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LAST UPDATED: October, 13th 2020

KOMPOSE SARASOTA, LLC (the “Company”) is concerned about privacy issues and wants you to be familiar with how it collects, uses and discloses your Personal Information. This policy covers the Company websites (the “Websites“) and Services (as defined below) and is applicable to the Company. This Privacy Policy informs you as to how the Company looks after your Personal Information and tells you about your privacy rights and how the law protects you. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

Important Information

This Privacy Policy aims to give you information on how the Company collects and processes your Personal Information through your use of its Websites and Services, including any data you may provide through the Websites when you sign up to the Company’s newsletter, make a booking reservation, log on to our WiFi network, take part in an event, or take part in a competition.

The Company’s Services are not intended for children and we do not knowingly collect data relating to children. 

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your Personal Information so that you are fully aware of how and why we are using your Personal Information. This Privacy Policy supplements the other notices we may provide to you and is not intended to override them.


The Company is the controller and is responsible for your Personal Information.

Contact Us

Full name of legal entity: KOMPOSE SARASOTA, LLC

Email address:


Attention: Legal Department
2080 Ringling Blvd

Sarasota FL 34237


Personal Information We Collect

Personal Information” is information that identifies you as an individual or relates to an identifiable person, including: 

Third Parties

We may use a third-party payment service to process payments made through the Services.  It is our policy to only share Personal Information with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.  If you wish to make a payment through the Services, your Personal Information may be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information. 

We may also disclose your Personal Information to a third party when you ask us to do so or when we believe it is required by law. 

If you submit any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We Collect Personal Information

This Privacy Policy describes our practices in connection with Personal Information that we collect through the Websites operated by us from which you are accessing this Privacy Policy , through the software applications made available by us for use on, or through, computers and mobile devices (the “Apps“), through social media websites and third-party services such as Expedia or Open Table (“Third Parties“) through which we collect or receive Personal Information from, or about, you, through HTML-formatted email messages that we send to you that link to this Privacy Policy, and through our WiFi network (“WiFi“) (collectively, including the Websites, Third Parties, WiFi and the Apps, the “Services“). 

We and our third party service providers may collect Personal Information in a variety of ways, including:

How We Use Personal Information

We will only use or disclose your Personal Information when the law allows us to. Most commonly, we use or disclose your Personal Information in the following circumstances:

Generally we do not rely on consent as a legal basis for processing your Personal Information, other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at  Please note that if, in the event we rely on your consent to process your Personal Information, you withdraw your consent we may no longer be able to provide you with: (a) updates and promotions; (b) the best user experience possible to our Services; (c) the best customer experience. 

We have set out below a description of all the ways in which we plan to use your Personal Information:

How We Disclose Your Personal Information We will only disclose your Personal Information when the law allows us to. Most commonly, we disclose your Personal Information in the following circumstances: 


Other Information We May Collect

Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as: 

How We May Collect Other Information / Online Tracking

We may collect Other Information in a variety of ways, including: 

How We May Use and Disclose other information 

We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat other information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

We may combine other information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.


This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link.  The inclusion of a link on the Services is solely for your convenience, and the inclusion of such links does not imply endorsement of the linked site or service by us or by our affiliates. You access linked sites at your own risk and by accessing them you leave the Services.

We are not responsible for the information collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, and we encourage you to check the applicable privacy policy to determine how these linked sites will handle any of your Personal Information.


We seek to use appropriate organizational, technical and administrative measures to protect Personal Information within our organization, including: (a) the pseudonymization and encryption of your personal information where appropriate; (b) ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) ensuring we can restore access to personal information in a timely manner if a physical or technical incident occurs; and (d) regular testing, assessment and evaluation of the effectiveness of our technical and organizational measures to ensure your personal information is secure.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure and we cannot ensure the security of the information that you transmit.  If you have reason to believe that your interaction with us is no longer secure, please immediately contact us in accordance with the “Contacting Us” section.


Your choices regarding our use of your Personal Information

You may opt out from receiving electronic communications from us.  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out of receiving them by following the instructions contained in each such message.  

We will try to comply with your request as soon as reasonably practicable. If you opt-out, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or suppress your Personal Information

If you would like to review, correct, update, suppress or delete Personal Information that you have provided to us, contact us at the address below.  In your request, please make clear what Personal Information you would like to have changed, whether you would like to have the Personal Information you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of the Personal Information you have provided us.  For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.  

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.  There may also be residual information that will remain within our databases and other records and which will not be removed.


We will retain your Personal Information for the period necessary to provide the Services. Processing is therefore necessary for the purposes of our legitimate interest, unless a longer retention period is required or permitted by law.  


The Services are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Services. 


We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Information.  

Since we are a global organization, Personal Information and any additional information submitted may be used globally in connection with employment, business processes within the Company, or communicating with our clients. Therefore, Personal Information may be transferred to other Kompose entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

If we transfer your Personal Information out of your jurisdiction, we will implement suitable safeguards or rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Information is protected.


The California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request please contact us at the address provided.  


You have rights under data protection laws in relation to your Personal Information: You have the right to:

In respect of exercising your rights, please note: 

No fee usually required. 

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. 


We may change this Privacy Policy.  The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised.  If there are any material changes to this Privacy Policy or our information practices change in the future, we will notify you by posting the changes to the Website. Any changes will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy.