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LOYALTY PROGRAM PRIVACY POLICY

The date this privacy policy was last revised was February 2021.

This Privacy Policy explains how the data controllers [referred to in this Privacy Policy as the Data Controller, we, us or our] (as defined below) collects and process your personal data in the context of the provision of our Loyalty Program (including the access to your loyalty account within the website and shopping center applications, together, the “Services”).

This Privacy Policy covers the following:

  1. Contact details of the Data Controller
  2. How do we collect your personal data
  3. Details about the processing of your personal data
  4. How do we share your personal data
  5. How do we keep your personal data secure
  6. Do we transfer your personal data outside the European Economic Area
  7. Your rights in relation to your personal data
  8. Geolocation
  9. Automated decision making / profiling
  10. Transfer in case of change of ownership.
  11. Update of this Privacy Policy

1. Contact details of the Data Controller

The local Data Controller :

GSSM Warsaw spółka z ograniczoną odpowiedzialnością with its registered seat in Warsaw at al. Jana Pawła II 82, 00-175 Warsaw, holding NIP no: 5272635896 and REGON no: 142564741, entered into the entrepreneurs register maintained by the District Court for the capital city of Warsaw, XII Commercial Division of the National Court Register, under the KRS no: 0000364145, with the share capital of 14 867 800,00 PLN,

Lokalny Administrator danych będzie przetwarzać Państwa dane osobowe w kontekście określonym poniżej.

The group Data Controller:

Unibail Management

Simplified joint stock company with a capital of 20 000 000€    
Having its registered office at 7 place du Chancelier Adenauer 75016 Paris
Registered within the Paris Register under number 414 878 389

GSSM Warsaw spółka z ograniczoną odpowiedzialnością and Unibail Management Data Privacy Team (including its DPO) may be contacted by email at data.protection@urw.com or via post at 7 place du Chancelier Adenauer 75116 PARIS.

In a general manner, the group data controller will process your personal data in order to assist the local data controller and to ensure a general governance at group level.

Some roles are specifically assigned to the local Data Controller or the group Data Controller as follows:

Role of the local Data Controller:

The local Data Controller  will process your personal data in order to send you communication to inform you about specific offers and events of the respective shopping centre and to provide you with offers.

Role of the group Data Controller

The group Data Controller has concluded several data processing agreements and service agreements with service providers to provide you with the technical opportunity to register you to the Loyalty Program or download and use the shopping center application.

The group Data Controller will also handle the preparation of some communication, coordinated at group level, that will be sent by local Data Controller. Furthermore, the group Data Controller will negotiate with third parties special offers which will be accessible for loyalty members.

The group Data Controller will process your personal data in order to :

  • Manage your registration to the Loyalty Program
  • analyse your behaviour within the shopping center as further detailed in the table below (3.1) to provide you with customised offers and events you might be interested in.

The local data controller and the group data controller are acting as joint data controllers and will hereinafter be referred to together as “Data Controller”, “we”, “us” or “our”.

2. How do we collect your personal data

We collect personal data about you through the following means:

  • directly from you; and/or
  • from your use of the Services

a) When you use the Loyalty Card, including the virtual one, if scanned during your visit, we collect information related to the type of service your Loyalty Card was used for (example : events, birthday present) and therefore your presence within our shopping center.

b) When you use our shopping center application or website  as authenticated user, we collect :
information about the frequency of your visits, your itineraries within the shopping centre provided that we have obtained your prior written consent to collect these information (only for shopping center application - see article 8 Geolocation).

c) When you use the website and accept the use of cookies, we collect the cookies you have accepted. You will find all details about cookies uses and policy in the Terms of Use accessible by clicking on the following link: LINK.

Details about those different way of collection are given in section “Personal data involved” in the table reproduced in article 3 below.

3. Details about the processing of your personal data

3.1 You will find in the table below all information in relation with:

  • Why we are processing your personal data (Specific purpose)
  • Which personal data are involved (Personal data involved)
  • On which legal basis we are processing your personal data (Legal basis)
  • How long we are storing your personal data (Retention period)
  • What rights you can exercise in relation to your personal data (Rights)

Specific purpose
Personal data involved
Legal basis
Retention period

Rights

The available rights depend on the legal basis

Management of your registration to the Loyalty Program

Directly provided by you:

Mandatory: Title, Name, surname, e-mail address, birth date

Optional: phone number, information regarding the fact that the data subject is working in the shopping centre area (if applicable)

Provided to us by a third party:

N/A

Execution of a contract (Terms of Use of the  Loyalty Program)

the GDPR Article 6(1),  b)

3 years from last digital contact or use of the Services
Access
Rectification
Deletion
Limitation of the processing
Portability

Management of the participation to events organized by the shopping Centre

 

Please note that we might send you communication to allow you to participate to the event (example : if the event requires you to have a proof of registration to enter it)

Directly provided by you:

e-mail address, name, surname, phone number

Provided to us by a third party:

N/A

Legitimate interest of the data controller to offer the opportunity for the members of the Loyalty Program to participate to events organized to their attention and ensure the security of such event

the GDPR Article 6(1),  f)

6 months after the event
Access
Rectification
Deletion
Limitation of the processing
Objection to the processing
Loyalty Points Collection
See details in article 3.2

Directly provided by you:

N/A

Provided by Transaction Connect:

amount, date and shop of purchase

Execution of a contract (Terms of Use Loyalty Program)
3 years from last digital contact or use of the Services Access
Rectification
Deletion
Limitation of the processing
Portability
Management of the offers and benefits of the Loyalty Program 

free access to services (in conditions detailed in the Terms of Use of the Loyalty Program):
birthday present  
Premium services (fashion stylist, online wrdrobe review, interior stylist)

Directly provided by you:

Loyalty card number, bar code, name, surname, birthdate

Provided to us by a third party:

N/A

Execution of a contract (Terms of Use Loyalty Program)

the GDPR Article 6(1),  b)

No storage for the use of the offers and benefit.

If the Loyalty Card is scanned (never for the use of the toilets) we may retain your date of visit and type of services/offer used

Access
Rectification
Deletion
Limitation of the processing
Portabilit
Participation to contests organized for loyalty members

Directly provided by you:

Loyalty card number, name, surname, birthdate, Personal information that may be contained in the contest itself (answers to questions)

Provided to us by a third party:

N/A

Execution of a contract (Rules of contest)

the GDPR Article 6(1),  b)

1 month after delivery of the prizes to the winner(s)
Access
Rectification
Deletion
Limitation of the processing
Portabilit
Granting of rewards  for loyalty members who have activated the Loyalty Point Collection

 (example : welcome offer)

Provided by Transaction Connect:

amount, date and shop of purchase

Legitimate interest of the Data Controller to manage the program in order to increase its database and the amount spent in the shopping center and legitimate interest of the members to win prizes

the GDPR Article 6(1) f

No specific data retention as the information are retained in the framework of the Loyalty point collection – see below Access
Rectification
Deletion
Limitation of the processing
Objection to the processing

Management of the communication for information purpose in relation with the Loyalty Program

(example : information about an event accessible only to the loyalty members)

Directly provided by you:

Loyalty card number, title, name, surname, e-mail address

Phone number (optional)

Provided to us by a third party:

N/A

Execution of a contract (Terms of Use Loyalty Program)

the GDPR Article 6(1)b

3 years from last digital contact or use of the Services
Access
Rectification
Deletion
Limitation of the processing
Portability

Management of commercial communication:

By e-mail and/or sms if you have provided us with your mobile phone number

Directly provided by you:

e-mail address
phone number (optional)

Provided to us by a third party:

N/A

Consent
the GDPR Article 6(1) a

3 years from last digital contact or use of the Services  or until withdrawal of the consent, whatever occurs first
Access
Rectification
Deletion
Limitation of the processing
Objection to the processing
Portability
Withdrawal of consent

Analysis of your information/use of the services:

  • to provide you with personalized offers; and

  • to improve our understanding of your expectations and needs  and develop new features and services

Please note in this perspective, we will combine the personal data listed  in the relevant column.

Obtained directly from you:

all information that may be provided by you.

Obtained from your activity:

Behaviour on the website (cookies)

Participation to events organized by the shopping centre,

Your use of the wifi : date of visit of the shopping center 

Your use of the Loyalty Point Collection

When your Loyalty Card is scanned for the use of a services or the participation to an event  in the Shopping Center

Legitimate interest of the Data Controller to better understand the customer in order to deliver appropriate services and/or offers  and legitimate interest of the loyalty members to receive personalized offers and services.

the GDPR Article 6(1),  f)

please note that:

- cookies are collected on the legal basis of your consent only (the GDPR Article 6(1)(a)

- information related to your use of the wifi are collected on the legal basis of your consent only (the GDPR Article 6(1)(a)

=> but the analysis of those information as described here is made on the basis of   legitimate interest ( the GDPR Article 6(1)(f)

3 years from last digital contact or use of the Services    Access
Rectification
Deletion
Limitation of the processing
Objection to the processing
Portability
Geolocation (within the shopping center  only – via the Shopping center application)

Directly provided by you:

Provided by the use of the service : location data inside the shopping centre

Provided to us by a third party:

N/A

Consent (given via Shopping Center application)

the GDPR Article 6(1),  a)

No storage of your geolocation will be made by Us. Access
Rectification
Deletion
Limitation of the processing
Portability
Withdrawal of consent.
Answer to the loyalty members requests related to personal data

Directly provided by you :

Name, surname, e-mail address, number of loyalty member or copy of ID Card, if applicable

Provided to us by a third party :

N/A

Legal obligation

the GDPR Article 6(1),  c)

The civil year of reception, plus 5 years

If your ID card is requested, it will be deleted right after the check of your identity

Access
Rectification
Limitation of the processing
Deletion
Obtain a feedback from you on our services

Directly provided by you:

answers to a questionnaire in respect with the appreciation of the services provided by us.

Legitimate interest of the data controller to better understand the customer and improve the services  and deliver appropriate services and/or offers

the GDPR Article 6(1),  f)

3 years from last digital contact or use of the Services Access
Rectification
Deletion
Limitation of the processing
Objection to the processing

Establishment, exercise or defence of legal claims

(for example where a law enforcement body or regulatory body are investigating a crime or incident

Relevant personal data related to the claim or litigation

Legitimate interest of the data controller to ensure its defence;

the GDPR Article 6(1),  f)

Legal time limit depending on the type of claim/litigation 
Access
Rectification
Deletion
Limitation of the processing
Objection to the processing

3.2 Specific provisions – Loyalty Points Collection

As part of a special functionality of the Loyalty Program to activate, please note that you have the possibility to subscribe to the Loyalty Points Collection. Under the Loyalty Points Collection, you may be entitled to get cashbacks, depending upon purchases you make in the shopping centre. The activation of the Loyalty Points Collection is optional and you remain completely free to activate this feature of your Loyalty Program or not. For further information, please see the Terms of Use of the Loyalty Program.

For the purposes of organizing, managing and implementing the cashback payments resulting from your transactions as well as analyzing the payment flows resulting from your use of the Loyalty Points Collection, please note that Transaction Connect (a French company with headquarters at 86, rue du faubourg St Denis 75010 Paris, and registered with the Registry of Commerce and Companies of Paris under number 822 619 185) alone shall be deemed acting as independent data controller with respect to the concerned processing of your personal data. For sake of clarity, both us and Transaction Connect are individually responsible for the processing of your Personal data for the purpose of the Loyalty Points Collection.

You can find additional information about the processing activities implemented by Transaction Connect, including information about your rights as a data subject, by clicking on this link.

Please note that, in any event, we are not responsible for the processing activities implemented by Transaction Connect acting as data controller. Consequently, any claims or requests relating to the processing carried out by Transaction Connect shall be directed to Transaction Connect directly subject to their respective privacy policy and terms of use, which you will be required to read and accept when subscribing to the Loyalty Points Collection.

Once you have activated the Loyalty Points Collection, the Data Controllers will receive confirmation and the relevant purchases you conduct within the shopping centre as detailed in the table above, so that the Data Controllers can manage and account your Loyalty Points to benefit thereof under the Loyalty Points Collection. Under no circumstances, we will have access to or receive any information related to you bank accounts, credit cards or any Personal data of financial nature.

4. How do we share your personal data?

We may share your personal data with:

  • our processors as listed in Appendix 1; The list of our current third-party processors is published in Appendix 1 below. The list is regularly updated and includes company-name, company-address, specific of purpose of processing of service provider;
  • any competent authority or legal entity to answer to legal or regulatory requests, court orders, subpoena or legal process, if necessary to comply with applicable laws;
  • any transferee, when personal data is transferred as part of the sale or otherwise transfer of all or part of our assets to another company;
  • with our insurers, lawyers, other advisers and courts when enforcing claims and/or defending our position.

5. How do we keep your personal data secure?

We take the security of all the personal data we hold very seriously and we are committed to protecting your personal data. We have therefore implemented all the necessary technical and organizational security measures, and have chosen our providers accordingly.

We have entered into specific data processing agreements with each service provider listed in Appendix 1 and have checked their general technical and organizational measures. The service providers are only authorized to process the data, as data processor, in compliance with the provision of this Privacy Policy, only on our behalf and according to our instructions.

However, we can't control all the risks related to the use of the Internet, and data security also relies on everyone's vigilance and good use of these technologies, therefore we invite our customers to remain vigilant on potential inherent risks while using Internet services.

6. When do we transfer your personal data outside the European Economic Area?

We use third party service providers that help us provide the Services to you and process your personal data on our behalf. Such third party service providers will always be subject to security and confidentiality obligations consistent with this Privacy Policy and the applicable law.

Note that some third party service providers are located outside the EEA (European Economic Area) and thus may access and process your Personal data from countries which do not provide an adequate level of data protection. In case of such transfer outside the EEA, we enter into the model clauses adopted by the European Commission to ensure that your personal data benefits from an adequate level of protection when accessed and processed from there. Our processors may also rely on Binding Corporate Rules.

If you need further information on this, please contact us  by e-mail at the address mentioned in article 7.5 below.

Information on the model clauses can be found here.

Information on the Binding Corporate Rules can be found here.

7. Your rights in relation to your personal data

7.1 Pursuant to all applicable laws, and in accordance with the provisions of the table of article 3.1 above (column “Rights”) you have the right* :

  • to access to your personal data: we will give you detailed information about your personal data being processed.
  • to obtain rectification your personal data: if the personal data we are processing are inaccurate;
  • to obtain erasure of your personal data: if you want us to erase some or all of your personal data;
  • to object to the processing of your personal information: if you want us  to stop the processing of your personal data until we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
  • to obtain the restriction of the processing of your personal information: if you contest the accuracy, lawfulness or our need to process your personal data, we will limit the processing of your personal data to the minimum (storage) and, if applicable, will process them only for the establishment, exercise or defence of legal claims or, where necessary, for protection of another natural or legal person, or other limited reason dictated by applicable laws.
  • to receive your personal data in a structured and standard format or to ask for the transmission of such information to other controller (portability)

Please note that the available rights depend on the legal basis of the processing. See provisions of the table of article 3.1 above (column “Rights”) to see the rights you can exercise specifically by processing activity.

7.2 Withdrawal of your consent(s) When the legal basis of the processing is your consent, as detailed in the table displayed in article 3.1 above (column “Legal basis”), you may withdraw your given consent(s) at any time without any reason.

If you do so, we will stop any further processing based on this consent. Please note that the withdrawal of your consent does not affect lawfulness of any processing done on the understanding that you have given your consent before.

To withdraw your consent to receive commercial communication:

  • send an e-mail as described in the section Exercise of your rights below
  • directly change the setting in your loyalty account 
  • click on the unsubscribing link available in all our communication

7.3 Unsubscribing to communication for information purpose in relation with the Loyalty Program 

As part of the Loyalty Program and based on the legal basis of the execution of a contract formed between us (the terms of Use of the Loyalty Program) we will send you communication (that will only be about the Loyalty Program and that will not contain any commercial offers).

If you do not want to receive this kind of communication, you can ask us to stop sending them as follows:

  • send an e-mail as described in the section Exercise of your Rights below; or,
  • directly change the setting in your Loyalty account or,
  • click on the unsubscribing link available in all our communication.

7.4 Deletion of your Loyalty Account 

If you want to delete your Loyalty Account, you can either:

  • delete it directly in the setting of your Loyalty Account; or,
  • send an e-mail as described in the section Exercise of your rights below.

7.5 Exercise of your Rights 

If you wish to exercise these rights and/or obtain all relevant information, please contact us at the following address: ksk@expansja.pl lub recepcja.westfieldarkadia@urw.com.

To ensure an effective exercise of your rights, please note that you can send your request at the above mentioned address for your questions and demands in relation
with processing to both data controllers (local Data Controller and group Data Controller).

In order to avoid to infringe third party rights, we reserve the right, in case of reasonable doubt, to proceed to prior verification of your identity in asking you :

  • your number of loyalty member, or, if you do not have it,
  • an ID Document

We will respond within 1 month after receipt of your request, but We retain, when necessary due to the complexity of your request,  the right to extend this period by 2 months. We will in any event inform you within 1 month after receipt of your request if We decide to extend the period to respond.

If needed, you can also address any question at the welcome desk of your shopping centre.

7.6 Complaints

You have the right to make  a complaint about the way We process your Personal data to the Personal Data Protection Office ul. Stawki 2, 00-193 Warsaw, Poland

8. Geolocation

8.1 General principle

Subject to your prior express consent given in the shopping center application, information related to your location within our shopping centre may be collected and processed by Us while you are authenticated on our shopping center Applications for the purposes of measuring the frequency of your visits and your itineraries within our shopping centre and/or providing location related services.

Geolocation will only take place if you have activated the additional services/specific function in the settings of your downloaded shopping centre application on your mobile device. You could deactivate those additional services at any time in the settings latter one at any time.

Please note that when given, your consent will be effective immediately for any further connections on our shopping center Application and for any further visits in our shopping centre within 12 months from first connection, unless you withdraw your consent.

8.2 How to manage your geolocation preferences on your mobile device

In order to be located within the shopping centre, you will be required to activate the Bluetooth feature on your mobile device.

If you only want to check out the map the activation of the Bluetooth feature is not required.

Please note that we will not locate you outside our shopping centre. The location option is carried out by the Bluetooth beacons which are installed in the common areas of the shopping centre only.

You may disable the geolocation of your mobile device through your mobile settings at any time.

9. Automated decision making / profiling 

There is currently no automated decision-making process or profiling which would legally affect you or otherwise significantly affects you. But we will provide you with specific offers based on your individual Personal data and analysis of your user behavior.

Indeed, as we do not want to bother you with information and promotions that may not be relevant to you, we assess your purchase profile, i.e. information such as your earlier purchases and preferences that we collect through your use of our Services as detailed in table (article 3.1), to send you only information and promotions we consider interesting or relevant to you.

10. Transfer in case of change of ownership

If Unibail-Rodamco-Westfield  Group is involved in a merger, acquisition, dissolution, or sale all or part of the shopping centre, or its managing company or owner, where you are registered as a Loyalty Program member, we reserve the right to transfer your personal data. You will be notified if such change requires notification or consent under applicable law, you will be notified or given the opportunity to consent.

11. Update of this Privacy Policy

We may revise or update this Privacy Policy from time to time. Any change to this Privacy Policy will become effective upon online publication on this website.

If such change requires notification or consent under applicable law, you will be notified or given the opportunity to consent.

Appendix1 - List of service providers