Data Destruction Policy

At Hedonist, we are committed to protecting your personal data and respecting your privacy rights. This Data Destruction Policy outlines our procedures for data retention and secure deletion of personal information in compliance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

1. Purpose and Scope

This policy establishes guidelines for:

• How long we retain personal data
• When and how we securely delete or anonymize data
• Your right to request data deletion
• Our procedures for handling data destruction requests

2. Data Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Our retention periods are as follows:

3. Right to Erasure (Right to be Forgotten)

Under GDPR, you have the right to request the deletion of your personal data in certain circumstances. We will delete your data if:

• The data is no longer necessary for the original purpose
• You withdraw your consent and there is no other legal basis for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed
• Deletion is required to comply with a legal obligation

Note: We may be required to retain certain data for legal, accounting, or regulatory purposes even after you request deletion.

4. Exceptions to Data Deletion

We may be unable to delete your personal data in the following circumstances:

• Legal Obligations: When we are required to retain data by law (e.g., tax records, financial transactions)
• Ongoing Legal Proceedings: When data is relevant to current or potential legal disputes
• Legitimate Business Interests: When retention is necessary for legitimate business purposes (e.g., fraud prevention)
• Public Interest: When retention serves important public interests
• Anonymized Data: Data that has been fully anonymized and cannot be linked back to you

5. Data Destruction Methods

When we delete your personal data, we use secure methods to ensure it cannot be recovered or reconstructed:

5.1 Electronic Data

• Database Records: Permanent deletion from our databases using secure deletion methods
• Backup Systems: Deletion from all backup systems and archives
• Cloud Storage: Secure deletion from cloud storage providers
• Email Systems: Permanent deletion from email servers and archives
• Log Files: Removal from server logs and analytics systems

5.2 Physical Records

• Secure shredding of paper documents
• Destruction of storage media (hard drives, USB drives, etc.) using certified methods

5.3 Third-Party Services

We ensure that any third-party service providers who process your data also delete it in accordance with our instructions and applicable laws.

6. Requesting Data Deletion

To request the deletion of your personal data, please:

1. Send a written request to hello@hedonist.house with the subject line "Data Deletion Request"
2. Include your full name, email address, and any booking reference numbers
3. Specify which data you want deleted (or request deletion of all your data)
4. Provide proof of identity to verify your request

We will respond to your request within 30 days. If your request is complex or we receive multiple requests, we may extend this period by up to 60 additional days, and we will inform you of the extension.

7. Data Anonymization

In some cases, instead of complete deletion, we may anonymize your data. Anonymized data:

• Cannot be linked back to you as an individual
• May be retained for statistical, research, or analytical purposes
• Is no longer considered personal data under GDPR

We may anonymize data when complete deletion would prevent us from maintaining important business records or analytics.

8. Automated Deletion

We have implemented automated systems to delete data that has exceeded its retention period:

• Regular automated reviews of data retention periods
• Automated deletion of expired data where legally permitted
• System alerts for data approaching retention limits

9. Data Destruction Records

We maintain records of data destruction activities, including:

• Date of deletion
• Type of data deleted
• Method of destruction
• Reason for deletion

These records help us demonstrate compliance with data protection regulations and assist with audits.

10. Third-Party Data Sharing

If we have shared your data with third parties (e.g., property owners, payment processors, service providers), we will:

• Notify them of your deletion request
• Request that they delete your data in accordance with our instructions
• Verify that deletion has been completed

11. Impact of Data Deletion

Please be aware that deleting your personal data may:

• Prevent you from accessing certain services or features
• Require you to re-register if you wish to use our services again
• Result in the loss of booking history and preferences
• Affect our ability to provide personalized services

We will inform you of any potential impacts before processing your deletion request.

12. Appeals and Complaints

If you are not satisfied with our response to your data deletion request, you have the right to:

• Contact us again to discuss your concerns
• Lodge a complaint with the relevant data protection authority
• In France, contact the Commission Nationale de l'Informatique et des Libertés (CNIL)

13. Updates to This Policy

We may update this Data Destruction Policy from time to time to reflect changes in our practices, legal requirements, or technology. We will notify you of any material changes by posting the updated policy on this page and updating the "Last Updated" date.

14. Contact Us

If you have any questions about this Data Destruction Policy or wish to request data deletion, please contact us:

• Email: hello@hedonist.house
• Address: 10 rue de Lancry 75010 Paris, France
• Subject Line: "Data Deletion Request" or "Data Destruction Policy Inquiry"