PERSONAL DATARELAIS & CHÂTEAUX PRIVACY POLICYThis Privacy Policy informs you of the origin and use of the information collected when you
consult our website www.relaischateaux.com and its affiliated websites except for websites
having specific privacy policies (hereinafter the "Website"), our mobile application and, moregenerally, within the framework of the relationship you may have with our company, including
through social media websites (hereinafter the "Processing"). It is compliant with applicable
French and European regulations on personal data protection.
Relais & Châteaux reserves the right to amend this Policy at any time and advises you toconsult it on a regular basis.
For your part, we ask you to ensure that all the information you provide to Relais & Châteaux
and/or the Properties is true, accurate and up to date. If you are required to provide access toinformation concerning third parties (for example persons staying with you), you guarantee thatyou:-

have only provided access to strictly necessary information,
have ensured that these persons are informed thereof and have not objected, or, whenconsent is required, that you have obtained such consent,
will provide them with a copy of this Privacy Policy, in which the use of the term "you"applies both to you and the third parties in question.

1. DEFINITIONSCapitalized terms and phrases, whether they are used in the singular or plural form, shall havethe meaning indicated when they are first used either in this Policy or in our Booking Terms
and Conditions accessible here https://static.relaischateaux.com/neo/legal/cgr_yield_en.pdf orin our Terms and Conditions of Sale and Use of Gift Offers accessible
https://static.relaischateaux.com/neo/legal/comments_policy_fr.pdf, or our Terms andConditionsofAccountCreationaccessible
here
https://static.relaischateaux.com/neo/legal/cgu_hosp_en.pdf or lastly in Regulation (EU)2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection ofnatural persons with regard to the processing of personal data and on the free movement ofsuch data ("GDPR").

2. DATA CONTROLLER
We inform you that your Personal Data undergo Processing by Relais & Châteaux Entreprise,
whose registered office is at 58-60 rue de Prony, 75017 Paris (hereinafter "Relais &Châteaux" or "We/Us").
When this Processing is done in the framework of the Guest Recognition Program, it is done
jointly with Relais & Châteaux by the Properties in which you may stay, the list of which isavailable at https://www.relaischateaux.com/us/site-map/etablissements. The Properties andRelais & Châteaux have defined their respective obligations in this context by means of anagreement, in accordance with Article 26 of the GDPR. This agreement provides that Relais &Châteaux plays a predominant role in defining the main purposes, Processing means, storage
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periods and applicable security measures. Regarding the exercise of your rights in accordancewith Article 7 below, you may send your requests to Relais & Châteaux or the relevant
Property, it being specified that, to improve efficiency, Relais & Châteaux alone shall take careof any update of your Personal Data on the shared tools.

3. PERSONAL DATA COLLECTED
You may be asked to provide your Personal Data when you browse the Website, use themobile application or are in contact with Us.
The mandatory or optional nature of the requested information is indicated with an asteriskwhen data are collected. Requested information that is marked with an asterisk is necessary
to process your requests or Booking or to meet a regulatory obligation. Other information is
generally designed to learn more about you or to improve the services offered to you. It istherefore optional.
In addition, some Personal Data may be collected indirectly, particularly from the Properties.
Relais & Châteaux particularly collects and Processes identification data (e.g. your last nameand given name) and family and personal contact data (e.g. your address, phone number andemail address), economic and financial data (such as your bank card number), data concerning
your tastes, and your preferences and habits as regards your stays, marketing data,connection data (e.g. your IP address, your browsing data) and, more generally, data relating
to the reason why you are in contact with us (e.g. data concerning your Bookings, Orders,requests for information, opinions, complaints).
Relais & Châteaux does not intentionally collect sensitive data, such as information concerning
racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union
membership, or details concerning your health or sexual life or preferences and asks you notto provide this kind of information.

4. PURPOSES OF COLLECTING YOUR PERSONAL DATA AND
STORAGE PERIODS➢ If you do not have a Guest Recognition AccountPurpose▪

To manage your Bookings madeon a non-professional basis▪

To manage your Orders for Gift
Offers made on a nonprofessional basis▪

To manage your Account(Standard Account) opened on anon-professional basis
To improve and customize Relais& Châteaux services▪

Legal Basis/Bases▪

To manage your subscription tonewsletters▪

To manage businessdevelopment operations

Performance of a contract to which
the data subject is a party or
performance of pre-contractual
measures taken at their request

Storage Period

3 years after the date of your stayor Order, then archived for sevenyears before deletion

3 years after the last connection
to the Standard Account or after
your last contact with Us

Legitimate interests of Relais &Châteaux (improve our services andprospect)

If you subscribe in the context
of a Booking or Order: 3 years
after your last contact with Us
If you just subscribe to anewsletter: as long as you do notask to unsubscribe2

▪

To develop business statistics
and statistical reports

Legitimate interests of Relais &Châteaux (improve our services)▪

To manage, monitor and improve
the guest relationship, assess
quality andsatisfaction (particularly pre- andpost-Booking questionnaires)

Performance of a contract to which
the data subject is a party
Legitimate interests of Relais &Châteaux (improve our services)▪

To manage any litigation andunpaid amounts▪

To manage your rights in respectof your Personal Data

Performance of a contract to which
the data subject is a party
Legitimate interests of Relais &Châteaux (defend rights in court)
Meeting the legal obligations ofRelais & Châteaux

10 years after the date of your stayor Order.
2 years after your last contact withUs or one of our Properties.
2 years after that last contact, theentire questionnaire isanonymized.
For the duration of proceedings(until all remedies have expired)
Invoices are stored for 10 years.
5 years after processing yourrequest.

➢ If you have a Guest Recognition Account
Subscribing to the Guest Recognition Program and opening a related Account aim at enabling
you to be recognized when you stay at one of the Hotel Properties member of the Relais &Châteaux Association, to benefit from personalized services matching your expectations bysharing with them you stay preferences, but also to enable you to consult the history of yourbookings and orders without time limitation.
That is why, in the framework of your subscription to this program, We keep the major part ofyour Personal Data for all the duration of your membership, in accordance with the terms
described below.
Purpose▪

To manage your Bookings madeon a non-professional basis▪

To manage your Orders for Gift
Offers made on a non-professionalbasis
To manage your Account opened
on a non-professional basis / To
perform and monitor the Guest
Recognition Program▪

Legal Basis/Bases

Storage Period

Performance of a contract to which
the data subject is a party or
performance of pre-contractual
measures taken at their request

Throughout the term ofmembership and 30 days after its
termination▪

To improve and customize Relais &Châteaux services▪

To manage your subscription tonewsletters▪

To manage business development
operations▪

To develop business statistics andstatistical reportsLegitimate interests of Relais &Châteaux (improve our services)▪

To manage, monitor and improve
the guest relationship, assess
quality and satisfaction (particularlypre- and post-Bookingquestionnaires)

Performance of a contract to which
the data subject is a party
Legitimate interests of Relais &Châteaux (improve our services)

Legitimate interests of Relais &Châteaux (improve our servicesand prospect)

Throughout the term ofmembership and 30 days after its
termination

10 years after the date of yourstay or Order.
2 years after your last contact withUs or one of our Properties.
2 years after that last contact, theentire questionnaire isanonymized.

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▪

To manage any litigation andunpaid amounts▪

To manage your rights in respect ofyour Personal DataPerformance of a contract to which
the data subject is a party
Legitimate interests of Relais &Châteaux (defend rights in court)
Meeting the legal obligations ofRelais & Châteaux

For the duration of proceedings(until all remedies have expired)
Invoices are stored for ten years.
5 years after processing yourrequest.

The Personal Data Processed in the framework of the Guest Recognition Program will only
be accessible to the Properties for the period necessary to prepare and monitor Bookings,
i.e. up to one month maximum before your stay and one month after your departure.
➢ Data collected via cookies when you browse the Website or the mobile
application

CookieIssuerPurposeIDE

googleadwordsremarketing
googleadwordsconversion

Advertising
servicebing

Advertising
service

MUID

Legal basis

Storageperiod1 year

1 yearConsent

MUIDB

bing

Advertising
service_uetsidbing

Advertising
service1 day_uetvid

bing

Advertising
service

16 dayseb-profile

earlybirdsAdvertising
service

12 months

eb-lastactivity-hashearlybirds

Advertising
service

12 months

anjgamnedAdvertising
service

180 daysuuid2

gamnedAdvertising
service

180 daysIDSYNC

gamnedAdvertising
service

180 days

APID

gamnedAdvertising
service

180 daysBgamnedAdvertising
service

180 days

apx_conv1

gamnedAdvertising
service

180 days

1 year4

apx_conv1020997

gamnedAdvertising
service

180 days

apx_conv1021500

gamnedAdvertising
service

180 days

apx_seg1

gamnedAdvertising
service

180 days

apx_seg14205345

gamnedAdvertising
service

180 days

apx_seg14206188

gamnedAdvertising
service

180 days

fr

facebookSocial media

3 months_fbp

facebookSocial media

3 months_hjid

hotjarWeb analytics

1 year_hjIncludedInSample

hotjarWeb analytics

Session_hjAbsoluteSessionInProgress

hotjarWeb analytics

30 minutes_hjTLDTest

hotjarWeb analytics

Session_hjIncludedInSessionSample

hotjarWeb analytics

30 minutes

etuix

eulerian

Web analytics

25 months➢ General
In any event, Personal Data are stored in an active database for a period not exceeding theperiod necessary to achieve the purposes for which they are collected, and particularly for theperiods indicated in the table above.
After that period, certain Personal Data will then be archived with restricted access for a period
not exceeding statutory limitation periods or applicable archiving obligations, and thendestroyed.

5. SHARING YOUR PERSONAL DATAYour Personal Data collected in the framework of the Processing may be sent:− Internally, to the authorized departments of Relais & Châteaux; and− within the Relais & Châteaux group to the authorized departments of the Relais &Châteaux Association and its subsidiaries;− to the Relais & Châteaux Association Member Properties with which you make a
Booking and/or that you may visit.
Your Personal Data may also be transferred to Third Parties which may use them for their own
needs (and particularly to authorized agents for the purpose of handling a dispute such as
attorneys, process servers, etc. and to certain social media such as Facebook when you use
our Website or mobile application in connection with these social media). Similarly, if any
company in the group to which Relais & Châteaux belongs or all or part of its assets areacquired by a third party, your Personal Data may be made accessible to anyone involved in
the preparation and completion of the transaction and included in the assets sold.
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If you decide to use the 3X Oney financing solution offered by Oney Bank to buy one or several
Gift Boxes, the Personal Data linked to your Order will als o be shared with Oney Bank. Oney
Bank will then process these Personal Data as Data Controller, for its own purposes which
include, in particular, the pre-filling of the requested credit subscription form, the analysis ofapplications in order to decide whether or not to grant the financing solutions, credit
management, as well as the recovery of funds and the fight against fraud. Finally, yourPersonal Data will be transferred to Processors of Relais & Châteaux within the meaning ofregulations; they are not authorized to use them for their own account.

6. INTERNATIONAL TRANSFERS
Your Personal Data may be made accessible to some of our Processors within the meaningof regulations, some of which may be located outside Europe, in countries recognized by theEuropean authorities as providing an adequate level of Personal Data protection, but also incountries that do not benefit from such recognition. In order to ensure adequate protection of
Data Subjects' privacy, Appropriate Safeguards have been established to govern Transfers.
The countries concerned by these Transfers and the Appropriate Safeguards are summarized
in the table below:
Country
UruguayArgentina
USAJapan
Mauritius
Australia
India
BrazilMexicoChina

European Commission
adequacy decision
Yes
Yes
NoNo
No
No
No
NoNo
No

Appropriate Safeguards

Standard contractual clausesStandard contractual clausesStandard contractual clausesStandard contractual clausesStandard contractual clausesStandard contractual clausesStandard contractual clausesStandard contractual clausesYour Personal Data may also be made accessible to subsidiaries of the Relais & Châteaux
Association located in Switzerland, the UK and the USA, and to certain Relais & Châteaux
Properties (the list of which is available at https://www.relaischateaux.com/us/sitemap/etablissements) that may be located outside Europe, in countries recognized by theEuropean authorities as providing an adequate level of personal data protection, but also incountries not benefitting from such recognition. The achievement of certain purposes
described in Article 4 above, including in particular the management of your Bookings or theperformance and monitoring of the Guest Recognition Program, therefore requires Personal
Data Transfers outside Europe and renders them lawful. However, to guarantee an even higher
level of protection of Data Subjects' privacy, each Property located outside Europe in a country
not benefitting from the abovementioned recognition has signed with Relais & Châteaux thestandard contractual clauses issued by the European Commission, to govern their relationshipand ensure a high level of Personal Data protection.
For more information about the Appropriate Safeguards governing these Transfers, you may
contact the Relais & Châteaux Data Protection Officer at: dpo@relaischateaux.com.

7. YOUR RIGHTS

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We remind you that you have a right of access to and rectification of incorrect data concerning
you and, in the cases provided for by regulations, a right to object and a right of erasure ofsome of your Personal Data, a right to restrict their use or to request their portability for transfer
to a third party, and a right to withdraw your consent, if We base processing on your consent,and also, if you reside in France, the right to define directives for the post-mortem processingof your Personal Data.
To exercise any of these rights, please write to the Relais & Châteaux Data Protection Officer
at:Relais & Châteaux EntrepriseDPO
58-60, rue de Prony
75017 Paris
Franceor send an email to:
dpo@relaischateaux.com
If We are unable to identify you with certainty, for security reasons, you must send a photocopyof an ID document with your request. You will be sent a reply within one month of your request
being received, subject to any longer period in accordance with the provisions of the GDPR.
Furthermore, you are reminded that Relais & Châteaux may, in accordance with regulations,refuse to grant certain requests concerning some of these rights (particularly the right oferasure), for legitimate reasons such as the need to defend rights in court or a legal obligation
to retain certain data.
You may also lodge a complaint with the Commission Nationale Informatique et Libertés(CNIL), the French data protection authority.
We inform you that if you do not wish to be canvassed by telephone, you may register free ofcharge on the Bloctel Do Not Call list.

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