Protection of personal data

PREAMBULE

This Privacy Policy tells you how Sabre uses and protects any information you give us when you use this site, which can be accessed from the following URL: www. sabre.com (the “Site”).

Please note that this privacy policy may be modified or supplemented at any time by Sabre, particularly in order to comply with any legal or technological developments. In such case, the date of the update will be clearly identified at the top of this policy. These modifications are binding on the Internet user as soon as they are posted online. It is therefore advisable for the Internet user to consult this privacy policy regularly in order to take note of any changes.

ARTICLE 1. PARTIES

This privacy policy is applicable between the publisher of the Site, namely Sabre, hereinafter “Sabre”, and any person connecting to the Site, hereinafter “the Internet user”.

ARTICLE 2. DEFINITIONS

Site Content”: elements of any kind published on the Site, whether or not protected by intellectual property rights, such as texts, images, designs, presentations, videos, diagrams, structures, databases or software.
Internet user”: any person connecting to the Site.
Site” means the website accessible at the URL www. sabre.co.uk, as well as any sub-sites, mirror sites, portals and URL variations thereof.

ARTICLE 3. SCOPE OF APPLICATION

This privacy policy is applicable to all Internet users. The fact of just browsing the Site implies your full and complete acceptance of this policy.

The Internet user acknowledges the value of Sabre's automatic recording systems as proof and, unless s/he can prove otherwise, s/he waives the right to contest them in the event of a dispute.

Acceptance of this privacy policy implies that Internet users have the legal capacity to do so or are at least 16 years old, or if they are not, that they have the authorisation of a guardian or curator if they are incapable, or of their legal representative if they are under 16 years old, or that they hold a mandate if they are acting on behalf of a legal entity.

ARTICLE 4. PERSONAL DATA

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on 14 April 2016 and current national legislation, Sabre provides you with the following information:


4.1 Identity of the data controller

The company responsible for the collection and processing of data is Sabre, a simplified joint stock company with registered office 4 allée des Vergers, building A, 78240 Aigremont, France. SIREN: 390649044.  

4.2 Identity of the Data Protection Officer

The Data Protection Officer is Deshoulières Avocats Associés, 121 boulevard de Sébastopol 75002 Paris, France. T: +33.1.77.62.82.03, rgpd@deshoulieres-avocats.com, www.deshoulieres-avocats.com.

4.3 Sabre Data Collection

4.3.1 Data collected 

4.3.1.1 Data collected during browsing

When browsing the Site, you consent to Sabre collecting information about the following:

  • your use of the Site;
  • the content you are viewing and clicking on;
  • your device and software environment;
  • your demographic data;
  • trackers, web tags, web storage, unique advertising identifiers;
  • your connection data (times, IP address...).
4.3.1.2 Data collected when using the contact form

The use of the contact form by the Internet user implies the collection by Sabre of the following personal data:

  • Family name;
  • First name;
  • Land mail address:
  • Phone number;
  • Email.
4.3.1.3 Data collected when registering for the members' area

The use of the registration form by the Internet user implies the collection by Sabre of the following personal data:

  • Family name;
  • First name;
  • Land mail address:;
  • Phone number ;
  • Email;
  • Bank details (credit card number, expiration date and CVV number).
4.3.1.5 Data collected when registering for the newsletter

The use of the newsletter form by the Internet user implies the collection by Sabre of the following personal data: 

  • Email.

4.3.2 Purposes of the collection of personal data

The data collected during browsing is subject to automated processing for the following purposes: 

  • develop, operate, improve, provide and manage the Site;
  • avoid any illicit or illegal activity;
  • verify the identity of Internet users;
  • target advertising content;
  • send information and contact Internet users, including by email, telephone and push notification;
  • contextualize and improve the user experience.

The data collected when using the contact form is subject to automated processing for the following purposes:

  • provide a detailed response to the Internet user;
  • verify the identity of Internet users;
  • send information and contact Internet users, including by email, telephone and push notification.

The data collected during the creation of a member space is subject to automated processing for the following purposes:

  • verify the identity of Internet users;
  • communicate with Internet users;
  • send information and contact Internet users, including by email, telephone and push notification;
  • contextualize and improve the user experience.

The data collected when using the newsletter form is subject to automated processing for the purpose of:

  • send a newsletter;
  • send commercial proposals;
  • verify the identity of Internet users;
  • target advertising content;
  • send information and contact Internet users, including by email, telephone and push notification.

4.3.3 Legal basis of the processing

The data collected during browsing is based on Sabre's legitimate interest, namely to analyse behaviour on the Site and to improve the security and operation of the Site. With regard to data resulting from the installation of certain cookies, the Internet user is invited to refer to Sabre's cookie policy.

The data collected when using the contact form is based on the consent of the persons concerned.

The data collected during the creation of a member's area has a legal basis in a contractual relationship.

The data collected when using the newsletter form is based on the consent of the persons concerned.

4.3.4 Internal recipients of the data

The data collected can only be consulted by the Sabre management team, as well as by personnel in charge of the management of the website and the members' area, and is never made freely viewable by a third party.

4.3.5 Duration of retention of personal data

Personal data collected during browsing is kept for a reasonable period of time necessary for the proper administration of the Site and for a maximum of 12 months, or until the consent of the persons concerned is withdrawn.

The personal data collected when using the contact form is kept for a reasonable period of time necessary for the proper management of the Internet user's request, and for a maximum of 12 months.

The personal data collected during the creation of a member space are kept for the duration of the contractual relationship.

The personal data collected during the use of the newsletter form are kept for the duration of the relationship until unsubscription.

At the end of each of these periods, Sabre will archive this data and keep it for the time during which it may be held responsible.

After this retention period, Sabre undertakes to permanently delete the data of the persons concerned.

4.3.6 Security and confidentiality of personal data

Personal data is kept in secure conditions, using state-of-the-art technical means, in compliance with the provisions of the General Data Protection Regulation and the national legislation in force. 

4.3.7 Minimization of personal data

Sabre may also collect and process any data voluntarily submitted by an Internet user, in particular when sending an email to the contact address.

Sabre supports Internet users as much as possible when they provide unnecessary or superfluous personal data.

Sabre undertakes to keep and process only the data strictly necessary for its activities, and will delete, as soon as possible, any data received that is not useful.

4.4 Respect for rights

You have the following rights with respect to your personal data, which you may exercise by writing to us at our postal address or by sending an email to the following address: rgpd@sabre.fr

4.4.1 Right to information, access and communication of data

You have the possibility to access your personal data.

Because of the obligation of security and confidentiality in the processing of personal data that is incumbent on Sabre, your request will only be processed if you provide proof of your identity, in particular by producing a scan of your valid identity document (in the case of an email request) or a signed photocopy of your valid identity document (in the case of a written request), both accompanied by the words “I certify on my honour that the copy of this identity document is a true copy of the original. Done at ... on ...”, followed by your signature.

To help you in your approach, you will find here a template letter drawn up by the CNIL (French Data Privacy Authority).

4.4.2 Right to rectify date and delete data and the right to be forgotten

You have the right to request the correction, updating, blocking or deletion of your personal data which may be inaccurate, erroneous, incomplete or obsolete.

You may also set general and specific instructions regarding the disposition of personal data after your death. Where applicable, the heirs of a deceased person may require that the death of their loved one be taken into account and/or that the necessary updates be made.

To help you in your approach, you will find here a template letter drawn up by the CNIL.

4.4.3 Right to object to data processing

You have the possibility to object to the processing of your personal data.

To do this, you should send an email to the following address: service-client@sabre.fr . In this email, you will have to specify the data that you wish to see deleted as well as the reasons justifying this request, except in the case of commercial prospecting.

4.4.4 Right to data portability

You have the right to receive the personal data you have provided to us in a transferable, open and readable format. 

4.4.5 Right to restrict processing

You have the right to request that Sabre limit the processing of your personal data. In this way, your data can only be stored and not used by Sabre.

4.4.6 Withdrawal of consent

Your consent is essential for Sabre to process your data. However, you may withdraw your consent at any time. Such withdrawal will result in the deletion of your personal data.

However, services that require Sabre to process your data will no longer be available.

4.4.7 Response times 

Sabre undertakes to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period of time, which may not exceed 1 month from receipt of your request.

4.4.8 Complaint to the competent authority

If you feel that Sabre is not complying with its obligations with respect to your personal information, you may make a complaint or request to the appropriate authority. In France, the competent authority is the CNIL to which you can send a request here

4.5 Transfer of collected data 

4.5.1 Transfers to partners 

Sabre informs you that we have recourse to authorized service providers to facilitate the collection and processing of the data you have communicated to us. These service providers may be located outside of the European Union and may have access to the data collected on the Site.

Sabre has previously ensured that its service providers have implemented adequate safeguards and comply with strict conditions regarding confidentiality, use and protection of data.

The Internet user consents to the data collected being transmitted by Sabre to its partners and being processed by these partners within the framework of third-party services, namely:

List of Subcontractors 
PartnerCountry of destinationTreatment carried outGuarantees
Aquaray France Website hosting.

Standard Contract Clause: 

https://www.aquaray.com/pages/donnees-personnelles

Sendethic France

Email service

Standard contractual clause:

https://www.sendethic.com/reussir-marketing/ressources-utiles/conformite-rgpd/rgpd-sendethic/

Google Analytics USA

Elaboration of business statistics in order to generate reports on Internet users' interactions.

Standard contractual clause:
https://policies.google.com/privacy?hl=fr

Google Adwords USA

Carrying out operations related to prospecting.

Standard contractual clause:
https://policies.google.com/privacy/frameworks

Facebook Pixel USA

Advertising content management

Standard contractual clause:
https://www.facebook.com/policy.php

Facebook USA

Managing people's notifications on products, services or content.

Standard contractual clause:
https://www.facebook.com/policy.php

Pinterest USA

Managing people's notifications on products, services or content.

Standard contractual clause:
https://policy.pinterest.com/fr/privacy-policy#section-residents-of-the-eea

Instagram USA

Managing people's notifications on products, services or content.

Standard contractual clause:
https://help.instagram.com/519522125107875

YouTube USA

Managing people's notifications on products, services or content.

Standard contractual clause:

https://www.youtube.com/intl/ALL_fr/howyoutubeworks/our-
commitments/protecting-user-data

Smartsupp

Germany and Czech Republic

Carrying out operations to put people in touch with each other

Standard contractual clause:
https://www.smartsupp.com/help/privacy-policy/

Linkedin USA

Managing people's notifications on products, services or content.

Standard contractual clause:
https://fr.linkedin.com/legal/privacy-policy

4.5.2 Transfer on requisition or court order

The User also agrees that Sabre may disclose the data collected to any person, upon request of a state authority or court order.

4.5.3 Transfer in connection with a merger or acquisition

If Sabre becomes involved in a merger, sale of assets, financing transaction, liquidation or bankruptcy or in an acquisition of all or part of its business by another company, the User consents to the data collected being transferred by Sabre to that company and to that company carrying out the personal data processing referred to in this privacy policy in place of Sabre.

ARTICLE 5. INTELLECTUAL PROPERTY

5.1 Legal protection of the Site Content

The Contents of the Site are likely to be protected by copyright and database law. Any representation, reproduction, translation, adaptation or transformation, in whole or in part, carried out illegally and without the consent of Sabre or its beneficiaries or assignees constitutes a violation of Books I and III of the Intellectual Property Code and may give rise to legal proceedings for counterfeiting

5.2 Contractual protection of the Site Content

The Internet user contractually undertakes to Sabre not to use, reproduce or represent, in any way whatsoever, the Contents of the Site, whether or not they are protected by an intellectual property right, for any purpose other than that of their reading by a robot or a browser. This prohibition does not apply to indexing robots whose sole purpose is to scan the content of the Site for indexing purposes.

ARTICLE 6. FINAL STIPULATIONS

6.1 Amendments

La présente Politique de Confidentialité peut être modifiée à tout moment par Sabre. Les conditions applicables à l’Internaute sont celles en vigueur lors de sa connexion sur le Site, toute nouvelle connexion au Site emportant acceptation le cas échéant des nouvelles conditions.

6.2 Entirely

The nullity of one of the clauses of this contract shall not entail the nullity of the other clauses of the contract or of the contract as a whole, which shall retain their full effect and scope. In such a case, the parties shall, as far as possible, replace the invalidated provision with a valid provision corresponding to the spirit and purpose of this agreement.

6.3 Non-waiver

Sabre's failure to exercise its rights hereunder shall not be construed as a waiver of such rights.

6.4 Languages

The present conditions are proposed in French.

6.5 Unfair terms

The stipulations of the present conditions apply subject to compliance with the mandatory provisions of the Consumer Code concerning unfair terms in contracts concluded between a professional and a consumer.

ARTICLE 7. LITIGATION

7.1 Applicable law

This Privacy Policy is subject to the application of French law and European regulations, in particular the European Data Protection Regulation.

7.2 Litigation

In accordance with the order n°2015-1033 of August 20, 2015, all disputes which could arise within the framework of the execution of the present general conditions and whose solution could not be found beforehand amicably between the parties will have to be submitted to an approved mediator.

7.3 Arbitration

Any disputes arising out of or in connection with this Agreement shall be settled by arbitration in accordance with the FastArbitre rules of the Institut Digital d’Arbitrage et de Médiation.

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