This User Privacy Notice (“Privacy Notice” or “Notice”) was last updated on 26 April 2018. This Privacy Notice may vary from time to time so please check it regularly.

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.

Savills plc, incorporated and registered in England and Wales. Registered office: 33 Margaret Street, London, W1G 0JD. Registered number: 2122174. Savills plc is a holding company, some of whose subsidiaries are authorised and regulated by the Financial Conduct Authority (FCA).

Wi-Fi

How do we collect information about you?

If you use the Wi-Fi network in Eden, we will collect personal information from you, such as your name, email address and postcode in order to log you on to the Wi-Fi network. Eden’s Wi-Fi is provided via a third party. You will also be offered the opportunity to subscribe to email marketing.

Through the Wi-Fi service, we may also collect data which shows how often, how long and what type of device you use to access the Wi-Fi services, which will include recording the address of your device that connects to the Wi-Fi network.

We use Wi-Fi that may communicate with your mobile device to 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. 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.

Children

Children under the age of 13 are not permitted to use Wi-Fi networks.

If you have reason to believe that a child under the age of 13 has provided personal information, please contact us and we will delete that information from our databases.

Marketing

How do we collect information about you?

1. Entering into a competition or promotion hosted by ourselves or our third parties: You may provide us with personal data when you subscribe to these services either online or through a physical form.
2. Enrolling for a loyalty card or a club: you will typically provide us with your name and contact details when you enrol for a loyalty card either through a physical form or through our website.
3. Feedback: providing feedback to us through via our feedback forms where you may provide your contact details and subscribe to marketing. You can also provide us feedback through writing or emailing the centre with your complaints, comments and suggestions.
4. Website usage: 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.
5. Purchasing a gift card at our centre: the processing of this data is performed by a third party. They may require you to enter personal information for payment processing.  You may also provide your consent to email marketing when purchasing a gift card.
6. Enrolling for an event: we may collect your name and contact details if you wish to participate in an event that is organised at one of our centres. This data may be captured on a third party booking system.
7. Promotional photography: we may take photographs or videos of you when you attend one of our events. Signs will be on display during the event to advise you when photographs or videos are being taken, and if you have concerns or do not wish to be photographed/ videoed please raise these with a member of our staff.
8. Interaction with social media: Depending on the Privacy setting you have applied in your Social Media accounts, and based on the content that you choose to share, when you interact with our Social Media presence we will have access to your user generated content, such as posts, comments, pages, profiles and images. Also depending on the Privacy setting you have applied in your Social Media accounts, and based on the content that you choose to share, we may have access to contact details, personal information (such as age, gender, employer, education, location and habits and preferences).
9. Car parking: we collect your license plate to administrate our car parking fees, and your credit card details will be collected if you choose this payment method. This data will be captured on a third-party system.

In all of the above instances, we will only provide you with email marketing where you have consented and you can withdraw this consent at any time by clicking the unsubscribe link within the emails you have been sent.  Where we send you information electronically, we 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.

We also use third party marketing agencies who may have access to your personal details to devise email marketing campaigns, to provide customer insight through the analysis of data and to collect personal data on our behalf.  We store your information in a secure marketing database hosted by a third party which we use to also generate our email marketing campaigns.

In relation to third parties, we ensure that they will also safeguard your data – please see Protection of Your Information below.

For what purpose is it collected

The personal information gathered through WIFI and Marketing is for our legitimate business interests, this includes to:

1. Tailor our online services to you 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.
2. Collect data obtained through our interaction with customers 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.
3. Promote our site externally.
4. We frequently ask for postcodes during our customer interactions to help us better understand our customers. We share this data with third parties without any personal identifiers to assist with our insight and analysis.

For the gift card, car parking, WiFi-Service and competitions and promotions, the legal basis is also to form a contract with you to provide these services and promotions.

Data minimisation and retention

We will only collect the minimum amount of personal information necessary and will only keep your information for as long as you remain engaged with our marketing campaigns. Where you have not engaged with our marketing material for over a year, we will take steps to remove your information from our marketing database.

Where you have provided your details in relation to a competition, we will delete your personal data when the competition has finished (unless you have consented to your information being used for marketing purposes).

Security

How do we collect information from you?

As part of our security operation, Eden Shopping Centre will also be collecting personal images relating to visitors and customers to its property from CCTV, Body Mounted Video and ANPR (Automatic Number Plate Recognition) systems. Eden Shopping Centre appoints third party service providers to provide security services.

Eden Shopping Centre also captures personal data within Access Control systems which provide access to the building. Personal data is also collected from visitors to our properties. Access control data & visitor management data is held by third party system providers.

In relation to access control and visitor data, where the data relates to Eden Shopping Centre employees, contractors or visitors, Eden Shopping Centre considers itself to be the Controller. However, personal data relating to our tenant’s staff, contractors and employees, we consider our tenant’s to be the Data Controller.

In relation to third parties, we ensure that they will also safeguard your data – please see Protection of Your Information below.

For what purpose is it collected?

CCTV, BMV, Visitor and Access control data is collated to pursue our legitimate interests to protect the property in question, to protect the vital interests of our visitors, tenants and customers and to assist with the prevention and detection of crime.

ANPR is collected to fulfill a contract between ourselves and our users of our parking facilities, including enforcement action.

Data minimisation and retention

For CCTV, Body Mounted Video and ANPR:

Generally, this data will not be held for longer than 31 days unless an incident or suspected incident has occurred.

Access Control Systems:

Any passes which have remained inactive for six months shall have all data relating to the card permanently deleted.

Visitor Management Systems:

All data to be deleted where the visitor has not returned to the site within six months.

Accident and incident reporting

How do we collect information from you?

When an incident occurs at one of our properties, Eden Shopping Centre is required to document the particulars of an incident which may include witness statements, CCTV footage, photographs and written reports. This information may include special categories of data depending on the nature of the incident. A third-party system is used to log details relating to these incidents, physical paperwork may also be stored on site.

The data may be shared with third parties such as insurance providers and legal advisors in order to defend a claim, government organisations who we are required to report on incidents by law or the police to investigate a crime.

For what purpose is it collected?

This information is collected to ensure that Eden Shopping Centre complies with its legal responsibilities in relation to Health and Safety investigation and reporting, and also for defending future legal claims. The information can also be used to prevent and detect crime, or to protect the vital interests of individuals. Where health information is collected we may also need this for our substantial public interest for Insurance processing.

Data minimisation and retention

All personal data (CCTV, Witness Statements, Photographs and written reports) relating to the incident to be recorded for six years, unless there are reasons to retain it for longer, such as ongoing HSE investigation, a suspected pattern of fraud, or because an injury has been sustained by a child.

Other third-party transfers not detailed previously:

We may also pass on or allow access to your information:

• to our suppliers, contractors and professional advisors where this is necessary for them to provide services and facilities to us, for example:
• to pay for parking services;
• to any purchaser of all or part of our business or any of our properties to which the relevant service relates;
• to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers;
• where we are required to do so by law, court order or other legal process;
• 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;
• to protect and defend our rights or property;
• to deal with any misuse of any of our Services; or
• in order to enforce or apply our terms and conditions and other agreements with third parties.

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.

Protection of your information

We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal information that we hold. We place similar obligations on our third parties and risk assess their security based on the sensitivity of the personal data that they hold.

If we transfer your personal information outside of the EEA, it will continue to be subject to one or more appropriate safeguards set out in the law. These might be the use of model contracts in a form approved by regulators, or having our suppliers sign up to an independent privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme).

Links to other websites

This Privacy Notice only applies to the websites provided by Eden Shopping Centre. 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.

Your rights

You have the right to opt out of receiving any marketing information which we send you. 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;

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;

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;

You have the right to request that we correct your Personal Data if it is inaccurate or incomplete;

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;

You have the right to object and/or 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

You can also contact the Information Commissioner’s Office via https://ico.org.uk/ for information, advice or to make a complaint.

If you wish to opt out of the marketing we send you, please click on the unsubscribe button at the bottom of our email communications.

If you wish for further information, or wish to exercise any other right, please contact customerservice@edenshopping.co.uk

We will respond to your request (including providing information on whether the rights apply in the particular circumstances) within the applicable statutory time period. If we are not sure of your identity, we may require you to provide further information in order for us to confirm who you are.

How you can contact us

If you have any questions about this Privacy Notice, please contact us at customerservice@edenshopping.co.uk.