PRIVACY NOTICE

1. INTRODUCTION

1.1 This Privacy Notice is intended to provide you with information on how Les Roches ("Les Roches", "we", "us", "our") process personal data you have provided to us or we have collected about you in connection with your use of the Pre-Mind App (the "App"). 

1.2 We will only process your personal data in accordance with this Privacy Notice and applicable laws which we are subject to, including the General Data Protection Regulation 2016/679 of 27 April 2016 (hereinafter the "GDPR").

1.3 We recognize that information privacy is an ongoing responsibility, and we will update this notice where necessary. The most current version will always be available on the application.

2. THE DATA WE COLLECT, THE PURPOSE AND THE LEGAL BASIS FOR PROCESSING

2.1 The purpose of the App is to allow you to create bookings at Les Roches venues, reserve tickets to events, and/or communicate with Les Roches. You will receive notifications when Les Roches confirm or cancel a booking. Also, when you come close to an iBeacon controlled by Les Roches, Les Roches staff may receive a notification indicating them that you are arriving at the venue coupled with information that has been previously saved by you in the application (see section 2.2 below) based on a unique iBeacon ID associated to your account.

2.2 When you sign up, you are required to provide your First Name, Last Name and Email address. You also have the opportunity (not mandatory) to add your Gender, Picture, Birthdate, Country, Preferences/Allergies. As indicated above, information of when (and the time during which) you are in close vicinity to an iBeacon belonging to Les Roches is also registered if you have provided your consent on the App and unless you turned off your Bluetooth or are using the airplane mode. Your mobile phone's temporary ID is also registered (a 40-character unique string, supplied by Apple or Google) so that we can send app notifications. The purpose is to provide you with the App services as described in section 2.1 and pursue our legitimate interests in organizing our on-campus activities (article 6(1) (b) and (f) of the GDPR).  

2.3 We may also collect similar or related information and in particular i) information you choose to share voluntarily about you whether in person or through any messaging channel and ii) inferred information that includes information derived from other information listed above. We create inferred and derived data elements by analysing our relationship and transactional information.

3. HOW IS YOUR PERSONAL DATA COLLECTED

3.1 We will usually collect your personal data from you as you register it on the App. We may also collect your personal data from the App directly (information of when and the time during which you are in close vicinity to an iBeacon belonging to Les Roches). 
 
4. DISCLOSURE OF YOUR PERSONAL DATA

4.1 Access to your personal data is granted to relevant Les Roches staff. Your personal data will also be accessible by PRE:MIND, the App provider. We have entered into a data processing agreement that complies with article 28 of the GDPR with PRE:MIND to ensure that PRE:MIND implements appropriate organizational and technical security measures in such a way that the processing complies with the requirements of the GDPR and ensures the protection of your rights. 

4.2 Access is anyway limited to employees and contractors who have a relevant and reasonably required need to access your personal information to perform their work.

4.3 It may also be necessary for us to process your personal data, in order to comply with our legal obligations or in connection with exercising or defending legal claims. This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to disclose certain information.

5. YOUR RIGHTS

To obtain access to, and copies of, the personal data we hold about you. 
To require that we cease processing your personal data if the processing is causing you damage or distress;
To require us not to send you marketing communications;
To request that we erase your personal data;
To request that we restrict our data processing activities in relation to your personal data;
To receive from us the personal data we hold about you, which you have provided to us, in a reasonable format specified by you, including for the purpose of transmitting that personal data to another data controller; and
To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and requests may be refused where legal exceptions apply.
If you have any questions about these rights or how your personal data is used by us, you should us using the details in section 7. 

6. DATA RETENTION

6.1 As a general rule, we will delete your personal data upon deletion of your account unless we are obliged to hold it for a longer period under applicable law or regulations or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

7. CONTACT DETAILS

7.1 Gesthôtel Sàrl (Les Roches) with registered office at Ecole Les Roches, Rte des Moulinettes 2, 3975 Crans-Montana, Switzerland is the data controller of the personal data collected about you.

7.2 If you have any questions or comments regarding this Privacy Notice or wish to exercise your rights as described in Section 5, please contact or email our Data Protection Officer at:

Sommet Education Data Protection Officer:
Marie-Claude Mathieu
Rue Saint Martin 7, 1003 Lausanne, Switzerland
T: +41 (0)21 989 27 06
dpo@sommet-education.com