Club Med privacy policy

1. When does this Charter apply?
This Charter informs you how your Data is collected, processed and used when:

• You book a stay with Club Med;
• You visit the Club Med website or our mobile application (hereinafter, the “Website”);
• You subscribe to our Club Med newsletter (information on products & special offers) and customised content;
• You contact our Customer Service Department;
• You take part in our contests.
• You exchange with us via WhatsApp

 
2. What Data does Club Med collect?
2.1 Data sent to us directly
You provide us with your Data when:

• You register on the Website by filling in the various forms relating to your account or by uploading Data;
• You book a holiday package;
• You take part in contests;
• You complete a Club Med questionnaire;
• You communicate with our Customer Service Department.
• You exchange with us via WhatsApp

 
This Data may, for instance, consist of your:

• Last and first name(s);
• Date of birth;
• Gender;
• Mailing address;
• Email address;
• Telephone number(s);
• Means of payment;
• Booking history.

 
The same applies for any information you provide about anyone for whom you book a holiday package. In this respect, you agree to obtain their prior consent before disclosing their Data.
 
You may opt not to disclose certain information to us; however, this decision may prevent you from using our services. The required information for the provision of our services is identified with an asterisk in our information gathering forms.
 
2.2 Data automatically collected
While browsing the Website, Club Med may collect Data on the following, in strict compliance with the laws in force and your rights:

• Features of the operating system, browser or devices (computer, pad, smartphone) you use to access our services;
• Your location, such as your IP address;
• Your browsing path and interactions with the content of the Website, such as pages viewed, key search words used, frequency of your visits to the Website, advertising clicked on.

 
This browsing Data is collected using cookies. For more information on cookies, see the relevant section.

3.1 Data from other sources
We may also collect Data through third parties, including in particular social media, when you register or log in to our services using a third-party account. When you do this, you will be informed of the Data transferred to us by the relevant third party.
 
We use, store and process your Data to process your requests, manage our commercial relationship, and optimise our services and tools to create and maintain a more secure environment and to comply with our statutory obligations.
 
3.2 Performing a contract
We use your Data to manage your holiday package booking and to perform various related services.
 
In particular, we use your Data to process your payments, to inform you by text message, e-mail or any other means of communication about how the contract you enter into with us is performed (information on your journey, any transport delays, on your loyalty program “Great Members”, extra services proposed, etc.).
 
As part of our commercial activity, we may use commercial partners to provide certain services on our behalf.
 
For instance, we do not have our own fleet of aircraft, trains or coaches. We are required to enter into contracts with various carriers to offer you ways of getting you to our various resorts. Accordingly, some of your Data (last name, first name, date of birth, etc.) will be provided to the carrier in order for it to issue you a travel ticket.
 
Our business partners may not use your Data for purposes other than those required to perform services that you have requested. They are also required to process your Data in strict compliance with Existing Legislation.
 
3.3 Providing you with access to the Website and certain services
We use the Data you provide to identify you in order to access your Account on the Website (hereunder "Customer Account"), access to which is restricted to authenticated persons.
 
3.4 Sending you our Club Med newsletter and customised content
If, while booking a holiday package, setting up your account on the Website or thereafter within your Customer Account, you ticked the box or filled in the form to receive Club Med’s newsletter (information on Club Med products and commercial offers) and customised content, we may use your Data to send you the following, according to your preferences (in particular, by e-mail, text message, telephone or letter):

• Information on the Website;
• Invitations to Club Med events which may be of interest to you;
• Information on our offers;
• Information on updates to the Charter or security measures.

 
To stop receiving commercial offers and communications from Club Med, you may at any time unsubscribe by either (i) clicking on the unsubscribe link or completing the objection process indicated in Club Med communications or (ii) contacting us (see Section 8 below). You may also object to receiving telemarketing calls.
 
We may also use your Data to send you advertising messages which may be of interest to you on third-party websites or on social media platforms. For more information, we suggest you read the terms relating to the use of your Data on these third-party websites and/or platforms.

3.5 For profiling purposes
We may also process your Data for profiling operations.
 
Profiling is the automated process of your Data to analyse, anticipate and assess your interests and preferences in order to send you customised content and commercial offers suited to your specific requirements.
 
Club Med will only share your Data with third-party service providers to determine your profile and preferences and send you more relevant Club Med content. Club Med will not disclose your Data to commercial partners.
 
You may object at any time to the use of your Data for profiling purposes by accessing your Account or by contacting us (see Section 8 below).
 
3.6 Optimising the Website and our services
We use your Data to carry out analyses, technical tests (which might include the anonymisation of your Data) and data deduplication in order to improve and optimise the Website and customise our tools and services. This means, for example, ensuring that the display of our content is adapted to your device or hosting your Data on even more secured servers, etc.
 
3.7 Handling complaints
When you contact our Customer Service Department by telephone or using the contact form available on the Website or by any other means made available by Club Med (social media, chat, etc.), we use your Data (ncluding the recordings of your calls, with your prior consent) to:

• respond to and resolve your complaint;
• track and manage the follow-up of your complaint;
• improve customer service.

 
3.8 For internal statistics and surveys
We may use your Data to carry out various statistical analyses and/or to ask you to take part in our surveys.

3.9 Ensuring compliance with legal and judicial obligations
Your Data may be used to:

• respond to a request from an administrative or judicial authority, a law enforcement representative, an officer of the court or to comply with a judicial decision;
• ensure compliance with our general terms and conditions of sale and with the Charter;
• protect our rights and/or obtain compensation for any harm we may suffer or mitigate the consequences thereof;
• prevent any act contrary to the laws in force, including in particular the prevention of fraud risks.

 
3.10 Managing your participation in contests
When you participate in contests, you provide us with a certain amount of Data. This Data is essential in order for you to participate and for us to award a prize.

With your prior and express consent, we may use this Data to send you the Club Med newsletter (information on Club Med products and commercial offers) and customised content.

3.11 Managing your participation to solidary projects identified by the Club Med Foundation

When you participate to funds raising by “Club Med Foundation Funds” which gather financial donations from our Customers willing to support solidarity projects identified by the Club Med Foundation, you will provide us with some Data. This Data will be necessary to take into consideration your participation and allows the sending of your tax receipt.

Club Med uses cookies and other tracking technologies on its websites. To find out more about how Club Med uses these cookies and how to configure them, please consult our policy on trackers using the “Cookies” link at the bottom of our web pages.

As a general rule, your Data is kept only for the time necessary to carry out the operations for which the Data was collected.
 
Depending on the Data category, Club Med keeps the Data for the following time periods:

• Prospect Data is kept for a maximum of three years from the last contact they initiated with Club Med;
• Data relating to customers who have subscribed to a package are kept for a period of 3 years after the end of the contractual relationship with Club Med, which expires at the end of the "Grand Members" loyalty program (more information by clicking on the "Great Members Programme" link on the Club Med website);
• Bank details are not kept after payment of your package and/or services ordered, unless you have given your consent for them to be recorded or in the event of recurring payment, in which case they are kept for the duration of our contractual relationship;
• Data collected automatically via cookies, including browsing data, is kept for a maximum of 13 months;
• Data relating to your participation in solidarity projects identified by the Club Med Foundation is kept for a period of 3 years;
• Data relating to the identity documents you send us when exercising your right of access or rectification are kept for a maximum of 12 months;
• Data relating to an incident that has led to your inclusion on Club Med's incident list is kept until the payment incident has been resolved or, failing that, for a period of 5 years;
• Information enabling us to take into account the opposition rights of the persons concerned is kept for a maximum of three years starting from the exercise of this right.
• Data relating to WhatsApp conversations is kept for 1 year when used for statistical, quality analysis and follow-up purposes.
• Data relating to recordings of your calls (subject to your prior consent) and Data relating to the processing of your complaints are kept for a period of 1 year.

 
We may also delete your Data on request, following the instructions detailed in article 8.
 
Note that on the expiry of these periods, and on receipt of your request to delete, your Data may be archived in order to comply with statutory, accounting and tax obligations (e.g. obligation to keep invoices for 10 years in accordance with Article L.123-22 of the French Commercial Code and/or during the applicable limitation period and/or for the duration of any legal dispute.

We may share your Data with various third parties including in particular:

• our affiliated entities to provide you with the requested services or acting as data processors in accordance with applicable laws;
• our commercial partners, suppliers and/or data processors who process your Data on our behalf, and according to our instructions, or as Controllers for the purposes specified in Section 3 (including in particular carriers, insurance companies, customs authorities, local service providers, financial institutions, technical data processors, etc.). We take special care to ensure that these third parties provide adequate guarantees to ensure the protection and security of your Data;
• duly authorised French or foreign authorities, particularly pursuant to legal proceedings or data transmission request.

In accordance with the laws in force, we rely on various legal bases to process your Data, including:

• your prior express consent to the processing of your Data for one of the purposes listed in Section 3;
• the performance of the contract you entered into with us;
• the need to comply with a statutory obligation or to defend ourselves in the event of legal proceedings;
• the legitimate interests pursued by Club Med.

You may ask us to access, rectify, update, restrict or delete your personal information.
You may also exercise your right to object to the processing of your personal Data.

The right to portability allows you to recover some of your personal Data, namely:

• Data you sent us directly as specified in Section 2.1;
• Data generated by your use of the Website as specified in Section 2;
  We endeavour to respond to your request within a reasonable time and no later than the time limit provided by law.

You have the right to set general or specific guidelines for the retention, deletion and disclosure of your Data after you close your account.

To exercise your rights, you can address your request:
Via a letter to: Club Med Suisse, Service Relation Client, chemin des mines 2, 1202 Genève, and enclose a copy of your identity documents along with your request.
 
In case of reasonable doubts on your identity, we may ask for additional information that will be necessary to confirm your identity.
 
If you believe your rights have not been respected, you may, at any time, file a complaint with Club Med’s Data Protection Officer (DPO) by sending a letter to: DPO - Service Relation Client, 11 rue de Cambrai, 75957 Paris Cedex 19, France or via dpo@clubmed.com
 
8.5. Right to form a complaint to the Data Protection Authority
You may also file your complaint with the competent regulatory authority: Federal Data Protection and Information Commissioner (FDPIC).

We may transfer your Data to countries outside of Switzerland / the European Union for the sole purposes indicated in this Charter.
 
When your data is transferred, we ensure that your Data is protected in accordance with protection levels provided for in Europe.
 
Transfers are made exclusively to countries that are recognised as providing an adequate level of data protection by the European Commission.
 
Data may be transferred to a country that does not offer an adequate level of protection, especially if your Travel Package is taking place in such a country. In that case, Club Med and its partners or service providers agree to implement appropriate guarantees to govern the transfer (e.g. standard contract clauses of the European Commission), which you may request by sending a letter to the DPO as specified above.

Club Med undertakes to guarantee the integrity and reliability of Data entrusted to it, including by taking all physical, organisational and logistical measures necessary to prevent any alteration or destruction of such Data and by ensuring secure access only to those persons authorised to process the Data.

Last updated in December 2023
Club Med may be required to amend this Charter in the event of a change in applicable laws. Amendments, if any, will be posted on this page, or will be communicated via email.