PRIVACY AND COOKIE POLICY

Updated: 26/11/2025

PRIVACY POLICY

General information

This Policy contains information on the personal data protection measures implemented by the White1921 hotel (1) (hereinafter, ‘Hotel(s)’), restaurants, spas and hair salons managed by the company LVMH Hotel Management (hereinafter, ‘LVMH HM’), as a data controller.

This Policy applies to all the personal data and information that you provide to us or that we collect when you stay at one of our Hotels or browse the www.white1921.com website (hereinafter, the ‘Website’).

Our Hotels and/or LVMH HM, acting as data controller, may collect and process personal data from anyone who makes an inquiry to the Hotels and /or LVMH HM via the ‘Contact’ form on our Website or makes an online reservation at one of our Hotels via our Website. Any personal information which you provide to our Hotels and/or to LVMH HM is governed by the Data Protection and Civil Liberties Act No 78-17 of 6 January 1978 (as amended), by the European General Data Protection Regulation (GDPR) 2016/679 of 27 April 2016, and by any other local regulations that apply to personal data processing.

For what purposes and on what bases will your data be processed?

The personal data which we collect from you and process concerning you allows us to:

• reply to your e-mail messages and provide you with information about our Hotels guest services, restaurants, spas, etc., Your data will be processed based on the Hotels legitimate interest in replying to your requests;
• enable you to make a reservation with us online, by e-mail, by telephone or in person concerning your stay at our Hotels. Your data will be processed for the purpose of fulfilling our contract with you;
• manage your stay at our Hotels and manage the restaurants, spas, points of sale and other services our Hotels offer. Your data will be processed for the purpose of fulfilling our contract with you and in the Hotel’s legitimate interest in running our business, finding out more about you and providing you with your chosen products and services;
• offer you an optimal guest experience and provide you with the same personalised service, today and in the future, whenever you stay at one of our Hotels. Your data will be processed for the purpose of fulfilling our contract with you and in the Hotel’s legitimate interest in providing the services we offer;
• share personal data concerning our clients’ preferences and reservations with other Hotels managed by LVMH HM. Your data will be processed based on our legitimate interest in finding out more about our clients in order to provide them with an optimal guest experience;
• manage payment irregularities or inappropriate behaviour that conflicts with our Code of Etiquette and subsequent access restrictions imposed on the person responsible. Your data will be processed in the Hotel’s legitimate interest in providing its services;
• complete check-in and check-out formalities when you stay at one of our Hotels. Your data must be processed in this way in order to comply with a legal obligation;
• manage security at our Hotels. Photos and images taken from our CCTV systems are processed in our Hotels legitimate interest in protecting people and property. This enables us to not only recognise our Hotels clients but also to identify any unusual inappropriate behaviour;
• interact with you and provide you with personalised services without needing to systematically ask you to prove your identity during your stay in our Hotels;
• collect, with your prior consent, data concerning your children if they are minors and if you wish to notify us, sensitive data concerning you;
• manage newsletter subscriptions and cancellations and provide you with information and special offers concerning our Hotels managed by LVMH HM. Your data will be processed based on our legitimate interest if you are already a client or with your consent if you are not a client yet;
• continually improve your guest experience by proposing personalised offers and services to you. The White1921 Hotels belong to the LVMH group, which includes many luxury Maisons that offer exceptional products and services in all sectors: Fashion & Leather Goods, Perfumes & Cosmetics, Watches & Jewellery, Wines & Spirits, Selective Retailing and Hospitality, Culture & Leisure. A list of all LVMH Maisons is available at https://www.lvmh.com. If you are an existing client of our Maison, you may also be a client of one or more other LVMH Maisons.

Therefore, with your express prior consent, pseudonymised data (which means that neither your name nor your contact details will be transferred to LVMH) concerning the purchases you have made from us over the last three years will be transferred to LVMH, our parent company acting in the capacity of processor. All data concerning the purchases you make from our Maison and from our group’s other Maisons to which you have also given your consent will then be compared. On the basis of this analysis, LVMH HM will receive additional information concerning your purchasing habits and preferences (which will not include information on the other Maison(s) from which you made those purchases);

• secure and improve your use of our Website. Your data will be processed based on the Hotel’s legitimate interest in running its business and in managing and protecting its network against fraud and hacking;
• manage accounting and financial matters and potential disputes. Your data will be processed for the purpose of fulfilling our contract with you and to comply with a legal obligation;
• manage your applications when you apply for one of our job offers, for performing pre-contractual measures.

After giving your consent, you may withdraw it at any time. This withdrawal will not affect the lawfulness of the processing operations carried out previously with your consent. As soon as you withdraw your consent to the processing of data needed to provide a service, you will no longer be able to receive the relevant service.

Are you obliged to provide us with your personal data?

The data which our Hotels and/or LVMH HM require for the above purposes are marked with an asterisk on the relevant forms. If you do not complete the required fields, we will be unable to provide you with your chosen services or to fulfil your request, as applicable.

The data not marked with an asterisk are optional and will enable our Hotels and LVMH HM to find out more about you and improve the services we offer.

How long will we retain your data for?

Your data will be retained strictly for the period of time necessary to fulfil the following purposes:

Manage client data
Your data will be retained for the duration of your stay at our Hotels and for five years after the end of your last stay with us.

Passport details
Your passport details will be retained solely for the duration of your stay at our Hotels.
If you wish, for your convenience and with your prior consent, we may retain your passport details for three years after the end of your stay.

Manage sensitive data
With your consent, your sensitive data will be retained for the duration of your stay at our Hotels or during 24 months if it is necessary to the safeguard of human life (ex. allergy)

Manage payments
Your payment details will be retained until the relevant transaction has been completed and for up to ten days after the end of your stay with us in case any further charges are incurred.
With your prior consent, your payment details (excluding your 3-digit security code) will be retained for 13 months after the date of any debit card transaction or for 15 months if you paid using a deferred payment method.

Manage financial and accounting information
Your data will be retained until the end of the relevant financial year and approval of our accounts.
Contract data will be retained for five years after the end of your stay (the limitation period). Your data will then be stored on an archive database for ten years from the end of your stay.

Manage our newsletter
Your data will be retained for as long as your subscription is active and we remain in contact, i.e., providing that you open our Newsletter or interact with us. If we do not hear from you for three years and if you do not reply to two successive messages from us, your data will be deleted.

Manage marketing operations
Your data will be retained for three years after our last contact or if you do not reply to two successive messages from us.

Who will your data be transferred to?

Your data will be communicated or transferred strictly on a need-to-know basis.

Your data will be sent to the following:

Internal recipients
- LVMH Hotel Management
- Our Hotels managed by LVMH HM (the current list is available on our Website: www.white1921.com)

External recipients
- The publisher of the Property Management System software, which is used to manage our Hotels reservations and client accounts
- The publisher of our online reservation software on our website
- The publisher of our Customer Relationship Management (CRM) software
- The host of our online reservation website
- The service providers that manage E-commerce transaction
- The service providers that manage our spas, restaurants, concierge services (including our reservation platforms) and the other services our Hotel provides
- Financial institutions and online payment service providers
- Our telephone reservation platform provider
- Our complaints handler
- Our satisfaction survey provider
- Our security service provider
- LVMH, our parent company, in the capacity of processor, which will compare data concerning the purchases you make from our group’s other Maisons

Recruitment
During the recruitment process and up to 3 months after the end of the process

Our Hotels and/or LVMH HM will only transfer your data to a third party in the following cases:

• if our Hotels and/or LVMH HM are required to share data with a third party in order to provide the service you have requested or to reply to your inquiry;
• if our Hotels and/or LVMH HM are required to share data with other Hotels managed by LVMH HM. Your data will be processed based on our legitimate interest in finding out more about our clients in order to provide them with an optimal guest experience;
• if you have given your prior consent for our Hotels and/or LVMH HM to share your data with our partners or other LVMH Maisons; and
• if our Hotels and/or LVMH HM are required by a competent authority (including a court of law or an administrative authority) to provide the relevant data.

Will your data be transferred outside the European Economic Area?

The persons to whom we transfer your data may be located in a foreign country, including outside the European Economic Area. Any of your data transferred to countries outside the European Economic Area are transferred subject to appropriate safeguards, including contractual safeguards and our Binding Corporate Rules (BCR) in relation to job applicants’ personal data, in accordance with applicable personal data protection regulations.

You may obtain a copy of the appropriate safeguards by contacting LVMH HM by post at 24-32 Rue Jean Goujon, 75008 Paris, France or by e-mail at: dataprivacy@white1921.com.

Personal data security and confidentiality

Our Hotels and/or LVMH HM have implemented technical and organisational security measures in accordance with industry standards, particularly in order to safeguard our information systems.

Our Hotels and/or LVMH HM have endeavoured to take appropriate measures to protect the confidentiality and security of your personal data which we process, ensure that they are not corrupted, damaged or destroyed and ensure that they are not accessed by unauthorised third parties.

In accordance with the security policy implemented by our Hotels and/or LVMH HM, when making a reservation with us, you must enter a password for your client account, which will be strictly personal to you.

Payment security

Payments made by bank card will be processed by a secure system in accordance with applicable regulations and standards, and in such a way as the transferred information will be encrypted by a software and no third party will be able to access the information whilst it is transported on our network.

What are your rights?

You have a right to access your data, request the rectification, erasure or portability of your data, as well as restrict the processing of your data, withdraw your consent and give instructions regarding the use of your data after you die.

You may also object, at any time, to:

• the processing of your data for the marketing operations carried out by our Hotels and/or LVMH HM;
• processing based on the legitimate interest of our Hotels and/or LVMH HM, for reasons pertaining to your personal circumstances.

You may exercise these rights at any time by contacting the Data Protection Officer (DPO) by post at LVMH HM, 24-32 Rue Jean Goujon, 75008 Paris or by e-mail at: dataprivacy@white1921.com.

You also have the right to submit a complaint to a supervisory authority concerning the data processing operations carried out by our Hotels and/or LVMH HM.

The French supervisory authority is the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 Paris CEDEX 07 | www.cnil.fr/plaintes.

COOKIE POLICY

What is a cookie?

A cookie is a small text file that uploads to your device (computer, tablet, smartphone, etc.) and collects and stores some of your personal data when you browse our Website (such as your preferences, the elements you click on, the time and number of times you visit our Website, your login details, etc.), thus enabling our Website to recognise your device.

Not all cookies are the same. They may differ depending on their origin and for how long they are stored on your device.

• Cookies may originate from two sources:
• Proprietary (or internal) cookies: these are created by the website you visit and are associated with the domain name of that website.
• Third-party cookies: these are created by third-party suppliers and installed on your device by the publisher of the website you visit and are therefore associated with a different domain name to the website on which they are implemented.
• Our external partners will install cookies on your device when you visit their web pages.
• Third-party cookies are governed by the privacy policy published by the relevant third party on its website.
• A list of our partners that use cookies on our Website is available in the Privacy Preference Center, which can be accessed by clicking on the ‘Manage cookie settings’ link at the bottom of the web page.
• Cookies are stored for two different periods of time:
• Session cookies: temporary cookies that are automatically deleted when you close your browser.
• Persistent cookies: even after you close your browser, these cookies will not be deleted until their expiry date, which varies according to the purpose for which they are installed. These cookies can also be manually deleted.

There are other types of tracking technologies, which are commonly referred to as web beacons which also collect information about you. Although this information will not necessarily include your personal data, it will also be linked to your browsing of a website and will be combined with the information collected by cookies, such as digital footprints, tags, logs, http variables, localStorage mechanisms, advertising identifiers, etc.

These other trackers are subject to the same rules as cookies and are therefore also governed by this policy. For the sake of simplicity, the term ‘cookies’ will be used here to refer to all types of tracker.

More information is available at https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs and https://www.youronlinechoices.com/uk/

The cookies we use on our Website

When you log into our Website, cookies will be stored on your device that will enable us to recognise the browser you are using for as long as the cookies remain valid. On our cookies banner and in this section, we inform you about the cookies that will be stored on your device.

The various cookies we use are stored for different periods of time, after which they will be deleted unless you renew your consent.

Information concerning the name and functionality of each cookie as well as the period of time for which it will be stored is available in the Privacy Preference Center, which is accessible by clicking on the “Cookie list” link at the bottom of the webpage.

Strictly necessary cookies

These cookies are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

These cookies are based on our legitimate interest and cannot therefore be deactivated via our settings system.

You may however configure your browser to block strictly necessary cookies, although if you do, we cannot guarantee that you will be able to use our Website.

Functionality cookies

These cookies enable our Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to the pages of our Website.

We use these cookies based on your consent. If you do not allow these cookies, then some or all of these services may not function properly.

Performance cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They also help us to know which pages are the most and least popular and see how visitors move around our Website.

We use these cookies based on your consent. Blocking them will not affect your browsing of our Website, but we will be unable to monitor and analyse how you move around and interact with our Website.

Targeting cookies

These cookies may be set through our Website by our advertising partners or social networks. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

We use these cookies based on your consent. If you do not allow these cookies, you will experience less-targeted advertising.

Why do we use cookies?

Cookies are used on our Website for the following purposes:

• to prepare statistics on visits to and the use of the various elements of our Website (pages and content visited, and how you move around and interact with our Website) to enable us to improve the appeal and efficiency of the services we offer;
• to adapt the presentation of our Website to your device’s display preferences (language, screen resolution, operating system, etc.) when you visit our Website, depending on your device and the visualisation and player software installed on it;
• to link any personal details (particularly your e-mail address) you provide to us when you register for or access one of our services with browsing information concerning your device, in order to send you marketing e-mails that might be of interest to you for example;
• to memorise information contained on a form you complete on our Website (when you register or access your account) or information about products, services or items you select on our Website (services, reservation details, etc.);
• to enable you to access reserved and personal pages on our Website, such as your account, using login details or data you have provided to us in the past; and
• to implement security measures, for example when you are asked to log in again to content or a service after a certain period of time.

Your cookie choices

Cookies will only be installed on your device with your consent, unless they are strictly necessary, in which case their use is based on our legitimate interest.

Consequently, you may choose to allow or block the majority of cookies used on our Website, at any time.

IV.1 The choices that will be put to you on our Website

As soon as you visit our Website, a cookie banner will appear, containing information on how cookies are used.

This banner enables you to allow or block some or all of the cookies we use. Your decision will apply solely to the cookies used on our Website.

If you block one or more cookies, you will not be able to use the relevant functionalities described above.

Your decision to allow or block the cookies that require your consent will apply for a maximum of six months.

You may change the cookie preferences you selected when you first visited our Website at any time by going to the Privacy Preference Center, which is accessible by clicking on the “Cookie list” link at the bottom of the webpage.

IV.2 The choices offered to you by your browser software

You may also configure your browser software to store cookies on your device or block them, either systematically or based on their origin.

You may also configure your browser software to ask you to allow or block cookies from time to time before they are stored on your device.

Cookies are managed differently, depending on your browser. Information on how to change your cookie preferences is available in the help section of your browser.

Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
Safari™: https://support.apple.com/kb/ph21411?locale=fr_CA
Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
Opera™: http://help.opera.com/en/latest/web-preferences/#cookies

Your decision to allow or block cookies will affect your browsing experience and determine whether you may access certain services that require the use of cookies.

If applicable, we decline all responsibility for any consequences due to the downgraded operation of our services resulting from the fact that it is impossible for our Hotels and/or LVMH HM to store or consult the necessary cookies which you have blocked or deleted.

If you share your device with others

If your device has several pieces of browsing software and is used by others, we cannot guarantee that the services and advertisements intended for your device will be suitable for you rather than another user.

If applicable, you may decide to share your device with others and must configure your cookie settings accordingly, under your sole responsibility.