Privacy Policy

Please read the following to learn about our Privacy Policy.  This Privacy Policy governs your use of the website of the Como Group at www.como.bz and any individual COMO Hotel's related websites (hereinafter collectively referred to as this "Website").  The COMO Group comprises of Club 21, COMO Hotels and Resorts, COMO Shambhala and the COMO Foundation (hereinafter referred to as the "COMO Group").

By visiting this Website, and/or using the services offered on or through this Website, you shall be deemed to have accepted to be legally bound by the terms and conditions set out herein (hereinafter referred to as our "Privacy Policy").

The COMO Group reserves the right to modify, add, vary or amend all or part of this Privacy Policy from time to time, without prior notice to you. Your continued use of this Website and any of the services offered by this Website shall be deemed an agreement by you to such Privacy Policy as modified.

1. What this Privacy Policy Covers
1.1. This Privacy Policy covers how the COMO Group uses the personal information (the "Personal Information") it collects.  However, please note that this Privacy Policy only applies to this Website and does not apply to the websites owned and/or operated by third parties.
1.2. The COMO Group is not responsible for any actions or policies of third party websites which are hyperlinked to and from this Website.  You should check the applicable privacy policy of such party before providing any information, including any Personal Information to such websites.

2. Collection of Personal Information
2.1. The COMO Group collects Personal Information such as your name, email address, birth date, gender, address, contact information, occupation, credit card and other payment information, and personal interests and preferences when you:
2.1.1. Apply to be a registered user of this Website;
2.1.2. Visit the web pages on this Website that can be accessed without the need for registration;
2.1.3. Make an online booking through the website of our third party service provider, GuestConnect (by Synxis) or such other subsequent service provider as we may use from time to time;
2.1.4. Enter promotions or contests that are available to you without having to be a registered user of this Website;
2.1.5. Use any online services available on this Website (the "Online Services");
2.1.6. Submit a comment, question or feedback to us using a "Contact Us" or similar feature on this Website, send us an email, or in any other way, submit Personal Information to us via this Website.
2.2. The COMO Group also automatically receives and records information from your browser on our server logs including but not limited to your Internet protocol address, cookie information and the page you requested.
2.3. The COMO Group uses the Personal Information:
2.3.1 To facilitate your access to this Website or your use of the Online Services;
2.3.2 To customize and personalise the content of the web pages that you see;
2.3.3 To fulfill your requests for the Online Services;
2.3.4 To evaluate your preferences and facilitate future works on this Website.

3. Information Collection and Use
3.1. Your Personal Information will not be sold, transferred or otherwise conveyed to unaffiliated third parties without your approval at the time of collection. At such point of collection, you shall have the opportunity to indicate whether you would like to "opt out" of receiving promotional and/or marketing information about other products, services and offerings from the COMO Group and/or any third parties.  Your request for us to cease sharing your Personal Information with other entities for marketing purposes will only take effect from the date we receive your request.
3.2. However, the COMO Group reserves the right to contact you regarding matters such as details of your booking with any of the COMO Hotels, payment status, feedback on your accommodation with any of the COMO Hotels and other matters relevant to the Online Services and/or the Personal Information collected.
3.3. The COMO Group reserves the right to do any of the following with the information collected from you;
3.3.1 Perform statistical analysis of user behavior and characteristics in order to measure interest in and use of the various areas of this Website and to inform advertisers of such information as well as the number of users that have been exposed to or clicked on their advertising banners. The COMO Group may sell or provide aggregated data from such analysis to third parties;
3.3.2 Use your Personal Information to help us develop and improve this Website, tailor this Website to your interests, and maintain our internal record keeping. We may match information collected from you through different means or at different times, and use such information along with information obtained from other sources, including third parties; and
3.3.3 Send you notices (for example, in the form of e-mails, mailings, and the like), and otherwise correspond with you about products, services, companies, promotions, contests and events, sponsored by the COMO Group and others, which we think might interest you.
3.4. The COMO Group may offer electronic newsletters and e-mails as a service to our customers and users of this Website.  You may receive a newsletter or promotional e-mail from the COMO Group if you agree during registration, or during your other activities on or through our Website to receive these items.
3.5. The COMO Group will send Personal Information about you to other companies or people when:
3.5.1.We have your consent to share the information;
3.5.2. We need to share your information in order to provide the Online Services or other services that you have requested;
3.5.3.We are compelled by any law, court order, legal process or regulatory authority to disclose your Personal Information to third parties.

4. Cookies
4.1. "Cookies" are small text files a website can use to recognise repeat users, facilitate the user's ongoing access to and use of the website and allow a website to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. Cookies are not programmes that come onto a user's system and damage files. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site.
4.2. The COMO Group may set and access the COMO Group cookies on your computer. 
4.3. The COMO Group allows other companies that are presenting advertisements on some of our pages to set and access their cookies on your computer.  The use of cookies by such companies is subject to their own privacy policies, not this one.  Advertisers or other companies do not have access to the COMO Group’s cookies.
4.4. If you do not want any information about yourself to be collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature.  However, please note that if you do this, certain features (e.g., customized delivery of information) available on this Website may not be available to you.

5. Business Transfer
5.1. In the event that the COMO Group or its affiliates, or substantially all of any of their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, Personal Information may be one of the transferred assets.  You hereby agree and consent to such transfer.

6. Third Party Advertisement Servers
6.1. We may use third-party advertising companies to serve advertisements when you visit this Website.  These companies may use information (generally not including your name, address email address or telephone number) about your visits to this Website in order to provide advertisements about goods and services of interest to you. These companies may employ cookies to measure advertising effectiveness. Any information that these third parties collect via cookies is generally not personally identifiable (unless, for example, you provide Personal Information to them through an ad or e-mail message). We encourage you to read these businesses' privacy policies if you should have any concerns about how they will care for your personal information.

7. Wireless Addresses
7.1. If the email address you provide to us is a wireless email address, you agree to receive messages at such address from the COMO Group (unless and until you have elected not to receive such messages by electing to opt out of receiving such messages). You understand that your wireless carrier's standard rates apply to these messages. You hereby represent and warrant that you are the owner or authorised user of the wireless device on which messages will be received, and that you are authorised to approve the applicable charges.

8. Governing Law
8.1. This Website is hosted and operated in Singapore pursuant to the laws of Singapore. By providing Personal Information to this Website, you understand and consent to the collection, maintenance, processing and transfer of such information in and out of Singapore.

9. Third Party "Linked-To" Web Sites
When you are on this Website you may have the opportunity to visit, or link to, other sites not operated by the COMO Group, including web sites operated by other affiliated companies of the COMO Group, or by unaffiliated third parties. These sites may collect Personal Information about you. The COMO Group does not control sites that are operated by these entities and is not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of those other web sites.

10.Changes to this Privacy Policy
10.1. The COMO Group reserves the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of this Website by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to this Website. Under certain circumstances (for example, if we would like to use your Personal Information in a manner different from that stated in our Privacy Policy at the time of collection), we may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as by sending you an e-mail.

© 2009 COMO Hotels and Resorts
All rights reserved
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