Westquay are committed to protecting any personal data you provide to us, including information you provide or we collect when you use our digital channels, including our app, Westquay PLUS, and their features.
We believe it is important for you to know what personal data we collect and how we use it. This policy (together with our terms and conditions and any other documents referred to in it) explains the personal data we process, what it is used for and the legal basis upon which we process this information. It also explains legal rights you may have to control that processing.
About us and how to contact us
Westquay are part of the Hammerson Group, and both Westquay and other Hammerson group companies, including Hammerson Group Management Limited are data controllers in respect of your data.
Our contact address is Kings Place, 90 York Way, London, N1 9GE.
What personal data do we process
We process the personal data set out below, provided to us by either you or your device when either accessing our website or using Westqauy PLUS.
There is no obligation on you to provide the information listed below; however, if you do not, we may be unable to engage with you, open an account for you, send you the materials you have requested or allow you to enter competitions or redeem offers if we do not have the necessary information to do so.
The type of data that we process about you includes:
Information you have given to us by filling in forms or by signing in using your Facebook, Twitter or G+ accounts, or by communicating with us, including name, address, title, contact details including email address and mobile telephone number, date of birth, details of any offer or competitions you have signed up for, any communications you may have with us (including reporting problems with our site), preferences as to any methods and types of marketing information you have consented to receive, your username (account ID) and password when opening an account.
Information we collect from or observe about you when you use our services, including:
(a) Geolocation data provided by your smartphone or other mobile device to access our services using the App, provided that you have consented to the App collecting this data on your smartphone or other mobile device. If you no longer wish to share this Geolocation data, you can de-activate it using your smartphone’s location settings.
(b) Device and Website Use Information – When you install one of our mobile applications or use a computer, tablet, smart phone or other device to access our websites, we may collect information about the device and how you use it.
(c) Images of you collected from CCTV cameras in operation at Westquay.
How we use it
Sending marketing messages or otherwise engaging with you
We use your data to
· send you marketing information by various channels including email, SMS, mail or telephone, or push messages if you use our app, including sending notices of new products, special offers and other marketing materials to enhance and support your relationship with Westquay. We will use this data in accordance with any preferences you have selected, either on the basis of consent (where requested) or of legitimate interests where you have not objected to receiving such information.
We may also use your data for our own legitimate interests, which include:
· sending you surveys or supporting Marketing Research activities to you in other ways to help us improve our services and understand our customers better;
· allowing you to participate in interactive features of our service, when you choose to do so;
· ensuring that content from our digital channels is presented in the most effective manner for you and for your computer/smart phone and/or tablet;
· allowing us to investigate and respond to any issues or correspondence received;
· administering your online account and any promotion or competition which you have entered;
· administering your online account and any event tickets you have purchased, promotion or competition which you have entered;
· notifying you about changes to our services.
We believe that these interests are justified as it is completely optional for you to register, participate or otherwise provide us with Personal Data in the above situations. You will be able to object to this processing at any time. For more information, please see Your rights below.
Geolocation and Device and Website Use
We use Geolocation and Device and Website Use information to improve the effectiveness and operation of Westquay PLUS and/or the website, to improve our existing services and develop new services and to inform and direct our marketing strategy. In addition, anonymised statistical data may also be shared with retailers or used by us to develop new promotions that may interest our customers.
We will also use this information for system administration and to report aggregate information to our retailers. This is anonymised statistical data about our users' browsing actions and patterns and to help us to improve our site and to deliver a better and more personalised service. They enable us:
· To estimate our audience size and usage pattern,.
· To store information about your preferences, and so allow us to customise our site according to your individual interests.
· To speed up your searches; and
· To recognise you when you return to our site.
Where we consider that, on balance, it is appropriate for us do so, we will process CCTV footage for the following legitimate interests:
• keeping our staff, visitors and property safe and secure;
• ensuring compliance with health and safety procedures;
• detecting and preventing crime;
• assisting law enforcement agencies in the apprehension, investigation and prosecution of offenders; and
• gathering retail analytics in order to improve the operational and commercial management of the centre
Data processed where it is necessary for compliance with a legal obligation imposed on us
We will process your personal data to allow us to comply with any requests you are lawfully entitled to make, including under data protection laws, to ensure that age inappropriate content is not provided to individuals under 18, and to allow us to keep records that we are legally required to retain, including evidence of consents provided, or to evidence our compliance with legal obligations.
How long will we hold your information
We will normally retain your personal data is for a period of up to 7 years from the latter of:
· the last date you logged into our website or used our App; or
· when you unsubscribe from receiving marketing from us (if later);
unless we are legally required to retain the information for longer. However, we may delete your data sooner if we have no purpose to retain it.
We will retain your details if you have unsubscribed from marketing to ensure that we respect your withdrawal of consent on an ongoing basis.
Who will we share your personal information with?
We will share your personal data within the Hammerson group of companies (including our subsidiaries, our ultimate holding company and its subsidiaries (if applicable)), for the purposes outlined above, including for our own internal business management and the provision of efficient centralised services within our group, where this occurs, they will comply with a privacy notice comparable to this one, unless they provide you with an alternative privacy notice. For further details of the Hammerson group of companies, please visit: https://www.hammerson.com/property/.
We also use third party service providers acting on our instructions to support our provision of the website, Westquay PLUS or our services to you, who are specifically contracted to process personal data on our behalf.
We may share your personal data, where necessary, with prospective purchaser(s) or purchaser of any part of our business, on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition.
We will also share your personal data where:
(a) you have provided prior explicit consent;
(b) where we are required by law, including any court order;
(c) where necessary to protect you, Westquay, its customers or the wider public.
Where will your personal data be held
We may store or process your personal data outside the European Economic Area (EEA) or other countries approved by the European Commission as providing appropriate safeguards for personal data, when we use service providers located in those countries. If this is the case, we will put in place appropriate safeguards to protect your personal data and ensure that it is compliant with all appropriate legal requirements. If you require further information in respect of the countries where your personal data is processed and/or copies of any documents setting out the appropriate safeguards we have implemented to protect it, please contact us.
Where people under the age of 13 download our App or use our services they are required to confirm that they have their parent’s consent. Parents should supervise the online activities of their children, and consider the use of tools available from online services and software providers that help provide child-friendly Internet environments. If any of our products or services are targeted directly at children, we will provide you with additional information about how their data will be used in the context of that service.
If the user’s age has been provided it is used to ensure that products inappropriate for those under 18 are not promoted to any user aged under 18.
You are solely responsible for maintaining the secrecy of your passwords and other account information, and we cannot take responsibility for any damage arising from any disclosure of your password or access to your email account by other parties.
If you wish to withdraw your consent to receive marketing materials, this can be done by:-
· emailing us at Dataprotectionofficer@hammerson.com
· updating your preferences on your online account; or
· by clicking on the unsubscribe link on any emails we have sent.
If you withdraw your consent, this will not affect our rights to have sent you marketing material prior to your withdrawal, but we will not send any further marketing. Whilst we will endeavour to ensure that you do not receive any further marketing material immediately, there may be a slight delay for any changes to take effect. Please note that your information will not be deleted but will be retained in a suppression list to ensure that we do not inadvertently send further marketing communications once you have withdrawn your consent to receive them.
If you do not wish us to process your Geolocation and Device and Website Use information, you may prevent this by disabling the function or blocking the cookies on your device or browser. However, if you select this setting you may be unable to access certain parts of our site, or it may impact on the usability of our website and/or App.
For further information on how to do this, please visit http://www.allaboutcookies.org/. You are also entitled to request that we:-
· provide you with a copy of any personal data we hold about you,
· provide you with a copy of any of your personal data, provided by you, that we hold in an electronic format, in a structured, commonly used, machine-readable format;
· have any incorrect personal data corrected or completed ( you can also update your records using your profile on your online account);
· delete any personal data that we no longer need for the above purposes, where you have withdrawn your consent and there are no other grounds to process that information, where the personal data has been unlawfully processed or where we are required by law to delete it; and
· restrict the processing of your personal data whilst we confirm whether any data needs correcting following your request, the processing is unlawful and you do not want us to delete this personal data; where we no longer need to process the personal data, but you require the information to establish, exercise or defend legal claims. In these circumstances we will only process your personal data for purposes for which you have consented, or for the establishment, exercise or defence of legal claims or the protection of the rights of another person; and/or
· object to our processing of your personal data, where we process it under the legitimate interests grounds and we are unable to show a compelling legitimate interest that overrides your interests, rights and freedoms, or for the purposes of defending, exercising or defending legal claims
We may require additional information to either confirm your identity before we can process your request and/or to assist us in responding to your request.
If you are unhappy with the outcome of your request or with our processing of your personal data, you are entitled to lodge a complaint with the Information Commissioner’s Office (ICO), whose website is www.ico.org.uk.
Modifications of this policy