Privacy Policy

How do we collect information about you?

 

  1. Entering into a competition or promotion hosted by ourselves or our third parties: You may provide us with personal data when you subscribe to these services either online or through a physical form.
  2. Enrolling for a Star card: you will typically provide us with your name and contact details when you enrol for a loyalty card either through a physical form or through our website.
  3. Feedback: providing feedback to us through our online surveys where you may provide your contact details and subscribe to marketing. Our main supplier for this service is based in the US so your data will be transferred securely and legally outside of the UK. You can also provide us feedback through writing or emailing to the centre with you complaints, comments and suggestions.
  4. Website usage: We may also collect information from you automatically when you access and use our Online Services, including the time and duration of your visit, the referring URL, your Internet Protocol (IP) or MAC address, the type of device you use and its operating system. As with most websites, we also operate cookies on ours and further details can be found in the section on cookies below.
  5. Enrolling for an event: we may collect your name and contact details if you wish to participate in an event that is organised at one of our centres. This data may be captured on a third party booking system.
  6. Promotional photography: we may take photographs of you when you attend one of our events. If this is a single shot for media purposes, Swansgate will ensure that approval is collected. Signs will be on display during the event to advise you when photographs are being taken, and if you have concerns or do not wish to be photographed please raise these with a member of our staff.
  7. Interaction with social media: Depending on the Privacy setting you have applied in your Social Media accounts, and based on the content that you choose to share, when you interact with our Social Media presence we will have access to your user generated content, such as posts, comments, pages, profiles and images. Also depending on the Privacy setting you have applied in your Social Media accounts, and based on the content that you choose to share, we may have access to contact details, personal information (such as age, gender, employer, education, location and habits and preferences).
  8. Miscellaneous Forms: There are miscellaneous forms at site which can also record your personal information – for example lost property, services etc.
  9. Retailers: Retailer engagement via a business address will be only at the say so of the owner of the address. This will be used to communicate only the needs of the business.

In all of the above instances, we will only provide you with email marketing where you have consented and you can withdraw this consent at any time by clicking the unsubscribe link within the emails you have been sent. Where we send you information electronically, we review whether the communication has been opened and whether you have clicked on any links in the communication. This is because we want to make sure that our communications are useful for you.

 

Any third party marketing agencies who we work alongside may have access to your personal details to devise email marketing campaigns, to provide customer insight through the analysis of data and to collect personal data on our behalf. We store your information in a secure marketing database hosted by a third party which we use to also generate our email marketing campaigns.

 

In relation to third parties, we ensure that they will also safeguard your data – please see Protection of Your Information below.

 

 

For what purpose is it collected

The personal information gathered through Swansgate Wifi and Marketing is for our legitimate business interests, this includes to:

 

  1. Tailor our online services to you so the content you see is relevant to you. For example, we may request your date of birth, gender and some basic interests (such as ‘shopping’ and ‘dining’) so that we can provide you with content that we think you will be interested in – “profiling”; and
  2. Collect data obtained through our interaction with customers for research, analysis, testing, monitoring, risk management and administrative purposes including the optimisation of service delivery at our properties and to improve the customer experience.
  3. Promote our site externally.
  4. We frequently ask for post code during our customer interactions to help us better understand our customers. We share this data with third parties without any personal identifiers to assist with our insight and analysis.

 

For the WiFi-Service and competitions and promotions, the legal basis is also to form a contract with you to provide these services and promotions.

 

 

Data minimisation and retention

We will only collect the minimum amount of personal information necessary and will only keep your information for as long as you remain engaged with our marketing campaigns. Where you have not engaged with our marketing material for over a year, we will take steps to remove your information from our marketing database. Where you unsubscribe from our marketing, we will add your email address to our suppression list and delete any additional information that we hold about you.

 

Where you have provided your details in relation to a competition, we will delete your personal data when the competition has finished (unless you have consented to your information being used for marketing purposes).

 

For any contractual purpose, your personal data will be held for as long as is required to execute the contract.

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