Comis Holdings Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, comishotelandgolfresort.com and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights as set out in this policy.
1. Information About Us
Our Site is owned and operated by COMIS Holdings a limited company registered in Isle of Man under company number 012690V.
Registered address: COMIS Holdings Limited
Main trading address: Mount Murray Back Road, Santon, Isle of Man, IM4 2HT
VAT number: 004613128
Data Protection Officer: Michael Taylor
Email address: email@example.com
Telephone number: +44 (0) 1624 661111
Postal address: Mount Murray Road, Santon, IOM, IM4 2HT
Representative: Michael Taylor
Email address: firstname.lastname@example.org
Telephone number: 01624 661111
Postal address: Mount Murray Road, Santon, IOM, IM4 2HT
We are a member of Isle of Man Chamber of Commerce
2. What Does This Policy Cover?
3. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the UK Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always endeavour to uphold:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about [ur use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
5. What Data Do You Collect and How?
6.How Do You Use My Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal to supply a product or contract we are about to enter into or have entered into with you, such as a hotel accommodation, club membership or golf or restaurant bookings. Where we need to comply with a legal or regulatory obligation.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and you will always have the opportunity to opt-out.
We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted may process your personal data without your knowledge or consent. This will only be done within the bounds of the relevant Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the Isle of Man. This means that it will be fully protected under the Isle of Man Data Protection Legislation.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
§ Other companies within the Comis Group (acting as joint controllers or processors) and based in UK or Isle of Man.
§ Service providers acting as processors, based within the UK, Republic of Ireland, and Isle of Man, who may provide necessary administration or the supply of relevant services to fulfil contractual / service requests
§ Professional advisers acting as processors including lawyers, bankers, auditors and insurers based within the UK, Republic of Ireland and Isle of Man) who may provide required consultancy, banking, legal, insurance or accounting services.
§ HM Revenue & Customs, or Isle of Man Income Tax Division; legal regulators and other authorities acting as processor) based in the UK, Republic of Ireland or Isle of Man who require reporting of processing activities in certain circumstances.
§ Third party booking engines who may process hotel reservations with our hotels on your behalf and who may by their very nature, may or may not be primarily based within the UK, Republic of Ireland or Isle of Man.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law applicable.
10. How Can I Control My Personal Data?
When you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
11. Can I Withhold Information?
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Our Site may place and access certain Cookies on your computer or device. These Cookies are those placed directly by us and are used only by us to facilitate and improve your experience of our Site and to provide and improve our products and or services.
Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
Data Protection Officer
Email address: email@example.com.
Telephone number: +44 (0) 1624 661111.
Postal Address: Mount Murray Road, Santon, Isle of Man IM9 5AF.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.