Privacy policy — sonnette-pms.com
To be verified by a professional before any publication:
- Confirm the exact name and address of the data controller once the SASU is registered (in the meantime, Samuel Wieder, as a private individual, is responsible for the site).
- Confirm the choice and actual configuration of the “cookie-free” analytics tool (Plausible or Umami depending on the product plan) and verify that no cookie or persistent identifier is actually set, before stating that no consent is required.
- Have a DPO or GDPR lawyer confirm the “legitimate interest” legal basis used for B2B prospecting and the compliance of the one-click unsubscribe mechanism.
- Verify the retention period for contact-form messages and trial requests that never became customers, and align it with actual practice before publication.
- Complete the contact details and, if applicable, appoint a data protection officer should the processing ever require it (unlikely at the current volume, to be reassessed).
1. Who is responsible for this site
The site sonnette-pms.com (“the Site”) is published by Samuel Wieder, a private individual,
during the formation period of the company Sonnette (a SASU being registered). Once the company
is registered, it will take over from Samuel Wieder as controller for the processing described
below, with no change of purpose. See mentions-legales-site.md for full contact details.
2. Data collected
The Site collects the following data:
| Source | Data | When |
|---|---|---|
| Contact form | name, email, hotel name, message, phone number where given | when the form is submitted |
| Trial request / sign-up | hotel name, email, password, SIRET number, address | when a trial account is created |
| Audience measurement | pages viewed, referrer, device type, approximate country — with no individual identifier or tracking cookie (a privacy-respecting analytics tool) | on every visit |
The Site does not use advertising cookies or third-party trackers for profiling purposes.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Responding to a contact request | Steps taken at the request of the data subject prior to entering into a contract (article 6.1.b GDPR) |
| Creating and managing a trial account | Performance of a forthcoming contract / pre-contractual steps |
| Measuring the Site’s audience in aggregate, to improve its content | Legitimate interest, with no individual tracker |
| B2B email prospecting aimed at hospitality professionals | Legitimate interest, under the conditions of article 6 below |
4. Retention periods
- Contact-form messages and requests that did not turn into a customer: kept only as long as needed to handle the request, then deleted or subject to restricted archiving (exact period to be specified before publication).
- Trial accounts not converted into a subscription: kept for the duration of the trial, then deleted, unless the prospect asks to keep their account.
- Audience-measurement data: aggregated, with no individual retention period since no individual identifier is kept.
- B2B prospecting list: see article 6.4.
5. Rights of data subjects
Anyone whose data is processed through the Site has the rights of access, rectification, erasure, restriction, objection and portability provided for by the GDPR. These rights are exercised at the address given in article 7. If the response received is unsatisfactory, the person may lodge a complaint with the French data protection authority (CNIL).
6. B2B commercial prospecting
6.1. Sonnette may send commercial prospecting emails to the professional addresses of independent hotels (generic addresses such as contact@, info@, reservation@, or named addresses tied to a role), to offer a hotel management software relevant to their activity.
6.2. Legal basis: this prospecting relies on Sonnette’s legitimate interest, under the conditions in which French law and the GDPR exempt B2B email prospecting — between professionals, for a product related to the recipient’s activity — from requiring prior consent, provided the recipient is clearly informed, given a means to object, and their refusal is respected.
6.3. Unsubscribing: every prospecting message includes a one-click unsubscribe link. Any unsubscribe or objection request is honored without delay and recorded in an opt-out register, checked before any further mailing.
6.4. Source of addresses and retention: the addresses used come from public sources (tourist office directories, contact pages of hotel websites, registers of classified establishments). No list is purchased from a third party. The prospecting list is kept for a maximum of three (3) years from its creation or the last contact with the recipient, then purged or updated.
7. Contact
For any question about this policy, or to exercise your rights: [email address to be completed, e.g. [email protected]] — [postal address to be completed once available].
8. Changes
This policy may be updated; the date of the last update is shown at the top of the page on the Site. Substantial changes are flagged prominently on the Site.
See also mentions-legales-site.md (publisher, hosting providers) and
dpa-sous-traitance-rgpd.md (processing carried out on behalf of customer hotels, separate from
what is described here).