PRIVILEGE AGREEMENT DATA PROTECTION NOTICE
The terms and conditions of this Data Protection notice as well as the Privilege membership terms and conditions [insert link] govern the Privilege (“Agreement”). If you visit our website, additionally, the data protection terms of our website apply.
You should read through the Agreement to fully understand the basis upon which we collect information about you, how we use the information, where we store the information and to whom the information is disclosed. The terms and conditions of this Agreement which relate to personal data are in addition to our individual privacy policies which relate to our use of information about you other than in connection with Privilege.
Commitment to Privacy
We are committed to protecting your privacy. We want to use your personal information to improve our services to you and our guests generally. We will always keep your personal information safe and comply with applicable Data Protection legislation from time to time in place.
Who we are
Please click here to see who we are. The entities listed are the owners and operators of retail outlet villages “Villages” indicated against their name and of Chic Outlet Shopping®. The Villages include retail outlet villages outside of the EU and EEA including those in China. References in this Agreement to “we” or “us” are to the entities listed. Each of the listed entities are committed to protecting your privacy and are joint data controllers within the meaning of data protection laws applicable in the EU and EEA.
What information do we collect about you?
We collect the information you provide to us as part of your registration and any further information you provide to update your registration details from time to time. This information includes your name, address, place of residence, nationality, gender, date of birth, email, land and mobile phone numbers and other contact details.
Depending upon the type of access device you use, additional information is collected electronically when you enter a Village and/or when you enter a retail outlet. The information we collect is your location at any particular time when in a Village as well as the time, place and frequency of your use of the access device. The access device referred to in this Agreement may be any of the following: the bar code, card, mobile application or other electronic identification device or software application we provide you from time to time. We also collect information concerning your transactions at any retail outlet using a point of sale device. The information captured may include details of the items purchased and amounts spent. We may also combine this information with other information we hold about you across the companies in the Chic Outlet Shopping group and the different channels you use to interact with us (eg website, our app, correspondence etc). In addition, we may combine all the information we hold about you with that held by our selected partners and/or retail outlets where you have agreed that they can share your information with third parties.
How we use your information
We use the information held about you in a variety of ways such as:
• To manage and improve Privilege
• 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 retail outlets at the Villages, the goods which they sell, the Villages and Chic Outlet Shopping® and the retail outlets at the Villages including the goods which they sell;
• To share your information with retail outlets in any of our Villages for the purposes of us or them informing you of goods, services, promotions, offers and forthcoming events which may be of interest to you;
• Data cleansing: To ensure that the information we hold is kept accurate and up to date;
• 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.
We will keep your information for as long as we have a legal or business reason to do so which generally means as long as you are a member of Privilege
Where we store or process your information
The information we collect from you will also be transferred to, and stored at, a destination outside the EU and EEA specifically to Villages and retail outlets in China and to our suppliers and partners in India and the USA. Such destinations may not have laws which protect your information to the same extent as in the EU and EEA. It will be processed by us or by our suppliers and partners operating outside the EU and the EEA, but we will ensure that your information is treated by us and each of our suppliers and partners 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 Agreement.
A list of persons who process your information on our behalf (i.e. our suppliers and partners) outside of the EU and the EEA is set out below:
Responsys Inc. 900 Cherry Avenue, 5th Floor, San Bruno, CA 94066, USA;
Salesforce.com Inc, The Landmark@One Market, Suite 300, San Francisco, CA 94105, USA
How we contact you
In order to provide you with the benefits of Privilege we may contact you by post, e-mail, SMS text messages, telephone or other means including other electronic means such as Facebook and social media applications, but 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 cancel your registration for Privilege by contacting us at Privilege@WertheimVillage.com or you may update your preferred contact details at any time by contacting us at the above address.
We share information amongst ourselves and disclose information to:
• Retail outlets located at the Villages (who may contact you directly);
• Suppliers that process information on our behalf and partners who assist in providing Privilege;
• If we are under a duty to disclose or share your information 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
• Successors in title or replacement operators of all or part of our respective businesses.
You have the right to ask us not to process your information for marketing purposes. To do so would be inconsistent with Privilege, so if you no longer wish us to do so, you should cancel your registration to Privilege. (see above)
You are entitled to ask us whether we are keeping information about you, the source of such information, the purposes for which it is used, and to whom it is disclosed. You can also ask to have access to any such information. In order to receive a copy of any personal data that we currently hold about you, please send your contact details including address and proof of identification (such as a copy of your passport, ID card or driving licence) to legal@WertheimVillage.com or the following address:
50 Pingle Drive
Bicester, Oxfordshire, OX26 6WD
We allow you to challenge personal data that we hold about you and, where appropriate, you may have personal data erased, rectified, amended or completed. We reserve the right to refuse to provide you with a copy of your personal data and to have personal data erased, rectified, amended or completed to the extent we are legally entitled to do so but will give reasons for our refusal, and you may challenge our decision.