Privacy Policy

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Carlisle Shopping Centre Limited are committed to protecting the privacy of users of this Site. This policy describes the types of information collected, how that information is used and disclosed, and how you can access, modify, or delete your information.

This policy may vary from time to time so please check it regularly.

For the purposes of this policy, the “data controller” is Carlisle Shopping Centre Limited (company number 55321) of PO Box 119, Martello Court, St Peter Port, Guernsey, GY1 3HB.

WIFI IN OUR CENTRES

If you use our free WiFI network, we may collect personal information from you, such as your name, email address and post code in order to log you on to the Wi-Fi network. Our WiFI network is provided via a third party and you will be offered the opportunity to subscribe to email marketing.

Through our WiFi service, we may collect data which shows how often and how long you have accessed this service. This will include recording the address of your device that connects to the Wi-Fi network.

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.

For more information you may also visit http://www.smart-places.org.

The address of your device will be stored for as long as it connects to the internet, and will be stored to allow you to reconnect at a later date.

The personal information gathered through WIFI for our legitimate business interests, to:

You may also be asked to consent to email marketing. You can withdraw this consent at any time.

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.

  1. Enrolling into our loyalty programme:

You will typically provide us with your email address when you enrol for a loyalty card either through a form or through our website.

  1. 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.

  1. Promotional Photography:

We may take photographs of you when you attend one of our events. Signs will be on display during the event to advise you when photographs are being taken, and if you have concerns or do not wish to be photographed please raise these with a member of our staff.

  1. 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).

  1. Miscellaneous Forms:

There are miscellaneous forms at site which can also record your personal information – for example lost property.

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:

For the loyalty programme, Wifi-Service, 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 unsubscribe from our marketing, we will add your email address to our suppression list and delete any additional information that we hold about you.

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).

For any contractual purpose, your personal data will be held for as long as is required to execute the contract.

SECURITY

HOW DO WE COLLECT INFORMATION FROM YOU?

As part of our security operation, we will also be collecting personal images relating to visitors and customers from CCTV and Body Mounted Video (BMV). Carlisle Shopping Centre Limited appoints third party service providers to provide security services, but the information recorded through these technologies is held on systems we control.

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 and BMV 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.

DATA MINIMISATION AND RETENTION

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

ACCIDENT AND INCIDENT REPORTING

HOW DO WE COLLECT INFORMATION FROM YOU?

When an incident occurs at one of our properties, we are 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 and 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 we comply 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 USES

In addition to the purposes already described, we may use Information collected to perform other important business operations, for example: to understand usage patterns (such as foot traffic) within our centres; to develop, provide, improve and personalise products and services; and, to provide customer service/support. We may undertake additional research, analysis, and surveys, both online and in our centres. The lawful basis for this use of Information is for the legitimate business interests of Carlisle Shopping Centre Limited.

OTHER THIRD-PARTY TRANSFERS NOT DETAILED PREVIOUSLY

We may pass on or allow access to your information:

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 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.

CHILDREN DATA

We do not collect Information from children under the age of 13. If you are under 13 and have been accidentally subscribed, please notify us as marketing@thelanesshopping.co.uk to have your consent to marketing removed.

YOUR RIGHTS

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

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact marketing@thelanesshopping.co.uk.

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.

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

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

For more information, please contact marketing@thelanesshopping.co.uk.

HOW DO WE USE COOKIES?

In our website we use cookies to collect information of how many visitors there are to different parts of the website, which helps us keep our site up to date. We may also use cookies to tailor the content that you see to suit your interests. This facility also allows you to receive personalised advertising relating to products viewed whilst using our website.

Our use of cookies generally fall into four categories:

CHANGES TO THE PRIVACY & COOKIES POLICY

This Privacy Notice was last updated on 22 May 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.

HOW YOU CAN CONTACT US

If you have any questions about this Privacy Notice, please contact marketing@thelanesshopping.co.uk.