1. PRIVACY & COOKIES POLICY
1.1 This User Privacy Notice (“Privacy Notice” or “Notice”) was last updated on 19th January 2018. This Privacy Notice may vary from time to time so please check it regularly.
1.2 This Privacy Notice explains our privacy and information practices for our website, mobile applications, provision of Wi-Fi and related services and centres (together, “Online Services”). This Notice describes the types of information collected, how that information is used and disclosed, and how you can access, modify, or delete your information.
1.3 Land Securities Properties Limited (company number 961477) whose registered office is at 100 Victoria Street London SW1E 5JL (“we”, “us” or “our”) is the ‘data controller’ for the personal data we collect. We are registered with the Information Commissioner’s Office with registration number Z5806812.
2. HOW DO WE COLLECT INFORMATION FROM YOU?
2.1 Through our Online Services we collect information about you when you sign up to receive our Online Services, email updates, fill out a feedback form, complete a “contact us” form, buy a gift card or enter a promotion. Not all of the input fields are mandatory and so provision of the information is optional, but if you provide less information this may limit your use of the Online Services or any product or service.
2.2 Where we send you information electronically, we do review whether the communication has been opened and whether you have clicked on any links in the communication. This is because we want to make sure that our communications are useful for you.
2.3 If you use one of the Wi-Fi networks in our centres, we will collect personal information from you, such as your name and email address in order to log you on to the Wi-Fi network. Through this Online Service, we may also collect data which shows how often, how long and from which one of our centres you are accessing the Wi-Fi services, which will include recording the address of your device that connects to the Wi-Fi network.
2.4 We use Wi-Fi within some of our centres that may communicate with your (mobile) device and identify its location if the device has Wi-Fi enabled and is properly configured. This will operate irrespective of whether or not you have subscribed to the Wi-Fi service or any other Online Services. When this location information is analysed it will be aggregated to prevent any identification of individuals. To opt out of the collection of your MAC or Internet Protocol (IP) address and location, turn off your device’s Bluetooth and Wi-Fi capabilities.
2.5 If you choose to log-in to our Online Services through your own Social Media accounts, we will also have access to data that is shared from your Social Media provider. Information of what personal data is being shared should be provided to you by your Social Media provider.
2.6 We may collect information about your computer or other device, including where available your MAC address, IP address, operating system and browser type, for system administration and to analyse aggregate information. This is statistical data about browsing actions and patterns, and does not identify any individual.
2.7 We may also collect information from you automatically when you access and use our Online Services, including the time and duration of your visit, the referring URL, your Internet Protocol (IP) or MAC address, the type of device you use and its operating system. As with most websites, we also operate cookies on ours and further details can be found in the section on cookies below.
3. HOW DO WE USE THE INFORMATION WE COLLECT?
3.1 We may use and process the information you have provided for the purposes outlined below as well as for any purposes specified at the time of collection:
a) to fulfil a contract by providing the relevant Online Service or information which you have requested, such as providing access to the Wi-Fi service, or fulfilling your order for a gift card;
b) to deal with your enquiries;
c) to pursue our business interests to tailor the Online Services so the content you see is relevant to you. For example, we may request your date of birth, gender and some basic interests (such as ‘shopping’ and ‘dining’) so that we can provide you with content that we think you will be interested in;;
d) to pursue our business interests to collect statistics, responses to any surveys and questionnaires, traffic patterns and related site information, including data analytics concerning traffic around our centres. For example, where we have a post code we will use this to understand where customers travel from to reach our centres. We aggregate this data so as it does not identify any individual visitors. We use it for research, analysis, testing, monitoring, risk management and administrative purposes including the optimisation of service delivery at our properties and to improve the customer experience; and
e) to send you important notices such as communications about changes to this Privacy Notice and any terms and conditions and policies of our Online Services.
3.2 If you consent, we may use your information to contact you via email SMS or social media channels about our new developments, services and any other information we think may be of interest to you. We may pass your details within our group of companies so that they can contact you via email SMS or social media with details of developments and activities which may interest you.
3.3 We may also pass on or allow access to your information:
a) to third parties to deliver a service to you, such as where you have purchased a gift card or where you have requested access to WI-FI;
b) to our suppliers, contractors and professional advisors where this is necessary for them to provide services and facilities to us, for example:
to enable marketing agencies to generate newsletters on our behalf;
to put your email and preference data in a marketing database that is used to send you email marketing;
to pay for parking services; and
to collate the responses you have provided through our feedback forms with our survey providers.
c) to any purchaser of all or part of our business or any of our properties to which the Online Service relates;
d) to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers;
e) where we are required to do so by law, court order or other legal process;
f) where, acting in good faith, we believe disclosure is necessary to assist in the investigation or reporting of suspected illegal or other wrongful activity. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
g) to protect and defend our rights or property;
h) to deal with any misuse of any Online Services; or
i) in order to enforce or apply our terms and conditions and other agreements with third parties.
3.4 We may disclose your personal data to our group companies and affiliates or third party data processers who may process data on our behalf to enable us to carry out our usual business practices.
4. DATA RETENTION
4.1 We retain the information we collect for as long as necessary to provide the Online Services and any other products and services you have requested, or for other essential purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
5. YOUR RIGHTS
5.1 When you use our Online Services and provide us with your personal data you are agreeing that we may use your personal data for the purposes set out in this Privacy Notice.
5.2 You have the right to opt out of receiving any marketing information which we send you.
5.3 If our processing of personal data is based on your consent, you have the right to withdraw consent for future processing at any time by contacting us. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason (other than consent) for doing so;
5.4 You have the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
5.5 As of May 25, 2018, in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to us;
5.6 You have the right to request that we correct your Personal Data if it is inaccurate or incomplete;
5.7 You have the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
5.8 As of May 25, 2018, you have the right to request that we restrict our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your Personal Data but we are legally entitled to refuse that request; and
5.9 You have the right to lodge a complaint with your Data Protection Authority. In the U.K, this is the Information Commissioner’s Office.
6.1 Children under the age of 16 are not permitted to use Wi-Fi networks.
6.2 If you have reason to believe that a child under the age of 16 has provided personal information, please contact us and we will delete that information from our databases.
7.1 Cookies (and similar technologies) are small files which are sent by websites and stored on your device. They collect information about how the website is being used by those accessing it and allow websites to remember information. You can find out more about cookies at www.allaboutcookies.org.
7.3 Most devices will automatically accept all cookies. However, you can change your browser settings so that cookies are refused. Guidance on how to change your settings can be found at the website referred to above or look at the “help” menu of your device. Please be aware however that blocking cookies may hamper the website’s functionality or restrict how much of the website you can access.
8. TRANSFERING INFORMATION OVERSEAS
9. LINKS TO OTHER WEBSITES
9.1 This Privacy Notice only applies to the Online Services and websites provided by us. If you link to another service and/or website from here, you should remember to read and understand that service and/or website’s privacy and cookies policy as well. We are not responsible for any use of your information that is made by other services and/or websites. Links or advertisements do not imply that we endorse or have reviewed such third parties or their privacy practices.
10. CHANGES TO THE PRIVACY & COOKIES POLICY
10.1 This Privacy Notice was last updated on 19th January 2018. If it is necessary for us to alter the terms of the Privacy Notice, we will post the revised Privacy Notice here. We encourage you to frequently review the Privacy Notice for the latest information on our privacy practices. For any material changes to the Online Services, we will also notify you by email.
11. HOW USERS CAN CONTACT US