PRIVACY POLICY
Last update : February 2023
This privacy policy (hereinafter the “Privacy Policy“) details how Bal du Moulin Rouge S.A., a public limited company with capital of 4,515 676.00 euros, registered with the Trade and Companies Register of Paris under the number B 552 046 120, having its registered office at 82 Boulevard de Clichy in 75018 Paris France (hereinafter “Moulin Rouge“), collects and processes the personal data of the users (hereinafter the “Users”) who visit or use the features and services offered on either of the Moulin Rouge’s websites accessible at the URLs www.moulinrouge.fr and www.store.moulinrouge.fr (hereinafter the “Websites“).
The person in charge of the questions regarding the personal data protection of Moulin Rouge can be reached at the following address information@moulinrouge.fr.
Constitutes a personal data any information related to the User, as identified individual or who could be identified, directly or indirectly, by reference to an identification number or to one or several elements of its own (notably its name, surname, date of birth, postal address, email address, photo, curriculum vitae, hereinafter referred to as “Personal Data”).
The Privacy Policy covers all the processing carried out by Moulin Rouge and forms an integral part of the , and which the User must read and accept, if applicable.
Moulin Rouge encourages the Users to carefully read the terms and conditions of the Privacy Policy before using any of the Websites and before disclosing any of their Personal Data.
The Privacy Policy is accessible to Users at any time, on the Websites, except during maintenance periods, by clicking the link labelled “Privacy Policy” at the bottom of the web pages of the Websites.
To the extent permitted by law, if there is any contradiction between the French version of the Privacy Policy and the English translation, the original French version shall prevail.
1. Ethics
Moulin Rouge and, where applicable, its subsidiaries and affiliates, protect the privacy of Users by complying with the laws in force.
To this end, Moulin Rouge and, where applicable, its subsidiaries and affiliates, collect and process the Personal Data concerning the Users in accordance with the national and European laws in force and notably the Regulation (EU) 2016/679 of the General Data Protection Regulation (hereinafter “GDPR”).
All Personal Data is processed with due care and confidentiality.
The Privacy Policy details how Moulin Rouge and, where applicable, its subsidiaries and affiliates, use the Personal Data and inform Users of the measures taken by Moulin Rouge to ensure the protection of Personal Data, in accordance with the provisions of the French Data Protection Act (Loi Informatique et Libertés) of 6th January 1978 as amended (hereinafter the “French Data Protection Act“) and in accordance with provisions of the GDPR.
2. Collection of Personal Data
2.1 To view and visit the Websites, the User does not have, in principle, to provide any of his or her Personal Data.
Moulin Rouge is only likely to collect Personal Data from Users through the tabs “CHECK OUT OUR OFFERS”, “SUBSCRIBE TO THE NEWSLETTER”, “RECRUITMENT & CASTING”, or “WITHDRAWAL FORM” in order to ensure proper monitoring of the requests made by the User.
2.2 Any User wishing to subscribe to the newsletter, open an account, place an order or make a reservation through the Websites must complete a detailed application form, give information about their identity, provide a valid e-mail address, and confirm their consent to the General Terms and Conditions of Use (GTCU) and to the General Terms and Conditions of Sale applicable (GTCS) as well as to this Privacy Policy.
2.3 Any User wishing to apply, as an artist or else, must complete a detailed application form, give information about their identity, provide a valid e-mail address, and confirm their consent to this Privacy Policy.
In support of their application and to demonstrate their artistic talent, if he or she wishes, the User may also upload photographs and a link to a media of their choice so as to illustrate their skills (e.g. presentation of resume on LinkedIn, performance art videos on YouTube, etc.).
2.4 When gathering Personal Data, the User expressly agrees to provide only information that is complete, accurate and up to date, and not detrimental to the interests or the rights of third parties.
The information required in order to carry out the tasks described above is indicated by an asterisk in the different pages of the Websites concerned. The other information is optional.
3. Purpose and legal basis of the processing of Personal Data
The processing of Personal Data carried out by Moulin Rouge has for legal basis the execution of the contract and the precontractual measures or the consent of the Users.
Moulin Rouge processes Personal Data particularly in order to:
– send the User information related to the activities of Moulin Rouge;
– manage the Users’ profiles and orders through the accounts;
– manage the reservation and ticketing services;
– carry out operations related to promoting the activities of Moulin Rouge, including commercial prospecting and the management of technical prospecting operations (which includes, in particular, technical operations such as standardization, enrichment and data deduplication) in compliance with the laws in force;
– manage requests from Users and develop the statistics needed to improve the Websites;
– organize contests, lotteries or any promotional activity;
– carry out recruitments and manage the applications;
– manage requests for the right to rectification, opposition, deletion, portability and limitation of treatment in accordance with the General Terms and Conditions.
4. Recipients of the Personal Data
Moulin Rouge is responsible for the processing of the Personal Data of Users as listed here above.
ATHYS, a limited liability company with capital of €7,622.45, registered with the Trade and Companies Register of Paris under the number RCS 410 723 886, having its registered office at 82 Boulevard de Clichy – 75018 Paris, as a subsidiary of Moulin Rouge, is the recipient and sole party responsible for processing the Personal Data of Users wishing to apply as an artist or dancer.
Within the limits of their respective duties, the following parties may have access to all or part of the Personal Data:
– the teams in charge of developing the Websites, and promoting the commercial products and services of Moulin Rouge;
– the teams in charge of auditing (auditor, teams responsible for internal audit procedures…);
– the subsidiaries and affiliates of Moulin Rouge in charge of managing all or part of the services offered by the Websites, including recruitment activities;
– the subcontractors in charge of providing the technical services related to the administration, maintenance and hosting of the Websites, in compliance the national and European provisions applicable regarding the personal data protection;
– the subcontractors in charge of ensuring the secure online payment services, in compliance with the provisions of the national and European provisions applicable regarding the personal data protection;
– organizations, court officials and ministerial officers.
5. Storage and security of the Personal Data
The Personal Data is generally stored for as long as it is strictly necessary for managing the relationship between Moulin Rouge and the Users. The durations of the Personal Data retention depend on the purposes for which the data is collected and processed.
The Personal Data is stored by Moulin Rouge throughout the effective period of use of the Websites by the User and, where applicable, for a maximum period of 3 years from the User’s last login to his or her account.
At the end of this 3-year period, Moulin Rouge may contact the User again to see if he or she wants to keep his or her account and continue to receive information related to the activities of Moulin Rouge. In the absence of an explicit and positive response from the User, his or her Personal Data will be deleted or anonymized according to the provisions in force.
Personal Data which enables establishing proof of a purchase or reservation may, however, be archived in accordance with the provisions in force (in particular that provided under the Commercial Code, the Civil Code and the Consumer Code).
Personal Data relating to recruitment activities (tabs “CHECK OUT OUR OFFERS”, “SUBSCRIBE TO THE NEWSLETTER”, “RECRUITMENT AND CASTING”, or “WITHDRAWAL FORM”) is stored for a period of 5 years from the last contact with the candidate.
All processing operations that may be initiated by Moulin Rouge is summarized in the table hereafter:
Processing operations of personal data table
Purposes
Collected data and collection method :
- Civility, email address, date of birth, country on https://www.moulinrouge.fr/en/homepage/
- Civility, email address, date of birth, country on https://store.moulinrouge.fr/?___from_store=default&___store=en
Collection made by the means of forms on the official websites of Moulin Rouge
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Consent of the persons concerned formalized by the sending of the registration and by the acceptance of the GTCU and the privacy policy.
Duration of retention :
Three (3) years from the moment of their collection or last incoming contact.
Recipients :
– Marketing service of Bal du Moulin Rouge
– The data processor in charge of the processing of registrations and sending of newsletters.
Collected data and collection method :
– Conversations content between the client / visitor of the website moulinrouge.fr and the reservations agent processing the request
– IP address of the client/visitor, civil status, identity, number of conversations, answers to the satisfaction survey
Collection processed on the chatbot available on the pages of the website www.moulinrouge.fr
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Consent of the persons concerned.
Duration of retention :
– Three (3) years from the moment of their collection or the last contact.
– Video/call/sms: Twelve (12) months into an active base.
– Semi-current archives: five years
– Other data (number of consulted pages, date and hour of the session, navigator language, ID of the website, duration of the navigation, etc) one (1) day by the data processor, or twelve (12) months for the visits’ number on the website or the unique ID of the client/visitor.
Recipients :
– Strategic Marketing service
– Reservation service
The data processor delivering the chatbot service (iAdvize)
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-dancers/
Data controller :
Athys
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
– The artistic direction service
– The human resources service of the company Athys (company in charge of the recruitment of the dancers)
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment/casting-acts/
Data controller :
Athys
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
– The artistic direction service
– The human resources service of the company Athys (company in charge of the recruitment of the dancers)
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-dressers/
Data controller :
Stentor
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Stentor
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-technical-services/
Data controller :
Stentor
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Stentor
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-restaurant/
Data controller :
Blanche 3
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Blanche 3
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-cuisine/
Data controller :
Blanche 3
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Blanche 3
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-maisons-dart/
Data controller :
Maison Clairvoy/Maison Février/Atelier Valentin/Blanche 5
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Maison Clairvoy/Maison Février/Atelier Valentin/Blanche 5
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-corporate-functions/
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Bal du Moulin Rouge
Collected data and collection method :
Civility, last name, first name, email address, phone number, photos and/or videos provided by the applicant
Collection made by the means of a form on the website https://www.moulinrouge.fr/en/recruitment-internships-apprenticeships/
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Consent of the User formalized by the application and the acceptance of the privacy policy and the GTCU
Duration of retention :
Necessary duration of the processing of the application and for five (5) years from the last incoming contact.
Recipients :
The human resources service of the company Bal du Moulin Rouge
Collected data and collection method :
Creation of an account during checkout process: Last name, first name, email address, address, phone number, password, city, region, zip code, country store.moulinrouge.fr
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Consent formalized by the acceptance of the GTCU, the GTCS and the privacy policy.
Duration of retention :
Three (3) years from their collection or the last contact.
Recipients :
The data processor managing the back office of the website www.store.moulinrouge.fr
Collected data and collection method :
- Last name, surname, email address, postal address, phone number
- Data regarding the transaction, the follow-up of the commercial relationship, etc…
Collection processed during the order on www.store.moulinrouge.fr and via the withdrawal form available on www.store.moulinrouge.fr
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Implementation of the contract
Duration of retention :
Ten (10) years, as financial records and supporting documents
Recipients :
- Strategic Marketing service
- The data processor managing the orders (payment platform)
- The data processor managing the back office of the website store.moulinrouge.fr
- Logistics officer
Collected data and collection method :
– Civility, last name, first name, company, postal address, email address, phone number
– Data related to the transaction
Collection made by the means of forms on https://reservations.moulinrouge.fr/en
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
Implementation of the contract
Duration of retention :
Ten (10) years, as financial records and supporting documents
Recipients :
– Reservation service
– IT service
Collected data and collection method :
Data stored in the terminal of the Users (the Cookies for instance) or any other element used to identify the Users and track the Users (web analytic tool).
Collection processed on the official websites of the Moulin Rouge through the cookies
Data controller :
Bal du Moulin Rouge
Legal basis of the processing :
User’s consent formalized by the acceptance of cookies via a banner
Duration of retention :
By default, twenty-four (24) months on the web analytic tool from the moment of collection of the consent.
Recipients :
– Strategic Marketing service
– Google Inc.
– The data processor managing the web analytic tool
5.2 Security measures
Moulin Rouge, and, where applicable, all of its subsidiaries and affiliates, undertakes to provide all appropriate measures to ensure the confidentiality and security of the Personal Data, and to protect it against any loss, misuse, unauthorized disclosure, alteration or destruction.
The computer systems used for the storing of Personal Data are equipped with a software protection system. Physical and electronic procedures are implemented for backing up the data collected from the Websites, in accordance with the French and European laws in force on the protection of Personal Data.
The employees of Moulin Rouge, and, where applicable, subsidiaries and affiliates, who, because of their position, have access to the Personal Data, undertake to maintain the utmost confidentiality in this respect.
The personal account of each User can only be accessed by using the login ID, such that only the User has access to the Personal Data contained in his or her profile. Moulin Rouge reminds the User that these logins IDs are personal and confidential, and that the User is solely responsible for their use and their disclosure to third parties.
For all practical purposes, Moulin Rouge recommends that the User log out of his or her account and close the browser window after finishing his or her session on the Websites.
Moulin Rouge has entrusted its payment system to a company specialized in secure online payments, which guarantees total confidentiality of the User’s bank information, secured by SSL protocol which systematically controls the validity of access rights when the User pays by credit card and encrypts all transactions in order to guarantee their confidentiality.
6. Rights of Users
In accordance with the regulations in force, the Users shall at all times have the right to access, rectify, delete or oppose personal data concerning them and limit the processing of their personal data.
The Users have the right to request for the deletion of their personal data collected when the User was underaged at the moment of the collection.
The Users have the right to withdraw their consent at any time for parts of the processing made by Moulin Rouge based on this consent.
The Users have the opportunity to ask for the transfer of all their Personal Data in a structured format in which case they would wish to transfer them to another data controller.
The Users can, at any time, define, modify and revoke directives related to the retention, the deletion and the communication of their Personal Data concerning them after their death (art.85-Loi n°78-17 of January 6th 1978).
The Users are informed that Moulin Rouge does not use an automated processing for Personal Data, including the profiling, neither to the transfer of their Personal Data outside of the European Union territory.
To exercise this right and to obtain communication of the information, the User must simply send a request for such information to Moulin Rouge providing by email the information necessary to formally identify said User, including name, address and email address, to the following address:
information@moulinrouge.fr or by ordinary mail to Bal du Moulin Rouge, Service RGPD, 82 Boulevard de Clichy, 75018 Paris, France, specifying the data controller in accordance with the table of personal data processing (article 5.1 above).
WARNING: due to material and technical constraints, the processing times for requests from Users will inevitably be increased if the request is made by mail.
Users may also file a complaint with the Commission Nationale Informatique et Libertés (www.cnil.fr ).
Moulin Rouge does not does not carry out telephone solicitation. Nevertheless, the Customer has the right to register on the free telephone anti-solicitation list known as “BLOCTEL”, which can be accessed at the following address: https://www.bloctel.gouv.fr.
7. Cookies policy
As part of the operation of the websites https://www.moulinrouge.fr/ and https://store.moulinrouge.fr (hereinafter the “Websites“), Moulin Rouge may be required to install cookies or other tracers on the User’s terminal. At the time of first visit on any of the Websites, the User is informed of the Privacy Policy and must consent to the installation of different cookies.
7.1 What is a cookie?
A cookie is a text file or tracer that allows us to identify and recognize your device during your next visits and to provide you with better navigation. These may be cookies that do not allow the User to be identified but record a certain amount of information necessary for the User to navigate on the Websites (navigation language, date and time of consultation, pages consulted, etc.) or Google Analytics cookies that allow the User to be identified (geographical information through the IP address).
7.2 What cookies do we use?
Strictly necessary cookies: These cookies allow the Websites to function optimally, mainly in order to save the current status of your navigation. These cookies cannot be deactivated.
Functional cookies: These cookies improve the experience of the User on the Website.
Statistical cookies: These cookies are installed by Google Analytics. These cookies are used to store information about how visitors use the Website and to generate an analytical report on how the website functions. The data collected includes the number of visitors, the source from which they accessed the Website and the pages visited in an anonymous form.
Advertising cookies: These cookies are installed to present you with advertisements or to send you information based in your interests on our websites or outside of our websites during your web browsing.
7.3 How to oppose these cookies?
Moulin Rouge informs the User that he or she can also at any time oppose the registration of technical cookies on the hard drive of his or her computer by properly configuring his or her internet browser. If so, the use of the Website may be degraded or even impossible.
For any information on how to configure web browsers, the User can consult the help menu of his or her browser, especially, for the most frequently used browsers, from the following links:
- for Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies ;
- for Safari: http://www.apple.com/legal/privacy/fr-ww/cookies/
- for Chrome: https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en;
- for Firefox :
http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies ;
- for Opera: http://help.opera.com/Windows/10.20/fr/cookies.html
7.4 Social networks
Moulin Rouge offers the possibility for the User to consult its pages on social networks through buttons (Facebook, X, Pinterest, Instagram and Tik-Tok). On this occasion, the social network plug-ins made available on the Websites use cookies that allow tracking the browsing of Users, regardless of whether they are registered with the social networks in question or whether they are connected to their personal account when browsing the Website. The implemented cookies also allow the publishers of the various social networks to target advertising offers on their respective platforms.
In this context, Moulin Rouge has no control over the processing of Personal Data possibly operated by the publishers of the various social network platforms concerned, which remain solely responsible for their own processing, except for processing resulting from specific settings made by Moulin Rouge on these social network platforms, where appropriate, for which Moulin Rouge is co-responsible for processing.
Moulin Rouge therefore invites the User to consult beforehand the general conditions of use and the respective privacy policies of these social network platform publishers if they wish to use the share buttons made available to them.
7.5 Audiences in Google Analytics
The audience measurement tool Google Analytics allows a better understanding of User behavior by collecting anonymous information and generating reports on Website usage statistics.
In particular, Moulin Rouge has activated a Google Analytics feature allowing to obtain reports on the demographics and interests of Users, in order to propose a commercial offer adapted and responding to the identified needs of its customers.
The processing of data generated by Google Analytics cookies may involve the transfer and storage (including temporary storage) of this data on Google Inc. servers located in the United States. In this context, Moulin Rouge has no control over the processing carried out and invites the User to consult the general conditions of use and the privacy policy of Google Inc. beforehand.
In the event that the User opts out of having data collected via the Google Analytics tool, the User may opt out of Google Analytics advertising features, including via the ad settings, mobile ad settings or any other available means (for example, via the Network Advertising Initiative or NAI opt-out page).
The User also has the possibility to download and install the add-on module for the deactivation of all Google Analytics functionalities made available to the public by the company Google Inc. at the following url address: https://support.google.com/analytics/answer/181881?hl=fr.
8. Revision of the Privacy Policy
Moulin Rouge may revise its Privacy Policy in response to changes in the laws in force as well as changes in its business.
Users will be notified, within a reasonable time, of any substantial change to the Privacy Policy, prior to the entry into force of such new terms.