Privacy Statement
Touchwood Solihull is committed to protecting the privacy of people using this website, the Touchwood App and guests visiting the shopping centre.
This Privacy Statement applies to www.touchwoodsolihull.co.uk (the "Website"), the Touchwood App (“the App”) and Touchwood Solihull (the "Shopping Centre") which is managed by Workman Facilities Management Limited.
This Privacy Statement explains how personal data will be treated as you access and interact with the Touchwood Website and/or the Shopping Centre.
Information collected through the Website or in the Shopping Centre may be collected by Workman Facilities Management in accordance with this Privacy Statement. We treat your personal identifiable details (“personal data”) with respect and integrity, and we will keep your personal data secure and use the information you provide consistently with applicable privacy and data protection laws (“Laws”) and the terms of this Privacy Statement.
We will post any updates to this Privacy Statement on the Website, so we encourage you to check from time to time. We will also take all reasonably necessary measures to notify you of any changes to this Privacy Statement.
In addition to the provisions of this Privacy Statement, there may also be additional provisions that apply to certain sections or functions of the Website, or the Shopping Centre (for example for specific shops operating within the Shopping Centre). Since those additional provisions also relate to your privacy, we recommend that you review them wherever they appear. In the event of any inconsistency between this Privacy Statement and those additional provisions, the additional provisions will prevail.
This Privacy Statement insofar as it applies to the Shopping Centre, only applies to general and/or public areas of the Shopping Centre. Where you enter a specific shop or make a purchase from a particular retailer, the use of your personal information will be subject to that retailer's privacy statement(s) and/or policies.
The personal data we collect and how we use it
The personal data which the Website, App and shopping centre may collect includes:
• Personal information, including but not limited to your name, postal address, email address, phone number, date of birth and any other information collected on registration or the ordering process through the website or Shopping Centre (for example gift cards)
• Automatic information about you and/or your device, including where available, your IP address.
• Photographic images and other information obtained at shopping centre events (for example. name, address, date of birth)
• Job applicant information such as CVs, employment history and references
• CCTV images
• Tenant and retailer information including name, postal address, phone number, email and any other information collected during the business relationship
• Personal information for accident reporting including name, contact details and special categories of personal data ie. medical information
The personal data which the Website, App and shopping centre collects may be used as follows:
• To fulfil contracts for goods and/or services between us and deal with orders, complaints and enquiries
• To build a profile of you to enable us to personalise your shopping experience.
• For research and analytical purposes and to allow us to carry out research and improve the functionality and administration of the Website.
• To allow you to enter competitions/ prize draws.
• To ask you to complete surveys
• To help us analyse how users use the Website (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our Website users and to assist us in managing your account and improving your online experience.
• Please see our cookies policy for further information bout what information may be automatically collected when you visit our website (insert link to cookies)
• With CCTV footage we have a legitimate interest in processing this information to (a) protect you, our other customers and our staff from harm; and (b) to protect our business from theft. We consider it necessary and proportionate to process the information in this way and there is no alternative method in which we could guarantee the same outcomes. We do not consider this will negatively impact you if you act lawfully within our Shopping Centre.
• Should we use images of just you (i.e. not within a group) for marketing or promotional materials, we will ask you to provide your consent and an image rights clearance, which you can always refuse. Where we take photographs of groups at these events, we are doing so for our legitimate business interest of using the images for marketing and promotional materials to promote our business. It is within your reasonable expectations that in attending a PR event, photographs will be taken and images used in this way.
• It is in our legitimate business interests to send you marketing material electronically or by post. It is in your reasonable expectations that as a business we would like you to see our other wonderful products and offers and we implement safeguards to ensure customers who have opted out of receiving such communications don't receive them.
• We will send you postal marketing, unless you have objected to us or subscribed to the MPS.
• Where you have [negotiated a sale with us/ put something in your basket or] bought something from us, we will send you electronic marketing material provided you haven't opted out, unsubscribed or changed your account preferences.
• Where you have not [negotiated a sale with us/ put something in your basket or] bought something from us, we will only send you electronic marketing material if you have consented to receiving it.
• If you are an individual representative of a business who has a relationship with us, it is in our legitimate interests to process your information in the course of that relationship/ contract and will be fully within your reasonable expectations.
• To fulfil the contract for goods and/or services between us and deal with orders, complaints and enquiries.
• It is in our legitimate business interests (and is a necessity) to process this information to notify next of kin/emergency contact in the event of an emergency.
• To comply with health and safety regulations.
• We process data reviewing your application for a relevant job role, with a view to taking steps to enter into an employment contract/arrangement with you. Please note, this is not relevant to applicants applying for roles in specific shops (in which case their policies will apply instead).
How we may share your personal data
Your information may, for the purposes set out in this Privacy Statement be disclosed to the third parties set out in "The personal data we collect and how we use it" section above.
Your information is also shared (and in most cases directly collected and processed by) with and by Workman Facilities Management, who act as our agent, operating the Website and Shopping Centre on our behalf.
We will only share your personal information with other members of Touchwood for marketing purposes where you have expressly opted-in/consented to the disclosure of your personal data for these purposes.
We will only disclose your information to:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• to our professional advisors
• to other third party suppliers for business administration or IT purposes;
• our affiliates and selected third parties, where you have expressly opted-out of receiving marketing from us / third parties, in which case we may share suppression lists with our affiliates and selected third parties, to ensure you do not receive unsolicited marketing;
• analytics and search engine providers that assist us in the improvement and optimisation of our Website;
• our regulators, law enforcement or fraud prevention agencies, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters etc.
We will disclose your personal information to third parties:
• in the event that we consider selling or buying any business or assets, in which case we will disclose your personal data to any prospective sellers or buyers of such business or assets;
• in the event of any insolvency situation
• if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
• in order to enforce or apply our Website terms of use
• to protect the rights, property, or safety of us, our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
You may browse some information-only areas of the Website without providing any personal data (other than your IP address and cookies), however, we may not be able to provide the full range of services through the Website if we are not provided with the information outlined above.
For more information about how we use cookies on the website please read the full version of our Cookie Policy [link].
How we use your information for marketing
We want to communicate with you only if you want to hear from us. We would like to send you offers and promotions which we believe will be of interest to you, both from ourselves and relevant third parties, by email, SMS, phone and/or post. If you prefer not to receive promotional information from us, you may opt out of receiving our promotional communication by following the instructions below or on each promotional communication. The relevant third parties may only send you offers and promotions by email and/or SMS where you have consented to this. However, if you wish to opt out of receiving offers and promotions from them by phone and/or post, please follow the instructions below or on each promotional communication.
Retaining your personal data
We may retain your personal data for an appropriate period of time in accordance with our data retention policies. Should you ask us to cease sending marketing communication to you, we will maintain your details on a suppression list for this purpose.
Links to other websites
The Website may, from time to time, contain links to the websites of other organisations which may be of interest to you. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements.
Security and monitoring
We use a number of mechanisms to protect the security and integrity of personal data. Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. So while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to use and individuals do so at their own risk. Once any personal data comes into our possession, we will take reasonable steps to protect that information from misuse and loss and from unauthorised access, modification or disclosure.
A user name and password may be essential for you to use some sections of the Website. For your own protection, we require you to keep these confidential and to change your password regularly (if required).
The use of our Website and the information submitted may be monitored by our services providers or our employees for purposes including compliance auditing and maintenance or where inappropriate or illegal behaviour is suspected.
Your Rights
You have a number of rights by Law in relation to the way we process your personal data. These are set out below. You may contact us at the address below to exercise any of these rights, and we will respond to any request received from you promptly and in accordance with the Law.
You have a number of rights by Law in relation to the way we process your personal data. These are set out below. You may contact us at the address below to exercise any of these rights, and we will respond to any request received from you promptly and in accordance with the Law.
Right 1: A right to access personal data held by us about you.
Right 2: A right to require us to rectify any inaccurate personal data held by us about you.
Right 3: A right to require us to erase personal data held by us about you. This right will only apply where (for example): we no longer need to use the personal data to achieve the purpose we collected it for; or where you withdraw your consent if we are using your personal data based on your consent; or where you object to the way we process your data (in line with Right 6 below).
Right 4: In certain circumstances, a right to restrict our processing of personal data held by us about you. This right will only apply where (for example): you dispute the accuracy of the personal data held by us; or where you would have the right to require us to erase the personal data but would prefer that our processing is restricted instead; or where we no longer need to use the personal data to achieve the purpose we collected it for, but you require the data for the purposes of dealing with legal claims.
Right 5: In certain circumstances, a right to receive personal data, which you have provided to us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal data to another organisation, at your request.
Right 6: A right to object to our processing of personal data held by us about you where the processing of such data is necessary for the purposes of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process personal data which override your rights or which are for the establishment, exercise or defence of legal claims.
Right 7: A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
Right 8: A right to withdraw your consent, where we are relying on it to use your personal data (for example, to provide you with marketing information about our services or products).
Contact details
We encourage you to contact us in the first instance using the details set out below if you have any questions, comments or concerns about our processing of your personal data or wish to exercise any of your rights set out below. Any information that we provided in response may be limited to the extent permitted by any applicable law.
Post: Management Offices, The Hub, Touchwood, Solihull, B91 3GJ
Email: guestservices@touchwoodsolihull.co.uk
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request by you in relation to your rights, then you also have the right to make a complaint to our lead supervisory authority, which is the UK's Information Commissioner's Office:
First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
This Privacy Statement was last reviewed and updated in May 2018.