PRIVACY POLICY

 

Last updated: December 18, 2015

1.                  General

Espace Expansion (“We” / “Us”) process your personal information in the context of the provision of our websites, loyalty program and mobile applications (together, the “Services”) which may be accessed through various media or devices and made available by Us. We place great emphasis on the protection of personal information. Personal information is any information, which allows identifying directly or indirectly an individual.

The purpose of this privacy policy (“Privacy Policy”) is to inform you about how We collect and process your personal information that you submit or disclose by accessing or using our Services.

We encourage you to read this Privacy Policy carefully. By using the Services and providing your personal information to Us, you acknowledge that you have been informed of our use of your personal information as set out in this Privacy Policy. If you do not wish your personal information to be used by Us as set out in this Privacy Policy, please do not provide Us your personal information. Please note that in such a case, you may not have access and/or use some features of the Services or some of our Services.

 

The Services are addressed to users of an age of eighteen (18) or above.

2.                  How we collect personal Information

We collect your personal information in several different ways:

2.1              Registration information you provide Us with. Some of our Services require you to sign up for an account, in particular our loyalty program and some features available through our mobile applications or websites. If you choose to create an account by completing the registration form, you will be asked to supply contact details and ID information (your title, first name, surname, date of birth, postcode, email address, mobile number and any other relevant information that you would give Us).

2.2              Registration information you allow social networks to transmit to Us. If you choose to create an account by using your social network account (i.e., Facebook, Google + or Twitter), upon your prior consent, your social media will transmit Us your personal information (first name, last name, username, profile picture, email address, gender, birthday, education, school, job title), your address information (Country, City, address, ZIP Code, phone), my “likes” (pages, favourite movies, favourite music, favourite TV Shows)  and friend list.

2.3              Personal information We collect from your use of our Services.

(i)                 When you use the loyalty card, We collect and process:

·         information relating to your shopping profile;

·         the frequency and duration of your visits;

·         information relating to your purchasing behaviour; and

·         if you are registered to the loyalty program using your social network account, information related to your interactions with the loyalty Service on such social network.

(ii)               When you use our mobile application or website Services as authenticated user, We collect and process:

·         personal information that you add to your profile (i.e., username or nickname, profile picture and password);

·         personal information included in the content that you post, upload, contribute to or otherwise make available on or through the Services, such as your timeline, likes, look books, wish list, contact list;

·         if you are connected to the Services using your social media account, information related to your interactions with the Services on social media;

·         information about the frequency of your visits, your itineraries and location within the shopping centre provided that We have obtained your prior consent. You can learn more about such use in Section “Geolocation” below;

·         technical data.

(iii)             When visiting our website, We may use cookies and similar technologies to collect information about your use of our website and you can learn more about such use in Section “Cookies” below.

3.                  How we use your personal information

We use your personal information We collect to:

(i)                 manage and provide the Services to you;

(ii)               analyse your use of the Services and, subject to your prior consent, combine your personal information collected from the use of our different Services (i.e., the loyalty card, our mobile applications and our websites) to improve our understanding of your expectations and needs and develop new features and services;

(iii)             provide customised information and promotional material to you. We will only use your personal information for the purpose of sending promotional material if We have obtained your prior consent. Accordingly, upon registration at any of our Services which collect personal information, you will be given the opportunity to provide your consent to the use by Us of your personal information for the purpose of sending promotional materials;

(iv)             measure, test, and monitor the metrics and the effectiveness of our Services; and

(v)               ensure the technical operating of the Services and protect your personal information against any theft, loss, damage or unauthorized access.

4.                  How We Share and disclose your personal information

We share the personal information We collect through the Services as follows:

(i)                 Sharing with third parties

We may share your personal information with:

·         any companies which belong to the same group as Us in order to develop and test new services and features ;

·         partner brands located in our shopping centre in order to allow them to deliver advertisements that they believe are of interest to you ;

·         third party service providers that help Us to provide the Services to you and process your personal information on our behalf. Such third party service providers will always be subject to security and confidentiality obligations consistent with this Privacy Policy and the applicable law. Note that such third party service providers may be located in the United States and thus may access and process your personal information from there. In case of such transfer to the United States, we enter into the model clauses adopted by the European Commission to ensure that your personal information benefits from an adequate level of protection when accessed and processed from there. We also obtain the requested authorisation from the CNIL;

·         our partners, in an anonymised form in a way that it is no longer possible to identify you;

·         respond to legal or regulatory requests, court orders, subpoena or legal process, if necessary to comply with applicable laws;

·         any transferee, when personal information is transferred as part of the sale or otherwise transfer of all or part of our assets to another company.

(ii)               Sharing with parties of your choice

·         Sharing with other users of the Services. Any information or content that you voluntarily disclose through our mobile application or website Services becomes available to all users of the Services. Such Services also enable you to share all or part of your content and personal information, on an individual basis, to the users of your contact list by changing your share settings on the Services.

·         Sharing with social networks. If you choose to access the Services using your social network account (i.e., Facebook, Google+ or Twitter) or to click on one of the plug-in buttons or links of social networks (e.g., Facebook “Like” button or Google “+” button) available through the Services, your content and personal information will be shared with the relevant social networks. You understand that such information may be published on your social network under your account.

You understand and agree that the use of your personal information, including information shared with the social networks via the Services, by the social networks is governed by their respective own privacy policies. If you do not want the social networks to collect information about you, please review the privacy policy of the relevant social network in this respect and/or log out of the relevant social network before using our Services.

5.                  How You can change Your preferences

Through your settings of the Services, you can update your account information, change your profile settings, subscribe/unsubscribe from communications you receive from Us, and set your sharing preferences of the Services, including location-enabled functionalities.

Please note that if you wish to limit or change access to or sharing of your personal information with social networks, please visit your account settings on that social network.

6.                  How We secure your personal information

Protecting your privacy and your personal information is our priority. If, as a registered user, you receive a password, you should keep it confidential, limit access to your computer or mobile device, and sign off after having used the Services. Learn more about your responsibilities on http://forumdeshalles.com/en/termsofuse

We take appropriate security measures to protect your personal information against any accidental loss, destruction, misuse, damage and unauthorised or unlawful access. However, please be aware that no information transmission over the Internet or storage technology can be guaranteed to be 100% secure.

7.                  How to access and update your personal information

We take reasonable measures to ensure that you are able to keep accurate and update your personal information. You have the right, in accordance with applicable law, to access, rectify, and oppose for legitimate purpose to the use of your personal information. If you wish to exercise these rights and/or obtain all relevant information, please contact ForumdesHalles.Webmaster@unibail.fr enclosing a copy of your identity card. We will respond within the legal timeframe upon verification of your identity.

8.                  Cookies

8.1              What are cookies

Cookies are small text files which are placed on your computer or mobile phone when you visit a website. They are widely used in order to make websites work or to work more efficiently. The cookies help website to recognize your device and remember information about your visit (e.g., your preferred language, font size and other preferences).

8.2              How We use cookies

We do not use cookies to track you individually or to identify you, but to allow Us to operate the Services as you have requested, facilitate your navigation on our website and the use of its features, so as to provide you with a seamless experience.

We use Google Analytics tools to help Us measure traffic and usage statistics in order to understand how visitors access and use our website. We use information collected through cookies to help improve our Services and to compile aggregate statistics about how our website is used by visitors. Please note that in this context, Google collects your personal information through the use of Google Analytics on our website. Learn more about how Google uses Google Analytics, and how it collects and processes data at www.google.com/policies/privacy/partners/.

The information is retained for a maximum period of 2 years.

8.3              How to manage your cookies preferences

Most browsers allow you to manage your cookies preferences by changing your browser settings. If you consent to our use of cookies but later wish to opt out, you may delete the cookies which have been set and change your browser settings to block any further cookies. The “Help” function of your browser should tell you how. Alternatively, the following links provide instructions for managing cookie settings of commonly used browsers:

·         Chrome (https://support.google.com/chrome/answer/95647?hl=en)

·         Internet Explorer (http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies)

·         Mozilla Firefox (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies)

·         Safari (http://support.apple.com/kb/index?page=search&fac=all&q=cookies%20safari)

 

In addition, if you do not want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on at https://tools.google.com/dlpage/gaoptout.

In addition, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.

Please note that if you block cookies, you may not have full access to all functionalities and pages of our website.

9.                  Geolocation

9.1              General principle

Subject to your prior consent, information related to your location within our shopping centre may be collected and processed by Us while you are authenticated on our mobile applications for the purposes of measuring the frequency of your visits and your itineraries within our shopping centre and/or providing the Meet My Friends Service.

9.2              How We use your geolocation information

In order to be located within the shopping centre, you will be required to activate the Bluetooth feature on your mobile device. If you only want to check out the map and your contacts’ location through Meet My Friends Service, the activation of the Bluetooth feature is not required. Please note that We will not locate you outside our shopping centre and you will not be able to share your location outside our shopping centre through Meet My Friends Service. The location option is activated by the beacons which are installed in the common areas of the shopping centre only.

We will collect and process information about your location within the shopping centre provided that We have obtained your prior consent to be located.

9.3              What is Meet My Friends Service

Meet My Friends Service allows you to share your location within our shopping centre with the users of the Service or only your friends who are also using the Service. Thus, you can visit the shopping centre knowing your friends’ location in the shopping centre and meet them up at a specific location or suggest a meeting place.

9.4              How your geolocation information is shared on Meet My Friends

For the purpose of the provision of the “Meet My Friends” Service, some features of the Service may require that your geolocation data be shared with all other users of the Services or only with your contacts depending on the way you have configured the settings.

In addition, if you have used your Facebook, Google or Twitter account to create your account with Us, you will be able to locate your contacts from such social network who are also using the “Meet My Friends” Service and ask them to share their respective location.

We may also share your geolocation information with the recipients set out in “How We share and disclose your personal information” above.

9.5              How to manage your geolocation preferences

(i)                 On your mobile settings

The first time that you authenticate on our mobile application, We will seek for your consent to enable the geolocation of your mobile device.

If you accept the geolocation of your mobile device, this will be effective immediately and for any further connections on our mobile application and for any further visits in our shopping centre.

You may disable the geolocation of your mobile device at any time through your mobile settings.

(ii)               On Meet My Friends Service

The first time that you connect to the “Meet My Friends” Service, We will seek for your consent to enable the geolocation of your mobile device and the sharing of your geolocation data.

If you accept the geolocation of your mobile device and the sharing of your geolocation data, this will be effective immediately and for any further connections, except if you use the “visible/non visible” feature available directly on the map to modify temporarily your geolocation settings. You may also disable permanently geolocation in your profile settings at any time.

Please note that by default, users of the “Meet My Friends” Service are visible to any other users of the “Meet My Friends” Service. You can configure your location-sharing settings on the Service by choosing one of the following options:

·         to be visible to all other users of the “Meet My Friends” Service; or

·         to be visible to your contacts only; or

·         not to be visible to any users of the “Meet My Friends” Service.

The confidentiality parameters that you have set up will be registered and applicable each time you use the mobile application. In addition, at any time, you will have a direct access to a “visible/invisible” option directly on the map in order to change temporarily the confidentiality settings for the duration of the current session.

10.              Additional services

We have developed the new services called Smart Park and In & Out in order to improve your experience when visiting our commercial centers.

When you log on to your user account in order to use the « Smart Park » service, We process  personal data in order to enable the geolocate your car in the  parking areas of our shopping centres. If you do not log on to your user account, no personal data will be processed.

When you want to benefit from the « In & Out » service, We process the personal data you provided us with when you created your user account. In particular, the licence plate enables to open automatically the parking when you enter or leave our shopping centres.

In addition, we may process your personal data as a result of using « Smart Park » and « In & Out » services, to inform you of any new services that We could develop and which may be of interest for you.

The personal data is not shared with and/or made available to third parties or used for any other purposes than those abovementioned. As a result of Article 39 and following of the French Data Protection Act 78-17 dated 6 January 1978 and amended in 2004, you have the right to access, rectify or delete your personal data. You can exercise these rights by contacting the service ForumdesHalles.Webmaster@unibail.fr

11. LINKS TO OTHER SITES

We may propose hypertext links from the Services or communications you receive from the Services, to third-party websites or Internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read carefully their privacy policies to find out how they collect and process your personal information.

12.              UPDATES TO PRIVACY POLICY

We may revise or update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy via the Services. If We make changes which We believe are significant and require your consent according to applicable law, We will inform you through the Services and seek for your consent where applicable.