Privilege Privacy Notice
Privilege at Ingolstadt Village, a member of The Bicester Village Shopping Collection® Privacy Notice
Your membership of the Privilege Programme is governed by the Privilege membership terms and conditions available here(Membership Terms). This Privacy Notice (Notice) gives you further information about the way we collect and use personal information about you (which is known as “personal data” under data protection legislation).
You have the right to object to us processing your personal data for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests. For more information, see the section “Your Rights” below.
NOTICE – CHANGE TO DATA PROTECTION LAW
The law in relation to data protection is changing with effect from 25 May 2018. This Privacy Notice has been updated for new guests registering with effect from 26th March 2018, and from the 12 April 2018 for guests who registered prior to 26th March 2018, to reflect your new and enhanced rights and to update how we process your personal data.
You should read through this Privacy Notice to fully understand the basis upon which we collect your personal data, how we use it, where we store it and to whom it is disclosed. Other privacy notices may also apply in relation to our use of your personal data other than in connection with Privilege (for example, when you use our website, our cookie consent tool will apply).
Commitment to Privacy
We are committed to protecting your personal data and right to privacy. We will always keep your personal data safe and comply with applicable data protection legislation from time to time in place.
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
Privilege Privacy Notice
Please see the section titled Requests to us below, for more information on how we will handle your requests to us.
Who we are
Please click here to see who we are. The entities listed are the owners and operators of retail outlet Villages (Villages) within The Bicester Village Shopping Collection brand. References in this Notice to “we” or “us” are to the entities listed. Each of the listed entities are committed to protecting your privacy and are joint data controllers within the meaning of data protection laws applicable in the European Union (EU) and European Economic Area (EEA).
As joint data controllers, we have arrangements between us to ensure that we handle your personal data correctly and in accordance with data protection law. These arrangements reflect our respective roles and responsibilities in relation to you, and considers which entity is in the best position to fulfil each obligation to you. This arrangement between us does not affect your rights under data protection law. For more information on these arrangements, feel free to contact us as set out under “Contacting Us” below.
What personal data do we collect about you?
We collect the personal data you provide to us as part of your registration and any further personal data you provide to update your registration details from time to time. This personal data includes your name, address, place of residence, gender, date of birth, email address, land and mobile phone numbers and other contact details.
We also collect information about your preferences. We ask you to provide us with information about your favourite brands and labels so we can tailor our offers to your specific preferences, and about your marketing preferences so we can make sure that we are contacting you using your preferred method of communication. If you receive a service from us, we may collect and record your preferences about the way the service was delivered so that we can improve your experience next time.
Please note that in order for you to register with or continue using Privilege, we only need to have means to communicate with you electronically such as your email address . However, if you provide us with more personal data on our request, we can provide you a better service and Privilege experience.
Where you register to become a Privilege member via a social media platform, we may collect the personal data above directly from the personal details you have provided to the platform (as long as the social media platform has the right to share your personal data with us).
We also gather information about the purchases you make at Villages, including:
• the stores you shop in; and
• transaction details (including the date, time and value of the transaction)
We gather this personal data when you scan your unique QR code at a Village store when making a purchase (we must gather this personal data in order to offer you all the benefits of Privilege).
If you have given us permission to do so, we collect information about your approximate location (based on your IP address):
• when you open emails or other electronic messages from us. This allows us to tailor the content of our messaging based on your approximate location; and
• when you are close to a particular location (when you log in to Privilege on your device) so we can deliver particular content to you on our website, and again when you enter a Village so we can determine whether or not the earlier messaging was effective.
We collect cookies from your mobile device when you use our app, or visit a website associated with a Village or one of our brands. Our cookie consent tool is available here.
We may also combine this personal data with other personal data we hold about you across the entities on the list of controllers in our group (see Who We Are above) and the different channels you use to interact with us (for example, our website or our app). In addition, we may combine all the personal data we hold about you with personal data about you held by our selected partners and/or retail outlets where you have agreed that they can share your personal data with third parties, according to their own privacy notice and your personal choices. We do this to form a clearer picture about the kinds of offers in which you might be interested.
When we interact with you (for example, when you are using services we provide) we may learn certain details about you that do not fit into one of the categories above. We may record this information in order to ensure we can remember important details about you in future. We ensure that only a small number of authorised personnel have access to this personal data and we will not use it for any purpose other than to build an ongoing relationship with you, our valued customer, when you visit us or when we interact with you.
Throughout your Privilege membership we may (if you have given us your consent to market to you) ask for your feedback on certain items about your experiences with us, including whether you are likely to recommend or revisit a Village. The feedback we receive from you may affect the nature or volume of marketing material you receive from us (again, if you have given us your consent to receive such marketing). For example, if we feel you are likely to recommend a Village to a friend, we may send you marketing content that you can easily pass on to others who may be interested.
How we use your personal data
We are processing your personal data to be able to provide you with membership to and participation in Privilege, and in particular to do the following:
• when we make Privilege members special offers about brands sold in a Village, we can tailor these offers to you to make sure you are sent the kinds of offers you will be most interested in (we call an offer like this a treat); and
• when we think that you deserve a little something extra based on your transaction activity, we can offer this to you (we call these little goodies rewards).
We gather information about your purchase activities at Villages so that we can give you all the benefits of Privilege membership. When we have information about your transactions, we can tell:
• when you will be eligible for rewards that are based on your purchasing activities; and
• more about your favourite stores and brands, so we can target our offers to you and your preferences.
In addition, we use your personal data:
• to manage and improve Privilege;
• to better understand your shopping behaviour in order to develop and improve our products and services so as to provide you with an enhanced shopping experience;
• to analyse the effectiveness of our marketing and to help us provide more relevant offers, advice and information to you and our other guests;
• to build up a clearer picture of our guests both as a group and as individuals and thereby provide you with a seamless, relevant and consistent service;
• to provide you with information about events, special offers, promotions and other relevant matters concerning the Villages, the retail outlets at the Villages and the goods which they sell and services they provide (if you have given your consent for us to do so);
• to advertise our Villages and services on social media to other people who may also be interested in what we have to offer (if you have given your consent for us to do so);
• to advertise offers or promotions made available by our third party partners (as set out under “Who we share your personal data with”) if you have given us your consent to do so;
• to provide any services which you may request or which we may offer as part of your Privilege membership, such as using your address for remote fulfillment delivery services;
• to ensure that the information we hold is kept accurate and up to date;
• (if we have your consent, where this is required by law) for research and analysis and in order that we may contact you, from time to time, for such a purpose or for the purpose of conducting surveys or focus groups; and
• to notify you about changes to our services.
How long we keep your personal data for
We will keep your personal data for as long as you continue to interact with us (for example, if you read or click on an email we send you, make a purchase from a Village, or attend an event we host). If we do not have any interaction with you for three years, we will attempt to contact you to see if you still want to be a Privilege member.
If we do not hear from you (or if you tell us, at any time, that you no longer want to be a member of Privilege) then we will delete your personal data from our records.
There may be some personal data we only need to collect in order to provide you with a particular service (for example, if you receive valet parking services from us, we will need to collect your vehicle license plate number in order to deliver the service). We will delete such personal data as soon as the relevant service has been completed. We may still retain your preferences about the way the service was delivered so that we can improve your experience next time.
Who we share your personal data with
We share your personal data between ourselves (see Who We Are above) by having joint access to a central database shared by all European villages. Each Village shares the personal data of its own Privilege members with other Villages, by including it as part of our central database. This allows you, as a Privilege member, to benefit from Privilege membership at all Villages across Europe, including by earning and redeeming treats and rewards in more Villages (in accordance with the Membership Terms).
For the purposes set out above, we may also provide your personal data to our suppliers and processors who perform certain business services for us. We share your personal data with third parties who:
• process transaction information to determine whether you are eligible for a treat or a reward; and
• if you have given your consent for us to do so:
o communicate with you on our behalf via email;
o share your personal data with social media platforms (through our advertising agency) who only use it for the purpose of identifying other people who are similar to you and who might also be interested in the Villages or in Privilege, so that we can advertise to them through these social media platforms;
o use your location to deliver specific electronic messaging to you (based on your location when you open an email or electronic message from us); and
o use your location to show you targeted website content when you log in to Privilege.
In some cases the personal data we collect from you may also be processed outside the European Economic Area (EEA) and such destinations may not have laws which protect your personal data to the same extent as in the EEA. We have obligations to ensure that your personal data processed by us or by our suppliers and partners operating outside the EEA is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Notice.
You can click here for a list of the suppliers and processors we currently use, and other parties to whom we disclose your personal data. The link also has information about how these parties use your personal data, any processing they perform outside the EEA, and the safeguards that are used to protect your personal data if this happens. This information may be updated from time to time. Please ask us if you would like more information about the safeguards that are used to protect your personal data when it is processed outside the EEA (see Contacting Us below).
In addition, we may disclose your personal data:
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
• to successors in title or replacement operators of all or part of our respective businesses.
The legal basis for us using your personal data
- It is necessary for us to process your email address for performance of the contract between us in relation to Privilege (which is governed by the Membership Terms).
- In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
• sending you marketing communications;
• advertising on social media platforms;
• using your location to deliver specific messaging and content to you; and
• using your location to monitor the effectiveness of our messaging.
- In most cases, it is in our legitimate interests to collect and use the personal data referred to above (see What personal data do we collect about you? above) so that we can:
• provide you with a service that is as useful, enjoyable and beneficial to you as possible, including by personalising our contact with you, making sure we tell you about all the offers that relate specifically to your preferred Village, tailoring treats to your specific preferences, and contacting you using your preferred method of communication; and
• better understand our customer base so that we can improve our services and marketing activities (which could also benefit you).
When we rely on our legitimate interests in order to collect and use your personal data (including for the purposes of automated decision making and profiling as set out in Automated decision making below), we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue only if we decide that your interests, rights and freedoms do not override our legitimate interests.
We have considered these matters, and where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not use your personal data unless there is another legal basis for us to do so (either that it is necessary for us to perform our contract with you, or on the basis of your consent). For example, we believe that collecting your location data may be intrusive, and so we will only do so with your consent.
What happens if you do not provide us with the personal data we request or ask that we stop processing your personal data?
Please note that in order for you to register with or continue using Privilege, we only need to have your email address. However, if you provide us with more personal data on our request, we can provide you a better service and Privilege experience. As we’ve noted above, we also collect certain information about your activities and transactions at Villages so that you can participate in Privilege.
If you ask that we stop using your personal data (see Your Rights above) then we may not be able to provide you with all the benefits of Privilege.
How we contact you
Privilege works best when we are free to communicate with you to share details of treats, rewards and other offers you might be interested in. In order to provide you with the benefits of Privilege we may, if we have your consent, contact you by post, e-mail, SMS text messages, telephone or other means including other electronic means such as Facebook and social media applications, and only using such contact details as you provide to us from time to time.
If you no longer wish to receive such or certain communications, you can let us know by contacting us using one of the email addresses here. You may also update your preferred contact details at any time by contacting us at the above address.
Automated decision making
We use technology which tracks your purchasing behaviour in Villages, which helps us to build a profile of your preferred brands and products. What this means for you is that you are more likely to receive offers that are tailored to your specific preferences, based on your previous transaction activity. It also means that we don’t send the same treats to all our Privilege members, so you may not be made the same offers as another Privilege member. If you don’t agree with an automated decision that our technology has made in relation to you, you can let us know (see Contacting Us below).. You may still have the right to object to us processing your personal data for the purpose of automated decision making or to restrict us from doing so (see Your Rights above).
Please note that the legal basis for us carrying out this automated decision making “or “profiling”) activity is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing. See The legal basis for us using your personal data (above) for more information.
Requests to us
We are required by law to act on requests and provide information free of charge, except where your requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please send us your request using the details here.