1. Introduction

Kamili Villas Limited, recognize the importance of protecting your privacy.   This privacy notice (“Notice”) describes how we collect, process, and share Guest Personal Data (defined below). This Notice also describes your rights and choices with respect to Guest Personal Data and other important information.

Kamili Villas may act as either a controller, a processor or both, depending on the circumstances, with respect to the collection, use, and other processing of personal identifying information which can be used to identify, directly or indirectly, or locate guests (“Guest Personal Data”) in connection with the guest relationship, as described in more detail in this Notice.

  1. How data is collected

Information you provide to us

Kamili Villas will collect personal data from you when you interact with our website, use our services, or purchase our products.

  1. Categories of guest personal data and purpose for processing
  2. Kamili Villas collects and processes the following categories of Guest Personal Data, for the purposes specified below when you make an enquiry or purchase a service or product:
  • Categories of Guest Personal Data
    – Purpose of processing
  • Personal name and initials (e.g. First Name, Last Name)
    – Communicate, interact and identify you and customize the content, products and services that are offered to you;
    – Verify your authority to enter and use our Services; and
    – Comply with legal requirements.
  • Personal characteristics (e.g., age, date of birth, gender, marital status, nationality) and personal preferences (product preferences, online preferences, interests)
    – Conduct our business and improve our websites and services, develop new products and services, provide information and support, to better understand your needs and interests, personalize communications and advertising, and generally promote a quality experience for you.
    – Process, fulfil and follow up on transactions and requests for products, services, support, and information
  • Financial information (e.g., credit card number, financial institution information and number)
    – Process transactions you enter into with us (e.g., purchase of goods and services, refunds, discounts and offers)
    – To prevent fraud
  • Contact information (e.g., address, phone number, email address)
    – Contact you with information about Kamili Villas.
  • Authentication information (e.g., login id, password)
    – Verify your authority to enter and use our website and other services
    – Deter, detect, and prevent fraud and other prohibited or illegal activities

The type of Guest Personal Data collected by Kamili Villas may vary from country to country, and in some countries Kamili Villas might not collect all of the categories of Guest Personal Data listed above.

Kamili Villas is committed to only collecting and processing the minimum amount of data from you that is necessary to the purposes of our data processing activities, and to retain such data only if required to fulfil such purposes.

Closed Circuit Television (CCTV)

We may operate CCTV or security cameras on properties operated or owned by Kamili Villas. In connection with these systems, we may collect and/or create Guest Personal Data as necessary in connection with certain legitimate business interests, such as (i) ensuring the safety and security of guests and employees; (ii) recording and investigating health and safety incidents; (iii) keeping track of guests and employees for safety and commercial purposes; and (iv)

  1. The legal grounds for processing guest personal data

In most instances, we process your personal data under the legitimate interests of providing you products and services. In other instances, we obtain your consent to process your personal data where we are required to do so by applicable law. Where we rely on your consent for processing your personal data, you may withdraw your consent at any time, by contacting us at reception@kamilivillas.com. Please note, however, that withdrawing your consent will not affect the lawfulness of processing based on the consent you gave prior to withdrawal. For direct marketing, we rely on our legitimate interests when applicable law does not require your consent.

Except as otherwise provided in this Notice, only a limited number of individuals within Kamili Villas, accounts and customer service teams (i.e., only persons with assigned responsibility or managerial responsibility for a guest or groups of guests) will receive access to Guest Personal Data when necessary in connection with their job responsibilities.

  1. Disclosures of guest personal data to third parties

Disclosures to third parties

We do not sell your personal data to third parties for their own marketing purposes. We may share or disclose your personal data as follows:

  • In order to streamline certain business operations, improve service personalization, develop products and services that better meet the interests and needs of our customers, and promote information we believe will be of interest to you, we will share your Guest Personal Data internally within our company, as well as any other current or future affiliated entities.
  • In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests and business purposes, we may share your Guest Personal Data with service providers who provide certain services or process data on our behalf;
  • In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violation of our Notice, as evidence in litigation in which we are involved, or to otherwise protect the rights or safety of any person or entity;
  • In order to respond to judicial process, valid government inquiry, or as otherwise required by law;
  • In order to carry out an acquisition by or merger with another entity, if all or part of our assets are acquired, or in response to a bankruptcy proceeding, we may transfer your information to the acquiring entity;

Transfers out of the UK, the EEA and Switzerland

Some service providers and other recipients may be in countries outside of the United Kingdom, the European Economic Area (EEA) or Switzerland; the data protection laws in such countries may not provide a level of protection to Guest Personal Data equivalent to that provided by a guest’s home country.

Wherever such a transfer is made, Kamili Villas will (i) exercise appropriate due diligence in the selection of such third party service providers, (ii) ensure that Guest Personal Data is adequately protected via appropriate contractual measures (which shall include the European Commission Model Clauses where Guest Personal Data is transferred out of the EEA and the international data transfer agreement or the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers where Guest Personal Data is transferred out of the UK), and (iii) place such third party service providers under such contractual obligations as are required under applicable law (including that Guest Personal Data be processed only as instructed by Kamili Villas and for no other purposes than those identified in this Notice where the party is our processor).

Kamili Villas may also disclose Guest Personal Data to governmental agencies and regulators (e.g., tax authorities), external advisors (e.g., lawyers, accountants, and auditors), courts and other tribunals, and government authorities or in the context of any sale or transaction involving all or a portion of the business, all to the extent required or permitted by applicable legal obligations.

Location of data processing and security measures

If you choose to provide us with your personal data, you understand that we are transferring it to Kamili Villa’s locations and systems of Kamili Villa’s service providers around the world. Kamili Villas has safeguards and security controls in place to protect your personal data. This includes appropriate technical and organizational measures to protect the personal data (i) from accidental or unlawful destruction, and (ii) loss, alteration, unauthorized disclosure of, or access to the data. Kamili Villas obtains written assurances from any third-party data processors given access to your data to require them to adopt standards that ensure an adequate level of protection for data.

  1. Data subject requests

You can contact us directly any time at the address below to update your personal data or make of the following requests regarding the data you know or believe Kamili Villas holds about you:

(1) Access to your Guest Personal Data

You may contact Kamili Villas at any time to request access to the personal data we hold about you. Kamili Villas will provide you with a copy of your personal data on request.

(2) Rectification or Erasure of your Guest Personal Data

If you notify us, or we otherwise become aware, that the personal data we hold is inaccurate, we will not use it, and will not allow others to use it, until it is verified. You can ask Kamili Villas to correct or complete our record of your personal data by contacting us at any time.

You may, in certain limited circumstances where the processing is not necessary in the context of any services we provide to you, ask to have the personal data Kamili Villas directly or indirectly processes deleted or removed. If the request is founded, we will try to do so promptly, and, to the extent possible.

(3) Restriction of Processing

It may be possible to require Kamili Villas to limit the way in which it processes your personal data (i.e., require Kamili Villas to continue to store your personal data, but cease certain processing activities with regard to it) where (i) you contest the accuracy of the personal data we have for you, (ii) you believe our processing of your personal data is unlawful (but you oppose the erasure of your personal data and prefer that our processing be restricted instead), (iii) we no longer need your personal data but you require such personal data for the establishment, exercise or defence of legal claims or (iv) you have objected to our processing pending the verification of our legitimate grounds for processing.

(4) Halting of Processing based on an objection

You have the right to object, on grounds relating to your situation, at any time to processing of personal data concerning you. If Kamili Villas can show sufficiently compelling legitimate grounds for processing your personal data, or Kamili Villas needs your data to establish, exercise or defend legal claims, Kamili Villas may continue to process it. Otherwise, Kamili Villas will stop using your personal data. Where we process your personal data for direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

(5) Personal data portability – The ability to move Guest Personal Data to another controller

You have the right to data portability in certain limited circumstances, where a) you provided the data to Kamili Villas, b) our processing is based on your consent or is necessary to fulfil a contract with you, and c) our processing is automated. Kamili Villas may refuse your request if these criteria are not met.

(6) To withdraw your consent to Kamili Villa’s Processing of your Guest Personal Data

Where we have relied on your consent as the legal grounds for processing, you may withdraw your consent at any time. Withdrawal does not invalidate the consent-based processing that occurred prior to withdrawal.

(7) To complain

You may contact us at any time where you believe that we are in breach of data protection laws or where you wish to make a complaint about our data processing. Furthermore, if you are located in the UK or EEA and you believe that our processing of your personal data is in breach of data protection laws, you have the right to lodge a complaint with the relevant data protection supervisory authority in the country where you are based or any place in the UK or EEA where you believe the infringement has occurred (or where you believe that we have not resolved an issue you have raised with us).

Responding to your requests

Kamilli Villas shall provide you with a response to any request you make in connection with your rights without undue delay and in any event within one month of receipt of the request.

  1. Security & retention

Kamili Villas maintains technical and organizational security measures to protect against unauthorized or unlawful processing of Guest Personal Data and accidental or unlawful loss, alteration, disclosure, destruction or damage of, or access to, Guest Personal Data.

Please be advised, however, that while we take reasonable security measures to protect your data, such measures cannot be guaranteed to be 100% secure.

Kamili Villas will retain Guest Personal Data no longer than is necessary to carry out the purposes listed in this Notice and/or as required by applicable law or in connection with actual or prospective legal proceedings or in accordance with accounting or reporting requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by sending an email.

In addition to the above, by law we must keep basic information about our guests (including contact information, identity, financial and transaction data) for seven years after they cease being guests for tax purposes.

  1. Changes to this notice

We reserve the right to change, modify, add, or remove portions of this notice from time to time and at our sole discretion.

Contact details: reception@kamilivillas.com