This is the privacy policy for the intu group of companies, headed by intu properties plc (referred to in these terms as intu, we, us, our etc.). intu runs many of the UK’s favourite shopping centres (the "Centres"). We are committed to safeguarding your privacy, so please read this policy to understand how information we hold about you will be treated on our website(s) and our app(s) (the "Site(s)"), when you visit us in person and when you otherwise interact with us. 
 
intu shopping centres plc (registered with the Information Commissioner’s Office with registration number Z5170264) and other intu group companies, including intuDigital Limited (registered with the Information Commissioner’s Office with registration number Z3470930) are data controllers for the purposes of European Economic Area data protection law in respect of your data.
 
If you have any questions in relation to this policy, please email data.protection@intu.co.uk or write to the Data Protection Officer, intu properties plc, 40 Broadway, London, SW1H 0BT.
 
We do occasionally update this policy so you should return to this page and read it through again from time to time. These terms were last updated on 23 May 2018. We may also update you separately about changes relating to the Sites by email or via our app(s), if appropriate.
 

1. Information we collect about you and our collection methods

“Personal data” is information about you from which we can identify you (either on its own, or by piecing it together with other information). Personal data does not include aggregated data where you cannot be identified (e.g. statistics about usage in general or in categories). 
 
We may, from time, collect your personal data in ways other than those set out in this policy, where we do so we will provide you with relevant privacy notices at the appropriate time. This privacy policy supplements the other notices and is not intended to override them.
 

The types of personal data we collect about you are:  

•Details you provide to us to participate in promotions or complete customer surveys which may include your title, name, postal address, email address, telephone number, and information about your use of our Centres;
•Demographic information; 
•Information provided when you interact with us directly (e.g. telephoning, writing or emailing us, buying gift cards or services from us, participating in promotions and competitions);
•Other information which you give us when dealing with us or interacting with us in any way including via third parties;
•Vehicle registration number and details (via our ANPR system);
•details you provide when using our WiFi in a Centre; 
•Your credit or debit card number and expiry date if you make a purchase from us;
 
•CCTV footage featuring your image, which in some Centres may be temporarily captured and processed using facial recognition technology;
•Information about your use of the Sites.  Some of this information may be automatically collected, such as your Internet Protocol (IP) address, unique device identifier, browser type, browser language and access times;
•Information about your location. We may automatically collect your location information (if you have consented to this on your device);
•Information about your preferences, including brands and content you like, dislike, click on or share with others; 
•Information provided when you interact with us directly through the Sites including when registering with us or participating in promotions and competitions;
•Technical Data from analytics providers;
•Data collected when you interact with us via third parties (e.g. via brand partners and social media platforms – see section 8 below); and
•From third parties (e.g. through third party surveys and market research you participate in).
 

2. How we use your personal data

We will ensure that in all circumstances the personal data we hold about you will be adequate to fulfil the purpose for which it was collected, relevant, and not excessive.  
 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
 
If we need to use your personal data for an unrelated purpose, we will notify you, where necessary or appropriate, and we will explain the legal basis which allows us to do so.
 
Please note that we will process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

We may use your personal data to: 

•Provide you with information, products, services or experiences that you request from us; 
•Process payments for purchases;
•Provide reservation or booking services;
•Compile a user profile for you where you have requested that we do so through your use of relevant services;
•Provide and personalise our products and services to you, including making predictions about your interests or preferences and to display targeted content, features, deals and offers that match your profile or that we believe will be of interest to you;
•Keep track of your activity patterns and preferences in order to improve the level of service you receive and to increase the functionality of the Sites, including monitoring and analysing usage and trends, determining the effectiveness of our content and personalising and improving the Sites;
•Link or combine with other information we get from third parties to help understand your needs and provide you with better service (through the use of cookies and related technologies, where these are enabled on your device);
•Inform you of products, services, experiences or promotions which we feel may be of interest to you where you have indicated that you wish to be contacted for such purposes by email, SMS, post, telephone, through the Sites or social media platforms, or by other means of electronic communication (and where you have indicated that you are happy to be contacted by specific third parties, you may be contacted about products, services, experiences or promotions by those third parties);
•Ensure that content from our Sites is presented in the most effective manner for you and for your computer/tablet/mobile;
•Send you push notifications;
•Interact with you on social media platforms;
•Allow you to participate in any interactive features of our products, services and experiences, when you choose to do so;
•Request feedback from you;
•Respond to your emails, submissions, questions, comments, requests or complaints and provide customer service; 
•Send you surveys, updates, security alerts and support and administrative messages and to facilitate your use of, and our administration and operation of, the Sites, including to notify you about important changes; and
• To detect fraud and combat criminal and antisocial behaviour. 
 

3. International transfers

Your personal data may be transferred outside of the UK and the European Economic Area (“EEA”). However, we have taken the steps outlined in section 4 below to protect the security of your personal data and comply with our legal obligations when transferring of your personal data to non-EEA countries by ensuring that adequate technological and legal measures are in place to permit such a transfer.
 

We may transfer your personal data outside of the EEA:

•In order to store it.
•In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
•Where we are legally required to do so.
•In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
 

4. Purposes for which we use your data – summary

We have set out below, in a table format, a broad summary of the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on more than one lawful ground if we are processing the same information for more than one specific purpose.
 
Purpose/activityType of data Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include:
 
(a)Notifying you about changes to our terms or privacy policy
 
(b)Asking you to leave a review or take a survey
(a)Identity
 
(b)Contact
 
(c)Profile
 
(d)Marketing and Communications
 
(a)Performance of a contract with you
 
(b)Necessary to comply with a legal obligation
 
(c)Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), data collected from on-site visits to Centres
(a)Identity
 
(b)Contact
 
(c)Technical
 
(d)Image
(a)Necessary for our legitimate interests, for running our business, provision of administration and IT services, network security, to prevent crime and fraud and in the context of a business reorganisation or group restructuring exercise.
 
(b)Necessary to comply with a legal obligation
To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences
(a)Technical
 
(b)Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Sites updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you
(a)Identity
 
(b)Contact
 
(c)Technical
 
(d)Usage
 
(e)Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)
 

5. How we keep your personal data safe

We have a number of measures to keep your data safe and secure:
 
•Your personal data is held on a secure database. 
•We have policies, rules and technical measures in place to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
•All of our employees and data processors that have access to, and are associated with, the processing of your personal data are obliged to respect the confidentiality of your personal data. 
•All third parties supporting our Sites as external data processors are engaged under appropriate contractual and confidentiality protections.
•We ensure that your personal data will not automatically be disclosed by us to government institutions or authorities.  However, if required by law, or when we receive a request from regulatory bodies or law enforcement organisations, we may disclose your information.
 

6. How we disclose your personal data

We may disclose your personal data to any of the following in any country within the EU (to the extent necessary to fulfil the purpose for which your data was collected: 
 
•Our staff;
•Our affiliates;
•Our group companies and their staff;
•Suppliers and service providers who may access your personal data when providing products or services to us, in particular providers of platform, data storage, marketing and data security services; 
•Purchasers or potential purchasers of our business or any part of it or of a Centre;
•Government bodies and law enforcement agencies and in response to legal or regulatory requests; and
•Auditors or other advisers auditing, assisting with or advising on any aspect of our business or a Centre, including our external legal advisors.
 
We may also share information or statistics with third parties in an aggregated or anonymised form that does not directly identify you, e.g. we may share aggregated information about your interests and geographic preferences and/or location (if given) with advertisers and third party deal sites for marketing purposes.
 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law and subject to appropriate contractual terms. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 

7. Your own sharing of your personal data

When you post in any profile, comments, forums and other interactive features of the Sites, or share personal data with individuals through the Sites or social media platforms, this personal data will be available to other users and in some cases may be publicly available outside of the Sites (e.g. on social media platforms). 
 

8. Our access to your personal data through social media platforms

If you interact with us on social media platforms, (for example, if you ‘Like’ our Facebook Page or post on our Facebook timeline, or if you follow us or mention us in a tweet on Twitter) we can interact with you and send you information via these platforms.  
 
The personal data we have access to through social media platforms will depend on your personal settings on these platforms. We will have access to all public information on these platforms. We may also be able to access personal data that others share about you (because they control how that is shared, not you).
 
We may collect any data that is accessible to us or that you provide through social media platforms, including but not limited to your Facebook and/or Twitter profile picture, gender, and usernames. We will interact with you through social media platforms in accordance with each platform’s rules but we are not responsible for how the platform owners collect and handle your data. We are not responsible for what third parties post on our social media accounts.
 

9. intu App

If you download or use our app(s) we will collect personal data from you, in accordance with this privacy policy.  
 
If you delete our app(s), we may still store your personal data for a period of time prior to deletion. 
 

10. Your legal right with respect to your personal data

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as listed below, to:
 
•request access to your personal data;
•request correction of your personal data; 
•request erasure of your personal data;
•object to processing of your personal data;
•request restriction of processing your personal data;
•request transfer of your personal data; and
•withdraw consent to processing of your personal data.
 
If you wish to exercise any of the rights set out above, please contact data.protection@intu.co.uk or write to the Data Protection Officer, intu properties plc, 40 Broadway, London, SW1H 0BT. 
 
When writing to us to obtain a copy of your personal data, please quote your name and address and provide brief details of the personal data of which you would like a copy of, or which you would like to be corrected, because this will help us more easily locate your personal data.
 
What we may need from you when you exercise your legal rights
When exercising your legal rights above, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that requests are made by the individual themselves and that personal data 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.
 
Fees and refusal to comply with requests
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee and/or refuse to comply with your request.
 
Time limit to respond
We will respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests and it is likely to take us longer than a month to respond, we will notify you of that and keep you updated as to progress.
 
Your right to make a complaint 
In addition to your legal rights set out above, you also have the right to make a complaint at any time to your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk). We are committed to protecting your personal data and would appreciate the opportunity to address any concerns or complaints you may have before you approach the ICO so that we can remedy them. Any concerns or complaints should be raised with the Data Protection Officer in the first instance.
 

11. Direct marketing – how to opt out

You have the opportunity to opt-out of receiving marketing communications from us at any time. You can do this by clicking on the unsubscribe link on any communications from us, updating your preferences in our Preference Centre, or by emailing customercare@intudigital.co.uk.  
 
We take your online privacy very seriously, so if you need any assistance in unsubscribing to future communications please contact us. We will promptly take action to ensure that you are “opted-out” from receiving any further mailing or other information. Although we will remove your name from our e-mail list as quickly as possible, there may be a period of time after you unsubscribe during which you may still receive e-mails from us. Additionally, in order to ensure you do not continue to receive correspondence from us, we may retain your Personal Data on a suspension list.
 

12. Cookies

Our Sites uses cookies, including third party cookies. For further details please read the Cookie Policy.
 

13. Third parties and the privacy of your personal data

You may be able to access third party websites and apps from the Sites. We are not responsible for the privacy policies and practices of other websites and apps.  We recommend that you check the policy of each website and app and contact the operator of the website or publisher of the app if you have concerns or questions.