[Draft — to be completed and validated by a lawyer before publication. Remove this notice once done.]
Privacy policy
Last updated: [date]
The Amour Club respects your privacy. This policy explains what personal data we collect through this website, why, how long we keep it, and the rights you have under the EU General Data Protection Regulation (GDPR) and French data protection law.
1. Who is responsible for your data
The data controller is [Company name], [legal form] with a share capital of [amount], registered office [address], registered with the [city] Trade and Companies Register under number [RCS number]. Contact for any privacy question: [privacy email address].
2. What we collect
When you request an invitation (guests): first name, email address, city and country, the experience you are interested in, your preferred season and, if you choose to write one, your message.
When you apply to join our evenings (gentlemen): first name, age, email address, profession, neighbourhood or town, level of English, your motivation if you choose to write one, and your acceptance of our charter.
For security, with each request: the language of the page, your IP address, your browser's technical identifier (user agent) and the date and time.
3. Why we use it, and on what legal basis
- To answer your request, assess your application and arrange a call: steps taken at your request before a contract (guests) and your consent (gentlemen). [Lawyer to confirm the legal bases.]
- To organise your stay if you book: performance of the contract.
- To protect the website against abuse and spam: our legitimate interest.
- To meet our accounting and legal obligations: legal obligation.
We never sell your data, and we never use it for advertising.
4. How long we keep it
- Requests and applications that do not lead to a booking or an invitation: [X months] after our last contact.
- Guests who book, and gentlemen who join our evenings: for the duration of our relationship, then [X years].
- Accounting records: 10 years, as required by French law.
- Security data (IP address, user agent): [X months].
5. Who can see it
Only our team, on a need-to-know basis. If you book, we share only what is necessary with the partners who deliver your stay (hotel, drivers, restaurants). Our website is hosted by [hosting provider, address], in the European Union, who acts as our processor. [List any other processors.] We do not transfer your data outside the European Union. [Update if this changes.]
The details of a guest and a gentleman are never shared with each other unless both choose to share them.
6. Cookies
This website does not use cookies, advertising trackers or third-party analytics. It loads no content from other websites.
7. Security
All traffic to this website is encrypted (HTTPS). Submissions are stored on our own server, accessible only to authorised team members with a password.
8. Your rights
You can ask to access, correct or delete your data, to restrict or object to its use, or to receive it in a portable format. Where we rely on your consent, you can withdraw it at any time. Write to [privacy email address]; we will reply within one month.
If you believe your rights are not respected, you can lodge a complaint with the French data protection authority, the CNIL (www.cnil.fr), or with the authority of your country of residence.