PRIVACY POLICY AND COOKIES

Updated: March 2021 

Personal information such as first and last names, addresses and, more generally, any information that the user chooses and/or accepts to share, will be subject to digital processing by SIBLU and will, therefore be subject to the General Data Protection Regulation (GDPR) and the French ‘Informatique et Libertés’ law.
 
Siblu commits to ensuring that processing of personal data on siblu.co.uk and siblu.ie respects the General Data Protection Regulation (GDPR) and the French ‘Informatique et Libertés’ law. 

The following policy should be read alongside the general conditions of use for the website siblu.co.uk which are available at https://www.siblu.co.uk/general-conditions-use 


Data Protection Policy of the site www.siblu.co.uk 

Information About the Data Processor 

Siblu France, a ‘société par actions simplifiée’ (simplified joint-stock company) with a capital of €2 819 200.00 registered with the Bordeaux RCS (French business register) under the number 321 737 736, SIRET (company registration) number: 321 737 736 000 58, APE code: 5530Z, intra-EU VAT number: FR 73 321 737 736; head office situated at: Europarc - 10 avenue Léonard de Vinci, 33600 PESSAC, represented by SIMON CRABBE in his role as Chief Executive. 

Purpose

The processing concerns visits to and/or use of features or services on the website www.siblu.co.uk. This purpose of this data processing is to allow for the following: 

  • The creation of a personal account by users (holidaymakers, Siblu mobile home owners),
  • Holiday bookings, 
  • Payment management,
  • Customer account management,
  • Reception of informative and promotional emails, texts, and phone calls, 
  • Participation in competitions,
  • Possibility to leave a review,
  • The use of data collected by cookies during browsing on the websites www.siblu.co.uk

Furthermore, the website siblu.co.uk provides online contact forms intended for the those who wish to gain more information on the following:  

  • Funding options for buying a mobile home
  • Questions about buying a mobile home
  • Sponsoring a holidaymaker
  • Free taster visits 
  • A general informational form, for example in case of technical issues with this website or issues encountered during your holiday
  • Booking a holiday 

Through the website www.siblu.co.uk the user can also: 


- Sign up to the Siblu newsletter to receive holiday or mobile home sales offers (request a copy of the ‘holiday brochure’ and/or request a copy of the ‘mobile home sales brochure’)

The user is informed that when they book a holiday, sign up to SIBLU’s newsletters or fill in a commercial form related to buying a mobile home (brochure request, a free taster visit etc.) SIBLU will use their email address to send them commercial offers, promotions or information about SIBLU. The user can withdraw their consent at any point, either by contacting dpo@siblu.fr or via the unsubscribe link at the end of the email. 

Legal Basis  

  • Creation of a personal user account (as a holidaymaker or a Siblu owner) - This processing is based on the contract between us
  • Booking a holiday - This processing is based on the contract between us
  • Payment management - This processing is based on the contract between us
  • Management of client accounts - This processing is based on the contract between us
  • Newsletter sign-up - This processing is based on your consent
  • Emails, texts and calls of an informative or promotional nature - This processing is based on your consent
  • Participation in competitions - This processing is based on your consent
  • Writing a review - This processing is based on your consent
  • Online forms - This processing is based on your consent
  • Brochure request - This processing is based on your consent
  • Use of data collected via cookies during browsing on www.siblu.co.uk - This processing is based on your consent

Types of data collected

As part of the services provided by the website www.siblu.co.uk SIBLU will collect data relating to:

  • The identity of the individual (first and last names, address, email address, phone number, etc.)
  • Their family situation (number of adults, children, etc.)
  • Payment methods used
  • Transactions and services used (data linked to payment of invoices, monitoring of the commercial relationship, reviews left, complaint management etc.)
  • Monitoring of the commercial relationship (history, correspondance, etc.)
  • Implementation of campaigns related to customer loyalty, prospection, surveys, questionnaires, product testing and advertising
  • Your contributions when you leave reviews/opinions on our services
  • The internet (cookies, trackers, browser data, audience measurement, etc.)

Data source

SIBLU collects your personal data from data that you provide directly. 
As part of its commercial prospection activities SIBLU collects data indirectly via commercial partners. Individuals whose data is collected in this way must have given prior consent for it to be communicated and used in this way. 

Mandatory nature of data collection and consequences of failure to provide data 

Data collection during browsing (including cookies) is optional. You can oppose this data collection and this will not stop you from being able to browse the different pages of the website. 

Data collection for other purposes is obligatory in order to use the service or feature that interests you, except for cases of case of direct collection where there is the option to specifically oppose this collection on the form or the digital platform in question. If all the necessary data is not provided, it will not be possible to process the request. 

Automated decision-making 

The processing does not include automated decision making 

People concerned

Data processing concerns those browsing and/or using the services and features of the websites siblu.co.uk/ siblu.ie 

Data Recipients

The personal data that is collected is can be accessed by: 

  • Those authorised to access as part of their professional role (including the sales and marketing departments, the accounting department and the customer service department)
  • Our subcontractors
  • Our partners who manage services that you sign up to via SIBLU (for example online reviews)
  • Our partners who manage services that require your consent (sending of sales emails, surveys, etc.) We would like to remind you that in these cases you can always to unsubscribe by clicking on the link in the email or by contacting the data protection officer (dpo@siblu.fr) 
  • Our IT service providers who work on our software and our website
  • Our technical service providers who manage online payments

Transfer of data outside of the European Union

Data from customers who have booked a holiday directly with SIBLU is communicated to the service provider of our booking engine software and can be accessed from their office in India in the context of support operations. The service provider formally guarantees that they will respect the adequate level of protection required by the European Union and the standard contractual clauses adopted by the European Commission have been signed by SIBLU to this ends. 

When it comes to market research, we will try our best to keep your personal data within the European Union. It is, nevertheless, possible that your data may be occasionally transferred to commercial partners or subcontractors in other countries provided they offer an adequate level of protection as required by the European Union  

In cases where your data is transferred to a country where the level of data protection is not recognised to be adequate by the European Union, we will put in place Standard Contractual Clauses, approved by the European Commission, which ensure a sufficient level of protection of privacy and fundamental human rights. 

If you have any questions on this subject, you can send us a written request to the follow email address: dpo@siblu or to the following postal address: 10 avenue Léonard de Vinci - 33600 Pessac

Length of storage depending of type of data 

  • Data linked to the creation of a personal user accounts (holidaymakers, Sibu owners) - 5 years from most recent usage
  • Data linked to booking a holiday - 5  years from the end of the commercial relationship 
  • Payment management - Bank documents (bank statements, cheque stubs, etc.) are conserved for 5 years (article L110-4 of the French Commercial code). Bank card data can be saved by a technical intermediary in an intermediary archive to be used as proof in case of potential dispute about the transaction for a time period of 13 months (article L133-24 of the French Monetary and Financial Code) or 15 months in order to take into account the possibility of use of credit cards. 
  • Data linked to customer account management - 5 years from the end of the customer relationship
  • Data linked to informative and promotional emails, text messages and phone calls - User data is stored for 3 years counting from the date of collection or from the most recent communication received from the user. At the end of this time period, Siblu France SAS may contact the user to ask whether they still want to receive commercial communications. In the absence of a clear and affirmative response, the data will be deleted. 
  • Data linked to participation in a competition - Your data will not be stored
  • Writing a review  - Your review will remain online unless you delete it 
  • Use of data collected through cookies while browsing the website siblu.co.uk - Data collected by cookies is conserved for 13 months unless opposed by the individual in question
  • Data collected via online forms - 5 years counting from the date the form is received 

Security

SIBLU has an Information Security Policy (ISP). 

SIBLU implements appropriate measures to fight against accidental or criminal destruction, loss, alteration or unauthorised disclosure of data. Some of the principal measures include: 

  • Management of access rights for accessing the data    
  • Use of a Europe-based, security-certified and GDPR-compliant hosting service
  • Regular and systematic saving of data.  

Your rights

In line with GDPR regulations, you have the following rights: 

-The right of access to your personal data stored in our databases
-The right to rectification or erasure of your data taking into account the fact that this may be limited by our contractual and/or legal obligations
-The right to restriction of processing of your personal data in cases mentioned in the regulation and, in particular, article 18 of the GDPR. This right works in conjunction with your other rights (right to rectification, right to objection…). If you contest the accuracy of the data used by Siblu or you object to the processing of your data, Siblu can proceed to validation or examination of your request within a specified time period. During this time period, you can ask Siblu to freeze the use of your data 
-The right to data portability which allows you to ask to recieve a copy of any data you have provided to Siblu for personal use or in order to transmit them to a third party of your choice. 
-The right to object to the collection and processing of your data. In particular, you have a right to object, at any time to the use of your data for commercial prospecting purposes by SIBLU. You can object using a tickbox or by a link on the commercial prospecting communication or by contacting us at the address mentioned below. 
-The right to erasure of your personal data if your data is being used for sales prospecting; if you data is not or is no longer necessary in order to fulfil the objectives for which it was initially collected or processed; if you withdraw your consent for the use of your data; or if you enact your right to objection and SIblu does not have a legitimate or necessary reason to not accept your request. If personal data has been processed illegallly, or if the personal data must be erased to respect a legal obligation. (see article 17 of the GDPR).  
- The right to withdraw consent at any time for processing for which we have previously obtained your consent 

Implementing your rights

Any requests for the implementation of these rights should be submitted to SIBLU’s data protection officer. You can send your request, free of charge; 

-by email to dpo@siblu.fr 
-or by post to the following address: 10 avenue Léonard de Vinci 33600 Pessac, for the attention of the Data Protection Officer 

To find out more about implementing your rights, you can visit the following website: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles 

Right to issue a complaint to the CNIL 

You also have the right to file a complaint with the French National Data Protection Commission (la Commission Nationale de l’Informatique et des Libertés) the main office of which is situated at   3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.  Téléphone: (+33)1 53 73 22 22. Of course, we remain available in case of any difficulty, to help you try and find an amicable solution.

About cookies

When you visit siblu.co.uk, you are informed that cookies may be used by SIBLU. 

Cookies are small text, image or program files which are situated and stored on your computer, your smartphone and any other internet-browsing device when you visit a website. Cookies allow a website to recognize you, to note your visits to certain pages, and to use this information to offer you additional services: improved ease of browsing, a more secure connection, and page content which is adapted to your interests. 

The information which is stored by cookies, during a limited time period, is, in particular, linked to the pages you have visited, the advertisements you have clicked on, the type of browser you are using, your IP address, and the details you have already submitted to a website (to prevent you from having to resubmit them).

Please note that before setting or reading a cookie, SIBLU uses a specially-designed banner to: 
•    Inform you of the  purpose of the cookies
•    Obtain your consent 
•    Give you a chance to refuse the cookies

A number of different cookies may be left on your terminal during your visit to our website. You can find a list of the types of cookies below. 

Types of cookies 

The cookies generated on the website include: 

1. Cookies relating to audience measurement and statistics

This refers to cookies that allow us to see how our site is performing and to establish statistics about the volume of traffic and the use of various elements of our sites (content visited, user journey). These cookies allow us to improve the relevance and the ergonomics of our services (the most visited pages or sections of the site, the most-read articles, etc.). Cookies also allow us to keep track of the number of visitors to a page and to detect any potential anomalies in a site’s functioning. These cookies are not mandatory for visiting the site.

 

  • Google Analytics - Purpose: Measurement and analysis of data - Stored for: 13 months
  • Adobe Analytics  - Purpose: Measurement and analysis of data - Stored for: 12 months
  • HotJar.com - Purpose: Measurement and analysis of data - Stored for: 365 days

2. Cookies related to advertising

In order to make your browsing experience more relevant to you, we use the following cookies. This technology allows you to receive adverts adapted to your interests as you browse. These cookies are not mandatory for browsing the site. 

  • Google Adwords   - To provide targeted or non-targeted commercial communications. To allow for commercial analysis. - Stored for: 30 days
  • Google Adwords - Call Tracking  - To allow for commercial analysis - Stored for: 30 days
  • Facebook Ads - To provide targeted or non-targeted commercial communications. To allow for commercial analysis. - Stored for: 90 days
  • Bing Ads - To provide targeted or non-targeted commercial communications. To allow the undertaking of commercial analysis. - Stored for: 390 days
  • Squadata  - To provide targeted or non-targeted commercial communications. To allow the undertaking of commercial analysis. - Stored for: 13 months
  • Location Vacances Express ( LVE ) Express - To provide targeted or non-targeted commercial communications. To allow the undertaking of commercial analysis. - Stored for: 12 months
  • Criteo - To provide targeted or non-targeted commercial communications. - Stored for:  12 months
  • Affiliate window (Awin) - To provide targeted or non-targeted commercial communications. To allow for commercial analysis. - Stored for: 30 days
  • Toocamp.com - To provide targeted or non-targeted commercial communications. To allow for commercial analysis. - Stored for: 3 weeks

3. Cookies integrated in our site from third-party applications 

The website includes features that make use of services offered by third-party sites (including Facebook). These computer applications come from third-party sites and allow you to share content from our website with others or to share your opinion or advice about content from our website with other people. This is, for example, the case with the ‘Share’ or ‘Like’ buttons on the social network Facebook. These third party applications use cookies which make it possible to identify and track your browsing. These cookies are not mandatory for browsing the site. 

  • Kiamo - Customer relations - Stored for: the length of the web session
  • Daisycon Affiliate  - Call Tracking  - To allow for commercial analysis - Stored for: 100 days
  • Livechatinc - Customer relations (chat) - Stored for: the duration of the web session

Nature of the data collected

Your IP address will be collected during the use of cookies generated on our site.

Configuration of cookies

You can change your cookie settings on the banner that appears on your first visit to the site. Following this, you can always change the settings again via the same banner which is found in the bottom left-hand corner of the website siblu.co.uk.  

You can also change your cookie management settings using the help menu in your browser software. Please follow the link which corresponds to the browser software you are using:

For mobile devices, you can consult the following links:

For more information and control  of all cookies, not only those on our site, we invite you to consult the website Youronlinechoices, put together by the French Interactive Advertising Office (IAB), in particular the ‘Your Ad Choices’ page.