PRIVACY POLICY - SHOPPING CENTRE WEBSITE/APP/WIFI

This Privacy Policy provides all the information on the Shopping Centres’ use of its Users’ data obtained through any of the following channels, depending on each User’s interaction with the Shopping Centre.

• Website.
• App.
• Wi-Fi Service.
• Physical (printed or tablet format).

User or Users means any individual who accesses, browses, uses, or takes part in the services and activities, free or paid, offered by the Shopping Centre through the Website, App, or Wi-Fi Service, as well as those services physically offered on the Shopping Centre premises.

Platform means, in general, any of the Websites, Apps, and Wi-Fi Services included in the “General Information” table below.

1. Who is the Data Controller for your personal data?

The registry information and contact data of the company that is the Data Controller for your personal data, depending on the Website, App, or Wi-Fi Service of which you are a User, is given below.

The terms “Shopping Centre” and “Data Controller” will refer individually to the relevant Shopping Centre from among those included in the table below:

2. What personal data do we process?

The Shopping Centre processes the data provided by Users through the various forms and channels activated on the Platform, as well as those obtained through the provision of any services enjoyed by Users. In all cases, we only process the personal data provided by Users for the purposes specified in this Privacy Policy.

Unless otherwise expressly stated, all the personal data requested in the forms activated on the Platform for the collection of data are mandatory as they are required for your registration or for proper provision of the services offered through it. If you do not provide these data, we will be unable to manage registration or offer the services requested by the User. Thus, Users must fill in the fields marked as “required” in Platform forms. Otherwise, we may be unable to provide the service requested or the Platform and its services may operate incorrectly. Except for the “required” fields, Users are completely free to provide their other personal data or not. In any case, Users must provide the Shopping Centre with their current personal data to ensure that their information is up to date and includes no mistakes.

Should third-party data be provided, the User guarantees that these have been obtained and provided to the Shopping Centre after informing and obtaining the authorisation from these data subjects, in accordance with data protection legislation. In this regard, Users will hold the Shopping Centre harmless for any liability arising from the failure to comply with this guarantee.

The personal data of Users younger than fourteen (14) and incapacitated Users will be collected and processed on the basis of the authorisation and consent given by their parents, tutors, or legal representatives. Thus we request that Users refrain from providing the personal data of any individuals under the age of 14 or incapacitated individuals or their own data if they are under the age of 14 or incapacitated, if they do not have the authorisation of their parents, tutors, or legal representatives. The Shopping Centre will not be held liable for any actions by a minor under the age of fourteen (14) or an incapacitated individual or any User who does not have this authorisation. The Shopping Centre may process the data of individuals older than fourteen (14) with their authorisation, except in those cases in which the Law require the assistance of those individuals who have parental authority or tutors.

The User confirms and guarantees the truthfulness and accuracy of the data provided, and that they are up to date. The User also agrees to notify any change in their data, following the procedure established in section: What are your rights when you provide us with your personal data?

3. What is the purpose of processing your personal data? What is the legal basis for the processing of your data?

The processing of your personal data will vary depending on the Platform used and the Shopping Centre visited, as each Shopping Centre acts independently and not all have the same functionalities or offer the same services.

Website:

• Should the User provide their data through the “Your Business” section in the Shopping Centre Website, the data will be processed to respond to the request made and send you information on the basis of the pre-existing contractual relation between the User and the Shopping Centre.

• If they access the “Jobs” section, Users will be referred to the jobs platform or website of a third party, which is its owner and is responsible for the service offered. Users are informed that the Shopping Centre takes no part in the activity performed by the owners of that jobs platform or website, so it is not responsible for its personal data processing.

• Should Users provide their data through the “Contact” section on the Website or through the email address provided for this purpose, their data will be processed to handle their request or query, on the basis of the Shopping Centre's legitimate interest in answering any requests or queries made.

  When the query pertains to the exercise of the rights specified below, or claims connected to the Shopping Centre services, the data will be processed by the Shopping Centre on the basis of the fulfilment of its legal obligations.

• Should the User subscribe to the Shopping Centre Newsletter, their data will be processed to send them advertising and commercial information connected to the various Shopping Centre activities, services, offers, and special promotions by any means, including electronic means. The legal basis for the processing of the data is the User’s express consent.

  Mere browsing through the Website will thus not imply the processing of Users’ personal data, except for those pertaining to their IP address and browsing, to manage and optimise the Website, as well as to preserve the security and integrity of the Website. This processing is based on the Shopping Centre's legitimate interest in guaranteeing proper operation of the Website and network and information security.

App:

• Should the User download and access the App without registering, the only personal data that will be processed to provide the services offered through the App as a guest will be the data pertaining to User geolocation in the Shopping Centre when required by the requested service, provided that the User has authorised this through its device settings. Following configuration by the User, push notices will also be sent regarding Shopping Centre offers and new developments, on the basis of the relation between the User and the Shopping Centre arising from the acceptance by the User of the App Terms and Conditions.

• Should the User register on the App, the personal data provided during registration will be processed to provide the services offered through the App, which includes the processing of data pertaining to geolocation within the Shopping Centre of Users who have so allowed in their device settings. Following configuration by the User, push notices will also be sent regarding Shopping Centre offers and new developments.

  The Shopping Centre also analyses the data connected to use of the App and the preferences specified within it to personalise the Shopping Centre contents and services displayed to the User on the basis of their profile. The legal basis for the processing of the data is the Shopping Centre's legitimate interest in performing its commercial activity.

• Should the User accept to receive commercial communications (emails, SMS, etc.) from the Shopping Centre, their data will be processed to send them advertising and commercial information connected to the various Shopping Centre activities, services, offers, and special promotions by electronic means. The legal basis for the processing of the data is the User’s express consent.

• Should the User apply for the Loyalty Card through the relevant section on the App, their data will be processed to manage the issuance of this card and manage use by the User, on the basis of the consent provided by the User when completing their registration on a free and voluntary basis.

  Mere browsing through the App will thus not imply the processing of Users’ personal data, except for those pertaining to their navigation, to manage and optimise the App, as well as to preserve the security and integrity of the App. This processing is based on the Shopping Centre's legitimate interest in guaranteeing proper operation of the App and network and information security.

Wi-Fi Service User:

• Should Users register with the Wi-Fi Service available at the Shopping Centre, their personal data will be processed to manage their access and offer the Wi-Fi Service, on the basis of the existing relation between the User and the Shopping Centre, arising from the User's acceptance of the Wi-Fie Terms and Conditions.

  Moreover, on the basis of the Shopping Centre’s legitimate interest, the personal data will be processed to manage and control use of the Wi-Fi Service, thus guaranteeing its security and its optimisation by making a strictly statistical use of the information on use of the Wi-Fi Service, e.g. to improve space design, control capacity, establish staff levels, opening hours, establish the Wi-Fi signal required to offer a better connection or improve another type of services offered by the Shopping Centre.

• Should the User accept to receive commercial communications (emails, SMS, etc.) from the Shopping Centre, their data will be processed to send them advertising and commercial information connected to the various Shopping Centre activities, services, offers, and special promotions by any means, including electronic means. The legal basis for the processing of the data is the User’s express consent.

Physical User:

• Should Users provide their Curriculum Vitae or a similar document, the data will be provided to manage their candidacy to jobs in the shopping centre or on the premises of shopping centre tenants, on the basis of the implementation of precontractual measures.
• Should Users fill in the Complaints form available at Customer Service, the Shopping Centre will process the personal data provided through it to manage and correctly respond to their claim, on the basis of the Shopping Centre’s Legitimate Interest in responding to User claims and complaints.

• Should Users fill in the relevant form to make Suggestions available at Customer Service, the data provided through it will be processed by the Shopping Centre to manage the suggestions received on the basis of its legitimate interest in User suggestions.

  Should Users provide their data as part of a competition, draw, event, and/or workshop run in the Shopping Centre, the data will be processed to manage their participation, which may include the giving of prizes and publication of their data on the website, on social media, or through any means for dissemination used by the Shopping Centre for purposes of disclosure and transparency. The processing of Users’ personal data for this purpose is based on the contractual relation between the Users and the Shopping Centre arising by the acceptance by the former of the relevant participation terms and conditions.

• Users are informed that, in some competitions, draws, events, and/or workshops run in the Shopping Centre, photographs and videos are taken for Shopping Centre advertising and commercial purposes. The Shopping Centre will inform Users about the capture of images through the corresponding information sign. These images may be taken:

  • generically and panoramically, without focusing on participants’ faces at any time. However, Users may state their opposition to the potential capture of images that enable their identification following the procedure established in section: What are your rights when you provide us with your personal data? The legal basis for the treatment of any personal data that might be obtained in this case, on a potential or secondary basis, is the Shopping Centre's legitimate interest on conducting commercial development activities to promote its activity.
  • to clearly identify the User. In this case, the Shopping Centre will previously inform the User directly and individually. In these cases, the legal basis for the processing of your personal data will be the User's consent.

  Should the User provide their data as part of the Lending service (chairs, trolleys, chargers, umbrellas, etc.), the data will be processed by the Shopping Centre to manage the service requested, including control on use and return of the materials provided, on the basis of the relation between the User and the Shopping Centre.

• Should the User notify their data or those of a minor as part of the Shopping Centre “Children’s Club” activities, the data will be processed to manage their participation or that of the minor in the various play area activities, including draws and competitions, as well as to send them the play area calendar and a birthday greeting. The legal basis for the processing of the data is the consent given by the User when completing their registration on a free and voluntary basis.
• Should the User request the Child Location Bracelet service, the data provided will be processed by the Shopping Centre to manage the service requested, on the basis of the express consent given by the parent, tutor, or legal representative requesting the service.
• Should the User subscribe to the Shopping Centre Newsletter, their data will be processed to send them advertising and commercial information connected to the various Shopping Centre activities, services, offers, and special promotions by any means, including electronic means. The legal basis for the processing of the data is the User’s express consent.

4. How long are your data kept?

Personal data will be kept for the time required to provide the service requested or answer the query made. After this period has ended and all the actions required to manage and terminate any obligation that might remain between the parties have been carried out, the personal data will be removed.

Without prejudice of the above, the data will be kept duly blocked for as long as liabilities might arise from the performance of the commercial, contractual, or pre-contractual relation between the User and the Shopping Centre, as well as for the fulfilment of other legal obligations by the Shopping Centre.

5. Which recipients will be notified of your data?

The Shopping Centre may notify your personal data to the public Authorities, regulatory, governmental, or jurisdictional bodies in those cases in which it is required to do so by law, by legal regulations, or in fulfilment of regulatory obligations, as well as to the various Shopping Centre tenants (Shopping Centre shops) to manage candidacy to a job or spontaneous candidacy to any jobs that might be offered by the various companies in the Shopping Centre, provided that the User authorised it when providing their CV.

The Shopping Centre also has agreements with third parties to make various services available to Users, e.g. the Personal Shopper service. Agreements with third parties, and thus Third-Party Services, may vary depending on the Shopping Centre. These services are directly provided by a third party unconnected to the Shopping Centre, so that, if a User requests a “Third-Party Service” offered through the platform, the personal data provided by completing the relevant form will be assigned to the third party providing that service, so as to facilitate management and provision of the requested service, as well as to enable the third party to identify them as a Shopping Centre User. This data transfer is thus required, and its legal basis is the Shopping Centre's legitimate interest in managing the relation with the Third Parties. Your data will be processed by this third party under its sole responsibility and as established in its own privacy policy and contracting terms and conditions. Consequently, these third parties will be responsible for the processing of the transferred data, as well as any other data directly provided by Users. These third parties will also be liable for any claim that might arise from the provision of their services.

Regardless of these data transfers, the Shopping Centre works with third-party service providers that have access to your personal data and process these data for and on behalf of the Shopping Centre as a result of a provision of services.

The Shopping Centre follows strict service provider selection criteria to fulfil its data protection obligations and the relevant data processing agreement is entered into with them.

6. What are your rights when you provide us with your personal data?

Users may exercise their right of access to their personal data, as well as request the rectification of any inaccurate data, and, as the case may be, their removal. You may also request data limitation and portability, and oppose the processing of your data.

Users are also entitled to revoke at any time the consent given, which will not retroactively affect the processing of their personal data until then.

Users may exercise these rights under the terms and conditions established in the legislation in force, at the Shopping Centre’s registered office or request it via email at the address stated in the table included in section “Who is the Data Controller for your personal data?” in this Privacy Policy.

If you see fit, particularly if you do not receive a satisfactory answer, you may file a claim with the Comissão Nacional de Protecção de Dados (www.cnpd.pt).

7. Contact with the Shopping Centre

If you have any doubts or questions regarding the processing of your personal data by the Shopping Centre, you may write to the post address or email address specified in the table included in the section “Who is the Data Controller for your personal data?” in this Privacy Policy.

© 2021 Shopping Centre. All rights reserved.

Latest update: February 2021.