1. Transparency
2. Legitimacy of use : we will gather and process your "PD" solely for the purposes described in this Charter.
3. Relevance and accuracy
4. Retention
5. Access and amendment
6. Confidentiality and security : we will put in place all reasonable technical and organisational measures to protect your "PD" against accidental or illicit alteration or loss and unauthorised use, disclosure or access.
7. Sharing and international transmission : we may share your "PD" with companies of the ACCOR group or third parties (such as our business partners and/or service providers) for the purposes indicated in this Charter. We will take all appropriate measures to guarantee the security of the data shared or transferred.

If you have any questions about the 7 principles of Accor's Data Protection policy, please contact the department below (§13).

This Charter applies:

1. To all data processed at our affiliated and managed hotels, i.e. all hotels operating under the ACCOR group name (Sofitel, Pullman, Novotel, Suite Novotel, Mercure, MGallery, Adagio, Ibis, All seasons, Etap Hotel, Hotel F1, Formule 1…). This list is updated regularly.
2. To all ACCOR booking sites, namely www.accorhotels.com and also to the brand sites ( www.sofitel.com , www.mercure.com , etc.). , www.mercure.com , etc.).

Although our customer privacy policies are not binding on our franchised hotels, ACCOR will do its utmost to promote the "7 principles" set out above to ensure that our franchises adhere to the applicable regulations when processing your "personal data".

As an ACCOR customer, you will be asked to provide certain information about yourself and/or the members of your family, such as:

1. contact details (surname, first name, telephone number, email address, etc.)
2. personal details (for example date of birth, nationality, etc.)
3. information about your children (e.g. their first name, date of birth, age, etc.)
4. your credit card no. (for booking and transactions)
5. your ACCOR loyalty programme number or membership number of another partner programme (Air miles for example)
6. your dates of arrival and departure
7. your preferences and interests (smoking or non-smoking room, preferred floor, type of bedding, which newspapers you read, sports, cultural interests, etc.)
8. your questions/comments during or following a stay in one of our establishments.

As a general rule, we will not collect any information about children under 18 years of age other than their name, nationality and date of birth, which will be provided to us by an adult. Please ensure that your children do not send us any "PD" without your consent (via the Internet in particular). Should this happen, please contact us to have this information removed.
Furthermore, local laws may also classify other information as sensitive, including your credit card no., leisure interests, personal activities and hobbies, whether or not you smoke, etc. We may be required to gather such information in order to satisfy your requests and provide you with a suitable service, such as meeting any special dietary requirements.
The laws in force in certain countries may require us to request your prior consent before gathering sensitive information.

Your "PD" may be collected by different methods, including:

At the hotel:

1. Booking an apartment or room
2. Checking in and paying your bill
3. While using the Aparthotel or hotel bar or restaurant during your stay
4. Requests, complaints and/or disputes

Marketing programmes or promotions:

1. Registering for the loyalty programmes
2. Completing customer satisfaction questionnaires (e.g. the Guest Satisfaction Survey)
3. Online competitions or games
4. Subscribing to newsletters in order to receive promotions and offers by email

Information passed on from third parties:

1. Tour operators, travel agencies, GDS booking systems etc.

On the web:

1. Connecting to ACCOR sites (IP address, session cookies)
2. On-line forms (online booking, questionnaires, etc.)

We collect your "PD" for the following purposes:

1. To manage your bookings:
   • For room bookings and accommodation requests
   • Drafting and retention of the legal documents in accordance with the laws in force
   • Internal management of lists of guests posing payment issues or guilty of anti-social behaviour
2. To manage your stay at the hotel:
   • To monitor your usage (phone, bar, payTV, etc.)
   • To manage room access
3. To improve our hotel service, specifically:
   • Processing your "DP" in our customer marketing programme
   • Better understanding of your needs and wishes
   • Adapting our products and services to best meet your requirements
4. To send you newsletters, travel, hotel and service promotions/offers or offers from ACCOR partners. You can unsubscribe from the newsletter at any time by clicking the unsubscribe link at the foot of the page.
5. To improve ACCOR services, for instance:
   • Conducting surveys and analysing customer questionnaires and comments
   • Handling your complaints
   • Passing on the benefits of our loyalty programme
6. Improve the user friendliness and security of our ACCOR sites:
   • Better browsing
   • Implementing security measures and preventing fraud
7. Complying with local legislation (retention of accounting documents, for instance)

We have a presence in many countries and make every effort to offer you the same services throughout the world. To this end, to guarantee you the right to access and change your "PD" (§13), we must share it with other parties inside and outside our company. The following terms and conditions apply:

1. Inside the ACCOR group: to provide you with the best possible service we may share your "PD" and allow authorised personnel to access it, including
   • Hotel staff
   • Booking personnel using the Accor booking tools
   • IT services
   • Business partners and marketing services
   • Any necessary medical services
   • Any necessary legal services
   • In general, any person in the ACCOR group who is required to handle certain quite specific categories of "PD"
2. With service suppliers and partners: your "PD" may be passed onto a third party with a view to providing you with services and improving your stay, for instance:
   • External service providers: IT subcontractors, international call centres, banks, credit card companies, lawyers outside the company, mailing houses, printers
   • Business partners
3. Local authorities: we may also pass on your details to local authorities if required to do so by law, in connection with an investigation or in accordance with local regulations.

For the purposes set out in clause 7 of this Charter, we can transfer your "PD" to recipients inside and outside the company who may be located in countries which offer different levels of "PD" protection.
Therefore, in addition to this Charter, Accor has put appropriate measures in place, including contractual clauses, to ensure the secure transfer of your "PD" to an ACCOR entity or recipient outside the ACCOR group located in a county where the protection levels differ from those offered in the country where the "PD" is collected.

Accor has taken all the necessary technical and organisational measures, in accordance with the applicable laws, to protect your "PD" against accidental or illegal destruction, accidental loss or alteration, unauthorised disclosure or access. The technical measures include firewalls and among the organisational measures put in place we have an ID/password system and physical protection measures
When you give your credit cards details during booking, your transaction details are secured by SSL (Secure Socket Layer) encryption.

When you visit the Accor Group's websites, some browsing-related information on your device (computer, Smartphone, tablet etc.) is likely to be recorded in files called "cookies" and stored on your device.
What are the different types of cookies?
There are several categories of cookies:

• Strictly necessary cookies: these cookies are essential in order to browse some websites and use all of their features (the user's operating system support, display etc.). Without these cookies, features such as the display will not have optimum functionality. Note: these cookies collect purely technical data and do not identify you personally.
• Performance cookies: these cookies help us improve a user's experience by helping us understand how they use our websites (most frequently visited pages, applications used etc.). These cookies do not identify you individually.
• Functionality cookies: in order to make browsing easier, these cookies store certain user preferences (language, username, country etc.).
• Targeting/advertising cookies: these cookies enable a user to receive targeted advertisements based on their interests, but they also limit the number of times that the advertisements appear.
• Affiliate cookies: these cookies enable third parties ("affiliates") that publish marketing campaigns on their websites to be paid on behalf of the "web merchant".
• Cookies from social networks: these third-party Cookies let you communicate the content of our site to others, as well as your opinion in relation to our site. This is the case with the "Share" and "Like" buttons on "Facebook," "Twitter," "LinkedIn," "Viadeo," etc. Social networks which offer these application buttons can identify you by these buttons, even if you did not click on one of them when you visited our site. Indeed, some Cookies allow the social network concerned to follow your navigation on our site whenever your social network account is activated on your device when at the same time, you are on our site. We have no control over the procedures social networks use to collect information about your navigation on our site. Please read these social networks privacy policies regarding personal data. These should allow you to exercise certain privacy options with these social networks, in particular by adjusting your user accounts for each of these networks.

Why does Accor use cookies?
Cookies help us to improve the quality of your browsing experience when visiting the Accor Group's websites. This technical process primarily allows us to:

• adapt the layout of our websites to suit your device's display preferences (language, display resolution, operating system used etc.)
• store some of the information that you fill in on our online forms to help us personalize your subsequent visits to our websites
• enable you to access your personal pages more quickly by storing the log-in details or information that you have previously entered
• collect statistics. These relate mainly to the number of times you visit our websites and your use of the different services that we provide (sections and content viewed, links), with the aim of improving their relevance and usability
• put security measures in place (for example asking you to reconnect to a page or service after a certain amount of time has elapsed)
• offer you, through advertisements, personalized content that is likely to be of interest to you (better offers, other destinations etc.).

Important: Advertisements or links to third-party websites may be included on our websites. Your personal details may be collected by third parties when you click on these links. This Charter does not cover visits to third-party websites. The Accor Group cannot be held responsible for the policy of third-parties regarding personal details and the use thereof.

How can you manage your cookies (enable, limit, block)?
Configuring your Internet browser (Internet Explorerâ„¢, Firefoxâ„¢, Safariâ„¢, Google Chromeâ„¢, Operaâ„¢etc.) is a free and effective way of managing cookies. You can then decide:

• to enable the use of all cookies integrated in the pages and content that you consult. Note: on the one hand, these cookies will only be readable by their issuers. On the other hand, this process is not definitive, and it will always be possible for you to disable these cookies afterwards, (cookie management will vary depending on your Internet browser; please refer to the relevant instructions)
• to block the use of cookies on your device. In this case, we would advise you that ease of navigation will be affected. Some functions require the use of cookies (for example, it is possible that your operating system will not be recognized or that the language displayed will not be the expected language). Consequently, we will accept no responsibility for any inconvenience caused by the possible malfunction of our services due to the necessary cookies being unavailable
• to be asked by your browser to either agree or disagree before the installation of a new cookie on your device
• to accept or reject the cookies depending on the issuer

Cookies "Flash"© in "Adobe Flash Player"™

"Adobe Flash Player"â„¢ is an application which enables the rapid development of dynamic content using "Flash" programming language. Flash (and applications of the same type) stores the settings, preferences and usage of this content using technology similar to cookies. However, "Adobe Flash Player"â„¢ manages this information and your preferences through an interface that is different to the one provided by your browser software.

As your device is likely to display content developed using Flash language, we would ask you to access Flash cookie management by consulting the site directly http://www.adobe.com/.

We retain your "PD" only for the length of time required for the purposes set out in our Charter or in accordance with the applicable laws.

You have a right to access your "PD" collected by ACCOR and amend it, subject to the applicable laws.
To exercise this right, please contact the aparthotel directly.
Should you experience a problem exercising this right, please contact the ACCOR group Data Privacy department:

ACCOR
Département Protection des Données Personnelles (Data Privacy)
Immeuble Odyssey
110 Avenue de France
75210 Paris Cedex 13, France

To ensure confidentiality and "PD" protection, we are required to check your identity before we can answer your request. We will therefore ask you to attach a copy of an official identity document (driving licence or passport) to your request.
If your "PD" is inaccurate, incomplete or out of date, please send all changes to the Data Privacy department (details above).
All requests will be processed as quickly as possible and in accordance with the applicable laws.

We may amend this Charter from time to time. We therefore ask you to refer to it regularly, and specifically when making a booking at one of our hotels.

If you have any questions about the ACCOR group's personal data policy, please contact the Data Privacy department (§ 13).