PRIVACY POLICY

Last Updated: July 2016


This Privacy Policy explains how the members of the COMO Group manage your personal data. It includes details of how we collect, store, use, record, hold, transfer and disclose your personal data. By visiting a COMO Group website or by providing us with your personal data whether by way of such website or by any other means whatsoever, you accept and consent to the terms of this Privacy Policy.


This Privacy Policy is issued by Culina Ptd Ltd (which is the data controller in respect of the personal data collected on this website. Culina Pte Ltd is a member of the COMO Group, which includes the following businesses:

- 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:

- Club21global.com;

- Culina.com.sg;

- Supernature.com.sg;

- kids21.com;

- blackbarrett.com;

- comohotels.com;

- comodempsey.sg;

- comoshambhala.com; and

- sg.club21global.com my.club21global.com th.club21global.com hk.club21global.com au.club21global.com int.club21global.com mobile applications for any of the above

(each a "COMO Group website" and together "The COMO Group websites").

This Privacy Policy does not apply to websites, services and products that do not display or link to this policy or that have their own privacy policies.

Please see below for more detailed information on how we process your personal data.

DISCLAIMER – COMO GROUP MEMBERS ARE NOT LIABLE TO YOU

NOTWITHSTANDING THAT THIS PRIVACY POLICY IS ISSUED ON BEHALF OF THE COMO GROUP, YOU ARE NOTIFIED THAT THE MEMBERS OF THE COMO GROUP ARE SEPARATE AND INDEPENDENT. YOUR USE OF THE WEBSITE IS SUBJECT TO THE RELEVANT TERMS AND CONDITIONS ISSUED BY THE RELEVANT COMO GROUP COMPANY IDENTIFIED AS TRANSACTING WITH YOU ON THIS WEBSITE.

MEMBERS OF THE COMO GROUP SHALL NOT HAVE ANY LIABILITY WHATSOEVER FOR ANY LOSS OR DAMAGE HOWESOEVER CAUSED WHETHER TO YOU OR ANYONE ELSE BY REASON ONLY THAT THEY ARE MEMBERS OF THE COMO GROUP AND/OR THAT THEY ARE IDENTIFIED AS A MEMBER OF THE COMO GROUP IN THIS PRIVACY POLICY OR ELSEWHERE ON THE WEBSITE.


For more information on this Privacy Policy or the use of your personal data, please contact the Culina’s Data Protection Officers at: privacy@culina.com.sg


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.Your Personal Data is collected by various means including via forms you complete, transactions made, subscriptions or through the use of cookies.

Where Personal Data of a minor is submitted by you, you confirm that you have authority to consent on behalf of that minor to the processing of their Personal Data as described in this Privacy Policy.


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
We may disclose your Personal Data in connection with the purposes described in this Privacy Policy. This may include sharing your Personal Data with, or transferring out of the country your Personal Data to, the following:
- 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
The COMO Group websites may contain links to other third party websites and microsites, whose privacy practices may differ from those of the COMO Group. If you submit Personal Data to any of those sites, your Personal Data is not subject to this Privacy Policy.
We encourage you to review the Privacy Policy of any site you visit. By clicking on or activating such links and leaving the COMO Group website, the COMO Group does not exercise control over any data or any information which you give to any other entity after leaving the COMO Group websites. Any access to such other sites or pages is entirely at your risk.

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.
Singapore

Culina Pte Ltd
24 Senoko Way
Singapore 758046
Tel: 65 6753 6966
Email: privacy@culina.com.sg

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.

CHANGES TO THE PRIVACY POLICY
Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. By continuing to visit a COMO Group website or continuing to allow us to retain or process your Personal Data following any such changes to our Privacy Policy, it is deemed that you have accepted such changes unless you expressly notify us otherwise in writing where this is permitted by law .

QUERIES, COMMENTS AND COMPLAINTS
If you have any questions, comments or complaints about our collection, use or disclosure of Personal Data, or if you believe that we have not complied with this Privacy Policy or applicable laws, please contact us using the details below.
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.

CONTACT US
All other questions on our use of your Personal Data should be addressed to the COMO Group Data Protection Officer at privacy@culina.com.sg

LANGUAGE
This Privacy Policy is published in both the English Language (“English Version”) and in such other languages as set out below. In the event of any inconsistency in the terms of the Privacy Policy between the English Version and the other relevant version, the terms of the Privacy Policy in the English Version shall prevail to the extent of such inconsistency.