PRIVACY NOTICE FOR SHOPPERS
1. WHO ARE WE?
We are The Guildhall Shopping Centre, Exeter, Devon EX43HP, United Kingdom
We want to reach out to our customers and hear what they’re saying – whether it’s by giving us feedback or comments, agreeing to receive our newsletter or services or taking part in our competitions or competitions we’re running – we’re thrilled you’re joining the conversation.
You can use our online services to benefit from our services (such as wifi), take part in campaigns which we might run from time to time, complete a survey, join our mailing list to receive our ezine and emails so we can tell you about what’s happening and/or to benefit from deals and discounts we’re offering
2. WHAT IS THIS NOTICE?
When you interact with us, you may give us Personal Data about you. Personal Data means data which can be used to identify an individual. The individual who can be identified from the Personal Data is known as the Data Subject.
In respect of any such Personal Data, we are acting as a Controller (which means we are the business responsible for making the decision to collect the Personal Data in the first place, and deciding what to collect and how to use it). To help us to connect with our customers and run some of our marketing services, we use a marketing agency. Currently we use a company called Velocity Worldwide UK Ltd (Velocity) to manage our marketing services for us. This means that they may handle Personal Data as a Processor (they are acting on our behalf and authorised to use the Personal Data in accordance with our instructions).
This notice deals with our marketing activity and sets out what Personal Data we collect from you when you interact with our marketing agency and what we do with it.
If you have any questions relating to how we use Personal Data about you, please contact us at the address above or by email at email@example.com
3. WHAT INFORMATION DO WE COLLECT AND STORE?
We may collect and process the following data about you, some of which may include Personal Data:
i. INFORMATION WHICH YOU PROVIDE US WITH WHEN YOU USE INTERACT WITH US ONLINE: for example if you use our services (such as wifi), take part in campaigns which we might run from time to time, complete a survey, join our mailing list to receive our ezine and emails so we can tell you about events, and you can benefit from deals and discounts we’re offering). This may include:
• your name, address and phone number
• where you come from
• your gender
• online contact information
• any opinions or preferences which you express (including your likes and dislikes)
• details about your location
ii. TRANSACTIONAL DATA: that is, information which we might collect if you use a voucher, loyalty card, discount code or take part in a promotion which we are running. This will help us to learn about:
• your shopping preferences, interests, hobbies and habits
• your health, well-being and lifestyle choices
iii. TRAFFIC DATA: that is, information about which websites you access or offers you click on when you’re using our services.
iv. LOCATION DATA: we may collect information about your location from time to time if you have provided us with certain information. For example we may use the following technologies to recognise you when you come into our shopping centre:
• i-beacons, which enable us to communicate with your device using bluetooth
• wi-fi, which enables us to communicate with your device
4. HOW DO WE USE THE DATA WE COLLECT ABOUT YOU AND WHAT’S OUR LEGAL BASIS?
We may use the data we collect about you in the following ways:
(i) TO CREATE A PROFILE ABOUT YOU TO INFORM OUR MARKETING DECISIONS: We might do this to make sure we send you information which we think might be of interest to you, about campaigns we’re running and other events or discounts we’re offering (including surveys and information about goods and services which we think you’ll like and which seem to tie in with your interests). To do this, we may need to undertake analysis of your purchase habits and preferences. Once an account has been set up, profiling is an automated process which enables us to learn things about you. We set up the account on the basis that you have agreed we can use the information you provide us with for marketing purposes. You may ask us to delete your account at any time and we will promptly comply. You may set up a new account at any time.
(ii) TO SEND YOU MARKETING COMMUNICATIONS: contacting you by email, SMS, push notifications in our app, social media (and potentially by other communication channels which may become available in the future) to provide you with competitions, deals and information about products and events). We are relying on you signifying your consent to us. You are entitled to withdraw your consent to all marketing or marketing via particular channels at any time and we will promptly comply with your request.
(iii) TO PROVIDE SERVICES: for example, if you have provided us with your details so that you can receive particular services from us (such as signing in to wifi, taking part in a campaign, benefiting from a discount or taking part in a competition), we will use your Personal Data in order to make that happen. For certain campaigns and competitions, this may include transferring Personal Data related to you to a third providing the prize or whose goods or services are being promoted. If a transfer of this nature is required, we will publish the name of the third party recipient and let you know that the transfer is required before we do so. In this case, we are relying on the fact that such use of your Personal Data is required to provide you with the services you have requested. This may be a contractual obligation or based on you giving us your consent. You may let us know at any time if you want to pull out of a competition or stop receiving our services and we will promptly comply with your request.
(iv) INTERNAL BUSINESS REQUIREMENTS: we may use your Personal Data in accordance with our internal business requirements. For example we may need to retain back-up copies of data to make sure we have adequate safeguards in place to prevent loss of the data we hold; we may need to use your data to resolve disputes. In this instance, we are relying on the fact that such use is essential to protect a legitimate interest to enable us to run our business successfully. Any copies of the data held will be held securely and no further use shall be made of such data save as set out herein. We believe that such use would be generally anticipated by data subjects and is highly unlikely to cause any damage to or be considered by data subjects to be invasive of their privacy.
(v) STATISTICAL ANALYSIS: we may collect and use aggregate data, for internal market research, statistical analysis and data mining purposes and we may transfer this data at will to third parties. This data will be anonymised and you will not be identifiable from it.
5. WILL PERSONAL DATA ABOUT YOU BE DISCLOSED TO ANYONE ELSE?
i. We will not pass Personal Data about you to third parties for marketing purposes unless you have expressly consented to it.
ii. We may disclose your Personal Data to third parties for the following purposes:
• to our licensors, employees and third parties who are contracted to provide services to help us to carry out our business. Any employees and/or data processors (including Velocity) contracted by us will be subject to strict contractual requirements only to use your personal data in accordance with our instructions.
• If we sell or buy any business or assets. We will never sell Personal Data as a sole asset.
iii. We may disclose aggregate data to third parties for analysis and market research purposes. Any data so disclosed will not contain Personal Data.
6. WHAT SECURITY PROCEDURES DO WE HAVE IN PLACE?
6.1 It is our policy to ensure that all Personal Data held by us (or any Processors we use) is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to an individual as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.
6.2 We undertake regular security and risk reviews and we monitor all of the controls that we have in place to ensure the security, accuracy and integrity of the Personal Data we hold. We also endeavour to ensure that such data is only accessed by authorised personnel for a legitimate purpose (in accordance with our privacy notice).
6.3 We have a set of formal procedures that must be adhered to within our organisation to ensure that security standards are maintained and that data privacy is respected.
6.4 Our marketing agent, Velocity (which manages any data it collects for marketing purposes) is ISO27001 accredited by the BSI.
6.5 There are some steps you can take to help make sure that your data is protected. For example:
(a) if you are contacting us with a query or complaint, only ever give us your work details rather than your personal contact details;
(b) if you are sending any financial details or sensitive information, consider sending it in separate emails or encrypted, password protected documents; and
(c) make sure that you keep any passwords associated with your DARIUS account secure.
7. WHERE DO WE STORE THE PERSONAL DATA WE COLLECT?
We only use servers in the EU (and Britain). Our current host servers are provided by Amazon Web Services, whose servers are based in Dublin.
8. FOR HOW LONG DO WE STORE PERSONAL DATA ABOUT YOU?
8.1 We will retain and use Personal Data which we collect for marketing purposes in accordance with the following provisions:
• We will hold identity and contact data until asked by you to delete the data or cease such processing. In order to make sure that we are doing this transparently, we will give you the option to opt out in every communication we send. If we haven’t heard from you or had any interaction with you for over 2 years, we will contact you and ask you if you would like to be removed from our database.
9. WHAT RIGHTS DO YOU HAVE IN RESPECT OF ANY PERSONAL DATA WE HOLD ABOUT YOU?
9.1 Data Subjects have the following rights in respect of Personal Data relating to them which can be enforced against the Controller:
(a) Right to be informed: the right to be informed about what Personal Data the Controller collects and stores about you and how it’s used.
(b) Right of access: the right to request a copy of the Personal Data held, as well as confirmation of:
(i) the purposes of the processing;
(ii) the categories of personal data concerned;
(iii) the recipients to whom the personal data has/will be disclosed;
(iv) for how long it will be stored; and
(v) if data wasn’t collected directly from the Data Subject, information about the source.
(c) Right of rectification: the right to require the Controller to correct any Personal Data held about the Data Subject which is inaccurate or incomplete.
(d) Right to be forgotten: in certain circumstances, the right to have the Personal Data held about the Data Subject erased from the Controller’s records.
(e) Right to restriction of processing: the right to request the Controller to restrict the processing carried out in respect of Personal Data relating to the Data Subject. You might want to do this, for instance, if you think the data held by the Controller is inaccurate and you would like to restrict processing the data has been reviewed and updated if necessary.
(f) Right of portability: the right to have the Personal Data held by the Controller about the Data Subject transferred to another organisation, to the extent it was provided in a structured, commonly used and machine-readable format.
(g) Right to object to direct marketing: the right to object where processing is carried out for direct marketing purposes (including profiling in connection with that purpose).
(h) Right to object to automated processing: the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects (or other similar significant effects) on the Data Subject.
We may need to ask you for further information and identification to help us to comply with this request.
10. WHO DO YOU COMPLAIN TO IF YOU’RE NOT HAPPY WITH HOW WE PROCESS YOUR PERSONAL DATA?
If you have any questions or concerns about how we are using Personal Data about you, please contact our Data Protection Officer immediately at our registered address (see clause 1.1 above) or by email to firstname.lastname@example.org
If you wish to make a complaint about how we have handled Personal Data about you, you may lodge a complaint with the Information Commissioner’s Office by following this link: https://ico.org.uk/concerns/.
Last updated: 18-05-2018
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