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©Julien Ratel
Reykjavic, Iceland city scape - lake quay in city center.

POLICY ON CONFIDENTIALITY AND COOKIES

Foreword

Iceland Like A Local, whose website www.iceland-like-a-local.com/ (hereinafter “the Site”) is published by bynativ, wishes to inform you about the measures implemented to protect your personal data and privacy in compliance with the legislation in force in particular the provisions of the amended French Act dated 6 January 1978 known as the “French Data Protection Act”, European Regulation 2016/679 and the instructions issued by the Commission nationale de l’informatique et des libertés (French Data Protection Commission - CNIL) (hereinafter, “the legislation in force”).
In application of the legislation in force, you have the right to access, challenge, correct, delete and limit the processing of your personal data. You also have the right to define what happens to your personal data after your death. These rights may be exercised by letter to the following address: bynativ, Service Relations Clients (Customer Relations Department), 3 rue de Gramont, 75002 Paris, France, attaching a copy of your ID to your application (this copy will not be retained and may be either destroyed or returned to you whichever you choose). For security reasons, your right to the portability of your personal data may only be exercised on our premises in your presence upon presentation of valid proof of identity. You are entitled to file a complaint with the CNIL (French Data Protection Commission) if you consider that we have not complied with the regulations that apply regarding personal data.
Being responsible for processing your personal data, we aim to answer any concerns you may have regarding the confidentiality of the information you send us by any medium, in particular website(s) we publish and run, chat, telephone communications, face-to-face meetings with our adviser (hereinafter “the Channels of Communication”) in order to offer our products and services.
We may obtain information about you from other sources. For example, we may ask a third-party supplier or collector to provide us with additional information about our existing clients (“data appending”) particularly information from your profile or publications on a third-party social network.

We may also collect information that appears in your profile on a third-party social network (particularly Facebook) if you authorize the social network concerned to share it with us or if you put it on line publicly. Such information may be general information relating to your account (e.g. name, e-mail address, profile photo, gender, date of birth, current town of residence, log-in, friends list, etc.) and any other information or activity you authorize the third-party social network to share with us or that you put on line publicly in your profile. We may, for example, receive your information regarding the social networks (or some of it) when you up/download or interact with one of our applications on a social network site, particularly Facebook. To find out more about how we may obtain your information regarding the social networks, please check the conditions of use of the third-party social network concerned.

When you share your personal data with us you authorize us to use, analyse, retain and possibly share it with our partners when processing your requests. By sharing personal data with us via the Channels of Communication you give your acceptance of this policy. Our policy may be changed in order to comply with changes in the legislation in force regarding personal data. We will notify you of any changes made.

I. Personal data sent to us

a) Data concerning your personal information
This consists of information about you as a natural or legal person that you have agreed to share with us via the various Channels of Communication and that is indispensable to the conception and performance of your journey such as in particular your surname, forename, e-mail address, telephone number, postal address, date of birth, etc.).

We hereby give you notice that information we must compulsorily be given is clearly indicated by asterisks on our Site. Information not identified by an asterisk is optional. In order for you to get in touch with us by telephone or at one of our offices, your adviser will tell you what information is required.

This information is indispensable for the processing of your requests for travel services which cannot, unfortunately, be processed without such information.
b) Data concerning the personal information of third parties
As part of your request for an estimate and your subsequent registration, you have the option of entering the details of one or more other people (other participants in a trip or people who have contributed to a gift list or to other events such as celebrations (marriage birthdays, etc.), emergency contact person, etc.)

Under these circumstances we will only use the data of the other people entered in order to ensure the processing of an application for an estimate and subsequent registration. If we wish to use the data of these other people listed for a purpose other than those given above, we will seek their consent beforehand.

You therefore warrant that the other people whose data you share with us are aware of the fact and agree to it.

We will inform the people whose personal data we have collected indirectly about their rights under this policy the first time we communicate with them by e-mail, including all the information necessary for the organization of their trip.
c) Minors
The various Channels of Communication are not, in principle, intended for use by minors without the permission of their parents or legal guardians. A minor aged at least 16 may request an estimate for the purposes of organizing a trip and may provide the personal data required for this purpose. As far as possible given the information provided and the technology available, we make every effort to check the minor’s age. Under no circumstances can a minor finalize, confirm or pay for a trip without the consent of the person who has parental authority.

We make every reasonable effort, given the technology available, to check that the person who has parental authority over the minor has given or authorized his/her consent.
d) Sensitive data
We have to collect data of a particular type such as health data (disability, allergy or special circumstances) and indirectly learn about the religion, beliefs or personal convictions of people concerned even though such harvesting is never direct and only undertaken by deduction (e.g. dietary characteristics). Such data is only collected for the purposes of organizing the transportation and/or the journey of the person concerned and will under no circumstances be used for any other purpose.

II. Data regarding your browsing the Site (cookies)

When you browse our website, temporary cookies may be placed on your computer.
a) What is a cookie?
A “cookie” or tracer is a text file that lets us identify the device on which it is recorded throughout the duration of validity or registration of the cookie.
While you are browsing the Site, we can record, in a dedicated area of the hard drive of your device (computer, tablet or smartphone), one or more “cookies” using the web browser you are using and according to the browser settings you have chosen regarding cookies.

This information includes:
• The type of web browser you use,
• The type of operating system and device you use to access the service,
• The domain name of your internet service provider,
• The web page you are coming from,
• Your country of residence and language,
• The pages and options you visit and access on our Sites.
During your first visit to our Site, as soon as we consider placing a cookie on your device, an information banner is displayed at the foot of the page. By continuing to browse the Site after clicking “I accept”, you give your express consent to us placing cookies on your device (cookies related to operations concerning targeted advertising, certain audience measuring cookies, cookies from social networks created particularly by “Share” buttons when they collect personal data). If you continue browsing the site, cookies may be placed on your device. The banner will remain visible until you leave the page, i.e. until you have gone to another page of the Site or until you click on an item on the Site. If you do not want to accept all or some of the cookies, we advise you to click on the “More info” on the banner and follow the detailed instructions on how to manage cookies via the settings of your browser. Cookies neither generate nor transmit computer viruses liable to infect your device. Only the issuer can read and recognize them.

You can change your cookie settings at any time. You will find below information concerning cookies and the various ways of managing the cookie settings on your browser. Your consent to have cookies placed on your device is valid for 13 months. Once this deadline expires we will again seek your consent.

If you want to know more about cookies and their use you can consult the booklet published by the French Data Protection Commission (Commission Nationale de l’Informatique et des Libertés) at the following address: www.cnil.fr in the section headed “Cookies : les outils pour les maitriser” (How to manage Cookies).

b) Cookies on the Site
We may need to use the following types of cookie (banner at foot of page):
- Session management cookies,
- Audience measuring cookies (statistical cookies),
- Cookies required for certain optional features,
- Cookies relating to targeted advertising,
- Cookies from social networks created particularly by “Share” buttons when they collect personal data.

Session management cookies are vital to the proper functioning of the Site. Refusing them may result in the Site operating slowly and/or malfunction of the Site.

By analysing how you use the Site we can offer you better browsing by responding appropriately to your expectations and also identify possible problems you encounter. This way we can quickly offer solutions.
We may include on our Site third-party IT applications enabling you to share Site content with other people. This is the case with the “Share” or “Like” button on Facebook, Pinterest, Twitter, Instagram, YouTube or LinkedIn. The social network concerned is then likely to identify you and place cookies on your devices. You should check the confidentiality policy of these networks.

You can simply challenge the placing of cookies using the procedures detailed at c) below.

c) Your choices regarding cookies
You can at any time change the settings of your web browser to accept, configure or refuse cookies. Several options are open to you: you can accept all cookies, receive notification when a cookie is recorded, or always refuse all cookies.

We hereby notify you that deactivating session or features cookies may result in you being prevented from visiting the Site. We can therefore accept no responsibility for the degraded functioning of our services as a result of settings you may have chosen.

Each web browser offers different ways of setting how cookies are managed. This process is usually described in the Help menu of each browser. If you are using a different type or version of a browser from those described in the following list, you should consult your browser’s Help menu.
Safari 5.0 (on computer):
1. Select Safari > Preferences then click “Security”.
2. In the section “Accept cookies” tell Safari if and when it should accept cookies from websites.
To get an explanation of the options available to you, click the Help button “?”.
If you have told Safari to block all cookies you should perhaps temporarily accept cookies to open a particular page. Repeat the above steps by choosing “Always”. When you have finished with the page concerned, again deactivate cookies and delete the cookies from the page.

For more information go to the following page:
http://support.apple.com/kb/ht1677?viewlocale=fr_FR
Safari on iOS (tablets and smartphones):
1. Open the application “Settings” and choose “Safari”.
2. In the section headed “Confidentiality” go to “Accept cookies”.
3. Define your confidentiality settings.

For more information go to the following page:
http://support.apple.com/kb/ht1677?viewlocale=fr_FR
Google Chrome:
1. Select the “Settings” menu.
2. Click “Show advanced settings” and go to the “Confidentiality” paragraph.
3. Click “Content settings”.
4. Select “Refuse cookies and data from third-party sites” to refuse cookies.
For more information go to the following page:
https://support.google.com/chrome/answer/95647?hl=fr
Mozilla Firefox:
1. Click “Menu” then “Options”.
2. Select “Privacy and Security”.
3. In the “History” zone, for the “Storage rules” option, select “use custom settings for history”.
4. Check the “Accept cookies” box to activate cookies, or uncheck it to deactivate. If you experience difficulties with cookies check that the “Accept third-party cookies” option is not set to “Never”.
5. From the “keep until” menu, select how long you want cookies to be kept by choosing one of the 3 options (a), (b) or (c) below:
(a) “They expire”: Each cookie will be deleted when it expires, this date being set by the website issuing the cookie.
(b) “I close Firefox”: cookies saved on your computer will be deleted when you close the Firefox browser window.
(c) “Ask me every time”: a warning appears each time a website wants to place a cookie, asking you whether or not you accept the cookie.
6. Click OK to close the “Options” window and confirm your choices.
For more information go to the following page:
https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
Internet Explorer 8.0 and later:
1. Go to the “Tools” menu and select “Internet Options”.
2. Click the “Confidentiality” tab.
3. Use the cursor to choose the desired level of confidentiality: upwards as far as “Refuse all cookies” to refuse all cookies, or downwards to “Accept all cookies” to accept all cookies.
For more information go to the following page:
http://windows.microsoft.com/fr-fr/internet-explorer/delete-manage-cookies
Opera:
1. Go to the “File” menu then select “Preferences”.
2. Click the “Privacy” icon.
3. Define the confidentiality settings you want to apply.
Android:
1. Hit the key in the top right-hand corner.
2. Select “Settings” followed by “Confidentiality and security”.
3. Define the confidentiality settings you want to apply.
Dolphin on Android:
1. Go to the menu and select “More” then “Settings”.
2. Select “Confidentiality” then “Security”.
3. Define the confidentiality settings you want to apply from the “Cookies” menu..

III. For what purposes is your data collected?

a) Meeting your needs

When you get in touch with us via the various Channels of Communication mentioned above, the purpose of collecting your personal data may be to:

Provide access to the Site and your dedicated client account to enable you to consult your estimates and/or any information on your travel,
- Respond to the requests you made either on the Site or via the other Channels of Communication (booking with our partners, drawing up your sales contract, tracking progress of your travel services, tracking any requests you may have made regarding your trip including after you get back, in accordance with the legal limitation periods, etc.),
- Send newsletters and any other documentation (particularly brochures) you may have requested,
- Answer your questions ,
- Inform you about new trips or similar services that may interest you,
- More generally, to comply with our legal, regulatory, accounting and fiscal obligations,
- Handle any requests and complaints made by or about you relative to the trip.

b) Establish statistics

We aim to improve our services and the purpose of collecting personal data about you may also be to:

- Establish statistical calculations, particularly regarding Site frequentation,
- Conduct studies and surveys,
- Conduct studies and research in order to improve your experience with us.

c) Contact you during marketing operations

Your data may also be used for commercial purposes:

- Managing your requests to subscribe and unsubscribe to newsletters,
- Issuing information on our mark and partners: news, products and services, canvassing and customized offers.

IV. How and for how long?

a) Data security

As we are responsible for processing your personal data, we take all the necessary technical and organizational steps to protect your personal data: access control, backups, traceability, security of premises, protective measures and ensure we limit the quantity of data processed to the purpose for which it is intended.

b) Data storage time

We store the information for a length of time that is in proportion to the purpose for which it is intended and, in any event, for the time needed to meet any legal or regulatory obligations. Data will be stored for a period of time that does not exceed the time required for the following purposes:

 Newsletter: your data will be stored for the time your subscription is valid. You may unsubscribe at any time by clicking the appropriate link.
 Request for an estimate for travel services, registration and provision of travel services: the data needed to process your request will be stored for the time needed to draw up an estimate or contract, then during your trip in accordance with the applicable legislation and, in any event, for the time needed to meet any legal or regulatory obligations.
 Commercial offers: your data will be stored for as long as you agree to receive our commercial offers. You may refuse them at any time and unsubscribe by clicking the appropriate link.
 Statistics and surveys: provided you give your consent, your data will be stored for the time needed to establish reliable statistics and process the surveys conducted with you.

In any event, unless you contact us within five years, your personal data will be stored for a further five years before being deleted definitively or made anonymous.

V. Who will receive this data?

a) Us and our partners

We would like to inform you that in order to achieve the purposes specified in point III above, your data may be stored, processed and shared with our subsidiaries and/or partners, particularly providers of reserved services (hotels, carriers, etc.) or technical service providers (IT, hosting, email distribution, online service providers, etc.), who may be located outside the European Union.

Our subsidiaries and/or partners undertake to only use your personal data to perform certain tasks that are vital to achieving the purposes stipulated in point III above, in strict compliance with your rights regarding personal data protection and in accordance with the legislation in force.

b) Non-partner third parties

We undertake not to divulge or sell your personal data to non-partner third parties. We do not provide agencies or companies with any personal data for marketing or commercial purposes.

If a law or an authority (for example the tax authorities or CNIL) or a judge obliges us to send them your personal data we undertake, in so far as possible, to notify you of the fact (unless we are not authorized to do so due to any legal or judiciary obligations with which we may have to comply).

Lastly, we may buy or merge or be bought out by another company or transfer all or part of our assets. Under these circumstances your personal data may be sent to another company in which case the policy of confidentiality protection and cookies in force will apply.

VI. How I am affected by links on Sites that send me to other sites?

We may occasionally include links on our Site that send you to other websites and applications operated by third parties. These links are present solely for your convenience and are intended to provide your visit with added value. By including these links, however, we have no control over the websites and applications, which are independent from us and have separate confidentiality protection policies. Please bear in mind that when you leave our Site our policies no longer apply. We are not therefore responsible for the accuracy, suitability, availability, reliability, copyright enforcement, legality or appropriateness of the content of the websites and third party applications linked to our Site. We strongly recommend you check the conditions and policies regarding confidentiality protection of any third party websites and applications before you use them.

VII. How can you access, update or delete information on “your account”?

If you wish to modify one or more items of personal data in your Client Account, please contact your advisor and/or contact dpd@bynativ.com.

VIII. What should you do if you have other questions about our confidentiality and cookies policy?

If you have any questions or doubts about the present confidentiality protection and cookies policy, please contact us by email at dpd@bynativ.com or write to bynativ, attn. Délégué à la Protection des Données Personnelles – 3 rue de Gramont - 75002 Paris - France.

Latest update: 3 May 2018

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