Privacy

Namastay

PRIVACY POLICY 

Last update: July 2022

1. Who we are 

Namastay, www.namastay.io (hereinafter "Namastay", "We", "Us" or "Our") is a French company that provides hoteliers with a fast and intuitive online booking and payment software solution, allowing their guests (hereinafter "You", or "Your") to book their rooms and other ancillary services directly on the hotel's website (the "Booking Tool"). 

Our head office is located 37 rue des Mathurins, 75008 Paris. 

2. What is the purpose of this privacy policy? 

In the context of Your use of the Booking Tool, some personal data relating to You are processed:

• for the benefit of the hotel, to complete the transaction and manage Your booking; and 
• for the benefit of NamaStay in particular, if You accept it, to facilitate Your subsequent purchases and to allow the suggestion of offers and services adapted to Your previous reservations and preferences during Your subsequent uses of the Booking Tool. 

The processing of Your personal data for the benefit of the hotel, for which Namastay is not responsible, is governed by the hotel's privacy policy, which We invite You to read. In this case, Namastay is only a processor of Your personal data, and acts on behalf of the hotel. 

The purpose of this privacy policy is to inform You of the way Your personal data is processed for the purposes of Namastay directly, as a controller. Your privacy and the protection of Your personal data is a priority for Namastay and We pay close attention to the way We process Your personal data.

For the purposes of this privacy policy, the terms "personal data", "processing", "controller" and “processor” have the meaning assigned to them by the General Data Protection Regulation (GDPR). The term "personal data" therefore refers to all information that identifies You, directly or indirectly, such as for example Your name, first name, e-mail address, postal address, IP address etc. 

3. What personal data do We collect about You?

1. Personal data that You communicate directly to Us 

Most personal data that Namastay collects about You is provided directly by You through the Namastay Booking Tool. 

This includes, but is not limited to, the following information: 

• Last Name and first name; 
• Email address;
• Phone number;
• Postal address (optional);
• Content of bookings made on the websites of hotels using the Booking Tool.

If You do not provide this personal data, We will not be able to facilitate Your subsequent purchases or provide You with offers adapted to Your previous preferences and reservations. 

2. Personal data that We collect in the course of Your use of the Booking Tool 

Some personal data that Namastay collects about You is collected in the course of Your use of the Booking Tool, in particular: 

• IP address ;
• Data relating to the use, navigation, interaction of the Booking Tool

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3. Cookies

Cookies are computer files that are placed on Your terminal (computer, smartphone, tablet, etc.) and that allow, during their existence, their issuer to identify the corresponding terminal and to record information relating, for example, to Your browsing. Certain personal data may be processed by means of these cookies (for example, an e-mail address, the unique identifier associated with a cookie, an IP address, a terminal identifier, etc.).

When You use the Booking Tool on the hotel's website, Namastay may place cookies on Your terminal, subject to the choices You have made and the cookies You have accepted via the information and consent mechanism provided by the hotel on its website. 

The cookies that may be placed by Namastay on Your terminal are the following: 

• Audience measurement cookies;
• User interface customisation cookies (e.g. for language selection);
• Cookies aimed to ensuring the security of user authentication;
• Authentications and sessions

The placement of some of these cookies requires Your prior consent. You will be able to provide this consent via the mechanism provided by the hotel on its website. This consent is valid for 13 months, unless You withdraw Your consent earlier. The data collected through these cookies will be retained for a maximum period of 25 months by Namastay. 

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4. For which purpose(s) do We process Your personal data and on what legal basis(s)? 

We only process Your personal data for defined and specific purposes, namely: 

• To facilitate Your subsequent purchases, by pre-filling Your identity data during Your subsequent use the Booking Tool on a hotel website; 
• To personalise the offers proposed by the hotels that use the Booking Tool and which websites You will visit in the future, and to propose relevant ancillary services, based on Your previous reservations and preferences;
• To exchange with You and to solve possible disputes;
• To respond to an official request from a public or judicial authority to which Namastay is subject.

With respect to the processing operated for the purpose of personalising future hotel offers, the underlying logic implemented by Namastay is to use Your previous reservations (room type, ancillary services, etc) to prioritise future offers by favouring those that seem to match Your past preferences. All offers that correspond to Your search will continue to appear, but will be prioritised according to the preferences identified by Namastay. 

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The table below summarises the legal basis for each of these processing operations: 

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Purpose of the processing: Facilitating Your subsequent purchases

Data concerned: Last name, first name, email, phone number 

Legal basis of the processing: Namastay’s legitimate interest in improving the user experience 

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Purpose of the processing: Personalise future offers

Data concerned: Last name, first name, email address, phone number, IP address, content of bookings made on the websites of hotels using the Booking Tool 

Legal basis of the processing: Explicit consent from You  

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Purpose of the processing: Exchanging with You and resolving any disputes 

Data concerned: Last name, first name, email address, phone number - 

Legal basis of the processing: Namastay's legitimate interest in maintaining relationships with users and preparing for possible disputes.

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Purpose of the processing: Responding to an official request

Data concerned: Last name, first name, email address, phone number 

Legal basis of the processing: Namastay's legal obligation or, failing that, Namastay's legitimate interest in complying with a request from an authority. 

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You may withdraw Your consent at any time by writing to the following address support@namastay.io, without affecting the lawfulness of past processing carried out by Namastay based on Your consent before its withdrawal.

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5. Who has access to Your personal data? 

1. Within Namastay 

We will only disclose Your personal data to Namastay's employees and officers to the extent that it is necessary for them to perform their duties. 

2. Outside of Namastay 

Your personal data may be made available by Namastay to third parties, in particular:  

• To the hotel whose website You visit or from which You make a reservation;
• To the service providers that Namastay uses to carry out its activities and implement the processing described in section 4, insofar as such access is necessary, including the channel manager, the online payment service provider, the property management system provider, the central reservation system provider, the hosting service provider, the technical service providers enabling the resolution of incidents;
• To any national or international authority, or any third party, when We are required to communicate such data to them, in particular by virtue of the law or an enforceable court decision, or if such communication is necessary in the context of an investigation or a judicial or administrative procedure. 

In the event of a merger, acquisition, dissolution, bankruptcy or liquidation, We may also disclose Your personal data to a purchaser, assignee, or other party involved in such operation which has a legitimate interest to have knowledge of such data. 

6. How do We protect Your personal data?

Namastay has put in place adequate technical and organisational measures to protect Your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. 

Access to Your personal data is only given to the persons listed in Article 5 of this privacy policy. These persons are subject to strict data protection and confidentiality obligations and implement adequate data security procedures.      

7. How long do We keep Your personal data? 

We retain Your personal data for the period necessary for the processing operations referred to above and in accordance with the applicable legal requirements, namely : 

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Purpose of the processing: Facilitating Your subsequent purchases

Data concerned: Last name, first name, email address, phone number 

Duration of retention:1 year after Your last use of the Booking Tool

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Purpose of the processing: Personalise future offers

Data concerned: Last name, first name, email address, IP address, phone number, content of bookings made on the websites of hotels using the Booking Tool 

Duration of retention: Until You withdraw Your consent, or 2 years after Your last use of the Booking Tool

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Purpose of the processing: Exchanging with You and resolving any disputes 

Data concerned: Last name, first name, email address, phone number

Duration of retention: 2 years after Your last use of the Booking Tool. Then 3 years in the intermediate archive for the purposes of possible litigation

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Purpose of the processing: Responding to an official request

Data concerned: Last name, first name, email address, phone number 

Duration of retention: 1year after Your last use of the Booking Tool

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At the end of these different retention periods, We undertake to delete Your personal data from Our databases. 

8. What are Your rights regarding Your personal data and how can You exercise them? 

You have a right to access Your personal data processed by Namastay. If You believe that any information We hold about You is incorrect or incomplete, You may also request that it be rectified. 

You also have the right to:

• Request the erasure of Your personal data, in accordance with the law. In this case, We will proceed with the requested erasure without delay, but subject to compliance with the legal and regulatory obligations incumbent on Us and by virtue of which We may be required to retain Your personal data;
• Requesting the restriction of the processing of Your personal data;
• Request the portability of Your personal data, i.e. the communication by Namastay to a third party of the personal data it holds in a structured, commonly used and machine-readable format.

You may withdraw Your consent at any time by writing to support@namastay.io, without affecting the lawfulness of past processing carried out by Namastay based on Your consent before its withdrawal. 

To exercise the above rights, You may send an email to support@namastay.io. Namastay will respond to such requests in accordance with the applicable regulations. 

You can also lodge a complaint with the competent personal data protection authority (Commission Nationale de l'Informatique et des Libertés, CNIL). 

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