Effective January 1, 2020
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;
- 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.
Image and Video Analytics. At some of our Centers, we use third party image and video analytics services to provide, among other things, general demographics information or aggregate insights about consumers’ behavior in our Centers. For example, some of our Centers have (i) digital signage cameras that process certain image and video information to determine aggregate demographics information and general audience reactions to advertisements, and (ii) digital cameras that provide aggregate insights about where individuals walk and the evaluation of general shopping habits.
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 parking, 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.
Smart Parking. At certain Centers, Westfield may photograph license plate numbers of visitors who use our parking facilities. Westfield collects this personal information to assist drivers in locating their vehicle, monitor available spaces in parking structures, and in certain instances, facilitate the payment of parking.
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/)..
- 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 share personal information we collect within the Westfield family of companies (e.g, relevant shopping center) to deliver products and services to you, ensure a consistent level of service across our products, services, and Centers, and 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.
- 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. You will be notified via email and/or a prominent notice on our website of any change in ownership.
YOUR PRIVACY CHOICES
We enable you to maintain certain control of your personal information by providing choices about what personal information you provide us and how we communicate with you, and by providing access to your personal information. You may adjust your communication preferences or opt out of communications at any time by clicking "unsubscribe" at the bottom of the email, following instructions provided in the communication, or changing your preferences within your Westfield account. If you are having difficulty updating your communication preferences, contact us.
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.
Information We Collect, Use, and Disclose
When using our Corporate Services or visiting our Centers, we may collect information that includes anything that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household. We have collected and disclosed to service providers and third parties for a business and commercial purpose the following categories of personal information from consumers within the last twelve (12) months:
- Identifiers – Such as the personal information collected through our loyalty program, competitions, sweepstakes, and events, and concierge and other convenience services.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – Such as the personal information collected through our loyalty program, parking and competitions, sweepstakes, and events.
- Commercial Information – Such as personal information collected through our Wi-Fi, loyalty program, parking, professional and client relationships.
- Biometric Information – Such as the personal information collected through our CCTV or through our image and video analytics services.
- Internet or other similar network activity – Such as personal information collected through our competitions, sweepstakes and events, and through cookies and other similar technologies.
- Geolocation Data – Such as through our BLE Beacons and Wifi tracking.
- Sensory Data – Such as through our image and video analytics and management and safety programs.
- Inferences drawn from other personal information – Such as through our BLE Beacons and Wi-Fi tracking and our loyalty program.
Please visit the Information We Collect and How We Share Your Information sections of the Privacy Notice for additional information on what personal information we collect and disclose. We use all categories for our business and commercial purposes. Please visit the section on How Information Is Used for additional information.
Your CCPA Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Information and Data Portability Rights
Consumers have the right to request a business disclose what personal information it collects, uses, discloses and sells. Once we receive and confirm your verifiable consumer request, we will disclose to you the specific pieces of personal information we have collected from you. In that disclosure, you will also receive information that describes the following:
- The categories of personal information that Westfield has collected
- The categories of sources from which the personal information is collected
- The business or commercial purpose for collecting or selling (if any) personal information
Deletion Request Rights
You have the right to request that Westfield delete all of the personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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.
Once verified, we will confirm receipt of the request within 10 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.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. You may only make a verifiable consumer request for your personal information twice within a 12-month period.
The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable.
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.
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.
Westfield will not discriminate against you for exercising any of your CCPA rights.
However, 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.
Sale of Personal Information
Westfield has not sold (as defined under the CCPA) and, does not plan to sell, any personal information of any consumers (including any consumers under 16 years old) to any third parties in the preceding 12 months. We do not “sell” personal information under the traditional sense of the word. However, we use advertising cookies with your consent. Please visit the section on How Information Is Used for more details.
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.
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