Shopping Centre Privacy Policy

Updated 4 June 2026

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit, use or order anything from our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our mailing list, subscribe to any notifications or newsletters, enter any competitions, make any bookings or place any orders.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

Edinburgh St James (GP) Limited on behalf of Edinburgh St James LP (collectively referred to as “St James Quarter”, “we”, “us” or “our” in this privacy notice) is the controller and responsible for your personal data provided when you access this website. Our contact details are St James Quarter, St James Crescent, Edinburgh, Scotland EH1 3AD and hello@stjamesquarter.com.

For all data matters contact our Data Protection Officer on hello@stjamesquarter.com.

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: which includes first name/maiden name/last name/username or similar identifier/marital status/title/date of birth/gender.

• Contact Data: which includes delivery address/billing address/email address/telephone numbers.

• Financial Data: which includes bank account and payment card details.

• Transaction Data: which includes details about payments to and from you and other details of products and services you have purchased from us.

• Profile Data: which includes your username and password/purchases or orders made by you/your interests/preferences/feedback/survey responses.

• Usage Data: which includes information about how you use our website, products and services.

• Marketing and Communications Data: which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Technical Data: includes internet protocol (IP) address/your login data/browser type and version/time zone setting and location/browser plug-in types and versions/operating system and platform/other technology on the devices you use to access this website.

• Location Data: which includes details relating to the users current location and travel routes.

• Social Media Data: which includes username and publicly available profile information.

• Physiological/Biological Data: which includes height and weight.

• Preference Data: which includes products and services which you like or save as a preference.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

• Direct interactions – You may give us your Identity, Financial and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply for our services;

  • Create an account on our website;

  • Subscribe to our newsletter service or publications;

  • Request marketing to be sent to you;

  • Enter our competitions;

  • Give us feedback or contact us;

  • Make a booking via our website;

  • Place an order or payment via our website.

• Automated technologies or interactions – As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

• Third parties or publicly available sources – We will receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties:

    • analytics providers such as Google based outside the UK; and

    • social media advertising networks such as Facebook and Instagram based outside the UK; and

    • other advertising networks based within and outside of the UK in relation to campaigns that we operate from time to time..

  • Social Media Data from the following parties:

    • Instagram; and

    • Facebook.

  • Identity Data, Location Data and Physiological/Biological Data from our third party accessibility partners, including:

    • Neatebox Limited;

    • Saloca Limited, t/a Appointedd; and

    • North East Mobility Solutions Limited.

  • Identity Data and Contact Data from Location Live, to the extent that you wish to book events in St James Quarter,

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as:

    • Drop-It;

    • Shopify; and

    • Stripe.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Legitimate Interest this means the interest of our business in conducting, marketing and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

• Where you have given your consent to the processing of your data for one or more of the purposes detailed below, including marketing or to allow us or another third party to provide services to you.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact on hello@stjamesquarter.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have either explicitly consented to receiving marketing communications from us or you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the St James Quarter group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the optout links on any marketing message sent to you or by emailing hello@stjamesquarter.com. at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product or service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email hello@stjamesquarter.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties (relevant departments within our company who can better serve your enquiry/needs)

• External Third Parties

  • Service Providers acting as processors based in the EEA who provide IT, marketing and system administration services.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice; and

  • Third party service providers who provide their services through our website on their own behalf or on behalf of us, including;

    • Placewise, for the purpose of sending our newsletters to you, where you consent to receiving these, and providing you with relevant offers based on your preferences;

    • Appointedd, for the purposes of allowing you to book services within St James Quarter;

    • North East Mobility Solutions Limited, for the purposes of providing you with accessibility solutions at St James Quarter;

    • CarePark, UbiPark and SKIDATA, for the purposes of providing services to you in relation to our car park offering at St James Quarter; and

    • Mall Solutions, in order to address your commercialisation requests.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers that provide services on behalf of us to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Any service providers that provide services on their own behalf through our website may do so in accordance with their own privacy statements. We do not control these third-party services and are not responsible for these privacy statements. We encourage you read these before engaging with any of these services when they are made available to you.

6. INTERNATIONAL TRANSFERS

Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing the following safeguards:

• A legally binding agreement between public authorities or bodies;

• Ensuring that the country to which the data is being transferred to is recognised as having an adequate level of protection for personal data or there is a certification under an approved certification mechanism as provided for in the GDPR;

• Contractual clauses agreed authorised by the competent supervisory authority; or

• Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority. Please contact us at hello@stjamesquarter.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;

• The right to request that we correct any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary to retain such data;

• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;

• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact hello@stjamesquarter.com.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 4 June 2026 and historic versions can be obtained by contacting us.

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

11. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer on hello@stjamesquarter.com.

You have the right to make a complaint to us about the processing of your personal data or in relation to the exercise of any of your rights at any time. Our data protection complaints procedure, which includes details of how you can make a complaint, can be found here.

You also have the right to complain to the ICO, who can be found via their website (www.ico.org.uk) or by telephone: 0303 123 1113 or any EU data protection regulator, in particular, the regulator for the Member State in which you reside or work, or in the member state where the activity which gave rise to the complaint occurred, or that of our lead supervisory authority insert details.