Presentation of the Website

The website of Whispering Dunes is the exclusive property of the Monegasque Anonymous Company (SAM) GIRAUDI GROUP SERVICES, with a share capital of 150,000.00 Euros, whose registered office is located at 74 Boulevard d’Italie, 98000 Monaco, registered in the Monaco Commerce and Industry Registry under the number 17S07591.

For any inquiries, please contact the Marketing Department at Phone: +377 93 10 42 42 Email address: web @giraudi.com. Legal representative of Giraudi Group: Riccardo Giraudi, Chairman and Managing Director Data controller: Giraudi Group Services S.A.M, Le Monte Carlo Sun, 74 Boulevard d’Italie, Block E/F, 98000 Monaco. The website is hosted by OVH, with its registered office at 2 rue Kellermann, 59100 Roubaix, France. Terms and Conditions of Website Use

The use of the website implies full acceptance by the user of the following terms and conditions. These conditions may be modified or supplemented at any time by GIRAUDI GROUP SERVICES SAM. Users of the website are encouraged to regularly review these general terms.

Intellectual Property and Counterfeiting GIRAUDI GROUP SERVICES SAM holds exclusive rights to intellectual property and elements accessible on the website, including text, images, trademarks, logos, icons, and software.

Limitations of Liability

GIRAUDI GROUP SERVICES SAM provides no warranties, implied or explicit, regarding the operation and/or content of the website and shall not be held responsible for direct or indirect damages, whether commercial or not, resulting from the use of the website.

Furthermore, GIRAUDI GROUP SERVICES SAM does not guarantee the continuity, access, and availability of the website’s operation and related services. Additionally, it disclaims all responsibility for viruses that may be imported when downloading any elements from the website or from sites linked via hyperlinks.

Collection and Processing of Personal Data – Right of Access

All personal data collected by the “Whispering Dunes” website may be subject to automated processing and are intended for internal use within the Giraudi Group only. This data is never transferred to third parties. The website user provides their personal information knowingly, especially when they enter it themselves. The user is then informed of the obligation or not to provide this information.

In accordance with Law No. 1.165 of December 23, 1993, relating to the protection of personal information, the website user has the right of access, rectification, opposition, and deletion of personal information concerning them.

Email address: data @giraudi.com

Hyperlinks and Cookies

The website may offer links to other websites or other resources available on the internet, set up with the authorization of GIRAUDI GROUP SERVICES SAM.

However, GIRAUDI GROUP SERVICES SAM is not responsible for the availability of such external sites and sources, nor does it guarantee them and cannot be held responsible for any damage of any kind resulting from the content of these external sites or sources, including information, products, or services they offer, or any use that may be made of these elements.

The risks associated with this use are solely the responsibility of the website user, who must comply with their terms of use.

Furthermore, browsing the website may result in the installation of cookies on the user’s computer. GIRAUDI GROUP SERVICES SAM takes care to inform the website user of the purpose of cookies, obtain their consent, and provide a means to reject them.

Any website user can object to the storage of cookies by configuring their browser. However, refusing to install cookies may make it impossible to access certain services offered on the website.

Applicable Law and Jurisdiction

Any dispute related to the use of the website is subject to Monegasque law. Exclusive jurisdiction is granted to the competent courts of the Principality of Monaco.

The company GIRAUDI GROUP SERVICES S.A.M, with its registered office located at 74 Boulevard d’Italie, 98000 Monaco, has committed to protecting your Personal Data. GIRAUDI GROUP SERVICES SAM is dedicated to complying with all obligations created by the law n° 1.165 of December 23, 1993, as amended, concerning the protection of personal data. In fact, the Principality of Monaco has adhered to the Council of Europe’s Convention 108 on the protection of individuals with regard to the automated processing of personal data, dated January 28, 1981, as well as its additional protocol concerning supervisory authorities and cross-border data flows, which entered into force on April 1, 2009.

Monaco has had legislation on the protection of personal data since 1993, with law n° 1.165 of December 23, 1993, regulating the processing of personal data, significantly revised by law n° 1.353 of December 6, 2008, which came into effect on April 1, 2009, and is now titled “law on the protection of personal data.”

GIRAUDI GROUP SERVICES SAM has already incorporated certain elements of the new European regulation on the protection of personal data, which came into effect on May 25, 2018 (GDPR).

This Policy reflects our commitment to transparency and loyalty to our customers.

Here you will find all the necessary information to understand how GIRAUDI GROUP SERVICES SAM collects, processes, and protects your data when using its services on the website giraudi.com (the “Site”) to present the activities of Giraudi Group.

 

(1) Who is your point of contact within GIRAUDI GROUP SERVICES SAM for any questions about your Personal Data?

GIRAUDI GROUP SERVICES SAM attaches great importance to respecting your rights and freedoms and protecting your data. To do this, GIRAUDI GROUP SERVICES SAM has internally designated a Data Protection Officer responsible for questions regarding personal data protection.

For any questions related to your data by GIRAUDI GROUP SERVICES SAM, you can contact the Data Protection Officer via email: web @giraudi.com.

 

(2) Why does GIRAUDI GROUP SERVICES SAM collect your data?

GIRAUDI GROUP SERVICES SAM uses your data to respond to your commercial requests or information inquiries.

 

(3) What data is involved?

The data you provide to GIRAUDI GROUP SERVICES SAM: GIRAUDI GROUP SERVICES SAM collects all the information you provide on the Site (e.g., when using the contact form).

GIRAUDI GROUP SERVICES SAM collects, in particular, your name, first name, address, phone number, and email address.

Subject to your explicit consent, if you have checked the appropriate box on the data collection form or any other contractual document involving data collection and processing, GIRAUDI GROUP SERVICES SAM uses your data to send you information about its product and service offers and news.

If you have enabled geolocation on your phone, tablet, or computer, GIRAUDI GROUP SERVICES SAM, subject to your rights, may highlight services or offer you location-based deals.

Furthermore, we reserve the right to use generic information about visitor profiles on our Site without indicating personal data, using suitable anonymization methods.

We may also collect statistical information to understand how visitors use the Site (frequency of page visits, sales statistics, and the origin of Site visitors, etc.).

Information about visitor profiles is retained by GIRAUDI GROUP SERVICES SAM and will only be used internally for market research.

Through GIRAUDI GROUP SERVICES SAM, visitors who have explicitly given their prior consent may receive commercial emails regarding products or services provided by GIRAUDI GROUP SERVICES SAM.

GIRAUDI GROUP SERVICES SAM does not collect:

• any health data, considered sensitive under the Informatique et Libertés law and the GDPR.

Data is also collected during your Site browsing to allow the Site to recognize your connection device and access the Site’s features. GIRAUDI GROUP SERVICES SAM uses “cookies” related to your experience, your preferences, especially to provide you with a personalized experience and improve its services. To learn more, you can consult our Cookie Policy below.

 

(4) Who can access your data?

The delegated services of GIRAUDI GROUP SERVICES SAM are authorized to process your data to respond to your requests and ensure the proper functioning of the services offered on the Site.

 

(5) Where is your data stored?

In principle, your data is stored in Monaco and with the host NAMEBAY, with its registered office at 30 Boulevard Princesse Charlotte, 98000 Monaco. None of the data processed and collected by GIRAUDI GROUP SERVICES SAM is transferred to a third country outside the European Union or a country that the European Commission does not consider to provide an adequate level of protection.

 

(6) How long does GIRAUDI GROUP SERVICES SAM retain your data?

In accordance with the law on personal data and the GDPR, GIRAUDI GROUP SERVICES SAM limits the retention of your data to a period not exceeding the time required for the purposes for which they are processed.

For example, in accordance with the recommendations of the CCIN, your contact information may be retained for up to 5 years after the end of the contractual relationship.

 

(7) What are your rights regarding your data, and how can you exercise them with GIRAUDI GROUP SERVICES SAM?

Subject to the limitations and reservations imposed by law, you have rights regarding data (Articles 15 to 20 of the GDPR). These rights include:

the right to confirm that your data is being processed by GIRAUDI GROUP SERVICES SAM and the methods of processing this data. the right to access your data. the right to rectify data that is inaccurate or incomplete. the right to request the deletion of data that no longer needs to be retained. the right to limit the processing of your data if your data is used. the right to be notified of updates to your data. the right to object, for a legitimate reason, to the processing of your data, or to direct marketing. To exercise these rights, you must prove your identity and make the request by email to web @giraudi.com.

 

(8) GIRAUDI GROUP SERVICES SAM protects your data

In accordance with the law on personal data and the GDPR, considering the state of knowledge, implementation costs, and the nature, scope, context, and purposes of the processing carried out, as well as the risks to your rights and freedoms, GIRAUDI GROUP SERVICES SAM implements appropriate technical and organizational measures to ensure a level of security adapted to the risk and to prevent, in particular, destruction, loss, alteration, unauthorized disclosure, or unauthorized access to your data.

GIRAUDI GROUP SERVICES SAM has made every effort to put in place all necessary precautions to preserve the confidentiality and security of the personal data processed and prevent them from being distorted, damaged, destroyed, or accessed by unauthorized third parties. Security measures, in line with the state of the art, particularly regarding information systems, have been put in place. However, the company does not control all risks associated with the operation of the Internet and draws visitors’ attention to the possible risks inherent in its use and operation.

 

(9) The Commission for the Control of Personal Data (“CCIN”)

GIRAUDI GROUP SERVICES SAM has completed the preliminary formalities required by the law on personal data with the CCIN.

GIRAUDI GROUP SERVICES SAM reminds you that you can contact the CCIN directly through their website at https://www.ccin.mc/fr/ or by mail at the following address: 12 Avenue de Fontvieille, 98000 Monaco.