Privacy Policy

This privacy policy ("Privacy Policy") applies to Cometa Living PLC. Cometa Living respects the privacy of every person who visits or registers with [www.cometaliving.com] and its affiliated website and who uses the services and products that we make available through our Site and our villas (our "Services"). We are committed to protecting your privacy and to ensuring a safe online experience.

1. Purpose of this Policy

This privacy policy ("Privacy Policy") explains how we process any personal information that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it.

Please also note that this Privacy Policy only applies to the use of your personal information provided, or obtained by us directly. It does not apply to personal information collected during your communications with third parties.

2. How to contact us?

General privacy matters

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an email to our contact inbox at: [contac@cometaliving.com]

In all correspondence, please provide:

the name, contact number, email address (if any) and address of the person submitting the complaint, feedback or enquiry; and
the relevant details pertaining to such complaint, feedback or enquiry such as the relevant time period, our employees or personnel involved, or copies of such relevant documents, if applicable.

3. What personal information do we collect and how do we use it?

We (and our service providers) use your personal information for legitimate business interests including the following:

to provide our Services to you, including enabling you to make, and us to accept, reservations online for our Villas and enjoy our Services;
to create and operate an account;
to verify your identity;
to help us improve our Services, and develop and market new products and services, including those of our affiliated companies;
to carry out any requests made by you on the Site;
to investigate or settle inquiries or disputes;
to comply with any applicable laws, court order, other judicial process, or the requirements of a regulator;
to enforce our agreements with you;
to protect any of our rights, property or safety or those of any third parties, including our other customers and users of the Site and visitors to our Villas and Locations;
to provide support for the provision of our Services; and
to use the information as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

3.1 Fulfillment of Services

We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or through your purchase of our Services. We also may receive your personal information from third parties you have used to purchase our Services.

We use the contact and payment details you have provided to us or
third parties so that we can fulfil the supply of Services you have purchased, including but not limited to:
providing you with any information, products or services you request
from us;
processing reservations, where we will ask for your name, mailing address, billing address, email address, telephone number, credit card information, arrival and departure dates, and airline frequent flyer (or any other applicable customer loyalty) programme information. We may also ask you to provide identification, e.g. your passport and details of your vehicle registration; and/or
processing your room preferences and any other special requests or needs, including allergy or dietary information.

3.1.1 With whom do we share your personal information for this purpose?

Your personal information will be shared within Cometa Living for the above purposes and with the following categories of third parties:

To verify card payments and process refunds -- we may share your information with credit card companies and other payment providers.
To help us manage our customer relationships and fulfil our Services
-- we use a variety of third party vendors who provide us with systems and platforms to help us provide Services to you.
To manage aspects of our Site -- we use a variety of third party suppliers to help us operate features on our Site or facilitate the delivery of any products and/or services purchased through our Site.

Please note this list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide the Services to you.

3.1.2 What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we or a third party may have with you.

3.2 Registration and management of your Cometa Membership account and other accounts associated with our Site and/or Services.

We collect your name, gender, email address, date of birth, and telephone number when you sign-up to our Cometa membership program. You can update your personal information by logging onto the Cometa website (via www.cometaliving.com)

We use this information in order to create and manage your account and to understand our customer base. Please see the "Customer Insight and Analysis" section below for more details about the personal information collected and how it is used.

3.2.1 With whom do we share your personal information for this purpose?

Your personal information will be shared within Cometa Living for the above purpose and certain third parties, including vendors that provide our Customer Relationship Management system and other systems and platforms that help us manage your account.

3.2.2 What is our legal basis?

It is in our legitimate business interests to use the information you or third parties provide to us for the programmes and/or purposes described above.

3.3 Other food & beverages services

As a part of our Services, we host events on behalf of third party entities and organisations and may otherwise provide food and beverage. We collect and maintain personal information that you voluntarily submit to us or which we collect from the third party entity or organisation whose event we are hosting.

We collect this personal information so that you can participate in or attend such events, and/or consume such food and beverages. The personal information that we may collect includes your name, contact details, details of allergies or any special dietary or other requests which have been submitted by you or the third party entity or organisation on your behalf.

Where events are hosted on behalf of political or religious organisations or trade unions, we may, by collecting your name and recording your participation at the event, indirectly process personal data revealing political opinions, religious or philosophical beliefs, or trade union membership. You may also be subject to the privacy policy of the applicable third party when signing up to or attending an event.

3.3.1 With whom do we share your personal information for this purpose?

Your personal information will be shared within Cometa Living for the above purpose and we sometimes share your personal information with third party event planners who help us to manage events.

3.3.2 What is our legal basis?

It is in our legitimate business interests to use the information you or third parties provide to us for events for the purposes described above.

Where we process 'special categories of personal data', including details of allergies or your association with political or religious organisations or trade unions, we rely on your explicit consent to process such special categories of personal data', which we obtain from you directly or via the relevant third party entity or organisation.

3.4 Customer services

Our Site, our Villas and Co-livings and other Cometa Living Businesses use various user interfaces to allow you to request information or provide general feedback about our Services: these include a printed and electronic enquiry forms, including the forms available here: https://www.cometa.living.com/contact-us/

Contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests and feedback.

3.4.1 With whom do we share your personal information for this purpose?

Your personal information will be shared within Cometa Living for the above purpose. We do not share your personal information with third parties for this purpose.

3.4.2 What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

3.5 Your feedback about our Services

From time to time, we will use your name and contact details to invite you to provide feedback about our Services in the form of online or in-hotel surveys. Alternatively, you may voluntarily provide us with personal information when giving feedback regarding your stay at our Villas and Locations or experience with the Services we provide. We use this information to help us monitor and improve the quality of service provided by our staff and in our Villas and/or Other Cometa Living Businesses, and to assist us with the selection or development of future types of services.

3.5.1 With whom do we share your personal information for these purposes?

Your personal information will be shared within Cometa Living for the above purpose and we use a third party service provider to assist us with customer surveys and feedback requests.

3.5.2 What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

3.6 Customer insight and analysis

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or by providing Services to you, such as the products and services you have purchased or viewed, or from your use of our in-hotel wifi.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

an IP address to monitor Site traffic and volume;
a session ID to track usage statistics on our Site;
information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.

Our web pages and emails contain "cookies" or "pixel tags." ("Tags"). Tags allow us to track receipt of an email to you, to count users that have visited a web page collect other types of aggregate information. In some of our email messages, we use a "click-through URL" linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

Please see our Cookie Policy for further information.

This information is used to create profiles and insights about your purchase habits and the purchase habits of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our guests, which parts of our Site are the most interesting and what kind of offers our registered users like to see.

We also use this information:

*to help us with the selection of future product and service lines,
villas and locations and to remember your preferences; and/or*
*for marketing purposes (see the marketing section below for further
details).*

3.6.1 With whom do we share your personal information for these purposes?

We share your personal information with a variety of third party service providers to assist us with customer insight analytics. These providers are described in our Cookie Policy.

3.6.2 What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

3.7 Marketing communications

We carry out the following marketing activities using your personal information:

3.7.1 Email marketing, WhatsApp marketing and SMS marketing.

We use information that we observe about you from your interactions with our Site, our email, WhatsApp and / or SMS communications to you and/or by providing Services to you (see the Customer Insight and Analysis section above for further details of the information collected and how it is used) and/or your email address, to send you marketing communications by email, WhatsApp or SMS where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

3.7.2 With whom do we share your personal information for these purposes?

Your personal information will be shared within Cometa Living PLC for the above purpose and we share your persona information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.

3.7.3 What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

3.7.4 How can I unsubscribe from receiving email, WhatsApp or SMS marketing communications?

You can unsubscribe from emails at any time by clicking "unsubscribe" at the bottom of any marketing email message you receive. If you unsubscribe, you will still receive service communications from us about your reservation and stay.

You can unsubscribe from WhatsApp messages at any time by following the instructions given in any marketing WhatsApp message

You can unsubscribe from SMS communications at any time by following the instructions in any marketing SMS.

3.7.5 Online personalised advertising

3.7.6 Social media remarketing

We use information that we observe about you from your interactions with our Site, our email communications to you and/or by providing Services to you (see the Customer Insight and Analysis section above for more details of the information collected and how it is used) to provide you with personalised advertising on social media channels operated by Facebook, Instagram, Tik Tok and/or Google where you are a registered user of such services. We do this using custom audiences, customer match and/or similar services. Please note that such activity is also subject to the privacy choices you have elected on such services.

3.7.6.1 With whom do we share your personal information for these purposes?

Your personal information will be shared within Cometa Living for the above purpose and with the following categories of third parties:

We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party service providers with Facebook, Instagram, Tik Tok and/or Google under the terms of their respective custom audiences, customer match and/or similar services.

3.7.6.2 What is our legal basis?

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

3.7.7 Social media insight

Where you are a registered user of Facebook, Instagram, Tik Tok, or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

*information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services in our Villas and Locations (see the Customer Insight and Analysis section above for more details of the information collected and how it is used); and*
*the information Facebook, Instagram, Tik Tok and/or Google hold about you.*

We do this using lookalike audiences, similar audiences and/or related services. Please note that such activity is subject to the privacy choices you have elected to make on such services.

3.7.7.1 With whom do we share your personal information for these purposes?

Your personal information will be shared within Cometa Living for the above purpose and with the following categories of third parties:

To administer marketing campaigns -- we share your email address with third party service providers who assist us with social media remarketing
To utilise social media platforms -- your encrypted email address is also shared by us or our third party marketing consultancies with Facebook, Instagram, Tik Tok and/or Google under the terms of their respective services, such as lookalike audiences and/or similar audience services.

3.7.7.2 What is our legal basis?

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

3.8 Prize draws, prize competitions and other promotions.

From time to time, we may run prize draws, prize competitions and other promotions on our Site, through our social media accounts, and/or in our Villas and Locations and/or Other Cometa Living Businesses. For the purposes of administering such promotions, we may process your name, contact details (including email address, postal address and/or telephone number), social media handle (if relevant) and any other personal information volunteered by you in your promotion entry.

3.8.1 With whom do we share your personal information for this purpose?

Your personal information will be shared within Cometa Living for the above purpose and we may share your personal information collected in connection with any prize draws, prize competitions and other promotions that we run with third party providers that assist us with the administration of such promotions from time to time.

3.8.2 What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (e.g., the terms and conditions applicable to the promotion) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions.

3.9 Careers

We may collect personal information in order to consider and process any enquiries or applications regarding our employment opportunities. We collect and maintain personal information that you voluntarily submit to us or which we collect from third party recruitment agencies for this purpose. The information that we collect may include your name, contact details, education details, and any other information that you include on your CV, résumé and any cover letter.

You can apply for vacancies here: Cometa Living Careers. Where you apply for a vacancy using LinkedIn, we may collect any information you make publicly available through LinkedIn. We also may use this information in order to communicate with you about your application.

3.9.1 With whom do we share your personal information for this purpose?

We may share your personal information with third party service providers who assist us to match applicants with job vacancies.

3.9.2 What is our legal basis?

It is in our legitimate business interests to use the information you provide to us when you apply for a job vacancy for the purposes described above.

3.10 Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

to comply with our legal obligations;
to enforce our legal rights;
to protect rights of third parties; and
in connection with a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets.

3.10.1 With whom do we share your personal information for these purposes?

Your personal information will be shared within Cometa Living for the above purpose and we will share your personal information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We will share your personal information with professional advisers such as lawyers and accountants, our insurers and/or governmental or regulatory authorities.

3.10.2 What is our legal basis?

Where we use your personal information in connection with a business transition, enforcing our legal rights, or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us, such as a court order.

4. Where we share your sensitive personal information, we shall obtain your consent to do so.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

5. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

at the time we collect your personal information following the instructions provided; or
by informing us by email or post using the contact details set out in this Privacy

6. Our use of cookies and similar technologies

Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

7. Third party links and services

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website of, or you request a service from, a third party, this Privacy Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, are subject to that website's or third party service provider's own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider with which you interact and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Services and does not apply to these third party websites and third party service providers.

8. PayPal transactions

All PayPal transactions made through our Site are subject to the PayPal Privacy Policy located at www.paypal.com.

9. Disclosures of personal data

[Disclosure to Internal Third Parties]

We may share your personal data within Cometa Living and some entities within Cometa Living may provide services as processors to the controllers who are responsible for handling your personal data.

[Disclosure to External Third Parties]

We set out in Section 4 the purposes for which we may have to share your personal data with third parties, and the types of third parties with whom we share your personal data. In addition, we generally share personal data with third parties as follows:

Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, shareholder services, legal, insurance and accounting services.
Regulators and other authorities, including tax authorities, acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions, or otherwise as required for their own regulatory compliance.

10. Overseas transfers of personal data

Due to the global nature of our business and that of our third party suppliers who process your personal data on our behalf, personal information we collect from you may be transferred, processed and stored overseas including (where applicable) outside the jurisdiction where the personal information is collected.

Although the data protection laws of these other countries may not be as comprehensive as those in your own, we will take all necessary steps to ensure that your personal information is treated securely, and in accordance with this Privacy Policy and any applicable laws.

In particular, where your personal data is transferred from one jurisdiction such as the EU, EEA or Israel to a jurisdiction outside of it, we will comply with our legal and regulatory obligations (and will ensure that our third party suppliers comply with their obligations) in relation to the personal information, including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

In respect of our third party suppliers, the use of personal data transferred outside the EEA shall (where applicable) be governed by contracts incorporating EU approved model clauses or the transfer shall be subject to another lawful transfer mechanism.

In respect of transfers within Cometa Living , the use of personal data transferred outside the EEA is governed by an intra-group data sharing agreement which incorporates EU approved model clauses.

11. How long do we keep your personal information for?

We hold your personal information in accordance with our data retention policies. Generally, we do not keep personal information for longer than is necessary for the purposes for which it was collected.

If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period.

If you have opted out of / unsubscribed from receiving marketing communications from us, we will need to retain certain personal information indefinitely so we do not send you marketing communications again.

12. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.

All of our employees and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

13. How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you:

13.1 Your right of access.

If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

13.2 Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we have shared your personal information so that you can contact them directly.

13.3 Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it, if you withdraw your consent (where applicable), or where you close your Luna Nueva loyalty programme account. However, note that we may retain some of your personal information for a reasonable period of time, even after you withdraw a consent or close your Luna Nueva loyalty programme, for legal or compliance purposes. If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you with whom we have shared your personal information so that you can contact them directly.

13.4 Your right to restrict processing.

You can ask us to 'block' or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it. It would not stop us from storing your personal information, though, or fulfilling contractual obligations, for example. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you with whom we have shared your personal information so that you can contact them directly.

13.5 Your right to data portability.

You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

13.6 Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we are:

*relying on our own or someone else's legitimate interests to

process your personal information, except if we can demonstrate compelling legal grounds for the processing; or*
processing your personal information for direct marketing.

13.7 Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you. However, we may conduct automated decision-making and/or profiling where it is necessary for entering into, or the performance of, a contract between you and us.

Examples of automated decision-making and/or profiling include if we use software to automatically scan employment applications and match candidates to job vacancies, or if we were to utilise an aptitude test with algorithms or automated criteria for decision-making in our recruitment process.

13.8 Your right to withdraw consent.

If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

13.9 Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the UK Information Commissioner's Office (ICO). You can find details about how to do this on the ICO website at [https://ico.org.uk/concerns/] or by calling their helpline on 0303 123 1113.

You may contact us at [contact@cometaliving.com] to process any of the foregoing requests in this Section 14.

14. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information or our business practices. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email (if we hold it) of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.