PRIVACY POLICY

Privacy policy

March 31, 2025

The purpose of this Privacy Policy is to provide a transparent and general overview of how GUESTRAVELER processes USERS’ DATA (including MEMBERS) and protects their privacy when they connect to the WEBSITE or download the APPLICATION, access the PLATFORM and wish to use the SERVICE or make REPORTS.

Capitalized terms used in the Privacy Policy have the same meaning as in the Terms of Use

In particular, the term DATA has the meaning given in Article 4 of the GDPR. The same applies to the term processing.

This privacy policy aims to inform the USER (i) about how GUESTRAVELER collects, uses, and discloses their DATA (ii) as well as their rights regarding their DATA.

It applies when the USER visits the PLATFORM and also when they register to access the NOHÔ connection services on the APPLICATION or on the WEBSITE and when, as a MEMBER, they use the SERVICE.

DATA collected and processed by GUESTRAVELER and/or transmitted to third parties
The processing carried out
The methods of DATA collection
The purposes of collection
The duration of data retention
The recipients of the data
The transfer of data
Technical and organizational measures
The storage and security of data
The procedure in the event of failure
The rights of USERS (and MEMBERS)
The duties of MEMBERS
The methods of information and complaint
Changes to the Privacy Policy

1. DATA collected and processed by GUESTRAVELER and/or transmitted to third parties

The DATA collected mainly includes:

– Information obtained when the USER accesses the WEBSITE or the APPLICATION, such as their IP address and connection information

Information entered by the USER when registering on the PLATFORM or subsequently when completing their profile, proposing or benefiting from a PASSION SHARING: surname, first name, email and postal address, telephone number, photograph, video, date of birth, profession, password, information on the content of communications (telephone, SMS, emails, etc.),

– Information obtained from third-party sources via social networks, when the USER has authorized this.

– Technical information related to the USER’s browsing on the WEBSITE or the APPLICATION

Information on complaints and REPORTS.

2. Processing carried out

GUESTRAVELER processes the following DATA related to the PLATFORM and the SERVICE:

-USER management

-ACCOUNT management

-NOMAD management

-HOST management

-SHARING OF INTERESTS management

-management of messaging between MEMBERS

-management of cookies on the PLATFORM

-management of REPORTS

-management of PLATFORM security

3. Methods of DATA collection

GUESTRAVELER collects data in two ways:

– By directly entering data provided by USERS and MEMBERS when they visit the WEBSITE or the APP, contact us via the contact form, create an account, suggest or sign up for a PASSION SHARING, use the internal messaging system, when they access the PLATFORM on the WEBSITE or the APPLICATION, when they browse the PLATFORM or use the SERVICE, or when they leave COMMENTS on the PLATFORM. USERS thus freely, specifically, knowingly, and unambiguously consent to communicate this information to GUESTRAVELER;

– Through the use that USERS make of the PLATFORM and the MEMBERS of the SERVICE (their IP address, their connection details to the PLATFORM, the Service, their browsing, the name of the operating system used, the language, the GPS functionality or any other information automatically disclosed by the computer terminal or smartphone used).

GUESTRAVELER may also use cookies to obtain information about USERS or to improve the functionality of the media. If the USER does not want their DATA to be collected via cookies, they can disable cookies in their browser. However, this may affect the performance and functionality of their browsing experience on the PLATFORM.

More specifically:

When the USER accesses the PLATFORM

GUESTRAVELER does not collect or store any personal data when the USER accesses the PLATFORM and when they browse the WEBSITE or the APPLICATION if they refuse cookies and do not contact GUESTRAVELER via the contact form.

If they accept cookies, please refer to the corresponding section

If they fill out a contact form, the following data provided by them will be collected by GUESTRAVELER: first name, last name, email address, subject of the message, content of the message. This DATA will be used to process the message, respond to the USER, and will be kept by GUESTRAVELER for one year without GUESTRAVELER using it for any purpose other than to keep a secure record of the USER’s message and to meet its legal and regulatory obligations.

When the USER wishes to become a MEMBER and access the SERVICE, they are asked to provide DATA by filling out an ACCOUNT opening form that indicates which DATA is required.

GUESTRAVELER thus collects the following DATA from USERS who wish to become MEMBERS: email address, first name, last name, date of birth, password (created by the USER).

The USER may choose not to provide the requested DATA, but this may limit their access to the SERVICE, in particular for booking SHARED PASSIONS.

When the MEMBER uses the SERVICE, they are invited to offer (as a HOST) or benefit from (as a NOMAD) a PASSION SHARING and, as such, provide additional DATA such as:

-Useful additional DATA (telephone numbers, profession, qualifications, photographs, languages spoken, etc.)

-Data related to the PASSION SHARING (contact details, schedule, photographs, etc.)

-Data related to the payment and allocation of PARTICIPATION FEES and EXPENSES (bank details, in particular for HOSTS)

-Data related to COMMENTS

4. Purposes of collection

All data collected by GUESTRAVELER is done so for a specific and legitimate purpose. Depending on the case, this may include:

– facilitating the USER’s navigation on the WEBSITE or APPLICATION,

– enabling the USER to use and navigate the PLATFORM in an optimal manner

– to subscribe the USER to a newsletter about the services offered by GUESTRAVELER,

– to enable the USER to open an ACCOUNT to become a MEMBER

– to allow a NOMAD to access the payment service and a HOST to receive PAYMENTS via STRIPE (it being specified that payment-related data is not stored by GUESTRAVELER but by STRIPE)

– to allow a MEMBER to benefit from the SERVICE offered by NOHÔ,

– to enable MEMBERS to communicate with each other, and a MEMBER to chat with other MEMBERS, as part of SHARING A PASSION via messaging,

– to operate, protect, and improve the SERVICE,

– to analyze and disseminate COMMENTS after the fact,

– to enable GUESTRAVELER to comply with its legal obligations, resolve disputes and enforce everyone’s commitments, respond to requests from USERS and MEMBERS.

– if necessary, to comply with applicable law or any other legal obligation,

The DATA collected on the PLATFORM and in connection with the SERVICE will, in principle, be used by GUESTRAVELER for the stated purpose.

5. Data retention period

The DATA is retained for the period necessary to fulfill the stated purpose. The retention period for this DATA is, in principle, one year from the closure of the ACCOUNT for MEMBER DATA, unless a longer period is required by French tax and criminal law, in particular. In the event of inactivity on an ACCOUNT for a period of three years (and in the absence of prior closure of the ACCOUNT by the MEMBER), the DATA relating to the MEMBER will be deleted.

6. Recipients of DATA

GUESTRAVEL is the main recipient of DATA.

However, certain DATA may be transmitted to external service providers of GUESTRAVELER, such as payment services and IT services providing services on behalf of GUESTRAVELER. Furthermore, when a MEMBER proposes or registers for a PASSION SHARING, they must be aware of the first and last names, email address, and telephone number of the MEMBER organizing or participating in the PASSION SHARING. Each MEMBER must respect the rights of other MEMBERS in accordance with the provisions of Article 12 below.

7. Transfer of DATA outside the European Union

No international transfer of data to countries outside the European Union shall be carried out unless prior authorization has been granted by a decision of the competent authority that the third country ensures an adequate level of protection within the meaning of the provisions of Article 40 of Regulation EU 2016/679.

In its capacity as data controller, GUESTRAVELER undertakes to ensure that USER DATA is protected in accordance with the legislation in force within the European Union.

8. Technical and organizational measures

GUESTRAVELER undertakes to implement appropriate technical and organizational measures proportionate to the nature, scope, context, and purposes of the processing.

The processing of DATA collected on the SERVICE has been subject to internal measures designed to ensure compliance with the General Data Protection Regulation, through the implementation of appropriate technical and organizational measures to ensure the security and confidentiality of the data.

9. Storage and security of DATA

As data controller, GUESTRAVELER is responsible for the storage and security of USERS’ and MEMBERS’ DATA.

In this regard, GUESTRAVELER uses subcontractors who are also subject to the obligation to comply with applicable data protection legislation and regulations. GUESTRAVELER uses the services of IMAGILE MH Communication, 171 rue Epron, 14200 Hérouville-Saint-Clair, and ALWAYSDATA, 62 rue Tiquetonne, 75002 Paris, which ensure the security of the PLATFORM and the transactions carried out on it.

10. Procedure in the event of failure

Any breach of DATA of which GUESTRAVELER becomes aware and which is likely to result in a risk to the rights and freedoms of natural persons shall be notified within forty-eight (48) hours to the competent supervisory authority (Commission nationale Informatique & Libertés) and to the USER concerned.

11. Rights of USERS (and MEMBERS)

All USERS have the right to obtain confirmation from GUESTRAVELER that DATA concerning them is or is not being processed.

In the event of a positive response, the person concerned may request access to the DATA being processed and receive a copy of said DATA as well as information relating to the processing carried out (purposes, categories of data, recipients of the DATA, retention period, etc.).

All USERS have the right to request that the DATA concerning them be, as appropriate, rectified, completed or erased. In certain cases, the processing of DATA may be subject to restriction instead of erasure. All USERS may, under the same conditions, request the portability of the DATA collected by GUESTRAVELER.

However, where requests for disclosure of information are manifestly unfounded or excessive, in particular because of their repetitive nature within the meaning of Article 12-5 of EU Regulation 2016/679, the data controller may refuse to comply with the request and/or require the payment of administrative costs associated with the request.

The data controller has a response time of one (1) month from the date of receipt of the request, to which the USER’s identity document must be attached. If the request is incomplete, the data controller is entitled to request additional information: the time limit is then suspended until the said information is received.

Finally, any USER may object to the processing of their DATA at any time, for any reason whatsoever. In such a case, the DATA will no longer be processed.

The USER has the right to request the limitation of the processing of their DATA by the site, without GUESTRAVELER being able to refuse, unless it can demonstrate the existence of legitimate and compelling reasons that may prevail over the interests and rights and freedoms of the USER.

The USER has the right to transfer their DATA to another site.

They also have the right to specify what should happen to their DATA on the day of their death.

Any request for access, rectification, addition, portability or erasure of the USER’s DATA, as well as any indication of post-mortem use, may be made at any time and must be sent in writing, with the contact details of the requester and a copy of an identity document, by email to the following address: confidentialité@guestraveler. com or by post to the following address: GUESTRAVELER 73 rue Marie Curie, 14200 Hérouville Saint-Clair.

USERS retain the right at all times and under all circumstances to object to the processing of their DATA by expressing their refusal by email to the above addresses, or by using the dedicated automatic function included in every email sent by GUESTRAVELER.

12. MEMBERS’ Obligations

When MEMBERS propose, subscribe to, and participate in a PASSION SHARING, they are aware of the DATA of other MEMBERS. They undertake to use this DATA solely for the purpose of enabling the SHARING OF PASSION concerned, during the organization and implementation of the SHARING OF PASSION, to keep it confidential and to delete it at the end of the SHARING OF PASSION. They undertake to respect the privacy and image rights of MEMBERS and not to record, publish or distribute any content reproducing the image or voice of MEMBERS without their prior written consent and to provide proof of this consent to GUESTRAVELER prior to posting it on the PLATFORM.

13. Information and complaints

All requests from USERS (including MEMBERS) must be sent to confidentialite@guestraveler.com or by post to the following address: GUESTRAVELER 73 rue Marie Curie, 14200 Hérouville Saint-Clair, specifying their full name and email address. A copy of the USER’s identity document must be enclosed with the letter for the request to be considered valid. The USER must also specify the subject of their request and enclose a copy of their identity document. GUESTRAVELER will respond to the USER within a maximum of thirty (30) days.

GUESTRAVELER informs USERS that they also have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), 3, place de Fontenoy, TSA 80715 – 75334 Paris Cedex 07.

Changes to the Privacy Policy

GUESTRAVELER complies with the provisions of the General Data Protection Regulation (GDPR) No. 2016/679 of April 27, 2016, as well as those of French law No. 78-17 of January 6, 1978, as last amended by law No. 2024-449 of May 21, 202 4 and the implementing decrees in force, in particular Decree No. 2019-536 of May 29, 2019.

It reserves the right to modify this Privacy Policy, in particular to comply with changes in the legislation and regulations in force.

The date of the version in force is that appearing at the top of this document. In the event of significant changes, GUESTRAVELER will inform MEMBERS by email.

COOKIES

This section supplements the T&Cs and the Privacy Policy.

Capitalized terms used in this section have the same meaning as in the T&Cs

GUESTRAVELER uses cookies and other trackers.

When consulting the WEBSITE, accessing the PLATFORM and/or using the SERVICE, one or more cookies may be automatically installed on the USER’s (including the MEMBER’s) computer, mobile phone, tablet or any other device via their browser software. GUESTRAVELER also uses mobile service identifiers and other similar technologies. The following provisions are intended to help USERS better understand how cookies and other trackers work, what GUESTRAVELER’s policy is regarding cookies and other trackers, and how to use current tools to accept, set parameters for, or refuse them.

What is a cookie?

A cookie is a small text file placed on the USER’s computer hard drive or in their browser’s memory that allows the USER’s computer, mobile phone, or tablet to store various technical data that can be read when visiting a website. This data may include the number of visits to the WEBSITE or the APPLICATION made by the User, their IP address, the pages of the WEBSITE or the APPLICATION visited, etc.

Cookies used by GUESTRAVELER

GUESTRAVELER uses these technologies primarily to improve the functionality of the WEBSITE and the APPLICATION, to get to know you, to recognize you, and thus to facilitate your use of the WEBSITE, the APPLICATION, the PLATFORM, and the SERVICE. These technologies may also help GUESTRAVELER detect certain types of fraud.

GUESTRAVELER uses different types of cookies:

Strictly necessary cookies

GUESTRAVELER installs this type of cookie to ensure the proper functioning of the WEBSITE, the APPLICATION, the PLATFORM, and the SERVICE. They cannot be disabled. They enable the use of certain features of the WEBSITE and the APPLICATION. The data recorded is deleted as soon as the USER leaves the page.

These trackers do not store any personal data.

Functional cookies

GUESTRAVELER places cookies on the User’s device to enable them to navigate the WEBSITE and the APPLICATION.

These cookies improve and personalize the features of the WEBSITE and the APPLICATION. If these cookies are not accepted, some or all of their features may not work for the USER.

The functional cookies used by GUESTRAVELER are as follows:

Cookie name Type Duration Company

Session functionality

Session operation

The USER may refuse them.

The data collected is kept for the maximum period specified above.

Analytics and audience measurement cookies

GUESTRAVELER uses Google Analytics G4 for audience measurement. The data collected is kept for a maximum period of 13 months.

Advertising cookies

GUESTRAVELER does not use these cookies.

Accept all, refuse all, customize

When a USER accesses the WEBSITE or the APPLICATION, a window appears informing them of their rights and how their data is processed.

Users can block certain types of cookies. However, this may affect the browsing experience and the services that GUESTRAVELER is able to offer.

“Accept all”:

By accepting the use of cookies and other tracking devices and browsing cookies, the USER expresses their consent to their use.

“Reject all”:

To refuse all cookies (other than those necessary for viewing the WEBSITE or the APPLICATION), please follow these steps:

Click on “Refuse all”: This choice will be taken into account for 6 months and will then be offered to the USER again each time they log in.

The USER is invited to refer to the browser software they are using and follow its instructions. For example:

With Internet Explorer™: Tools menu ► Internet Options ► Privacy tab ► select the desired level
With Firefox™: Tools menu ► Options ► Privacy tab ► select the desired options
With Chrome™: settings menu (settings logo) ► Settings ► Advanced settings ► Content settings ► Select the desired options
With Safari™: Safari (settings logo) ► Preferences ► Security ► Show cookies ► Select the desired options
With Opera™: Tools menu ► Preferences ► Advanced tab ► Cookies section ► Manage cookies ► Select the desired options

“Customize”:

On the cookie banner, click on the “Customize” button.

The USER can then choose to accept the cookies they want by checking the corresponding box.

The USER’s choice will be taken into account for 6 months, after which the choice will be offered to the USER again.

Withdrawing consent:

The USER may withdraw their consent at any time by going to “Manage my cookie preferences” at the bottom of this page. Another option is to change the cookie settings.

USERS’ rights regarding DATA communicated by cookies

The rights of USERS regarding their DATA are those set out in Article 11 above of the Privacy Policy. They include the right to access, rectify, withdraw consent when it has been given by the USER, transfer data to another data controller, and object to the processing of data. The USER may also indicate what they wish to happen to their data in the event of their death.

These rights may be exercised by contacting GUESTRAVELER at the email address confidentialité@guestraveler.com, specifying the USER’s first and last names and email address, the subject of the request, and attaching a copy of their ID. GUESTRAVELER will respond to the USER within a maximum of thirty (30) days.

Third-party cookies

GUESTRAVELER does not transfer any data from cookies to third parties.

However, plug-ins from third-party social networks such as Facebook, X, LinkedIn, and YouTube are installed on the WEBSITE and the APP.

As such, the third party may have access to the information you view on the WEBSITE or the APPLICATION if you are logged into your account with these third-party social networks. GUESTRAVELER invites you to consult the privacy policies of the third parties concerned to find out about their privacy and cookie policies.

More information

By clicking on this link, USERS can obtain further information about their rights and the management of cookies, including how to configure their browser to be informed about cookies and, where applicable, refuse them.

Cookies: tools to control them | CNIL

If applicable, add details about flash cookies, web beacons, tracking URLs, server logs, and other technologies.