conditions) or data which may indirectly enable us to obtain information concerning the religion, beliefs or personal convictions of the persons concerned (e.g. diet),

- any other information that you may provide when using the Site or our Services.

We may also collect Personal Data from third parties. When you use our Services, you have the possibility of providing the contact details of one or more other persons (other participants in the trip, persons to be contacted in the event of an emergency, or persons who have participated in a gift list) or for other events (for example, for a wedding or a birthday). You therefore guarantee La Pélerine that the other persons whose data you provide are informed of this transmission and accept it.

4) WHY DO WE COLLECT PERSONAL DATA?

The processing carried out and the legal bases for which we collect your Personal Data are as follows:

Treatment	Legal basis for processing
- The creation of your travel file and a travel history in order to improve knowledge of the customer within the limits of the retention periods referred to in article 8 ;	- Our legitimate interest: managing our customer base in order to offer the most suitable trips
- The provision of access to the Site and access to your dedicated Customer Area to enable you, in particular, to consult your quotes and/or any information relating to your travel and our Services;	- Our legitimate interest: managing the service
- Execution of the Services (organising your trip, booking with our partners, drawing up your sales contract, monitoring the completion of your trip, following up any requests you may have concerning your trip, including after your return from your trip, in accordance with the statutory limitation periods, etc.);	- Performance of the travel contract (GTC)
- The collection of your special category data for the sole purpose of organising their trip;	- Your consent pursuant to Article 9 of the GDPR and the performance of the sales contract (GTC) pursuant to Article 6 of the GDPR.
- Statistical calculations, in particular concerning the number of visits to the Sites;	- Your consent (cookies)
- Carrying out studies and research to improve your experience with La Pélerine;	- Your consent (cookies)
- The retention of Personal Data in order to meet our legal obligations and to manage requests for the disclosure of data from authorised authorities;	- Meeting our legal and regulatory obligations
- The sending of marketing communications concerning our Services (such as newsletters) and any other documentation (brochures in particular) that you have requested in order to establish a commercial relationship;	- Your consent
- The communication of information relating to La Pélerine and its partners: news, products and services, commercial prospecting and personalised offers;	- Your consent
- Managing complaints and claims in relation to Services.	- Performance of the travel contract (GTC)

 

5) WHO WILL RECEIVE YOUR PERSONAL DATA?

Your Personal Data is intended for use by La Pélerine departments concerned by your requests. We ensure that only duly authorised persons have access to your Personal Data when this is necessary for the aforementioned purposes.

La Pélerine undertakes not to transfer or sell your Personal Data to non-partner third parties.

We may share your Personal Data with the following third parties in accordance with current legislation:

- with our affiliates in order to provide you with the requested Services;

- with our business partners, in particular suppliers of booked services (hoteliers, transporters, activities, excursions, etc.) or technical service providers (IT, hosting, email distribution, online payment service providers, etc.). We take particular care to ensure that these third parties offer sufficient guarantees to ensure the protection and security of your Personal Data;

- duly authorised French or foreign authorities (e.g. the tax authorities or the CNIL), in particular in the context of legal proceedings or a request for the disclosure of information.

6) SECURITY OF PERSONAL DATA

As the party responsible for processing your Personal Data, La Pélerine implements all the technical and organisational measures necessary to respect the protection of your Personal Data and takes care to limit the amount of data processed in relation to the finalities pursued. We have procedures in place to deal with any

suspected breach of data security and will notify you and any relevant supervisory authority of a suspected breach where we are legally required to do so.

However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of an account you have with us has been compromised), please notify us immediately by contacting us using the details above.

7) DATA PROCESSING OUTSIDE THE EUROPEAN UNION

We may transfer your Personal Data to countries outside the European Economic Area ("EEA") solely for the purposes described in this Privacy Policy.

If Personal Data is transferred outside the EEA, we will take appropriate steps to ensure that the recipient adequately protects your Personal Data in accordance with this Privacy Policy. These measures may include the following:

(a) requesting your consent ;

(b) ensure that there is an adequacy decision from the European Commission in the event of a transfer outside the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data;

(c) enter into a data transfer agreement within our group that complies with the European Union's standard contractual clauses; or

(d) enter into the standard contractual clauses published by the European Commission. These standard contractual clauses include certain safeguards to protect personal data.

8) HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will only retain your Personal Data for as long as is necessary for the purposes for which it was collected, including to meet any legal or accounting requirements.

In determining the appropriate retention period for Personal Data, we take into account the amount, nature and sensitivity of the Personal Data, the potential risk of harm arising from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and the possibility of achieving those purposes by other means, as well as applicable legal requirements.

We keep the following information for the periods indicated below:

- For prospective subscribers to the newsletter:

Maximum retention period: 3 years from the date of last contact between the prospect and La Pélerine.

- For prospects who have requested a quotation but have not yet received one:

Maximum retention period: 10 years from the date of last contact between the prospect and La Pélerine.

- For customers,

Maximum shelf life :

- 15 years from the date of last contact between the customer and La Pélerine

- 1 month after return from travel for copies of identity documents

- 10 years for travel contracts, registration forms and invoices (legal obligation)

-10 years after return from travel in the event of travel-related personal injury (legal obligation)

-In the event of legal proceedings, until the proceedings are terminated.

After the set deadlines, the data is either deleted or kept after being anonymised, in particular for statistical purposes. They may be kept for pre-litigation and litigation purposes. It should be noted that deletion or anonymisation are irreversible operations and that La Pélerine is not subsequently able to restore them.

9) RIGHTS OF THE PERSONS CONCERNED

As a Data Subject, you have various rights. These rights are not absolute and each of these rights is subject to certain conditions in accordance with the GDPR and applicable national laws.

- the right of access - you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed by us and certain other information (similar to that provided in this Privacy Policy) about how it is used. You also have the right to access your Personal Data, by requesting a copy of your Personal Data. This allows you to know and verify that we are using your information in accordance with data protection laws. We may refuse to provide information where this may reveal Personal Information about another person or adversely affect the rights of another person.

- the right of rectification - you can ask us to take steps to correct your Personal Data if it is inaccurate or incomplete (for example, if we have the wrong name or address).

- the right to erasure - also known as the "right to be forgotten", this right allows you, in simple terms, to request the erasure or deletion of your Personal Data where, for example, there is no compelling reason for us to continue to use it or its use is unlawful. However, this is not a general right to erasure and there are some exceptions, for example where we need to use the information to defend a legal claim or to be able to comply with a legal obligation.

- the right to restrict processing - you have the right to "block" or prevent further use of your Personal Data when we are assessing a request for rectification or as an alternative to erasure. Where processing is limited, we may still retain your Personal Data, but we may not use it further.

- the right to data portability - you have the right to obtain and re-use certain Personal Data for your own purposes in different companies (which are separate data controllers). This only applies to Personal Data that you have provided to us, which we process with your consent and for the purpose of fulfilling the contract, which is processed by automated means. In this case, we will provide you with a copy of your data in a structured, commonly used and machine-readable format or (where technically possible) we may pass your data directly to another data controller.

- the right to object - you have the right to object to certain types of processing, on grounds relating to your particular situation, at any time, insofar as such processing is carried out for the purposes of legitimate interests pursued by La Pélerine. We will be permitted to continue to process Personal Data if we can demonstrate that the processing is justified on compelling legitimate grounds that override your interests, rights and freedoms or if we need it for the establishment, exercise or defence of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.

- the right to withdraw your consent - where we process your Personal Data on the basis of your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that took place prior to such withdrawal.

- the right to provide us with instructions on the use of your Personal Data after your death - In France, you have the right to provide us with instructions on the management (for example, retention, erasure and disclosure) of your data after your death. You may change or revoke your instructions at any time.

If you have any questions about this Privacy Policy, about how we process your Personal Data or if you wish to exercise any of your rights, please send a letter to the following address La Pélerine - Service Relations Clients, 32 Place Limozin, 43170 Saugues.

Any request will be considered within the time limits set by the applicable law. Please note, however, that certain Personal Data may be exempt from such requests in certain circumstances, in particular if we need to continue processing your Personal Data for our legitimate interests or to comply with a legal obligation. There will be no charge for exercising your right of access (or any other right). For your information, we will sometimes be unable to comply with your request if it is manifestly unfounded or excessive.

We may need to ask you for specific information to help us confirm your identity and secure your right to access this information (or exercise your other rights). This is an appropriate security measure to ensure that Personal Data is not disclosed to anyone who does not have a right to receive it.

If you are not satisfied with our response to your complaint or if you believe that the processing of your Personal Data does not comply with the Legislation in force, you may lodge a complaint with the competent supervisory authority for data protection. The Commission Informatique et Libertés ("CNIL") is La Pélerine's lead data protection authority.

10) THIRD-PARTY SITES

The Site may contain links to other websites operated by third parties. Please note that this Privacy Policy applies solely to Personal Information collected by La Pélerine. We are not responsible for Personal Information that third parties may collect, store and use on their own websites or applications. We recommend that you carefully read the privacy policy of each website and/or application that you visit.

Furthermore, La Pélerine is not responsible for hypertext links to the Site that third-party websites and/or applications may include, even if La Pélerine has authorised the third-party publisher of the said third-party website and/or application to place such a link.

11) COOKIES

11.1 What are cookies?

Cookies" are small text files, often containing unique identifiers, which are sent by web servers to web browsers, and which can then be sent back to the server each time the browser requests a page from the server.

Cookies are very useful and enable a website to recognise you, to log you in when you visit a particular page, to provide a secure connection to a website and to improve your user experience by enhancing your browsing comfort and/or adapting the content of a page to your areas of interest.

11.2 How are cookies used?

The following types of cookies are used on our Site:

Types of cookie	Who places these cookies?	How do you accept or reject them?
Technical cookies: These cookies are strictly necessary to provide you with theservices available on our website and to use some of its features, such as access tosecure areas.	La Pélerine	As these cookies are strictlynecessary to provide you withaccess to the Site, it is notpossible to refuse them.
Functional cookies: These cookies enable our Site to remember the choices youmake during your visit in order to offer you improved and more personalisedfunctionalities, but they are not essential to their use. However, without these cookies,certain functionalities may become unavailable.	La Pélerine	To accept or refuse these cookies,please click on the "Accept" or"Refuse" button when the cookiesbanner appears.
Targeted advertising cookies: These cookies are used to make advertising messagesmore relevant to you. They perform functions such as preventing the regularreappearance of the same advertisement and, in some cases, selecting advertisementsbased on your centres of interest. We also use cookies or similar tracking technologiesto combat advertising fraud.	La Pélerine and its partners	To accept or refuse these cookies,please click on the "Accept" or"Refuse" button when the cookiesbanner appears.
Analytical cookies: These cookies are used by us or by third-party service providersto analyse the use and performance of our Site. We use cookies from GoogleAnalytics, Piano Analytics, AB Tasty, Content Square, Hotjar, Issuu and GoogleMaps.	La Pélerineand its partners	To accept or refuse these cookies,please click on the "Accept" or"Refuse" button when the cookiesbanner appears.
Cookies relating to social networks: La Pélerine may integrate third- partyapplications on its Website that allow you to share content on the Website with otherpeople. This is particularly the case with the "Share" or "Like" button on Facebook,Pinterest, X (formerly Twitter), Instagram, YouTube or LinkedIn. The social networkconcerned may then identify you and save cookies on your devices.	La Pélerine and social networks concerned	To accept or refuse these cookies, please click on the "Accept" or "Refuse" button when the cookies banner appears. We also invite you to consult their privacy policy.

Where prior consent is required for their use, the period of validity of consent to the deposit of cookies is 6 months. At the end of this period, we will ask you again for your consent.

The retention period for an audience measurement cookie that does not require consent is 13 months. However, the information collected by means of these cookies is kept by us for a maximum period of 25 months, in accordance with the applicable regulations.

11.3 How to block the use of cookies:

There are two ways to refuse the use of cookies.

On your first visit to our Site, you will be asked to consent to the use of your data by cookies via an information banner which will be displayed visibly at the bottom of the page.

Using the "Accept" and "Reject" buttons, you can accept or reject the overall placement or non-placement of cookies on your computer or device (cookies linked to targeted advertising operations, certain audience measurement cookies, social network cookies generated in particular by their sharing buttons when they collect personal data).

However, if you wish to refuse the use of any type of cookies on a website, you can do so by changing the settings on your browser to block the use of cookies. Please note that if you block the use of cookies using this browser setting, you may not be able to use or view all or part of the website concerned, including our Site. Each web browser offers different ways of configuring cookie management. Generally speaking, these are described in the help menu of each browser.

- Firefox : https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent

- Click on the menu button and select "Preference Options".

Select the "Privacy and security" panel.

Set the "Retention rules" menu to "Use personalised settings for history". Uncheck the "Accept cookies" box.

The changes you have made will be saved automatically.

- Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7

- Click on the "Tools" button, then on "Internet Options".

- Click on the "Privacy" tab, then under "Settings", move the cursor up to block all cookies or down to authorise all cookies, then click OK.

- Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr

- Select the Chrome menu icon.

- Select "Settings".

- At the bottom of the page, select "Show advanced settings".

- In the "Privacy" section, select "Content settings".

- Select "Prohibit all sites from storing data".

- Select OK.

- Safari: https://www.apple.com/legal/privacy/fr-ww/cookies/

- Click on "Settings" > "Safari" > "Privacy" > "Cookies and website data".

- Then select "always block".

Please note that if you block the use of cookies using this browser setting, you may not be able to use or view all or part of the website, including our Site.

Furthermore, if you wish to block the use of analytical cookies, both of which are provided by our third-party service providers, please go to the following URL to suspend the use of these cookies.

Google Analytics: opt-out for cookies

Description of cookies and their purpose :

Google Analytics _ga ;

Google Analytics _gid. These cookies are used to distinguish [https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage];

users.

Google Analytics _gat. These cookies are used to reduce the number of requests. However, if Google Analytics is deployed via the Google tag manager, these cookies will be named : _dc_gtm_<property-id>. [https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage].

Google Analytics is a web analysis service provided by Google LLC ("Google"). The information generated by the cookie about your use of the Site will generally be transmitted to and stored by Google on servers in the United States.

Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage in general. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can refuse the use of the data created by these cookies in connection with the use of our Site (in particular your IP address) and the processing of this data by Google, by downloading and installing the plug-in available on your browser under the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

12) CONTACT

If you have any questions or doubts about the Privacy Policy, you can contact us by email at dpd@lapelerine.com or by post at La Pélerine for the attention of the Data Protection Officer - 32 Place Limozin 43170 Saugues.

13) CHANGES TO THIS PRIVACY POLICY

La Pélerine may change this Privacy Policy from time to time to reflect changes in our privacy practices. When we change this Privacy Policy, we will also change the "Last Updated" date at the top of the first page. We encourage you to periodically review this Privacy Policy to be informed of how La Pélerine is protecting your Personal Information.