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- Scope
This Charter applies to all data processing implemented by SAS Marval, and operated under the Club Pierre Charron brand.
- About SAS MARVAL
The data controller, SAS MARVAL, is a company whose head office is located at 62 Rue Pierre Charron 75008 Paris, registered with the Paris Trade and Companies Register under No. 841959190.
SAS MARVAL, a simplified joint-stock company (SAS - société par actions simplifiée), shall hereinafter be referred to as “MARVAL” or “us/we” or “Club Pierre Charron”.
Because MARVAL is a company that is receptive to the needs of its customers in compliance with regulatory and legal texts, it has implemented a privacy policy applicable to the personal data collected as part of its gaming club and catering activities (hereinafter the “Services”).
This Policy covers online and offline data collections, including information that we collect through our websites and applications, as well as the programs and events in our Gaming Club.
This policy details the way in which the information collected via our websites or in our establishment is used and protected.
We recommend that you regularly review this Policy as we update and modify it regularly. We try to keep you informed of any changes made.
- Personal data processing
Personal data is any information collected and recorded in a format that can be used to personally identify you, either directly or indirectly, as an individual.
The provision of information marked with an asterisk on the data collection forms is mandatory and necessary to take your request into account and provide you with the response or service requested.
In addition to this information, we also collect information that you agree to communicate to us or that we collect in our legitimate interest or within the framework of our legal obligations.
Below you will find a general overview:
Categories of personal data that we use and keep about you (or that third party processors acting on our behalf have collected - for more information on processors acting on our behalf, see below, Article 7);
The purposes for which this information is collected;
Legal bases applicable to data processing.
- The categories of personal data we collect
As part of our Services, we collect, directly from you or through our tools in our establishment or on websites, the following categories of personal data:
Your identity, marital status and contact details;
Information on your consumption, your preferences;
Information about your bank card (for transaction and reservation purposes);
Information about your browsing via our cookies and similar technologies used on our website;
Your image and voice (as part of the surveillance of our establishments).
- The purposes of processing
We process your personal data for different reasons, mainly to:
- Manage transactions in our establishments, reservations and Services in general;
- Manage the sending of commercial and marketing offers, contests, to target offers according to your preferences;
- Manage our loyalty programs;
- Carry out satisfaction surveys, studies and statistics;
- Improve our services by taking into account all the comments you leave during your visit to our club;
- Respect our vigilance obligations with regard to our customers and public bodies (gambling bans for example);
- Manage your requests to exercise rights;
- Customize and optimize the ease of use of our websites;
- Manage complaints and disputes;
- Manage a list of clients who behaved inappropriately during their stay in our establishment or who have access restrictions;
- Ensure the surveillance of our establishment, the safety of property and people, regulate the games and finally fight against xxx
- The purposes of processing and legal bases
In addition to cases where you expressly consent to the processing of your data (sending marketing messages for example) or cases where the processing of your data is necessary for us to comply with our legal obligations (such as duty of vigilance, fight against fraud), data processing may be necessary to ensure the performance of the contract between us or to satisfy our legitimate interest. Indeed, it is in our legitimate interest to be able to manage claims and complaints in order to ensure our defense, to be able to customize and optimize our offers and websites in order to improve them, and to ensure the monitoring of the club, safety and the regularity of games within the club.
- Information sharing
In the unique context of being able to give you complete satisfaction in the use of our Services, we are required to communicate your personal data to internal and external persons.
Internal recipients:
This concerns all the internal staff called upon to intervene to enable you to benefit from the services of our club: staff at the counters/customer reception, support service staff, such as the IT department, the marketing departments, and the legal department.
External recipients:
These are subcontractors, service providers and banks. The sole purpose of transmitting information is the thorough performance by MARVAL of the Services you have requested and the exclusive quest for your satisfaction.
The local or national administrative and judicial authorities may also request the communication of your personal data should the law require it. This type of disclosure may be required in connection with any lawsuit, petition or investigation, government request, legal order, enforcement of legal rights (e.g., contractual terms, intellectual property rights, etc.), matters relating to combating money laundering, security issues or other similar legal or security problems. Sharing your information in this context is not a regular event, but can happen at any time. We will endeavor to limit the types and volumes of information that we may have to share for legal purposes to what is reasonably necessary and will ensure that any transfer outside the European Union is made on a suitable legal basis.
- Cookies
We use cookies on our website. For more information, see the dedicated policy in the legal notices of the websites.
- Data transfers
When the processing of your data involves a transfer outside the European Union, such transfers are made with appropriate safeguards. When the sharing of information involves a transfer to the United States, said transfer is made on the basis of the Privacy Shield certification or on the basis of standard contractual clauses of the European Union.
- Data security
MARVAL implements the appropriate means to preserve the security and confidentiality of data, via physical and logical protection procedures, including data encryption.
We also process your personal data on servers hosted by us at 62 rue Pierre Charron 75008 PARIS and we implement the necessary means to secure our service.
Likewise, we impose the same conditions of security and confidentiality on our service providers and subcontractors having access to your personal data only within the context of the Services.
- Third-party websites and features
Our website may offer links or features to other third-party websites (including third-party social networks), which we do not own or control. If you click on any such links or use these features, you do so at your own risk. We are not responsible for the content or practices of any third-party website, application or feature.
- Retention of collected data
We store your information for a period commensurate with the purpose for which we process it, to meet legal and regulatory requirements and within the limits imposed by them.
In terms of commercial communication and marketing, your data is kept for a maximum period of three years from the end of our commercial relationship.
In accordance with Article L.561-13 of the Monetary and Financial Code and with decree No. 2016-774 of June 10, 2016, your names and addresses are kept for a period of five years from the date of verification.
Video and audio recordings made in our casinos are kept for a period of one month, unless extended due to investigations linked, in particular, to suspicions of fraud.
The data concerning your bank card are erased from our operational databases after the completion of the transaction, but may be kept in archives to protect us against any possible dispute of the transaction for a period of 13 months after the collection.
- Your rights
In application of the French Data Protection Act of January 6, 1978 as amended and the EU General Data Protection Regulation (2016/679) (the “GDPR”), as a data subject, you have the following rights:
- The right to access the personal information we hold about you;
- The right to ask us to update or correct any outdated or incorrect personal information about you;
- Where the processing is based on your consent, the right to withdraw your consent at any time,
- The right to object to the receipt of communications;
- The right to erasure when the conditions of Article 17 of the GDPR are met;
- The right to limit processing when the conditions of Article 18 of the GDPR are met;
- The right to data portability insofar as the conditions of Article 20 of the GDPR are met;
- The right to define directives relating to the fate of your personal data after your death;
- The right to object to the processing of personal data concerning you, insofar as the conditions of Article 21 of the GDPR are met; and
- The right to lodge a complaint with a regulatory authority, namely CNIL in France (https://www.cnil.fr/fr/plaintes);
You can exercise these rights at any time by sending us an e-mail at
rgpd@groupemarval.com.- Contacts - Contact details of our Data Protection Officer
If you have any questions or complaints about this privacy policy or about the processing of your data by MARVAL, you can contact the MARVAL data protection officer by e-mail at rgpd@groupemarval.com or at the following postal address: SAS MARVAL - RGPD - 62 rue Pierre Charron 75008 Paris.
For the sake of confidentiality and the protection of your personal data, we ask you to attach to your request a copy of an official document allowing you to be identified (identity card, passport, driver's license). Your request will be processed as soon as possible and in accordance with the applicable legal and regulatory texts.
DATA PRIVACY POLICY
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