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Politique de protection des données personnelles

1. Preamble

This Personal Data Protection Policy is intended to inform, in a clear, complete, and transparent manner, every person accessing the Tunisian Campers website about the conditions under which personal data are collected, used, stored, protected, and, where applicable, disclosed to third parties.

Tunisian Campers gives particular importance to privacy and to the fair, lawful, proportionate, and secure processing of personal data. In this respect, the company seeks to comply with the requirements of Tunisian Organic Law No. 2004-63 of 27 July 2004 relating to the protection of personal data, as well as Regulation (EU) 2016/679 (GDPR) whenever it applies, particularly with regard to individuals located in the European Union

This policy is designed to be compatible with the website’s current structure, developed on WordPress and WooCommerce, as well as with the future evolution of the services offered, including the activation of a secure online payment solution operated by an approved payment provider such as Flouci.

2. Definitions

For the purposes of this policy, the following terms shall have the meanings set out below:

• Personal datal : any information, whatever its origin or form, that directly or indirectly identifies a natural person or makes such person identifiable..ins
• Processing :any operation or set of operations relating to personal data, whether automated or not, including collection, recording, organization, storage, use, disclosure, consultation, modification, erasure, or destruction.ins
• Data subject : any natural person whose personal data are processed.ins
• Controller : the natural or legal person that determines the purposes and means of the processing of personal data.ins
• Sous-traitant : toute personne physique ou morale traitant des données personnelles pour le compte du responsable du traitement.ins
• Personal data breach :a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. gdpr-info
• Consent : a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which the data subject agrees to the processing of personal data where such legal basis is required.
• Cookies :trackers or similar technologies placed on or read from the user’s device for technical, statistical, or advertising purposes.

3. Data controller

The controller of the personal data collected through the website is:

Tunisian Campers
Tax registration number : 1654190/P/A/M/000
Registered office : 14 Rue de Syrie, 2ème étage, Ain Zaghouan Nord, 2046 Tunis, Tunisie
Legal representative : M. TEMIMI MOHAMED, Company Manager
Data protection contact email : contact@tunisiancampers.com

Tunisian Campers determines the purposes and essential means of the processing carried out in connection with the operation of the website, booking management, customer relations, and, where applicable, the future integration of a secure payment service.

4. Scope

This policy applies to all personal data processing activities carried out in connection with:

• browsing the Tunisian Campers website;
• creating a customer account;
• booking tourist activities, excursions, hiking trips, camping, organized trips, and outdoor activities;
• using the contact form;
• communications with customer service before, during, and after an activity;
• technical, statistical, and marketing management of the website through cookies and similar technologies.

It applies to users located in Tunisia as well as to visitors located abroad. Where the territorial scope conditions of the GDPR are met, the rights and safeguards provided by that regulation may also apply.gdpr-info

5. Data collected

As part of its activities, Tunisian Campers may collect and process the following categories of personal data

• last name;
• first name;
• email address;
• phone number;
• WhatsApp number;
• postal address;
• numéro de Carte d’Identité Nationale (CIN) ;
• passport number;
• data relating to bookings, orders, requests, communications, and customer relationship follow-up;
• technical and browsing data collected through cookies and website technical logs.

When a booking is made, only the data of the customer making the booking are collected by the website. The personal data of other participants are not collected as part of the ordinary booking process, unless a later legal or operational necessity arises and is duly brought to the attention of the data subject.

Tunisian Campers undertakes to collect only data that are relevant, adequate, and limited to what is necessary for the purposes pursued.ins

6. Collection methods

Personal data may be collected:

• directly from the user when creating a customer account;
• directly when booking an activity;
• directly when submitting a request through the contact form;
• directly during exchanges by email, telephone, WhatsApp, or any other communication channel used for customer service;
• automatically through cookies, logs, tags, or similar technologies when browsing the website;
• indirectly, where applicable, through technical service providers acting on behalf of Tunisian Campers, strictly within the limits of their assignments.

Under Tunisian law, personal data should in principle be collected directly from the data subjects, except in cases legally permitted.ins

7. Purposes of processing

Personal data are processed exclusively for the following purposes:

• managing activity bookings;
• creating and administering a customer account;
• managing orders created in WooCommerce;
• responding to requests sent through the contact form;
• communicating with the customer before, during, and after the booked activity;
• sending booking confirmations and practical information;
• providing customer service and managing the commercial relationship;
• handling cancellations, changes, or complaints;
• complying with legal, regulatory, accounting, and administrative obligations;
• improving service quality and operational organization;
• ensuring the security, availability, and integrity of the website;
• preparing the future activation of online payments through a secure provider such as Flouci;
• preventing, detecting, and handling security incidents and personal data breaches.gdpr-info

No use of personal data for purposes incompatible with the original purposes is carried out without prior information to the data subject and, where required, without an appropriate legal basis.ins

8. Legal bases

Depending on the nature of the processing operation, Tunisian Campers relies on one or more of the following legal bases:

• Consent : in particular for certain non-essential cookies, certain optional communications, or any processing requiring the data subject’s explicit authorization.
• Performance of a contract or pre-contractual measures :to process a booking request, create a customer account, manage an order, send a confirmation, process a cancellation, or organize the booked service.
• Legal obligation :to retain certain information, respond to requests from competent authorities, comply with accounting, tax, administrative, or security obligations, or complete any prior formalities that may be required before the INPDP.
• Legitimate interest : to ensure website security, prevent fraud, defend Tunisian Campers’ rights, improve service quality, manage evidence, measure audience in compliance with applicable rules, or prepare the secure evolution of digital services.

Where Tunisian law requires express consent that leaves a written trace, such consent is collected through appropriate means.

9. Activity bookings

The booking of activities is one of the core purposes of the website. In this context, the data collected make it possible in particular to:

• identify the person making the booking;
• confirm the booking and send useful information;
• ensure logistical communication before the activity;
• manage possible changes, cancellations, or incidents relating to the booking;
• comply with administrative and legal obligations attached to the service.

The processing of data necessary for bookings is primarily based on the performance of a contract or pre-contractual measures. Where certain identity data are requested, including a national identity card number or passport number, such data must be limited to cases where they are necessary for organizing the activity, ensuring safety, reliably identifying the customer, or complying with a legal or contractual requirement.

10. Account creation

Creating a customer account allows the user to access a personal area, manage bookings, and facilitate future actions on the website.

In this context, Tunisian Campers may process the identification and contact data strictly necessary for:

• opening and managing the account;
• authenticating the user;
• retaining the history of bookings and communications;
• securing access to the customer area.

Inactive accounts are retained for a maximum period of two years from the last significant activity, subject to longer legal retention obligations or the need to retain certain data for evidentiary purposes.

11. Contact form

Data sent through the contact form are used exclusively to:

• process and reply to the user’s request;
• follow up on that request;
• keep a record of communications where necessary for administrative, contractual, or evidentiary purposes.

The contact form must enable the user to understand the identity of the controller, the purpose of the collection, whether the requested fields are mandatory or optional, and how to exercise their rights, in accordance with the transparency principles recognized under Tunisian and European law.ins

12. Online payment (Flouci)

As of the effective date of this policy, no online payment is activated on the Tunisian Campers website.

However, the company plans to integrate a secure payment solution at a later stage, in particular through Flouci or any other approved payment service provider. In that case: Flouci ou de tout autre prestataire de paiement agréé. Dans cette hypothèse :

• Tunisian Campers will not store customers’ full banking data on its own systems;
• payments will be processed exclusively by a secure and authorized payment provider;
• payment data will be protected in accordance with applicable security standards and the provider’s legal and contractual obligations;
• only the information strictly necessary for order management, payment confirmation, fraud prevention, and accounting may be received by Tunisian Campers;
• additional information may be provided when online payment is effectively activated, especially concerning the identity of the provider, data flows, and associated security measures.

If payment integration involves new processing operations or additional data sharing, this policy will be updated accordingly.

13. Minors

Certaines activités proposées par Tunisian Campers peuvent concerner des familles et, indirectement, des mineurs. En principe, le site collecte uniquement les données de la personne majeure qui effectue la réservation.

Tunisian Campers is not intended to directly collect minors’ personal data through the standard booking process, unless a specific need arises relating to the organization, safety, supervision of the activity, or a legal requirement. In such case, only the data strictly necessary shall be collected.

Where the processing of a minor’s data requires consent, such consent must be given or authorized by the holder of parental authority or the legal representative, in accordance with applicable law. Tunisian Campers may request any reasonable element allowing verification of that capacity where such verification is necessary.

14. Cookies

The website uses cookies and similar technologies to ensure proper functioning, measure audience, improve user experience, and, where applicable, offer adapted content or advertising.

The cookies used may include in particular:

• Essential cookies : necessary for the technical functioning of the website, browsing, security, session management, cart features, user account functions, or technical processing of bookings under WordPress/WooCommerce.
• Statistical cookies: used in particular through Google Analytics to measure audience, analyze traffic, understand website usage, and improve the services offered.
• Marketing cookies: used in particular through Google Ads and Meta Pixel to measure campaign effectiveness, track conversions, deliver promotional content, or personalize certain advertisements.

Unless the applicable rules allow their use without consent, non-essential cookies are subject to the user’s prior consent. Accordingly, this policy assumes that the website has an actual consent management mechanism allowing, at a minimum, users to:

• accept non-essential cookies;
• refuse them;
• configure them by category;
• later withdraw consent with effect for the future.

The wording displayed on the cookie banner, the granularity of categories, the scripts actually deployed, and the technical behavior of the website must be consistent with each other. As no technical audit of the WordPress website was carried out within the scope of this document, this clause should be understood as a compliance requirement to be implemented and verified before final publication.

Cookie retention periods vary depending on their nature, purpose, and the settings of the relevant services. Cookies are retained for no longer than the period authorized by applicable law or strictly necessary for the intended purpose. Browser settings also make it possible to delete or block certain cookies.

15. Déclaration INPDP

Under Tunisian law, the general principle is that any processing of personal data is subject to a prior formality before the National Authority for the Protection of Personal Data (INPDP), generally under a declaration regime, subject to cases requiring additional authorization, especially for certain sensitive processing operations or certain transfers abroad.

Accordingly, Tunisian Campers must verify whether the processing operations implemented for the website, booking management, customer relations, cookies, and third-party tools have been subject to:

• a prior declaration before the INPDP for each relevant processing purpose; and/or
• where applicable, an authorization request where a processing activity or transfer falls under an authorization regime.

The wording to be published should be adapted to the company’s actual situation:

• If the filing has been completed: “The personal data processing operations carried out by Tunisian Campers have been subject, where required by law, to the necessary prior formalities before the INPDP.”
• If the filing has not yet been completed: this statement should not be published as an established fact; the prior formality should be completed before final publication or, at the latest, before the relevant processing operations are effectively implemented.

16. Hosting, processors, and third-party services

Tunisian Campers uses, depending on the operational needs of the website and its services, technical providers or partners acting as processors, independent providers, or technical recipients, strictly within the limits necessary for their tasks.

The following may in particular be involved:

• OVHcloud, for hosting, technical maintenance, backups, and infrastructure security;
• Flouci or any other approved payment provider, only when online payment is activated;
• Google Analytics, for audience measurement and statistical analysis;
• Google Ads, for advertising campaign and conversion tracking;
• Meta Pixel, for marketing performance measurement and certain conversion tracking.

Tunisian Campers seeks to use only service providers offering appropriate guarantees in terms of confidentiality, security, and compliance. Where these services involve access to personal data, hosting, transfers, cookie placement, or technical processing, they must be governed by appropriate legal bases, settings, contractual arrangements, and security measures.

17. Data retention

Personal data are retained for no longer than is necessary for the purposes for which they were collected, subject to longer periods required by law or necessary for the defense of Tunisian Campers’ rights.

For this purpose, the following retention periods apply as a matter of principle:

• customer and booking : 5 years;
• invoices and accounting documents: 10 years;
• inactive accounts: 2 years from the last significant activity;
• National Identity Card numbers and passport numbers: a reduced retention period, limited to the period strictly necessary for identity verification, activity organization, safety, incident handling, or compliance with a specific legal obligation; as a rule, such data should not be retained for more than 1 year after the date of the activity , unless a longer legal obligation or duly justified evidentiary need applies;
• cookies: variable period depending on their nature, function, the relevant tool settings, and the applicable rules.

At the end of the applicable periods, data are deleted, anonymized, or securely archived where continued retention is justified by a legal, regulatory, or evidentiary obligation.ins

18. Security and data breach

Tunisian Campers implements appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, loss, destruction, or any other unlawful or accidental processing.

Such measures may include in particular:

• use of HTTPS ;
• encryption or suitable protection mechanisms for certain data and flows;
• regular backup systems;
• logical and physical access controls;
• authentication mechanisms;
• strict limitation of administrator access;
• hosting on secure infrastructure;
• logging of relevant access and technical operations;
• regular updates of the website, plugins, themes, and software components;
• mechanisms for preventing and detecting attacks, vulnerabilities, and abnormal behavior.

In the event of a personal data breach, Tunisian Campers undertakes to:

• document the incident, its effects, and the corrective measures taken;
• assess, as quickly as possible, its nature, scope, and the risks for the data subjects;
• notify the competent authority without undue delay and, where the GDPR applies, where feasible within 72 hours after becoming aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons;
• inform the affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms, unless a legally recognized exception applies;
• take any reasonable measure to limit the consequences of the incident and prevent recurrence.gdpr-info

Where Tunisian law or INPDP guidance imposes additional specific requirements, Tunisian Campers shall apply them as a complement.

19. Data sharing

Personal data are not sold, commercially assigned, or made available to third parties for their own marketing or commercial exploitation purposes.

Subject to the technical processing performed by the providers listed in the “Hosting, processors, and third-party services” section, data may be disclosed only to administrative, judicial, or legally authorized authorities where required by law, regulatory obligation, or a legally grounded request.

20. International transfers

As part of the use of certain third-party services, in particular Google Analytics, Google Ads, and Meta Pixel, certain browsing data or technical identifiers may be processed, stored, or accessed from countries located outside Tunisia or outside the European Union.

Where an international data transfer occurs, Tunisian Campers endeavors to implement appropriate safeguards according to the nature of the transfer and the applicable law, including:

• use of providers offering adequate contractual commitments;
• verification, where relevant, of the existence of an appropriate level of protection;
• implementation of suitable contractual, technical, or organizational safeguards;
• limitation of transferred data to what is strictly necessary;
• completion, where applicable, of the formalities or prior authorizations required under Tunisian law before the INPDP.

Under Tunisian law, transfers of personal data abroad are subject to strict conditions relating in particular to the level of protection ensured by the recipient country and, in principle, to the prior authorization of the competent national authority.inpdp

21. Users’ rights

Sous réserve des conditions, limitations et exceptions prévues par la réglementation applicable, toute personne concernée dispose des droits suivants sur ses données personnelles :

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object;
• right to data portability, where the GDPR applies;
• right to withdraw consent at any time for processing based on consent;
• right to lodge a complaint with the competent authority.

Tunisian law notably recognizes the data subject’s right to consult the data concerning them, obtain a copy, correct, complete, rectify, update, clarify, or erase them when they are inaccurate, ambiguous, or processed in violation of the law, as well as a right to object for valid, legitimate, and serious reasons.ins

22. Exercising rights

Any request relating to the exercise of the above rights may be sent to: contact@tunisiancampers.com

The request should, where possible, specify:

• the identity of the requester;
• the exact purpose of the request;
• any useful information enabling the relevant data to be located.

Tunisian Campers may request reasonable proof of identity where there is a legitimate doubt as to the requester’s identity, in order to prevent unauthorized access to personal data.

Requests are handled within the time limits provided by applicable law or, failing that, within a reasonable time. In the event of a total or partial refusal, where the law permits, the data subject may refer the matter to the competent authority, in particular theNational Authority for the Protection of Personal Data (INPDP) in Tunisia. en Tunisie.inpdp+1

23. Changes to the policy

Tunisian Campers reserves the right to amend this policy at any time, in particular to reflect:

• changes in applicable laws and regulations;
• developments in the services offered;
• integration of new features or technologies;
• changes affecting service providers, processing operations, or security measures.

The version in force is the one published on the website on the date of consultation. In the event of a substantial change, appropriate information may be provided to users by any relevant means.

24. Contact

For any question regarding this policy or the processing of personal data, users may contact:

Tunisian Campers
14 Rue de Syrie
2nd floor
Ain Zaghouan Nord
2046 Tunis
Tunisia
E-mail : contact@tunisiancampers.com

25. Effective date

This policy shall enter into force from the date of its publication on the Tunisian Campers website.

Before final publication, three operational points should be verified: the actual existence of the applicable INPDP filing or authorizations, the effective implementation of a cookie banner consistent with the real behavior of the WordPress website, and the contractual framework of the third-party services and international transfers actually used.