www.cooperbvi.com (the “Site”) is owned and operated by Cooper Island Beach Club Ltd.

Cooper Island Beach Club Ltd is the data controller and can be contacted at:

[email protected]

Manchioneel Bay, Cooper Island, BVI, VG1110

Purpose

The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

1. The personal data we will collect;

2. Use of collected data;

3. Who has access to the data collected; and

4. The rights of Site users.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European

Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the

“GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection

Act 2018.

Consent

By using our Site users agree that they consent to:

1. The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that

processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make

processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by: Contact [email protected].

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so

under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:

1. Users have provided their consent to the processing of their data for one or more specific

purposes.

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect

any additional data beyond the data listed below without notifying you first.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

1. Email address.

This data may be collected using the following methods:

1. When using the email links.

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated

on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy

Policy.

The data we collect when the user performs certain functions may be used for the following purposes:

1. Communication.

Who We Share Personal Data With

Employees

We may disclose user data to any member of our organization who reasonably needs access to user data

to achieve the purposes set out in this Privacy Policy.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;

2. If it is required for any legal proceeding;

3. To prove or protect our legal rights; and

4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and

have no control over their privacy policies and practices.

How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data

No data is saved. Your data is only used to respond to email information and reservation requests.

While we take all reasonable precautions to ensure that user data is secure and that users are protected,

there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we

are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User

Under the GDPR, you have the following rights:

1. Right to be informed;

2. Right of access;

3. Right to rectification;

4. Right to erasure;

5. Right to restrict processing;

6. Right to data portability; and

7. Right to object.

Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that

we have collected personal data from a child under 16 years of age, the personal data will be deleted as

soon as possible. If a child under 16 years of age has provided us with personal data their parent or

guardian may contact our data protection officer.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data,

if we have disclosed your personal data and to who we disclosed your personal data, if you would like

your data to be deleted or modified in any way, or if you would like to exercise any of your other rights

under the GDPR, please contact our data protection officer here:

[email protected]

(284) 343-4949

Manchioneel Bay, Cooper Island, BVI, VG1110

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and

to reflect any changes to our data collection process. When we amend this Privacy Policy we will update

the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review

our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by

email of changes to this Privacy Policy.

Complaints

If you have any complaints about how we process your personal data, please contact us through the

contact methods listed in the Contact Information section so that we can, where possible, resolve the

issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a

supervisory authority. You also have the right to directly make a complaint to a supervisory authority.

You can lodge a complaint with a supervisory authority by contacting the

[email protected]________________________________________________________

______

Contact Information

If you have any questions, concerns or complaints, you can contact our data protection officer at:

[email protected]

(284) 343-4949

Manchioneel Bay, Cooper Island, BVI, VG1110

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