Last Updated: June 2016
- Club 21 Pte Ltd;
- Kids 21 Pte Ltd;
- Culina Pte Ltd;
- SuperNature Ptd Ltd;
- COMO Hotels and Resorts (Asia) Pte Ltd and
- Club 21 managed brands identified on the Club 21 websites at http://www.club21global.com/#/corporate/home
(together "we", "our" or "us") and all websites and applications including:
- comoshambhala.com and
- mobile applications for any of the above (each a "COMO Group website" and together "The COMO Group websites").
Please see below for more detailed information on how we process your personal data.
WHAT WE COLLECT
Your “Personal Data” includes any information you provide to us or that we collect and that identifies you, or from which you are reasonably identifiable (and has the equivalent meaning under applicable national laws). This includes, where relevant and appropriate, your name, email address, photograph, birth date, gender, address, contact information, occupation, nationality, travel identification information, health information, credit card and other payment information, personal interests, details of your specified preferences including dietary preferences, family particulars, your memberships of other loyalty programs, information on social media, records of questions that you ask us, answers you provide to questions we ask, other information about your dealings with us and information about you stored in cookies (such as your purchase history and other usage information) and Internet Protocol address or addresses when you interact with a COMO Group website.
The provision of certain Personal Data by you to us such as your name, email address, contact information, credit card and such other information may be indicated by The COMO Group as compulsory or obligatory in order for the COMO Group to perform the relevant services for the identified purposes.
The COMO Group may not be able to perform the relevant services for the identified purposes if you fail to supply the relevant Personal Data.
HOW WE USE YOUR PERSONAL DATA
The COMO Group uses the Personal Data for relevant purposes including:
1. To facilitate your access to our websites and mobile applications;
2. To register you as a member of any program operated by a member of the COMO Group and to administer your membership including providing you with all the benefits of membership;
3. To communicate with you on different channels and media regarding any ongoing marketing and promotions of any member of the COMO Group or update you on the COMO Group news;
4. To customize, and personalise the content of the COMO Group websites that you visit;
5. To communicate with you to fulfill your requests for online transactions on the COMO Group websites or for any business or legal reason;
6. To process any transaction, including orders, bookings, reservations, purchases, returns, refunds and deliveries;
7. To evaluate your preferences and for the maintenance and improvement of the COMO Group websites;
8. To analyse and understand how you use the service;
9. For security and fraud prevention purposes; and
10. Where users contact customer service for support.
HOW WE SHARE YOUR PERSONAL DATA
- all companies within the COMO Group for marketing, business, administrative and legal purposes (for example payment, verification or membership awards and points ; and
- marketing partners, hotel partners and third-party service providers (such as subcontractors, agents or service providers, fitness, medical and healthcare professionals providing assessments for treatment, IT, website, delivery, printing, storage, hosting, travel planning, reservation, booking, rewards management, customer relationship management, business development and marketing support) who perform functions such as marketing, payment, fulfillment and delivery of orders administration and processing of payments, bookings and reservations.
The businesses to whom we disclose your Personal Data may be located in different countries depending on the circumstances. In the ordinary course of business we may disclose and transfer Personal Data to the COMO Group companies located elsewhere including in Singapore, Bhutan, Brunei, Macau, Malaysia, New Zealand, Hong Kong, Indonesia, Philippines, Thailand, Taiwan, Vietnam, United Kingdom, the United States and Australia and subject to the appropriate legal data transfer mechanisms.
The COMO Group may also store, disclose or transfer out of the country Personal Data as permitted or required by law.
LINKS TO THIRD PARTY WEBSITES
RETENTION OF INFORMATION
Your Personal Data will be retained for as long as it is necessary to fulfill the purposes for which it is collected or for business or legal purposes, or in accordance with applicable laws.
Should you choose to unsubscribe from our mailing list or should your any of your COMO Group memberships expire, please note that your Personal Data may still be retained on our database to the extent permitted by law.
HOW WE STORE AND SECURE YOUR PERSONAL DATA
The Personal Data that we hold about you will be stored either on our servers or using third party data storage providers in Singapore or if elsewhere, in compliance with the Singapore Personal Data Protection Act and any other applicable laws.
We take reasonable care, in so far as it is within our power to do so, to keep your Personal Data secure, but in the absence of negligence on our part we cannot be held liable for any loss you may suffer as a result of unauthorized access to, disclosure of, misuse of or loss or corruption of any data (including any Personal Data you provide when accessing or ordering from the COMO Group websites).
We may post a notice on our website if a security breach occurs. We may also notify by email or otherwise in these circumstances.
ACCESSING, RESTRICTING, CORRECTING, AND AMENDING YOUR PERSONAL DATA
Where available, you may access, review, correct, and amend your Personal Data by signing into your account and selecting “Update Profile”, or where not available or if you choose otherwise you may request the correction or amendment of your Personal Data by contacting us using the contact details below. The COMO Group may comply with your request to access, amend or delete the Personal Data, to the extent required by law.
You may by notice in writing to us requiring us at the end of such period as is reasonable in the circumstances to cease or not to begin processing your Personal Data for purposes of direct marketing. You may also by notice in writing withdraw your consent to our use or processing of your Personal Data to the relevant address listed below.
For COMO Hotels and Resort (Asia) and COMO Shambhala in all locations
COMO Hotels and Resorts
6B Orange Grove Road, Singapore 258332
Fax: +(65) 6304 1472
Australia, Brunei, Macau, New Zealand, Philippines, Singapore and Vietnam
Customer Relationship Management (CRM) Department
Club 21 Pte Ltd
COMO House 6B Orange Grove Road, Singapore 258332
Fax: +(65) 6304 3512
Customer Relationship Management (CRM) Department
Club 21 (Hong Kong) Ltd
3/F, One Island East
18 Westlands Road, Quarry Bay, Hong Kong
T: 852 2629 6388
Customer Relationship Management (CRM) Department
Club 21 Pte Ltd Taiwan Branch
NO. 51 Section 3 Mingsheng East Road, Taipei Taiwan
T: 886 2 2517 8859
PT.Kelab 21 Retail
Graha Surya Internusa
JL HR Rasuna Said KAV X-0 Kuningan Indonesia
10th floor #1003A
T: 62 21 527 2833
Club 21 (Thailand) Company Limited
Park Ventures Ecoplex
57 Wireless Road, Lumpini, Pathumwan, Bangkok
T: 66 2 650 9181
Club 21 Malaysia
Menara Hap Seng
Letter box No. 57, Jalan P. Ramlee, Kuala Lumpur, Malaysia
Suite 17-03, 17th floor
T: 603 2173 3000
When contacting the CRM department, please state your name and valid contact details. The COMO Group may refuse to comply with any request or reply to any inquiries or complaints unless it is supplied with such information as it may reasonably require.
We will respond to your requests within a reasonable time and in accordance with the relevant national laws.
QUERIES, COMMENTS AND COMPLAINTS
When contacting us please provide as much detail as possible in relation to your question, comment or complaint. We will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.
We request that you cooperate with us during this process and provide us with any relevant information that we may need.
All other questions on our use of your Personal Data should be addressed to the COMO Group Data Protection Officer at email@example.com
FOR HONG KONG RESIDENTS ONLY – DIRECT MARKETING
In addition to our policies above, the COMO Group may collect, use and transfer your personal data for Direct Marketing purposes - i.e. the offering and advertising of goods and services to you.
Collection of your personal data for use in Direct Marketing
The COMO Group intends to use the personal data it has collected from you for direct marketing purposes. In particular, the COMO Group may use your name, email address, contact information and preferences to communicate with you by email, SMS, post or phone in relation to COMO Group promotions and COMO Group News.
Consent & Opting Out
Provision of your personal data for the COMO Group's direct marketing activities is voluntary and the COMO Group will not use your personal data for direct marketing purposes without first obtaining your consent. You may also withdraw your consent at any time by contacting the COMO Group Data Protection Officer at firstname.lastname@example.org. Alternatively, you may contact the Hong Kong Customer Relationship Management (CRM) Department at email@example.com.
Transfer and sharing of your Personal Data
The COMO Group may transfer your personal data including your name, email address, contact information and preferences to other members of the COMO Group and its marketing partners for their direct marketing activities where permitted by law.
Our marketing partners include our subsidiaries and affiliated companies worldwide or third-party service providers who are employed to perform functions such as marketing, payment, fulfilment and delivery of orders and they will only use the transferred personal data for the following purposes of offering and advertising of goods and services sold and provided by the COMO Group to you.
The COMO Group will only transfer your personal data to its marketing partners if it obtains your prior written consent. You may withdraw your consent at any time by contacting the COMO Group Data Protection Officer at firstname.lastname@example.org. Alternatively, you may contact the Hong Kong Customer Relationship Management (CRM) Department at email@example.com.
The COMO Group obtains a benefit through provision of your personal data to its marketing partners and such personal data is transferred to our marketing partners on a reciprocal basis.
FOR EU RESIDENTS ONLY
Collection and Use of Personal Data
Both we and other third parties such as our service providers and advertising networks may collect Personal Data about our visitors’ online activities, over time and across third-party websites.
Retaining or Disclosing your Personal Data
In addition to our policies above, the COMO Group may retain or disclose your Personal Data if we have a good faith belief that such processing is reasonably necessary to:
- comply with any applicable law, regulation, court order, legal process or other binding request;
- prevent harm, injury or damage to us, our property, our staff, our users or members of the public
- defend our legal rights or enforce the applicable Terms of Service; or
- detect, prevent, or otherwise address fraud or security issues.
Personal Data Transfers
In addition to our policies above, please note that your Personal Data may be transferred to and stored in countries which do not provide the same level of protection for personal data as under your local law. The rights of governmental and law enforcement authorities to access your Personal Data may also differ. By using or visiting a COMO Group website, you authorize us to use your Personal Data in the countries in which the COMO Group operates.
Direct Marketing Opt-Out
Provision of your Personal Data for the COMO Group's direct marketing activities is voluntary and the COMO Group will not use your Personal Data for direct marketing purposes without first obtaining your consent in accordance with applicable law. You may withdraw your consent at any time by following the unsubscribe link in our direct marketing emails or by contacting the COMO Group Data Protection Officer at firstname.lastname@example.org
FOR AUSTRALIAN RESIDENTS ONLY
FOR U.S. RESIDENTS ONLY
Both we and other third parties such as our service providers and advertising networks may collect personal information about our visitors’ online activities, over time and across third-party websites. The COMO Group websites are not designed to respond to “do not track” signals from browsers.
NOTICE TO CALIFORNIA RESIDENTS
Bahasa Melayu - Coming Soon!
Traditional Chinese - Coming Soon!
Simplified Chinese - Coming Soon!
Thai - Coming Soon!