Many shopping centres and other properties owned or managed by Land Securities Properties Limited may offer its visitors and occupants free wi-fi. Landsec may work in partnership with a third-party provider to offer this service. This privacy notice explains the information we collect and how we use it if you choose to use our wi-fi.

What information do we collect and how do we collect it?

Email address: We normally ask for your email address before you can use the service. We collect this to authenticate the service and to form a contract with you so you can use the service.

Location tracking and profiling: some of our wi-fi services may communicate with your device to identify its location. This will operate irrespective of whether or not you have subscribed to the Wi-Fi service.

If you subscribe to our wi-fi service, your device’s unique identity will be collected, and this will be combined with your email address. This will allow us to understand your device’s (and therefore your) movements through the centre.

If you do not subscribe to the service, the unique address of your device may be hidden but this varies depending on the make and model of the device. To minimise any privacy impact, for analytics purposes we ‘blur’ the unique address of your device with other devices’ addresses to make it unidentifiable.

To fully opt-out of any data collection, you may need to turn off the wi-fi on your device.

What do we use the information for?

We use the device location data described above to analyse the types of retail premises you visit and the time and frequency of your visits. We will use this information to build a marketing profile and will use this to send you targeted marketing if you opted-in to marketing when you signed-up to use the wi-fi. We will send this through a channel of your choice, for example email or SMS if you wish to be contacted in this way. If you chose to provide us with information about your age and postcode, then this will also be used to build a more targeted profile.

We may also use personal information to carry our research and to monitor and improve the products and services we offer. We may also use the information to create customer profiles so we can send out better quality personalised communications if you agree to receive these.

If you want to opt-in or out of Landsec marketing or to view or delete your profile, please visit profile.skyfii.com

What is our legal basis for collecting your personal information via wi-fi?

Legitimate interests:

• Landsec believes that it is in our legitimate interests to provide wi-fi services in our properties, to build a marketing profile of visitors to our premises, to share consumer insights with Landsec customers such as our tenants and to and to understand how people use and navigate our premises.

Consent:

• Consent is our legal basis for sending direct marketing to you if you agree to this as part of the wi-fi sign-in process.

If you provide your consent wi-fi marketing, you are always free to revoke it using the skyfii link above or by clicking the ‘unsubscribe’ link the messages we send to you.

Do we share your personal information with anyone else?

We may share your personal information with organisations where this is necessary to provide our wi-fi service.

If you choose to provide your postcode to us, we may combine the first part of this with data obtained from a third party to produce enriched customer insight, but this will not happen in a way that identifies you.

Other recipients of third-party data:

• We may pass on or allow access to your information:
• to our suppliers, contractors and professional advisors where this is necessary for them to provide services and facilities to us, such as the provider of our customer database, our WIFI systems operator and marketing agencies used to generate content for our marketing campaigns;
• to our Joint Venture partners;
• to any purchaser of all or part of our business or any of our properties;
• to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers;
• where we are required to do so by law, court order or other legal process;
• where, acting in good faith, we believe disclosure is necessary to assist in the investigation or reporting of suspected illegal or other wrongful activity. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
• to protect and defend our rights or property;
• to deal with any misuse of any of our Services; or
• in order to enforce or apply our terms and conditions and other agreements with third parties.
• to our group companies and affiliates or third-party data processers who may process data on our behalf to enable us to carry out our usual business practices.

Personal information about children

Children under the age of 13 are not permitted to use our wi-fi networks. If you believe that a child under the age of 13 has provided their personal information, please contact us using the details below and we will delete their information.

International transfers of your personal information

In some cases we may transfer your personal information outside the UK. If we do this, we always make sure that the information will be subject to appropriate security and will only be used for the purpose it was collected for originally.

The security of your personal information

Landsec has technical and organisational measures in place to make sure your personal information is subject to suitable security and is not shared or used inappropriately.

If we share personal information with a third party, we always require them to maintain appropriate technical and organisational measures to protect it.

How long do we keep your personal information for?

We retain your personal information for as long as we need it for the purpose it was collected for. In some cases we are required by law to retain certain information for a particular period, but otherwise our retention periods are set according to business need.

In some cases we keep personal information for longer than usual, for example to manage a complaint or in the context of litigation.

In some cases we will anonymise your personal information for research or statistical purposes. We may hold anonymised information indefinitely.

Your personal information rights.

You have the right to:

• Obtain a copy of your personal information.
• Require Landsec to rectify any inaccurate personal information or to add any information that you think is missing.
• Have personal information about you erased.
• Restrict the processing of your personal information – i.e. to stop Landsec using it.
• Object to the processing of your personal information, for example for direct marketing purposes.
• Have your personal information transferred to another organisation.
• If applicable, not to be subject to an automated decision-making process.

There may be some exemptions from, and limitations to, the rights above, depending on the circumstances. However, it is Landsec’s policy to comply with all information rights requests as fully as we can.

If you want to exercise any of your information rights, please contact us using the details below and we will be in touch to request any further information we need, including proof of ID.

Our Contact Details

If you have any questions about this Privacy Notice, want to know more about how we handle your personal information or want to complain about our use of it, please contact us at:

Land Securities Properties Limited

Address: 100 Victoria Street, London, SW1E 5JL
Email address: dataprotection@landsec.com

If you are not happy with any aspect of way Landsec collects and uses your personal information, you can complain to the Information Commissioner's Office, the UK regulator for data protection issues. Please see www.ico.org.uk. Please contact us first though and we will always try to resolve any issues you have.

This Privacy Notice was last updated on 02/24