Le Chic 102 Privacy Policy

Introduction

This Privacy Policy outlines Le Chic 102 (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at https://lechic102.myweb.smoobu.com/ (" Site "), or otherwise share personal information with us (collectively: " Users "). 

Grounds for data collection 

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter " Personal Information ") Upon your consent and for marketing purposes, we sporadically send you messages concerning news, offers, products, and services we and our partners recommend, which may interest you, as further described in detail, through email and or other marketing channels. You can change your preferred marketing channels by following the link in the subscription confirmation email which is sent to you as a result of your subscription request. We will be delighted to welcome your family, including your children, at Le Chic 102. However, our services, including our website, apps and other service-related offers, are not directly intended for your children and should not be used by them without supervision.


is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.


When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.


We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions. 

What information we collect?

We collect two types of data and information from Users. 


The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).


By visiting our website, and using our services or otherwise interacting with us, you agree to the data processing activities described in this privacy statement. Please note that all associated websites are subject to their own terms and conditions, and privacy statement. If we modify this statement, your continued use of our website and services will constitute your acceptance of the modified statement.


The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  • Data collected about you. With reference to your visits to our website or your use of our applications, we may collect:
  • Data that does not reveal your identity, for example, the type of destination that you are looking up the information for. We use this data primarily to ensure the relevance of the messages, and we may link them to your name or email address.
  • Technical data, including the Internet Protocol (IP) address used to connect your computer to the Internet, your connection details, the type and version of the browser, the time zone set, the date and time of the access to our website, types and versions of browser modules, operating system, and other related information.
  • Information about your visit, including the complete flow of URL clicks to, via and from our website, pages viewed or searched, page response times, download errors, length of visits to certain pages, the page's interaction information (scrolling, clicks, and cursor pointers), and the methods used to navigate the page.
  • Information about children under 16 years old. We will collect certain information about your children as described in the Information about Children section below.
  • Information obtained from a person making a reservation for your account. If you are acting on behalf of another person, you must confirm that you are authorised by that person to provide their personal data and that the information you provide to us is accurate. You may be liable for any loss or damage we suffer as a result of a breach of this commitment by you.
  • Information about you obtained from third parties. We may obtain information from credit reference agencies, online travel agents that you have used to make a reservation or request, our broadband providers and other service providers who will inform us, for billing purposes, whether our guests have used certain services and other third parties. In addition, in anticipation of your stay, we may collect your photo from publicly available sources so that we can recognise you upon your arrival and provide you with exceptional customer service.
  • Where European data protection laws apply to our processing of your information, for example, if you do business with Le Chic 102, then some of the information collected about you by Le Chic 102 may constitute what is called the 'personal data'. In this case, you will be considered as a "data subject". Personal data will include any information from which you may be directly or indirectly identified, including by reference to an identifier such as a name, an identification number, location data, an online identifier, or by one or more factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity. When necessary, we will treat your personal data in accordance with these laws.
  • You can provide us with even partial information by completing forms, setting up an account or user profile, subscribing to newsletters and other services, making or cancelling a reservation or ordering a product, by uploading data to our website, making an "enquiry" about Le Chic 102, using our contact form, participating in one of our online surveys, random draws or promotions, or by contacting us for personal or professional purposes via email, phone, or otherwise. This information may include your name, email address, billing address, room preferences or special requirements, phone number, guarantee and deposit data to secure your reservation, content of any email you send us, and any other data of the same nature. You have no obligation to provide us with this information, but without it we may not be able to respond to you and provide you with access to the content, services, or information you request from us.
  • We record the details of your expenses and other charges made to your room. Specific information about your stay may also be stored, such as requests for services, creditworthiness, special preferences or requests relating to health issues. Information specific to your stay will be recorded in our software and associated with those from your previous stays in this property. Images of your person may be recorded if you are in the areas monitored by our CCTV system.

How do we receive information about you?

We receive your Personal Information from various sources:

  • When you voluntarily provide us your personal details in order to register on our Site;
  • When you use or access our Site in connection with your use of our services;
  • From third party providers, services and public registers (for example, traffic analytics vendors).

What information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.


We may use the information for the following:

We may process your data, in accordance with the legislation, for:

  1. responding to your questions, complaints and requests, and dealing with them.
  2. processing your reservations or cancellations, providing the services, products or content you requested, managing and administering your user account, providing service communications and enabling you to use interactive features of our applications and websites, when you wish to do so.
  3. providing you with personalised and high-end customer service before, during and after your stay, whether you are a new customer or not. To do this, we may create a profile about you including information from our real estate software, which will also allow us to improve the relevance of our communication.
  4. posting content on our websites and applications, such as news stories, product reviews, comments, and photos that you have provided.
  5. allowing our suppliers and service providers to perform certain activities on our behalf, including the hosting of our websites, applications and booking platforms, as well as audit, technical, logistical or other functions.
  6. sending you marketing communications, alerts and newsletters through our marketing channels, and sending personalised advertisements to your devices, subject to your consent, or as otherwise permitted by law.
  7. communicating with you and administering your participation in special events, programmes, surveys, contests, sweepstakes, and other offers or promotions.
  8. administering our business, including financial transactions, credit control, and recoveries.
  9. ensuring the security of your user account, our premises and facilities, and our activities, for example, by monitoring account activity and deploying a video surveillance system; verifying your identity, when required, preventing or detecting fraud or abuse on our sites, in connection with our products and services, for example, by requesting verification data in order to reset the password of your account; implementing and enforcing the terms and conditions of our business, or any other contract with you; administering the technical component of our website, including problem solving, diagnosis of technical and service issues, testing, encryption, and other similar operations;
  10. performing data analysis, statistical research, and trend analysis in relation to user activity, demographic information, host profiles, user comments, or other contributions, with a view to developing and improving our websites, products and services, and ensuring the effectiveness of our business efforts.
  11. complying with applicable laws, for example, in response to a demand from a court or regulatory body, where the demand is made in accordance with the law. We also record data to comply with financial reporting requirements, including those imposed by auditors and regulators. We may also collect certain data in accordance with local laws (for example, the ID or passport number, the names and date of birth of all guests spending nights, including those of children and spouses).

 

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.


In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

  • Hosting and operating our Site;
  • The processing required to fulfil a contract, such as our terms and conditions, or the terms of the reservation agreement between us, including processing for the purposes set out in paragraphs (1), (2), (3), and (4); the processing needed to ensure our legitimate interests or those of third parties, including processing for the purposes set out in the paragraphs (5), (6), (8), (9), (10), and (11), which is carried out on the basis of our legitimate interest to ensure that our website, our content, and our services are competitive and provided efficiently, without delay, and in a friendly and personalised manner, taking account of the comments, data and profiles of users, to ensure the safety of our operations and information of our users, and to ensure the proper and effective administration of our activities, unless consent to this processing is required under the applicable law; your consent, such as for processing for the purposes set out in paragraph (7) and 2 where such consent is required by applicable law; the processing necessary to fulfil a legal obligation to which we are subject, such as processing for the purposes set out in paragraph (9); and other legal grounds applicable to the processing, if any.

 

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may request to: 

  1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information. 
  2.  Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format. 
  3.  Request rectification of your personal information that is in our control.
  4.  Request erasure of your personal information. 
  5.  Object to the processing of personal information by us. 
  6.  Request to restrict processing of your personal information by us.
  7.  Lodge a complaint with a supervisory authority.

 

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. 


Right of withdrawal of consent.

Data subjects may at any time withdraw their consent to the processing of their personal data carried out by us on the basis of their prior consent. Such withdrawal will not affect the legality of the processing based on this prior consent. Please note that if you withdraw your consent, you will no longer be able to benefit from certain service features for which the processing of your personal data is necessary.

 

Right to oppose processing, including profiling.

We comply with valid opposition requests unless we have a legitimate and overriding compelling reason to continue our processing, or we have another legal reason to refuse the request of the person concerned. We will comply promptly with any valid refusal to participate in marketing communications. Le Chic 102 will endeavour to respond to your request within 72 hours. However, it may take up to 7 days to remove your profile from our systems.


Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 


We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services. 


A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 


The Site uses the following types of cookies:


a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 


b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 


c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.


Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.


We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics .

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 


This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy. 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. [explain about your security practices, such as: we employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy] . Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside the EEA 

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Advertisement

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 


You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members.http://optout.aboutads.info/#!/ .

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you. 


Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 


Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at management@lechic102.be .

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at :


Le Chic 102

Buzlu Group SRL, n° 76 rue des Meridien

1210 Saint-Josse ten Noode

Brussels BE

VAT identification number: BE1024642375

management@lechic102.be


Last Modified October 2025