Privacy Policy
Last Updated: Nov 2018
At the SHAMBALI LTD also named as Shambali Retreat, we take your privacy very seriously and we are committed to protecting your personal data.
This privacy statement (together with any terms of use or terms and conditions) explains how the members of the Shambali Retreat manage your personal data. It includes details of how we collect, store, use, record, hold, transfer and disclose your personal data. If you wish to contact us regarding this privacy statement, please see the contact us at contact@shambali.com
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Who we are
Our website address is: https://shambali.com and our company legal name is Shambali LTD
This privacy statement is issued by Shambali LTD, but applies to the handling of personal data by each member of the Shambali LTD. The members of the Shambali LTD could be “data controllers” in relation to your personal data.
There will typically be one member of the Shambali LTD to whom you have given your personal data. 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 Shambali LTD in which case each such member could be a data controller of your data in that context.
As updated from time to time and referred to in this privacy statement as the Shambali LTD / we / our or us.
What personal data we collect and why we collect it
Your personal data includes any 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. We may collect, use, store and transfer the following personal data about you:
- Data you give us
- when you place an order or make a booking on a Shambali Website or otherwise;
- when you create an account on a Shambali Website;
- when you join a Shambali loyalty program;
- when you stay at Shambali Retreat location;
- by filling in forms on Shambali Website;
- when you use Shambali 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 personalized content (such as targeted advertising);
- if you contact us or correspond with us (for example, by phone, email or otherwise) for any reason; or
- when you provide us with comments, opinions and/or feedback about the Shambali.
- Data we collect about you when you visit or use Shambali Website
- technical information, including the type of device (and its unique device identifier) you use to access the Shambali Website, 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 Shambali Website including full Uniform Resource Locators (URL), clickstream to, through and from the Shambali Website (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.
- When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
- Data other Shambali LTD members collect about you. Any information you provide to a member of the Shambali LTD will be shared between us.
- 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 Shambali LTD. We may also collect information that is publicly available, for example, when we interact with you through social media.
The provision of certain personal data by you to us (such as your name, email address, contact information, credit card and such other information as may be indicated by the Shambali LTD) will be compulsory or obligatory in order for the COMO Group to perform the relevant services for the identified purposes. Shambali LTD may not be able to perform the relevant services for the identified purposes if you fail to supply the relevant personal data.
As our valued Shambali LTD customer, we wish to advise you that the information collected by us in relation to persons under 18 years of age is limited to their name, nationality, date of birth and, where applicable, special requirements, which can only be supplied to us by an adult. We would be grateful if you could ensure that children you are responsible for do not send us any personal data without your consent (particularly via the Internet). If such data has been previously provided, you can contact the Data Privacy department to arrange for this information to be deleted at contact@shambali.com
Our websites are not intended for children and we do not intentionally solicit or collect personal information from individuals under the age of 18. If we learn that personal information of minors has been collected without the appropriate notification or consent, we will take the appropriate steps to delete such information and prohibit its further collection.
If you are a parent or guardian and discover that your child has a registered account which provides Shambali LTD with access to personal information, please alert us at contact@shambali.com
How we use your personal data and the legal basis for processing your personal data
Shambali LTD uses the personal data for relevant purposes where we have a legal basis to use your personal data without consent, this privacy statement fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.
Where consent is required for our use of your personal data as described above, we will request your consent. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non-mandatory information), you consent to our use of that personal data as set out in this privacy statement. For example, we will only process your personal data for marketing purposes if we have your consent to do so. Please see here for further information on this.
Marketing choices: We will, if you have given us your consent and in line with your choices, provide you with information by post, telephone, email, SMS and electronic messaging, which may be of interest to you in respect of Shambali LTD. Where you have consented to receive our direct marketing online this means that you could be presented with our advertisements while using Shambali LTD Website or the services of our online partners. For example, if you have given us this consent we may run a Facebook advertisement campaign, which could include our advertisements being presented to you while you are on Facebook. We may also personalize the content that you see using analytical or profiling tools. We will only provide you with marketing communications if you would like us to. You will have the opportunity to clearly set out whether you wish to receive marketing messages from us by ticking the relevant boxes.
How we share and disclose your personal data
We may share or disclose your personal data in connection with the purposes described in this privacy statement. This may include sharing your personal data with the following:
- all companies within Shambali LTD for marketing, business, administrative and legal purposes (for example, payment, verification or membership awards and points);
- Facebook, Twitter or Instagram (if you use your account with them to sign up / in with us), if applicable;
- service providers, business partners, suppliers, subcontractors or agents (for example, fitness, medical and healthcare professionals providing assessments for treatments, IT services, travel planning, reservation, booking, rewards management, customer relationship management, business development, and marketing support services) who perform functions such as marketing, payment, fulfilment and delivery of orders, administration and processing of payments, as well as bookings and reservations;
- professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance, and accounting services;
- vendors who provide services to us, such as fulfilling orders, providing data processing and other information technology services, managing promotions, carrying out research and analysis, and personalizing individual Shambali LTD customer experiences. We do not allow these vendors to use this information or to share it for any purpose other than to provide services on our behalf;
- government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information;
- third parties, who acquire us or substantially all of our assets, in which case your personal data (including any sensitive personal data) will be one of the transferred assets (however, we will let you know before this happens); and
- analytics and search engine providers that assist us in the improvement and optimization of the Shambali LTD Website.
Where we store your personal data
The personal data that we collect from you may be transferred to, processed and stored, in different countries depending on the circumstances (including outside the European Economic Area).This includes any country where Shambali LTD companies are located including in Hongkong and Indonesia, but also countries where our external service providers are based or hosting your personal data on our behalf.
Links to the third party website
Shambali LTD Website may contain links to other third party websites and microsites, whose privacy practices may differ from those of Shambali LTD. If you submit personal data to any of those sites, your personal data is not subject to this privacy statement.
We encourage you to review the privacy policy of any site you visit. By clicking on or activating such links and leaving Shambali LTD Website, Shambali LTD does not exercise control over any data or any information which you give to any other entity after leaving Shambali LTD Website. Any access to such other sites or pages is entirely at your risk.
Retention of personal data
Your personal data will only be retained for as long as it is necessary to fulfil the purposes it was collected as outlined in this privacy statement and for the purpose of satisfying our business (accounting and reporting) or legal requirements, but also to properly resolve disputes or to troubleshoot problems.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In addition, certain information may be stored indefinitely due to technical constraints, and will be blocked from further processing for purposes which are not mandatory by law.
If you choose to unsubscribe from our mailing list or should your access to any of your Shambali LTD memberships expire, your personal data will still be retained on our database to the extent permitted by law and in accordance with the Shambali LTD Data Retention Policy.
How we store and secure your personal data
We are committed to taking appropriate measures designed to keep your personal data secure. Our technical and organizational procedures are designed to protect your personal data from accidental, unlawful or unauthorized loss, access, disclosure, use, alteration, or destruction. While we make efforts to protect our information systems, no website, mobile application, computer system, or transmission of information over the Internet or any other public network can be guaranteed to be 100% secure. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access or inadvertent disclosure.
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 applicable data protection laws. We may post a notice on the relevant Shambali LTD Website, notify you by email or contact you otherwise if a security breach occurs and such breach presents a high risk to your rights and freedoms.
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Cookies
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
Changes to the privacy statement
This privacy statement is in effect as of the date noted at the top of the statement. We may change our privacy statement from time to time. Any changes we may make to our privacy statement 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 statement. By continuing to use Shambali LTD Website or continuing to allow us to retain or process your personal data following any such changes to our privacy statement, you are deemed to have accepted such changes unless you expressly notify us otherwise in writing (except to the extent we are required to make such changes in accordance with applicable law).
Where we need to seek updated, additional or different consents from you, we will, of course, do so.
If you have any further questions, contact us: contact@shambali.com