PERSONAL DATA PROTECTION CHARTER
1. What is the purpose of this charter?
The purpose of this charter (the “Charter”) is to inform internet users (“You”, “Your”) about how their Personal Data (as defined below) is processed by SILVER RESORTS (“SILVER RESORTS” or “We”), in connection with Your use of the website / (respectively the “Site” and the “Processing”).
For the purposes hereof, the term “Personal Data” means any information relating to an identified or identifiable natural person. A natural person is deemed to be identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
We invite You to read the Charter carefully before continuing Your browsing on the Site.
2. Data Controller: SILVER RESORTS
SILVER RESORTS, a simplified joint-stock company with a sole shareholder, with share capital of €15,000 registered under no. 979 724 457 00010 R.C.S PARIS, with registered office at 30/32 boulevard Sébastopol, 75004 Paris, reachable at +33 9 70 70 30 20 – email: contact@ehpad-tunisie.com, determines the purposes and means of the Processing and consequently acts as data controller. The representative of SILVER RESORTS is Mr Farès Bouslama, as President.
When carrying out the Processing, SILVER RESORTS undertakes to comply with the “Regulations”, namely all legal provisions applicable to the protection of personal data, in particular (i) Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (ii) Directive 2002/58/EC of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, and (iii) French legal and regulatory provisions, including Law No. 78-17 of 6 January 1978 as amended.
3. How does SILVER RESORTS collect Your Personal Data in the context of the Processing?
SILVER RESORTS collects Your Personal Data when (i) You browse the Site and (ii) You fill in the various accessible forms, namely the “Contact” form and the “Receive our brochures” form.
4. What Personal Data is collected for the Processing?
In the context of the processing of online forms, the Personal Data processed are Your identity data (surname, first name), Your personal email address, Your telephone number and any information You wish to communicate to us. In this context, You agree not to communicate any health data to SILVER RESORTS, as defined by the Regulations[1].
Regarding the cookies used on the Site, these process Your connection data, Your preferences recorded during previous connections (authentication, choice trackers and interface customisation, data allowing audience measurement by SILVER RESORTS, Your terminal information).
We invite You to regularly update Your data by informing Us in writing of any modification by referring to the dedicated section “What are Your rights and how to exercise them?“.
5. Purposes, legal bases and retention periods of Personal Data
SILVER RESORTS processes Your Personal Data within the limit strictly necessary to accomplish the purposes pursued, on the basis of the legal grounds and for the durations detailed below:
| Purposes | Legal grounds | Retention period |
|---|---|---|
| Operation of the Site | Our legitimate interest in ensuring the proper functioning of the Site | 1 year and 2 months from the date of Your last consultation of the Site |
| Operation of the Site (personalised features/services, analysis of connection data) | Our legitimate interest in offering You personalised services. Some cookies may require the collection of Your consent via the information banner appearing during Your connection to the Site | 1 year and 2 months from the date of Your last consultation of the Site |
| Processing of “Contact” and “Receive our brochures” forms | Our legitimate interest in developing our clientele | Three (3) years from the date of submission of the form concerned |
| Compliance with Our legal obligations | Compliance with Our legal obligations | The duration necessary for the extinction of the legal obligation concerned |
SILVER RESORTS will only use Your Personal Data for the aforementioned purposes.
The provision of Your Personal Data is mandatory and necessary to enable SILVER RESORTS to accomplish the aforementioned purposes; failing this, You will not be able to use the Site under normal conditions, or the Site will not be able to offer You a maximum experience, nor will You be able to benefit from the information requested via the forms.
Focus on cookies
| Cookie | Functionalities | Characteristics |
|---|---|---|
lang-pref | Remember Your language preference (FR/EN/DE/IT/ES) selected via the language selector. Duration: 1 year. | Necessary |
cgu-accepted (local storage) | Remember Your acceptance of the Terms and this Charter so that the window is not displayed again on subsequent visits. | Necessary |
cookie-consent (local storage) | Remember Your choice (accept/reject) regarding audience measurement cookies in order to respect Your preferences during subsequent visits to the Site. | Necessary |
_ga | Distinguish Site users in order to calculate data relating to visitors, sessions and campaigns for the Site analytics report. Duration: 2 years. Deposited only after Your explicit consent. | Analytics |
_ga_D0W97HGCF8 | Maintain the state of the visit session and calculate audience statistics (Google Analytics 4). Duration: 2 years. Deposited only after Your explicit consent. | Analytics |
You can reset Your choices at any time by clearing the cookies and local storage of the Site from Your browser.
The Site also uses two internal audience measurement tools without cookies or persistent identifiers, self-hosted on SILVER RESORTS infrastructure and operated without transmission to a third party: Matomo (configured with disableCookies, IP address anonymisation and compliance with the Do Not Track signal) and Umami (cookieless by design). These tools comply with CNIL deliberation No. 2020-091 and benefit from the consent exemption as such.
6. Who are the recipients of Your Personal Data?
SILVER RESORTS only shares Your Personal Data with the following persons, who need to have access to it for the purpose of carrying out the aforementioned purposes and the tasks entrusted to them. The recipients of Your Personal Data are therefore:
- Internal recipients: SILVER RESORTS personnel in charge of the “Customer/Sales” and “IT” services;
- External recipients: SILVER RESORTS subcontractors, in particular the subcontractor in charge of the IT system (data hosting), the owners and managers of the residences/retirement homes, namely:
- Cloudflare, Inc. (San Francisco, United States) — Site hosting and execution of server functions (CDN, application firewall);
- Google LLC (Mountain View, United States) — audience measurement via Google Analytics 4, only after Your consent (cookies
_ga,_ga_D0W97HGCF8); - Resend, Inc. (San Francisco, United States) — transactional email sending service to notify You of the proper receipt of Your requests;
- the owners and managers of the partner residences / retirement homes.
SILVER RESORTS ensures that these recipients are required to implement appropriate security measures in order to comply with the Charter and are in no way authorised to process Your Personal Data for purposes other than those provided for in Article 5.
7. Are there transfers of Your Personal Data outside the European Union?
The Personal Data relating to the processing of the “Contact” and “Receive our brochures” forms is transferred to countries located outside the European Union (EU), in particular Tunisia and Morocco. These transfers are governed by measures ensuring a level of protection equivalent to the Regulations, in particular the standard contractual clauses adopted on 4 June 2021 by the European Commission.
8. What are the security measures?
SILVER RESORTS implements technical and organisational measures to protect Your Personal Data against accidental or unauthorised destruction, alteration, loss or disclosure.
9. What are Your rights and how to exercise them?
With regard to the Processing, You have the following rights:
- to be informed: You have the right to be informed of the Personal Data that SILVER RESORTS holds about You, as well as the Processing. This is precisely the purpose of the Charter;
- access: You have a right of access to all the Personal Data concerning You that SILVER RESORTS holds. You can exercise it by sending a simple request to SILVER RESORTS at the address provided below;
- rectify: In the event that You consider this Personal Data to be incomplete or erroneous, You may ask SILVER RESORTS to rectify it, which SILVER RESORTS will do as soon as possible;
- restrict: In certain cases listed in Article 18 of the GDPR, You may ask SILVER RESORTS to restrict the Processing of Your Personal Data;
- transfer: You have the right to the portability of Your Personal Data and You may require its transfer to the recipient of Your choice;
- erase: You may request from SILVER RESORTS the erasure of Your Personal Data (“right to be forgotten”);
- lodge a complaint: You always have the right to lodge a complaint with the French Data Protection Authority (CNIL);
- object: You sometimes have the possibility to object to the Processing: SILVER RESORTS will put an end to the Processing unless it is legally obliged to continue it or in case of legitimate and compelling reasons justifying the Processing;
- set directives after Your death: these directives, revocable at any time, may relate to the retention, erasure, communication of Your Personal Data by designating a person in charge of their execution:
- when it comes to general directives, You may transmit them to a trusted digital third party certified by the CNIL;
- when it comes to specific directives, You may transmit them directly to SILVER RESORTS;
If You wish to exercise all or part of Your rights or obtain additional information, You may send a request to SILVER RESORTS at any time, accompanied by a copy of proof of Your identity, which will allow Us to verify Your identity:
- by email to: contact@ehpad-tunisie.com
- by post to: 30/32 boulevard Sébastopol, 75004 Paris
10. Modification of the Charter
The Charter may at any time be subject to modifications and updates, which will be sent to You by SILVER RESORTS by any means it deems appropriate.
We recommend that You always take note of the most recent version of the Charter before using the Site and/or interacting with Us.
[1] Data relating to the past, present or future physical or mental health of a natural person (including the provision of healthcare services) which reveals information about that person’s state of health. For example, information concerning an illness or certain data from which information about a person’s state of health can be deduced.
Last updated on 14/05/2026.