This privacy policy should be considered and read in conjunction with the terms and conditions for the Website operated by Spinningfields Management Company whose data is controlled by Allied London Properties Management Limited (registered company number 1004005) (“the Site”).
Your privacy is very important to us and we take our privacy commitments to you very seriously. By using the Site, you consent to the collection and use of the information that you provide to us, for example, during the registration process, in accordance with this privacy policy.
You authorise us to use, store or otherwise process any personal information including but not limited to your name and address, which personally identifies you (“Personal Information”) to enable us, our partners, associates, sub-contractors or the Avenue retailers together our “Partner Companies”) to provide the services which are available through the Site.
If you send us personal correspondence such as e-mails or letters we may collect such information into a file specific to you and we will use such information for general development of the Site in order to maximise the Site’s relevance to you. This information will not be made available to other companies unless you request us to do so or we first obtain your permission.
We may transfer or disclose Personal Information to our professional advisers and to such other parties as we consider necessary, for the administration of the Site and related business or if required to disclose such information by law. We will always make sure any disclosure complies with data protection requirements.
We may use the Personal Information to keep you up to date with news, information particular to your Location (as defined in the terms and conditions), local services, and to include your details in an online tenant’s handbook.
We may aggregate statistics, traffic patterns and related Site information and disclose such aggregate data to third parties for marketing, advertising, auditing usage or other promotional purposes but such aggregate data will not include any Personal Information.
Certain information relating to visitors to the Site is recorded by the standard operation of our servers, including but without limitation, the URL that you just came from, which URL you go to next, which browser you go to next, what browser you are using and your IP address. Such information is primarily used to provide an enhanced on-line experience for the visitor.
The Site places our “cookie” in the browser files of your computer. A cookie itself does not contain any Personal Information but lets the computer remember that you have registered, if applicable, and saves your passwords and preferences from your last visit to the Site. The use of cookies enables us to tailor the Site to your particular needs.
We may take any action with respect to your Personal Information we deem necessary or appropriate if we believe it may cause us to suffer any loss, liability or commercial damage.
The Personal Information you provide shall be accurate and complete and all registration details (where applicable) shall contain your real name, address and other requested details.
You can follow us on Twitter here. We also have a Twitter feed to this website, so please remember that if you reply to one of our tweets, your reply and a link to your user name and time of the reply will be displayed on our website, allowing other visitors can click into your Twitter account.
We also have a blog on this site. The blog is run by us, not the retailers in The Avenue, so please do not attribute anything we say to them as it won't represent their views - please see the disclaimer in our terms of use. If you comment on the blog, your site user name and comment will of course be published on our site. Please make sure you follow the content rules in our terms of use when posting comments as there can be serious consequences for you as well as us if you break the law.
Please only give us your email address if you want to receive newsletters from us about what's happening at The Avenue including information about retailers and their products and services. There will be an opt-out in every email - so you can stop receiving these at any time.
By accepting the terms and conditions, or by registering on the Site, unless you opt out by contacting us as described below, you consent to the processing and disclosure of your Personal Information as set out above. We will not use Your Personal Information for any other purpose other than set out above without first obtaining your permission.
You can opt out of receiving communications from us and/or update Personal Information you have previously provided and/or ask us any questions relating to our privacy policy by sending an e-mail to feedback@spinningfields.co.uk
Make it clear who the data controller is – which legal entity – and provide its register number in the ICO's regsiter of data controllers – e.g. is it ALLIED LONDON PROPERTIES MANAGEMENT LIMITED behind Spinningfields?
This gives you the flexibility you referred to – e.g. if you want to ask for age you can – just make sure if you collect data through a form you mark with a * those fields that are mandatory (email address, name) and leave blank those that are voluntary (such as age)
Better for compliance with the transparency/fairness principle in DPA to be clear who these other third parties are – do you need to say "retailers"?
This looks like profiling – or is it just feedback that goes into general development of the site rather than personalising it for each individual?
I would add here "We will always make sure any disclosure complies with data protection requirements.
As a general point, identify whether these cookies are yours or third party (such as advertisers' cookies) and whether they are persistent or session – the site developers will have details. If the site uses Google Analytics there is set wording Google provides which must be included in the privacy policy.
This isn't strictly true in that the company is responsible for the security of the information.
For third parties you need to collect opt-in consent rather than opt-out, althoguh here you are not going to pass on email addresses to third parties. You (the company) can only collect opt-out consent for email markeitng if it's in the course of negotiations for your goods and services and you provide an opt-out at the point of collection, so I suspect here it will need to be opt-in consent, or a box for the email address to be filled in with a "subscribe" button next to it.
Arguably not "free" as no choice here – either use the site on these terms or not. Suggest remove "freely".
"Update" better You'd normally have a bit after this about further inforamtion and how to get in touch with the company's data protection officer / exercise rights to see a copy of you personal information we hold.
