Effective January 1, 2023
Westfield Privacy Notice
SCOPE AND CONSENT
PERSONAL INFORMATION WE COLLECT
Personal information is defined as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include anonymous or non-personal information (i.e., information that cannot be associated with or traced back to a specific individual or household). Westfield may collect the following types of personal information from you when you use our Corporate Services or visit Westfield Centers:
Personal information you provide to us. When using our Corporate Services, you may provide personal information directly, such as by creating an account, filling out a form, signing up for SmartParking, completing a "contact us" query, or signing up for newsletters or other communications. Additionally, you may choose to provide your location when using a Westfield Online Service. This personal information may include your name, email address, and depending on the Corporate Services, it may also include payment information, license plate number and/or other identifiers.
Personal information we collect automatically from your device. We may also collect personal information from you automatically when you use our Corporate Services. For instance, we may collect personal information about your use of our Corporate 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.
Competitions, Sweepstakes and Events. When you enter a competition, sweepstakes, or register for an event you may provide contact information directly to us including name, address, email address, phone number, and if required by law, certain tax information.
Loyalty Program. We partner with Thanx to provide you with our loyalty program, Westfield Rewards. When you sign up for Westfield Rewards, we (along with Thanx independently) may collect the following categories of personal information:
- Phone Number;
- E-Mail Address;
- Purchase Data;
- Date of Birth; and
- Reward Redemption Data.
Professional and Client Relationships. In the course of professional or client interactions involving the purchasing of advertising or the leasing of retail or other real estate space, we collect personal information about you such as your name, position, entity name and other details surrounding the transaction.
In Our Centers.
Location Information. In some of our Centers, we use Bluetooth (BLE) Beacons, Wi-Fi, and similar technologies 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 completely opt-out of BLE Beacons and/or the collection of your MAC address, turn off your device Bluetooth and Wi-Fi capabilities. To learn more about mobile location analytics and to opt-out of mobile location tracking for companies that have agreed to the Mobile Location Analytics Code of Conduct please 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 personal 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.
Digital Displays and Demographic Data Some of our Centers have digital displays with Quividi technology, which uses camera sensors to detect your generic facial features and infer certain demographics, such as age and gender. This demographic data is aggregated among all viewers, and we use the resulting aggregate demographic data to better understand the general demographics of people who viewed the content and advertisements on the digital displayers, and to improve the content, advertisements, and digital display locations moving forward.
We do not use facial features data or any demographic data to directly identify any specific individuals, nor do we combine it with any lists, databases, or other datasets that could be used to identify specific individuals. We do not lease, trade, or share in exchange for anything of value, or otherwise profit from the transaction of such data. Facial features data is immediately deleted, and any demographic data is aggregated and cannot be used to link multiple views on a digital display, or visits to a Center across days or across multiple Centers. For more information on the Quividi technology, please visit Quividi’s FAQ.
Concierge or Other Convenience Services. If you use our concierge services in Center or online, or other services offered at your convenience such as mobile charging capabilities, package delivery, wheelchair and stroller rentals, and valet and related parking services, we collect personal information from you to facilitate the products or services you request. Please note that these vary by location—check with your local center to see what services are available and what personal information is required to use those services.
Competitions, Sweepstakes and Events. When you enter a competition, sweepstakes, or register for an event at one of our Centers, you may provide contact information directly to us including name, address, email address, phone number, and if required by law, certain tax information.
Management and Safety. We collect personal information on incidents and accidents that occur in our Centers that may include the use of Closed Circuit Television Video (CCTV), video taken from parking lot security cameras, photographs and pertinent personal information regarding accidents/injuries that may have occurred at the center(s), and other security measures for your protection.
Third-Party Sources. Westfield may obtain personal information about you from third parties and/or link the personal information we collect from you to additional records made available by third parties. For example, if you use social media features in our websites or apps or post to a social media platform, the social media site will give us personal information about you.
Professional and Client Relationships. In the course of professional or client interactions involving the purchasing of advertising or the leasing of retail or other real estate space, we may collect personal information about you such as your name, position, entity name and other details surrounding the transaction or potential transaction.
HOW PERSONAL INFORMATION IS USED
Westfield uses the personal 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, Developing, and Improving Westfield Products and Services. We use the personal information we collect to perform essential business operation purposes, 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 personal 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 for our business and commercial purpose. See the "Choice" section below on how to change your communications preferences.
- Loyalty Program. If you have an account with Westfield Rewards, we may use the personal information provided for our business and commercial purpose to:
- Initiate and service your account;
- Provide you with notices as to how to better manage your account;
- Credit your account based on eligible purchases;
- Offer you program rewards or special offers;
- Redeem earned rewards; and
- Notify you of special events or deals unique to Westfield Loyalty members.
You may access, edit, or delete your account information at any time by logging into your account and/or contacting us.
You may opt out of some interest-based cookie advertising by clicking Cookie Settings and for more information about third-party advertisers and your ability to opt-out of targeted advertising from such third-parties please visit the Network Advertising Initiative (http://www.networkadvertising.org/choices/) and the Digital Advertising Alliance (http://www.aboutads.info/choices/). Note that opting out through these links only means that you should no longer see interest-based ads from the selected participants on the browser or device from which you opted out, but does not mean that the participants will not process your information for interest-based advertising purposes. We are not responsible for the effectiveness of these opt outs.
- Maintaining a Secure Environment. We may use the personal information we collect for a business purpose to investigate, detect, and prevent or report, fraud, security breaches or incidents, or other potentially prohibited or illegal activities. In addition, we may also use personal information to comply with applicable laws or regulations or to protect our customers’ rights, or the security and integrity of our Centers or Corporate Services.
HOW WE SHARE YOUR PERSONAL INFORMATION
- Affiliates entities. We may disclose personal information we collect with our affiliates and related entities (e.g. relevant shopping centers), including without limitation, those affiliates and related entities in the Unibail-Rodamco-Westfield family in the US and abroad, including where they act as our service providers or for their own internal purposes, in order to deliver products and services to you, to ensure a consistent level of service across our products, services, and Centers, and to enhance our products, services, Centers, and your customer experience.
- Service Providers. We may share personal information we collect about you with third parties who provide services on our behalf to help with our business activities, for example:
- processing credit cards and payments;
- hosting, managing and/or servicing our data;
- distributing emails;
- to provide CCTV and security services within our Centers;
- managing and operating our loyalty program;
- providing advertising, analytics, and research; and
- managing brand and product promotions and administering and marketing services and features.
- • Analytics and Advertising. We may disclose personal information to vendors and other third parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your personal information.
- 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.
YOUR PRIVACY CHOICES
Our Corporate Services are not directed to children under the age of 13 and 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.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
Westfield retains the personal 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, general archival purposes, resolving disputes, and enforcing our agreements. If you have any questions about the retention of your personal information, please contact us directly at firstname.lastname@example.org.
HOW WE PROTECT YOUR PERSONAL INFORMATION
The security of your personal information is important to us. While we follow generally accepted security standards to safeguard the personal information submitted to us, it is not possible to guarantee the security or integrity of personal information. Therefore, we encourage you to take precautions to protect your personal 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 AND THIRD PARTY SOCIAL MEDIA
Westfield's products and services may contain links or references to other websites or companies not operated or controlled by Westfield. It may offer you the ability to share your personal information through a social networking site (e.g., Facebook, Eventbrite, etc.), using such site’s integrated tools (e.g., Facebook “Like” button). This includes, among other things, your name, gender, profile picture, your “likes” and check-ins, and your list of friends, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access the Corporate Services.
Notice of Information We Collect and Use
When using our Corporate Services or visiting our Centers, we may collect personal information. Within the last twelve (12) months, we have collected the following categories of personal information:
Within the last twelve (12) months, we have collected the following categories of personal information:
- Identifiers – Such as name, account name, online identifier, address, email address, phone number, license plate number, internet protocol address, advertising ID (e.g., AAID and IDFA), device identifiers, cookies, web beacons, or other similar identifiers.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – Such as signature, credit and/or debit card number, or certain tax information (if required by law when you enter a competition, sweepstakes, or register for an event).
- Characteristics of protected classifications under California or federal law – Such as date of birth and gender.
- Commercial Information – Such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity – Such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Non-precise Geolocation Data – Such as location derived from an internet protocol address. You may choose to provide your location when using a Westfield Online Service. Additionally, in some of our Centers, we use Bluetooth (BLE) Beacons, Wi-Fi, and similar technologies 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 completely opt-out of BLE Beacons and/or the collection of your MAC address, turn off your device Bluetooth and Wi-Fi capabilities. To learn more about mobile location analytics and to opt-out of mobile location tracking for companies that have agreed to the Mobile Location Analytics Code of Conduct please visit https://smart-places.org.
- Professional, employment, or education-related information – In the course of evaluating you for a position, we may collect such information.
- Inferences drawn from other personal information – Such as inferences about a consumer reflecting the consumer’s characteristics and shopping behavior and preferences.
Please visit the Information We Collect section of the Privacy Notice for additional information about the personal information we collect.
We use personal information for the business and commercial purposes set out in the How Information Is Used section of the Privacy Notice.
We do not sell your personal information as that term is traditionally understood.
However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and a “share” is broadly defined under the CCPA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below.
We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
To the extent any of the personal information we collect is sensitive personal information, we collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CCPA. We do not sell or share sensitive personal information
Sources of Information
We collect personal information from the following categories of sources:
- From You – For example, when you create an account, fill out a form, sign up for SmartParking, complete a “contact us” query, or sign up for newsletters or other communications; when you enter a competition, sweepstakes, or register for an event at one of our Centers; or when you use our concierge services in Center or online, or other services offered at your convenience such as mobile charging capabilities, package delivery, wheelchair and stroller rentals, and valet parking.
- Operating Systems and Platforms – For example, we may collect personal information from you automatically through the use of logging and analytics tools, and as a result of your use of and access to the Corporate Services, including the time and duration of your visit, referring URL, IP address, type of device you use and its operating system, and other device identifiers. In some of our Centers, we may collect personal information through Bluetooth (BLE) Beacons, Wi-Fi networks, and similar technologies, as well as through image and video systems, including CCTV and ALPR technology.
- Third Parties and Social Networks – For example, we may obtain personal information about you from third parties and/or link the personal information we collect from you to additional records made available by third parties. For example, if you use social media features in our websites or apps or post to a social media platform, the social media site will give us personal information about you.
Information We Disclose
We have disclosed to service providers and third parties, for business purposes, the following categories of personal information from consumers within the last twelve (12) months:
- Identifiers – Affiliated Entities and Service Providers
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – Affiliated Entities and Service Providers
- Commercial Information – Affiliated Entities and Service Providers
- Internet or other similar network – Affiliated Entities and Service Providers
- Geolocation Data – Affiliated Entities and Service Providers
- Sensory Data – Affiliated Entities and Service Providers
- Inferences drawn from other personal information – Affiliated Entities and Service Providers
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).
Please visit the How We Share Your Personal Information section of the Privacy Notice for additional information on what personal information we disclose.
Your CCPA Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know, Correct, and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold or shared;
- The business or commercial purpose for collecting or selling or sharing the personal information; and
- The specific pieces of personal information we have collected about you.
In addition, subject to exceptions, you have the right to correct or delete the personal information we have collected from you.
To exercise any of these rights, please do one of the following:
- Submit a request to our online webform located here: https://www.westfield.com/privacy-ccpa-enquires
- Call us at our toll free number: (844)977-CCPA
- Visit any of our California shopping centers’ management offices
- If you are a job applicant, you may submit a request via this webform to exercise your rights regarding data collected as part of your application.
In order for Westfield to verify your identity, we will request that you provide us with your E-mail address and name. We will then send you a verification E-mail for you to respond to.
We will confirm receipt of the request within 10 business days and provide information on how the business will process the request. We endeavor to respond to verifiable consumer requests within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. You may only make a verifiable consumer request for your personal information twice within a 12-month period.
Please note that we cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm the personal information that relates to you. We will only use personal information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.
Only you, or a person you authorized in writing or registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor.
Right to Opt-Out of Sales and Sharing. To the extent we sell or share your personal information to third parties as those terms are defined under CCPA, you have a right to opt-out from the sale or sharing, which you can exercise through this “Do Not Sell or Share My Personal Information” link or the link in the footer of our website.
Note that when you submit an opt-out, your opt-out will only apply to sales and shares of personal information through tracking technologies from the specific browser from which you submitted the opt-out because the connection between your browser identifiers and other personal information we have about you is not known to us.
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. If any authorized agent submits a consumer request on your behalf, we may also request the following information:
- To verify an agent’s authorization to make a request on behalf of a California resident, proof of signed permission to submit the request.
- Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.
You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Westfield will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Some of our products and services, however, may require your personal information. If you choose not to provide your personal information that is necessary to provide any aspect of our products or services, you may not be able to use those products or services.
We may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. Please see the “Notice of Financial Incentives” section below for more information about the financial incentives we offer.
CCPA Request Metrics
For more information about the requests we have received from all individuals in 2022, please see below.
||Days to Respond
|Opt-Out of Sale or Sharing
Other California Privacy Rights
Do Not Track Signal
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Westfield responds to "Do Not Track" browser settings. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take actions with respect to “Do Not Track” signals.
Shine the Light
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California residents to request and obtain from Westfield once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:
ATTN: Privacy Counsel
2049 Century Park East, 40th Floor
Century City, CA 90067
United States of America
Please be aware that not all information shared is covered by the "Shine the Light" requirements and only information on covered will be included in our response.
Notice of Financial Incentive
From time to time, we may offer financial incentives, such as a program, benefit or other offering, and/or a price or service difference to our customers related to the collection, retention, or sale of personal information. This Notice of Financial Incentives explains the terms of each financial incentive or price or service difference that we offer, so that you can make an informed decision on whether you would like to participate.
Westfield Rewards Loyalty Program
Customers who sign up for our loyalty program, Westfield Rewards, earn rewards for shopping and spending at participating Westfield shopping centers. Westfield Rewards members are eligible to receive special rewards, offers, discounts, targeted promotions, and invitation-only access to events and activities. At this time, each participating Westfield shopping center operates its own individual loyalty program. For more information please consult the Westfield Loyalty Program FAQs and Rewards Terms of Service for each participating center, which are accessible through our rewards page:https://www.westfield.com/rewards.
You can opt-in to Westfield Rewards online, through our mobile app or at participating Westfield shopping centers. You can also opt-in to multiple loyalty programs using your Westfield account across participating Westfield shopping centers, and earn and redeem rewards separately at each participating center. You can withdraw your consent to participate at any time by cancelling your account through your Westfield account or by sending an email to Westfieldrewards@thanx.com.
We partner with Thanx to provide you with our loyalty program. When you sign up for Westfield Rewards, we (along with Thanx independently) may collect personal information, such as your identifiers (e.g., name, phone number, email address, date of birth), as well as purchase data and reward redemption data.
We value our customers and their data. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of financial incentives or price or service differences that we offer, we have valued the personal information collected through our loyalty program as being reasonably related to the rewards and benefits offered, and the calculation of the value is based upon a reasonable and good-faith estimate often involving the consideration of (i) the categories of personal information collected (e.g., email address, date of birth, purchase data, reward redemption data), (ii) the value of the rewards and benefits offered and provided, and (iii) the value of the annual spend for membership tiers (excluding taxes and fees). The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.
CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice to reflect changes to our personal 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 Privacy Notice shall indicate your agreement with the revised terms.
QUESTIONS AND CONTACT INFORMATION
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 Privacy Notice, please contact us as follows:
If you are located in the United States, via email or at:
2049 Century Park East, 40th Floor
Century City, CA 90067
United States of America
For more information about how users with disabilities can access this Privacy Notice in an alternative format, please click on the accessibility icon located at the bottom right corner of the screen.