This User Privacy Notice (“Privacy Notice” or “Notice”) was last updated on August 16, 2017. It is effective immediately for all new Westfield users and on October 1, 2017 for all pre-existing Westfield users.
This Privacy Notice explains Westfield’s privacy and information practices for its website, mobile applications (together, “Online Services”), and centers. This Notice describes the types of information collected, how that information is used and disclosed, and how you can access, modify, or delete your information.
We collect information from you when you use our Online Services or visit Westfield centers.
ONLINE SERVICES. When using our Online Services, you may provide information directly, such as by creating an account, filling out a form, signing up for SmartParking, completing a “contact us” query, applying for a career with Westfield, or signing up for newsletters or other communications. Additionally, you may choose to provide your location when using a Westfield Online Service.
We may also collect information from you automatically when you use our Online Services. For instance, we may collect information about your use of our Online Services, including the time and duration of your visit, the referring URL, your Internet Protocol (IP) address, the type of device you use and its operating system, your advertising ID (e.g., AAID and IDFA), and other device identifiers.
IN OUR CENTERS. We use Bluetooth (BLE) Beacons, Wi-Fi, and similar technologies within some of our centers that may communicate with your (mobile) device and identify its location if the device has Bluetooth and/or Wi-Fi enabled and is properly configured. As a result, we may collect your Wi-Fi and/or Bluetooth MAC Address and send BLE signals to your device. To opt out of BLE Beacons and/or the collection of your MAC address, turn off your device Bluetooth and Wi-Fi capabilities.
For more information you may also visit https://smart-places.org/.
Westfield Wi-Fi. If you use one of the Wi-Fi networks in our centers, we will collect personal information from you in order to log you on to the network, including your name and email address. We may also collect information about your use of the Wi-Fi, such as the web pages you visit, your MAC or IP address, and your location while using the Wi-Fi.
Concierge Services. If you use our concierge services in center or online, we may collect information from you to facilitate the products or services you request. Concierge services vary by location--check with the concierge in your local center to see what services are available and what personal information is required to use those services.
THIRD-PARTY SOURCES. Westfield may obtain information about you from third parties and/or link the information we collect from you to additional records made available by third parties.
HOW INFORMATION IS USED
Westfield uses the information it collects for three primary purposes: 1) to operate our business, including providing and improving our products and services; 2) to send you communications; and 3) to tailor and show advertisements to you.
Providing Westfield products and services. We use the information we collect to perform essential business operations, for example to understand usage patterns (such as foot traffic) within our centers, and to develop, provide, improve, and personalize Westfield products and services and to provide customer support.
Communications. We use information we collect to deliver and personalize communications through various channels, including email, SMS messaging, push notifications, and other channels where you have consented to receiving communications from Westfield. See the “Choice” section on how to change your communications preferences.
You may opt out of some interest-based cookie advertising by clicking “Cookie Settings” in the footer below.
SHARING PERSONAL INFORMATION
Service Providers. We may share information we collect about you with third parties who provide services on our behalf to help with our business activities (e.g., payment processing, data storage).
We may also share your information with service providers that help us market our products or services to you and to tailor and deliver advertisements to you.
Disclosure for Legal Reasons. We may disclose personal information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with the law, including valid legal requests from private parties, law enforcement, or other government agencies (e.g., subpoena, summons, or court order).
Change of Ownership. If Westfield is involved in a merger, acquisition, dissolution, or sale of all or a portion of its assets, we reserve the right to transfer your personal information. You will be notified via email and/or a prominent notice on our website of any change in ownership and choices you may have regarding your personal information.
YOUR PRIVACY CHOICES
We enable you to maintain control of your privacy by providing choices about what information you provide us and how we communicate with you, and by providing access to your personal information.
Choice: You have choices about what information you provide Westfield. Where information is required, it will be marked as such. If the information input fields are not marked as required, providing the information is optional. Note that failing to provide some of the requested information may limit your use of our products or services.
You may adjust your communication preferences or opt out of communications at any time by clicking “unsubscribe” at the bottom of the email, following instructions provided in the communication, or changing your preferences within your Westfield account. If you are having difficulty updating your communication preferences, contact us.
Access. You may access, correct, or delete your personal information by logging into your Westfield account and following the relevant prompts, or by contacting us.
We will endeavor to provide you with access to your personal information wherever possible. Note that in some cases we may not be able to provide you access, such as where providing access would be unreasonably difficult or would compromise the privacy of others.
EUROPEAN PRIVACY RIGHTS
Where applicable, Westfield adheres to data protection laws in the European Economic Area, including:
Westfield Europe Limited is the ‘data controller’ for the personal data we collect. It is registered with the Information Commissioner’s Office with registration number Z5539526.
You have the right to request access to, to update and delete your personal data (see “Access”).
If Westfield’s processing of personal data is based on your consent, you have the right to withdraw consent for future processing at any time.
You have the right to object to the processing of your personal data; and
You have the right to lodge a complaint with your Data Protection Authority. In the U.K, this is the Information Commissioner’s Office.
To exercise any of these rights, contact us.
INTERNATIONAL TRANSFERS OF EUROPEAN PERSONAL INFORMATION
By agreeing to this User Privacy Notice, you consent to the transfer of your personal information outside of the European Economic Area.
Westfield Europe Limited is in the process of certifying under the EU-U.S. Privacy Shield and currently uses lawful mechanisms such as model clauses and Privacy Shield-certified service providers in order to facilitate such transfers.
Westfield does not knowingly collect personal information from children under the age of 13.
Children under the age of 13 are not permitted to use Wi-Fi networks in Westfield centers.
If you have reason to believe that a child under the age of 13 has provided personal information to Westfield, please contact us and we will delete that information from our databases.
Westfield retains the information we collect for as long as necessary to provide the products and services you have requested, or for other essential purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.
The security of your personal information is important to us. While we follow generally accepted security standards to safeguard the information submitted to us, it is not possible to guarantee the security or integrity of information. Therefore, we encourage you to take precautions to protect your information, including protecting your passwords, using secure networks to access the Internet, and logging out of online services when you are away from your device.
LINKS TO OTHER WEBSITES
Westfield’s products and services may contain links or references to other websites or companies not operated or controlled by Westfield. The policies and procedures described here do not apply to those third parties. Links or advertisements do not imply that Westfield endorses or has reviewed such third parties or their privacy practices. Visit those third parties’ websites or contact them directly for information on their privacy policies.
CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of Westfield products or services after any changes or revisions to this Notice shall indicate your agreement with the revised terms.
When possible, we will archive previous versions of our Privacy Notice here.
If you have questions or complaints regarding our privacy practices or this Privacy Notice, or would like to exercise your rights as explained in this Notice, please contact us as follows:
If you are located in the United States, via email or at:
ATTN: Head of Privacy
835 Market Street, Suite 517
San Francisco, CA 94103
United States of America
If you are located in the European Union, via email or at:
6th Floor MidCity Place
71 High Holborn, London
ATTN: Head of Data Protection