The Liberty Shopping Centre
We want to make sure you understand what personal information we may collect about you when you interact with us and our group of companies (The Liberty, we, us and our), including when you visit The Liberty Shopping Centre, interact with us through our social media accounts, and use the following website: www.theliberty.co.uk (our Website). See section 12 (Data Controllers and representative) below for details of The Liberty companies that are the controller of your personal information.
This Privacy Notice explains:
(i) how we obtain your personal information;
(ii) what personal information we collect about you;
(iii) how we use your personal information;
(iv) on what basis we use your personal information;
(v) how long we keep your personal information;
(vi) with whom we share your personal information;
(vii) the countries to which we transfer your personal information;
(viii) how we protect your personal information;
(ix) your rights regarding your personal information; and
We may change this Privacy Notice from time to time and, where we make any material changes, we will inform you of these. A copy of this Privacy Notice can be found at: Website Privacy Notice
If you have any questions, feel free to get in touch via the method set out in the section 11 (Contact Us) below.
2. How do we obtain your personal information?
We gather information about you when you provide it to, or interact with, us or third parties that we work with; e.g. when you visit The Liberty Shopping Centre, our Website or social media pages, attend our events, purchase our gift cards, or when you engage with one of our representatives. We may gather information about you from various public sources. We may also receive information from law enforcement agencies, for example where the police are involved with incidents relating to any of our properties.
3. What personal information do we collect about you?
The personal information that we process includes:
- information from your visit to our Website, which is collected using website log files, cookies and tools such as ‘Google Analytics’. This information includes:
- details of your visits to our Website and the pages you visited, how long you were on the Website and how you landed at those pages; and
- your Internet Protocol (IP) address;
- information collected when you visit The Liberty Shopping Centre, including:
- CCTV images from our properties;
- criminal data or other similar information about security incidents – for example, where the police or our third party security provider are involved with incidents or receive reports relating to any of our properties; and
- information you provide our third party Wi-Fi provider, when you sign up to use Wi-Fi in The Liberty Shopping Centre;
- information that you provide to us, including:
- when you engage with us via the ‘Contact Us’ section on the Website – including your email address, name and optional telephone number, along with the contents of the email or message;
- when you provide feedback – you do not need to provide your name or contact details for general enquiries but you will need to provide an email address if you want us to reply to you;
- when we send you newsletters (including details of offers and events), where you have consented to us contacting you in this manner – we may require your first name and email address;
- when you phone us – we will collect only personal information you provide to us during the call;
- when you contact us by email – we will retain the email and our response to it as long as the business issue remains;
- when you contact us via post – we will retain your letter, postal address, and other personal information that you may provide to us and our response to it for as long as the business issue remains; and
- when you interact with us (including when visiting our centre), or send us a private or direct message, on a social media platform – we may collect any personal information contained within these interactions; and
- information collected when we meet in person, including:
- when you provide feedback – you can provide feedback anonymously, but should you require a response, we will require your full name and address;
- when you are purchasing a Liberty Shopping Centre gift card – we may collect your name, address, telephone number, fax number and e-mail address; and
- when you are attending an event, we may request your name, telephone number, email address and the area where you live, including the first part of your postcode.
4. How do we use your personal information?
We use your personal information for the following purposes:
- to interact with you – including to:
- respond and resolve any complaints or feedback; and
- inform you of upcoming events;
- to promote and market our products and services directly to you if you have indicated that you would like to receive marketing from us, and to send you newsletters. Should you wish to stop receiving marketing please click the unsubscribe link in the marketing email or contact us using the contact information in section 11 (Contact Us) below;
- to operate our business – including to:
- respond to your requests;
- administer Liberty Shopping Centre gift cards, including to verify the purchaser of a gift card in the event that the card is lost or stolen;
- comply with applicable laws, rules, regulations, guidance, codes and industry and professional rules and regulations;
- comply with demands or requests made by regulators, governments, courts and law enforcement authorities;
- investigate and take action against illegal or harmful behaviour; and
- for the establishment, exercise or defence of legal claims or proceedings.
5. On what basis do we use your personal information?
We may use your personal information for the following reasons:
- to comply with legal and regulatory obligations;
- because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes;
- for legitimate business purposes – using your personal information helps us to operate and improve our business and minimise any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant to you;
- to perform a contract to which you are a party;
- for the establishment, exercise or defence of legal claims or proceedings; and
- because it is necessary for reasons of substantial public interest, on the basis of applicable laws.
6. How long will we keep your personal information?
We will always keep your personal information for the period required by law in Jersey, the Isle of Man, Luxembourg and the United Kingdom. We will also keep your personal information where we need to do so in connection with legal action or an investigation involving us or any member of The Liberty group of companies. Otherwise, we keep your personal information for as long as it is necessary and relevant for our operations, such as:
- personal information obtained from complaints for five years and then confidentially destroy it;
- consent to receiving newsletters is retained on a secure database for five years from your last communication with us. If you withdraw consent it will be destroyed within a month;
- personal information is stored for six months after we respond to your feedback, in case you ask for more detail or have further feedback; and
- personal information relating to queries (but not complaints) received from you via social media is retained for one month after we respond to your query.
Personal information that is no longer necessary or relevant for our operations will be de-identified and/or disposed of securely. In addition, we may retain information to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce our terms and conditions and take other actions permitted by law. The personal information we retain will be handled in accordance with this Privacy Notice.
7. With whom do we share your personal information?
We may share certain of your personal information with:
- members and affiliates of The Liberty group of companies;
- the following trusted third parties:
- marketing and social media agencies, who will process your personal information on our behalf when you visit our Website;
- with a prospective seller or buyer, as part of a merger, business or asset sale;
- our security providers who provide security services at The Liberty Shopping Centre;
- our service providers, including third parties that may be involved with issuing and administering our gift cards;
- our professional advisors, agents and auditors, including our representative whose details can be found in section 12 (Data Controllers and representative) below; and
- courts, regulators, governments and law enforcement authorities.
See section 9 (Protecting your personal information) for information on how we keep your personal information secure when sharing it with others.
8. Transfers of your personal information outside of your home country
Your personal information will be processed by The Liberty, its affiliated entities and The Liberty’s trusted third party suppliers in the United Kingdom, the Isle of Man, Jersey, Luxembourg and Ireland.
It may also be processed in countries such as the United States and other jurisdictions where data privacy laws may not be equivalent to, or as protective as, the laws in your home country.
We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country, in accordance with applicable data protection and privacy laws. These measures include data transfer agreements implementing standard data protection clauses. You can find more information about data transfer agreements at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
9. Protecting your personal information
We use a variety of security measures and technologies to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection and privacy laws.
When The Liberty uses a third party service provider, they are carefully selected and required to use appropriate measures to protect the confidentiality and security of personal information.
The transmission to us of information via the internet or a mobile phone network connection may not be completely secure and any transmission is at your own risk.
10. Your rights
Data privacy laws provide you with a number of rights over your personal information. You may be entitled to:
- ask us about the processing of your personal information, including to be provided with a copy of your personal information;
- request the correction and/or deletion of your personal information;
- request the restriction of the processing of your personal information, or object to that processing;
- withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent);
- request receipt or transmission to another organisation, in a machine-readable form, of the personal information that you have provided to us; and
- complain to your local supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.
Where you are given the option to share your personal information with us, you can always choose not to do so.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see section 4 – How do we use your personal information?) or that you are unable to make use of the services offered by us.
11. Contact us
If you have questions or requests about the processing of your personal information, need additional information, or would like to exercise any of the rights set out in section 10 (Your rights) you can contact us at: cust.serve@TheLiberty.co.uk.
12. Data controllers and representative
(a) the trustees of Liberty Centre Unit Trust (Liberty Centre (Trustee No.1) Limited and Liberty Centre (Trustee No.2) Limited),
(b) the trustees of the Liberty Square Unit Trust (Castle Hill Nominees No.7 Limited and Castle Hill Nominees No.8 Limited),
(together, the Liberty Trustees) and
(c) Romford Investment Holding S.À R.L.,
are each a controller of your personal information, and can be contacted via the email address in section 11.1.
Representative: The representative of the Liberty Trustees in the United Kingdom and the European Union is BM Data Services Ltd, who will also be the representative of Romford Investment Holding S.À R.L. in the United Kingdom after the United Kingdom leaves the European Union. The contact details of BM Data Services Ltd are: 50 Oxford Road, High Wycombe, HP11 2EE and all correspondence should be marked for the attention of James Simpson.
This Privacy Notice was last updated in January 2020.