Privacy Statement

This Privacy Statement was last updated in August 2022.

At the COMO Group, we take your privacy very seriously and are committed to protecting your personal data.

This Privacy Statement explains how members of the COMO Group process and manage your personal data and rights in this respect.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

About the COMO Group

This Privacy Statement and Cookie Policy is issued by the COMO Group, but applies to the handling of personal data by each member of the COMO Group. The members of the COMO Group who could be “data controllers” in relation to your personal data are here.

The websites and applications of the COMO Group are here.

There will typically be one member of the COMO Group to whom you have given your personal data. (From a UK/EU perspective, this entity would be a “data controller” in relation to your personal data. The term “data controller” broadly means the person who determines the purpose and means for which your data is processed. It is possible that you have given your data directly to more than one member of the COMO Group in which case each such member could be a data controller of your data in that context.)

If you are a member of the COMO Club Recognition Programme, which is the loyalty scheme administered on behalf of the COMO Group, the relevant data controller is COMO Club Pte Ltd.

Members of the COMO Group may have separate privacy notices that they provide to you either to replace or supplement this Privacy Statement and Cookie Policy.

Disclaimer – no overarching liability of COMO group members

Even though this Privacy Statement and Cookie 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 any website is subject to the relevant terms and conditions issued by the relevant COMO Group member identified as transacting with you on that particular COMO Group Website. Members of the COMO Group shall not have any liability whatsoever for any loss or damage howsoever 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 Statement and Cookie Policy or elsewhere on the relevant COMO Group Website.

Data we collect from you or about you and our sources of that data

Your personal data, or personal information, means any information about you that may be used to identify you. It includes information that you provide to us, that we collect or that we are provided with by third parties and that identifies you, or from which you are identifiable, whether directly or indirectly. It does not include data where the identity has been removed so that it can no longer be associated with you (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, nationality, passport number and country of residence.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. If you participate in a loyalty programme operated by a member of the COMO Group, we would process your information in order to administer the loyalty programme.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. For our hotels and properties and family club, this could include the age and special requirements of children, where we need this information to provide services to you.
Usage Data includes information about how you use our website, products and services.
Accessibility Data includes personal data related to health which you provide to us in order to access our facilities or services (for example if wheelchair access is required or information on allergens).
Wellness and Health Data includes information related to our wellness services, including when you visit one of our spas or restaurants. This may include medical data relevant to your treatment or dietary requirements relevant to your visit to our restaurants.
Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Children’s Data includes Identity Data, Profile Data, Accessibility Data and Wellness Data relating to individuals under 18 years of age.

This includes data that we may collect from you:

when you place an order, make a booking, cancel or modify a booking on a COMO Group Website or otherwise;
when you create an account on a COMO Group Website;
when you join a COMO Group loyalty programme;
when you stay at one of our COMO Hotels & Resorts. Where a booking is made which includes persons under the age of 18, we may also collect Children’s Data;
when you use any COMO Group wellness services, such as our spa or wellness mobile application, we may additionally collect Wellness Data and, where relevant, Children’s Data;
when you visit our COMO Group Hotels & Resorts or any of our COMO Group restaurants or properties, we may additionally collect Accessibility Data;
when we provide you with babysitting, childcare and other activities and services for individuals under 18 years of age, we may collect Children’s Data;
by filling in forms on a COMO Group Website;
by downloading or registering with a COMO Group mobile app;
when you use a COMO Group Website;
when you sign up to receive email updates from us;
when you ask us to provide you with marketing communications such as newsletters, updates or information about special events or promotions;
if you ask us to keep in touch with you or provide you with personalised content (such as targeted advertising);
if you contact us or correspond with us (for example, by phone, email, social media platforms or otherwise) for any reason; or

when you provide us with comments, opinions and/or feedback about the COMO Group.

We may collect “Technical Data” when you visit or use any COMO Group websites:

technical information, including the type of device (and its unique device identifier) you use to access the COMO Group Websites, the Internet protocol (IP) address used to connect your device to the Internet, your unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, your device and component serial numbers, your login information, browser type and version, time zone setting, browser plug in types and versions, operating systems, mobile network information and platform and details of any referring website or application; and
information about your visit to the COMO Group Websites including full Uniform Resource Locators (URL), clickstream to, through and from the COMO Group Websites (including date and time), pages you viewed, page response time, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Data other COMO Group members collect about you. Information you provide to a member of the COMO Group may be shared between us (for example, when you stay at one of our COMO Hotels & Resorts this information could be shared with the other COMO Hotels & Resorts). We will also share your personal data for the purposes of the COMO Club Recognition Programme, and any other of our loyalty schemes you may have signed up to (though will only do so with your consent, where consent is legally required).

Data we collect from or are provided with by third parties. We may be given information about you from third parties, such as social media platforms or anyone making a booking on your behalf at one of our COMO Hotels & Resorts, restaurants or wellness retreats and spas. This may include personal data from third parties who are affiliated members of the COMO Club Recognition Programme, and any other loyalty schemes we may operate. We may also collect information that is publicly available, for example, when we interact with you through social media.

We will require you to share certain personal data with us (such as Identity, Contact, Financial Data and such other information as may be indicated by the COMO Group) in order for the COMO Group to perform the relevant services you have requested. The COMO Group may not be able to perform the relevant services if you fail to supply the relevant personal data.

Where Children’s Data is submitted by you, you confirm that you have authority to provide such data to us on behalf of that minor to enable us to process their personal data as described in this privacy statement and cookies policy.

Certain categories of personal data receive particular protection under the laws of certain countries. For example, in the UK/EU, special categories of personal data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) as well as data relating to criminal convictions and offences receive enhanced protection. We will comply with applicable laws when processing such personal data.