This website is owned and controlled by Six Senses Con Dao. This Privacy Notice explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

This privacy policy includes information concerning:

• what information we collect

• how we collect it

• how we use it

• the security measures we take concerning your Personal Information

• whether it is shared and with whom

• your rights concerning your Personal Information

This privacy policy contains information on how Six Senses Con Dao collects, uses, and shares information collected from you as well as how such information is protected from unauthorized access. This privacy policy only covers the Site. By using the Site, you agree that Six Senses Con Dao may collect, use, and share information consistent with this privacy policy.

Effective Date of Privacy Policy

The effective date of this privacy policy is September 3, 2019.

Changes To Privacy Policy

Six Senses Con Dao may change this privacy policy from time to time. You can tell when this privacy policy was last updated by looking at the date at the top of the privacy policy. Any changes to this privacy policy will become effective upon posting of the revised policy on the Site.

If any of the changes to this privacy policy affect how Six Senses Con Dao treats or handles personally identifiable information or personal data collected from you such as your name, address, phone number, email address, credit card number or any other type of information that could identify you (“Personal Information”), we will notify you by email in advance of when such changes are scheduled to go into effect in order to give you the option to opt out of the changes. The email you receive notifying you in advance of changes to this policy will request that you opt in to the continued use of the Site. If you do not opt in, your consent will not be assumed and you will not be further contacted by us.

Collection and Use of Information

Six Senses Con Dao will explicitly state on the Site when Personal Information is required to be collected. This Personal Information is requested only for the following purposes: when making reservations, requesting a specific service, if you need us to contact you for any reason, to operate the Site, provide Site services, administer services reserved through the Site, contact you in response to a question or about a good or service you purchased or reserved through the Site, and/or to inform you of new features, services, and products.

We do not sell or otherwise make your Personal Information available to any third parties for their own use. However, subject to applicable laws, Six Senses Con Dao may collect, use and disclose to our business partners relevant portions of your Personal Information in order to, among other things:

• process your online reservations and bookings for our hotel/resort accommodation and spa services;

• provide and charge for the hotel/resort accommodation, spa services and other goods and services you purchase;

• provide you with a better, more personalized level of service;

• fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (such as travel agents or group travel organizers), and vendors (such as credit card companies and airline operators); and

• conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions.

We may collect your name, email address, telephone number, and any other information you choose to provide so that we may process your requests. All required and optional information is clearly denoted on any form that you are presented. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.

The Personal Information that we may collect about you broadly falls into the following categories:

Information you provide voluntarily

We ask you to provide certain information voluntarily. The types of information we ask you to provide, and the reasons why we ask you to provide it, include your contact details in order to make a reservation, book or purchase one of our services, subscribe to marketing communications from us, and to submit enquiries to us.

We will also ask you to provide your credit card details so that we can charge you for any purchases that you make during your stay at the hotel/resort.

If we ask you to provide any other Personal Information not described above, then the Personal Information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your Personal Information.

Information we collect automatically

We may also collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws.

Specifically, the information we collect automatically may include information, such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our website, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

Information we obtain from third party sources

From time to time, we may receive Personal Information about you from third party sources (including travel agents that have made a booking on your behalf), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your Personal Information to us.

The types of information we collect from third parties include your name, address, email, credit card rewards number and stay history. We use the information we receive from these third parties to honor your reservation.

Cookies

You should also be aware that information and data might be automatically collected from you through the standard operation of our internet servers and through the use of “cookies.” Cookies are small text files that a site can store on your computer. Six Senses Con Dao uses cookies to recognize repeat users, facilitate users’ ongoing access to and use of the Site, track Site usage behavior, and compile aggregate data that will allow content improvements and targeted advertising. Cookies generally neither damage your files nor allow us to personally identify you. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. You should note that some cookies may be necessary to provide you with some features offered on the Site, so any deletion of them may adversely impact how the Site functions to you.

Please note that by using the Site, you agree that your Personal Information and your other non-personal data may be transmitted to Vietnam.

How Collected Information Is Shared

Six Senses Con Dao does not sell any of your Personal Information to third parties for any reason. As noted above, Six Senses Con Dao may share some of your Personal Information with certain third parties in order to properly run its business, including the operation of its spa and hotel/resort services. For example, your name and credit card information will be shared with our credit card processing vendor in order to process payments. Personal Information is not shared with third parties for use in connection with their own purposes, but only Six Senses Con Dao own business purposes and to better serve our Site users.

Six Senses Con Dao may also disclose your Personal Information if required to do so by law, or in a good-faith believe that such action is necessary: (a) to comply with applicable law or with legal process served on Six Senses Con Dao or the Site; (b) to protect and defend the rights or property of Six Senses Con Dao or the Site; or (c) if Six Senses Con Dao ownership status changes, such as it being acquired by another party.

Online Reservations and Bookings

Online reservations and bookings for lodging at our hotels/resorts are handled by a third party vendor, namely, Sabre Hospitality Solutions (“SynXis”). In connection with making lodging reservations and bookings, you will leave the Site and go to a site maintained by SynXis. Further, when making lodging reservations or bookings through the site maintained by SynXis, you will be bound by SynXis’s privacy policy regarding the collection of information. Please note that any information you provide to SynXis as part of reserving or booking lodging at Six Senses Con Dao hotels and resorts will be shared with Six Senses Con Dao for reasons consistent with how we use information collected directly through the Site.

Legal Basis for Processing Personal Information

Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about, or need further information concerning, the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided below.

Data Retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Your Data Protection Rights

You have the following data protection rights:

• If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us using the contact details provided below.

• In addition, you can object to the processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided below.

• You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided below.

• Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time.

• Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the EEA, the UK and certain non-European countries (including the US and Canada) are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Security of Information

Six Senses Con Dao uses appropriate technical and organizational measures to protect the Personal Information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. While Six Senses Con Dao takes the security of your information seriously, there is no system that is one hundred percent secure from outside threats. Six Senses Con Dao cannot guarantee that information sent over the Internet is fully secure, nor will it remain fully secured once on Six Senses Con Dao’s system.

Children’s Privacy

The Site is not marketed to or directed at, nor intended for, children under 18 years of age. Six Senses Con Dao does not knowingly collect any information from children under 18 years of age. If Six Senses Con Dao learns that it collected any information from someone younger than 18 years of age, Six Senses Con Dao will delete the information.

Miscellaneous

Your Personal Information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. However, we have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Notice.

The Site may contain links to external sites not controlled and/or affiliated with Six Senses Con Dao and therefore not bound by this privacy policy. If you access these linked sites, you will be subject to the privacy practices of those sites.

Your use of the Site is also governed by our Terms and Conditions found in the previous link, which terms are incorporated by reference into this privacy policy.

If you need to contact Six Senses Con Dao for any reason, including if at any time you believe that Six Senses Con Dao has not adhered to this privacy policy, please notify Six Senses Con Dao using the below information and we will use all reasonable efforts to promptly determine and correct the problem.

Six Senses Con Dao

Email: reservations-condao@sixsenses.com

Telephone: +84 28 3823 2229