New Square West Bromwich is committed to ensuring that your privacy is protected and our use of your personal information is governed by this Privacy Notice. On this site, “New Square”, “our” and “we” each mean all the channels which collect and use your information in the manner set out in this Privacy Notice. Any reference to “you” or “your” refers to anyone whose personal information we process.
Our use of your personal data will be governed by this Privacy Notice.
New Square are part of the Savills portfolio and are data controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
This Privacy Notice explains;
If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.
Some personal information is classified as “special” data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data.
We process the personal data set out below, provided to us by either you or your device when either accessing our website
There is no obligation on you to provide the information listed below; however, if you do not, we may be unable to engage with you, open an account for you, send you the materials you have requested or allow you to enter competitions or redeem offers if we do not have the necessary information to do so.
The type of data that we process about you includes:
Information you have given to usby filling in forms or by signing in using your Facebook, Twitter or G+ accounts, or by communicating with us, including name, address, title, contact details including email address and mobile telephone number, date of birth, details of any offer or competitions you have signed up for, any communications you may have with us (including reporting problems with our site), preferences as to any methods and types of marketing information you have consented to receive, your username (account ID) and password when opening an account.
Information we collect from or observe about youwhen you use our services, including:
(a) Geolocation data provided by your smartphone or other mobile device to access our services using the App, provided that you have consented to the App collecting this data on your smartphone or other mobile device. If you no longer wish to share this Geolocation data, you can de-activate it using your smartphone’s location settings.
(b) Device and Website Use Information – When you install one of our mobile applications or use a computer, tablet, smart phone or other device to access our websites, we may collect information about the device and how you use it.
(c) Images of you collected from CCTV cameras in operation at New Square West Bromwich
• send you marketing information by various channels including email, SMS, mail or telephone, or push messages if you use our app, including sending notices of new products, special offers and other marketing materials to enhance and support your relationship with New Square West Bromwich. We will use this data in accordance with any preferences you have selected, either on the basis of consent (where requested) or of legitimate interests where you have not objected to receiving such information.
We may also use your data for our own legitimate interests, which include:
• sending you surveys or supporting Marketing Research activities to you in other ways to help us improve our services and understand our customers better;
• allowing you to participate in interactive features of our service, when you choose to do so;
• ensuring that content from our digital channels is presented in the most effective manner for you and for your computer/smart phone and/or tablet;
• allowing us to investigate and respond to any issues or correspondence received;
• administering your online account and any promotion or competition which you have entered;
• notifying you about changes to our services.
We believe that these interests are justified as it is completely optional for you to register, participate or otherwise provide us with Personal Data in the above situations. You will be able to object to this processing at any time. For more information, please see Your rightsbelow.
Geolocation and Device and Website Use
We use Geolocation and Device and Website Use information to improve the effectiveness and operation of New Square3 and/or the website, to improve our existing services and develop new services and to inform and direct our marketing strategy. In addition, anonymised statistical data may also be shared with retailers or used by us to develop new promotions that may interest our customers.
We will also use this information for system administration and to report aggregate information to our retailers. This is anonymised statistical data about our users’ browsing actions and patterns and to help us to improve our site and to deliver a better and more personalised service. They enable us:
• To estimate our audience size and usage pattern,.
• To store information about your preferences, and so allow us to customise our site according to your individual interests.
• To speed up your searches; and
• To recognise you when you return to our site.
Where we consider that, on balance, it is appropriate for us do so, we will process CCTV footage for the following legitimate interests:
• keeping our staff, visitors and property safe and secure;
• ensuring compliance with health and safety procedures;
• detecting and preventing crime; and
• assisting law enforcement agencies in the apprehension, investigation and prosecution of offenders.
This may include sharing footage with the police or other law enforcement agencies, or our insurers where necessary in relation to a claim, as well as any other third parties in connection with legal proceedings or emergency situations.
Data processed where it is necessary for compliance with a legal obligation imposed on us
We will process your personal data to allow us to comply with any requests you are lawfully entitled to make, including under data protection laws, to ensure that age inappropriate content is not provided to individuals under 18, and to allow us to keep records that we are legally required to retain, including evidence of consents provided, or to evidence our compliance with legal obligations.
How long will we hold your information
We will normally retain your personal data is for a period of up to 7 years from the latter of:
• the last date you logged into our website or used our App; or
• when you unsubscribe from receiving marketing from us (if later);
unless we are legally required to retain the information for longer. However, we may delete your data sooner if we have no purpose to retain it.
We will retain your details if you have unsubscribed from marketing to ensure that we respect your withdrawal of consent on an ongoing basis.
Who will we share your personal information with?
We will not share your personal data with third parties
Where will your personal data be held
We may store or process your personal data outside the European Economic Area (EEA) or other countries approved by the European Commission as providing appropriate safeguards for personal data, when we use service providers located in those countries. If this is the case, we will put in place appropriate safeguards to protect your personal data and ensure that it is compliant with all appropriate legal requirements. If you require further information in respect of the countries where your personal data is processed and/or copies of any documents setting out the appropriate safeguards we have implemented to protect it, please contact us.
Where people under the age of 13 download our App or use our services they are required to confirm that they have their parent’s consent. Parents should supervise the online activities of their children, and consider the use of tools available from online services and software providers that help provide child-friendly Internet environments. If any of our products or services are targeted directly at children, we will provide you with additional information about how their data will be used in the context of that service.
If the user’s age has been provided it is used to ensure that products inappropriate for those under 18 are not promoted to any user aged under 18.
You are solely responsible for maintaining the secrecy of your passwords and other account information, and we cannot take responsibility for any damage arising from any disclosure of your password or access to your email account by other parties.
If you wish to withdraw your consent to receive marketing materials, this can be done by:-
• emailing us at email@example.com
• updating your preferences on your online account; or
• by clicking on the unsubscribe link on any emails we have sent.
If you withdraw your consent, this will not affect our rights to have sent you marketing material prior to your withdrawal, but we will not send any further marketing. Whilst we will endeavour to ensure that you do not receive any further marketing material immediately, there may be a slight delay for any changes to take effect. Please note that your information will not be deleted but will be retained in a suppression list to ensure that we do not inadvertently send further marketing communications once you have withdrawn your consent to receive them.
If you do not wish us to process your Geolocation and Device and Website Use information, you may prevent this by disabling the function or blocking the cookies on your device or browser. However, if you select this setting you may be unable to access certain parts of our site, or it may impact on the usability of our website and/or App.
For further information on how to do this, please visit www.allaboutcookies.org. You are also entitled to request that we:-
• provide you with a copy of any personal data we hold about you,
• provide you with a copy of any of your personal data, provided by you, that we hold in an electronic format, in a structured, commonly used, machine-readable format;
• have any incorrect personal data corrected or completed ( you can also update your records using your profile on your online account);
• delete any personal data that we no longer need for the above purposes, where you have withdrawn your consent and there are no other grounds to process that information, where the personal data has been unlawfully processed or where we are required by law to delete it; and
• restrict the processing of your personal data whilst we confirm whether any data needs correcting following your request, the processing is unlawful and you do not want us to delete this personal data; where we no longer need to process the personal data, but you require the information to establish, exercise or defend legal claims. In these circumstances we will only process your personal data for purposes for which you have consented, or for the establishment, exercise or defence of legal claims or the protection of the rights of another person; and/or
• object to our processing of your personal data, where we process it under the legitimate interests grounds and we are unable to show a compelling legitimate interest that overrides your interests, rights and freedoms, or for the purposes of defending, exercising or defending legal claims
If you wish to make such a request, please use either our Contact Uspage or email firstname.lastname@example.org
We may require additional information to either confirm your identity before we can process your request and/or to assist us in responding to your request.
If you are unhappy with the outcome of your request or with our processing of your personal data, you are entitled to lodge a complaint with the Information Commissioner’s Office (ICO), whose website is www.ico.org.uk.
Modifications of this policy