Lanes Xtra is operated by Carlisle Shopping Centre Limited (company number 89053) with its registered office at PO Box 119, Martello Court, St Peter Port, Guernsey, GY1 3HB. Members of the programme will be able to receive benefits, discounts and special offers from participating retailers within The Lanes Centre.  The offers you have access to may vary from time to time and from person to person.

These terms and conditions will govern your membership of the Programme.  These terms tell you who we are, details of the programme, how we may change or end the terms, how we use your data, what to do if there is a problem and other important information.  Joining the programme constitutes acceptance of these terms. Please read these terms carefully.  If you do not agree to the terms you must not take part in the programme.

You have the right to object to us processing your personal data for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests. For more information, see the section “Your Rights” below.

NOTICE – CHANGE TO DATA PROTECTION LAW

The law in relation to data protection is changing with effect from 25 May 2018. This Privacy Notice has been updated for new guests registering from 25 May 2018 and for guests who have registered before 25 May 2018.

You should read through this Privacy Notice to fully understand the basis upon which we collect your personal data, how we use it, where we store it and to whom it is disclosed. Other privacy notices may also apply in relation to our use of your personal data other than in connection with Lanes Xtra (for example, when you use our website, our cookie policy will apply).

Commitment to Privacy
We are committed to protecting your personal data and right to privacy. We will always keep your personal data safe and comply with applicable data protection legislation from time to time in place.

Your rights
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can also contact the Information Commissioner’s Office via https://ico.org.uk/ for information, advice or to make a complaint.

Please see the section titled ‘Requests to us’ below, for more information on how we will handle your requests to us.

What personal data do we collect about you?
We collect the personal data you provide to us as part of your registration and any further personal data you provide to update your registration details from time to time. This personal data includes your name, address, place of residence, gender, date of birth, email address, land and mobile phone numbers and other contact details.

We also collect information about your preferences. We ask you to provide us with information about your favourite brands and labels so we can tailor our offers to your specific preferences and about your marketing preferences so we can make sure that we are contacting you using your preferred method of communication. If you receive a service from us, we may collect and record your preferences about the way the service was delivered so that we can improve your experience next time.

Please note that in order for you to register with or continue using Lanes Xtra, we only need to have means to communicate with you electronically such as your email address. However, if you provide us with more personal data on our request, we can provide you a better service and Lanes Xtra experience.

Where you register to become a Lanes Xtra member via a social media platform, we may collect the personal data above directly from the personal details you have provided to the platform (as long as the social media platform has the right to share your personal data with us).

We also gather information about the purchases you make at The Lanes Shopping Centre, including:

• the stores you shop in; and
• transaction details (including the date, time and value of the transaction)

We gather this personal data when you scan your unique QR code at a store when making a purchase (we must gather this personal data in order to offer you all the benefits of Lanes Xtra).

We collect cookies from your mobile device when visit The Lanes Shopping Centre website. Our cookie and privacy policy is available here.

We may also combine this personal data with other personal data we hold about you from the different channels you use to interact with us (for example, our website or social media). We do this to form a clearer picture about the kinds of offers in which you might be interested.

When we interact with you (for example, when you are using services we provide) we may learn certain details about you that do not fit into one of the categories above. We may record this information in order to ensure we can remember important details about you in future. We ensure that only a small number of authorised personnel have access to this personal data and we will not use it for any purpose other than to build an ongoing relationship with you, our valued customer, when you visit us or when we interact with you.

Throughout your Lanes Xtra membership we may (if you have given us your consent to market to you) ask for your feedback on certain items about your experiences with us, including whether you are likely to recommend or revisit The Lanes Shopping Centre. The feedback we receive from you may affect the nature or volume of marketing material you receive from us (again, if you have given us your consent to receive such marketing). For example, if we feel you are likely to recommend The Lanes Shopping Centre to a friend, we may send you marketing content that you can easily pass on to others who may be interested.

How we use your personal data
We are processing your personal data to be able to provide you with membership to and participation in Lanes Xtra, and in particular to do the following:

• when we make Lanes Xtra members special offers about brands sold in the Centre, we can tailor these offers to you to make sure you are sent the kinds of offers you will be most interested in; and
• when we think that you deserve a little something extra based on your transaction activity, we can offer this to you.

We gather information about your purchase activities at The Lanes Shopping Centre so that we can give you all the benefits of Lanes Xtra membership. When we have information about your transactions, we can tell:

• when you will be eligible for rewards that are based on your purchasing activities; and
• more about your favourite stores and brands, so we can target our offers to you and your preferences.

In addition, we use your personal data:

• to manage and improve Lanes Xtra;
• to better understand your shopping behaviour in order to develop and improve our products and services so as to provide you with an enhanced shopping experience;
• to analyse the effectiveness of our marketing and to help us provide more relevant offers, advice and information to you and our other guests;
• to build up a clearer picture of our guests both as a group and as individuals and thereby provide you with a seamless, relevant and consistent service;
• to provide you with information about events, special offers, promotions and other relevant matters concerning The Lanes Shopping Centre and the goods sold and services provided (if you have given your consent for us to do so);
• to advertise our Centre and services on social media to other people who may also be interested in what we have to offer (if you have given your consent for us to do so);
• to advertise offers or promotions made available by our third party partners if you have given us your consent to do so;
• to provide any services which you may request or which we may offer as part of your Lanes Xtra membership;
• to ensure that the information we hold is kept accurate and up to date;
• (if we have your consent, where this is required by law) for research and analysis and in order that we may contact you, from time to time, for such a purpose or for the purpose of conducting surveys or focus groups; and
• to notify you about changes to our services.

How long we keep your personal data for
We will keep your personal data for as long as you continue to interact with us (for example, if you read or click on an email we send you, make a purchase from the Centre, or attend an event we host). If we do not have any interaction with you for three years, we will attempt to contact you to see if you still want to be a Lanes Xtra member.

If we do not hear from you (or if you tell us, at any time, that you no longer want to be a member of Lanes Xtra) then we will delete your personal data from our records.

There may be some personal data we only need to collect in order to provide you with a particular service. We will delete such personal data as soon as the relevant service has been completed. We may still retain your preferences about the way the service was delivered so that we can improve your experience next time.

Who we share your personal data with
For the purposes set out above, we may provide your personal data to our suppliers and processors who perform certain business services for us. We share your personal data with third parties who:

• process transaction information to determine whether you are eligible for a treat or a reward; and
• if you have given your consent for us to do so:
• communicate with you on our behalf via email;
• share your personal data with social media platforms (through our advertising agency) who only use it for the purpose of identifying other people who are similar to you and who might also be interested in the The Lanes Shopping Centre and Lanes Xtra, so that we can advertise to them through these social media platforms;

In some cases the personal data we collect from you may also be processed outside the European Economic Area (EEA) and such destinations may not have laws which protect your personal data to the same extent as in the EEA. We have obligations to ensure that your personal data processed by us or by our suppliers and partners operating outside the EEA is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Notice.

In addition, we may disclose your personal data:

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
• to successors in title or replacement operators of all or part of our respective businesses.

The legal basis for us using your personal data

It is necessary for us to process your email address for performance of the contract between us in relation to Lanes Xtra (which is governed by the Membership Terms).

In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:

• sending you marketing communications;
• advertising on social media platforms;
• using your location to deliver specific messaging and content to you; and
• using your location to monitor the effectiveness of our messaging.

In most cases, it is in our legitimate interests to collect and use the personal data referred to above so that we can:

• provide you with a service that is as useful, enjoyable and beneficial to you as possible, including by personalising our contact with you, making sure we tell you about all the offers that relate specifically to your preferred Village, tailoring treats to your specific preferences, and contacting you using your preferred method of communication; and
• better understand our customer base so that we can improve our services and marketing activities (which could also benefit you).

When we rely on our legitimate interests in order to collect and use your personal data (including for the purposes of automated decision making and profiling as set out in Automated decision making below), we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue only if we decide that your interests, rights and freedoms do not override our legitimate interests.

We have considered these matters, and where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not use your personal data unless there is another legal basis for us to do so (either that it is necessary for us to perform our contract with you, or on the basis of your consent). For example, we believe that collecting your location data may be intrusive, and so we will only do so with your consent.

What happens if you do not provide us with the personal data we request or ask that we stop processing your personal data?
Please note that in order for you to register with or continue using Lanes Xtra, we only need to have your email address. However, if you provide us with more personal data on our request, we can provide you a better service and Lanes Xtra experience. As we’ve noted above, we also collect certain information about your activities and transactions at The Lanes Shopping Centre so that you can participate in Lanes Xtra.

If you ask that we stop using your personal data then we may not be able to provide you with all the benefits of Lanes Xtra.

How we contact you
Lanes Xtra works best when we are free to communicate with you to share details of treats, rewards and other offers you might be interested in.

In order to provide you with the benefits of Lanes Xtra we may, if we have your consent, contact you by post, e-mail, SMS text messages, telephone or other means including other electronic means such as Facebook and social media applications, and only using such contact details as you provide to us from time to time.

If you no longer wish to receive such or certain communications, you can let us know by contacting us. You may also update your preferred contact details at any time by emailing us at marketing@thelanesshopping.co.uk

Automated decision making
We use technology which tracks your purchasing behaviour and helps us to build a profile of your preferred brands and products. What this means for you is that you are more likely to receive offers that are tailored to your specific preferences, based on your previous transaction activity. It also means that we don’t send the same treats to all our Lanes Xtra members, so you may not be made the same offers as another Lanes Xtra member. If you don’t agree with an automated decision that our technology has made in relation to you, you can let us know (see ‘Contacting Us’ below). You may still have the right to object to us processing your personal data for the purpose of automated decision making or to restrict us from doing so.

Please note that the legal basis for us carrying out this automated decision making “or “profiling” activity is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing.

Requests to us
We are required by law to act on requests and provide relevant information. You will not have to pay a fee to access your personal information (or to exercise any of the other rights); however, if your request for access is clearly unfounded or excessive, we may refuse to comply with the request in such circumstances.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

Updates to these terms and conditions

These terms and conditions were last updated on 22 May 2018. If it is necessary for us to alter the terms , we will post them here. We encourage you to frequently review these terms and conditions for the latest information on our practices.

Contacting us
If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please email us at marketing@thelanesshopping.co.uk.