Privacy Notice
1. INTRODUCTION
1.1 This is the privacy notice (the Privacy Notice) for the St Enoch Centre Unit Trust (St Enoch, we, us) relating to the personal data that we may collect about you when you (i) interact with us and our group of companies, (ii) visit the St Enoch Shopping Centre (either as a member of the public or an employee of a business in the centre), (iii) interact with our social media accounts, and (iv) use our website www.st-enoch.com (our Website).
1.2 This Privacy Notice explains:
(i) how we obtain your personal data;
(ii) what personal data we collect about you;
(iii) how we use your personal data;
(iv) on what basis we use your personal data;
(v) how long we keep your personal data;
(vi) with whom we share your personal data; and
(vii) your rights regarding your personal data.
1.3 Your personal data may also be collected when you interact with vendors within St Enoch Shopping Centre. This Privacy Notice does not address the collection of your personal data in those circumstances. Please contact the individual vendor to request a copy of their privacy notice that applies to the collection of your personal data in those circumstances.
1.4 We may change this Privacy Notice from time to time. Where we make any material changes, we will inform you of these changes by a notice on our website prior to the change becoming effective.
2. HOW DO WE OBTAIN YOUR PERSONAL DATA?
2.1 We gather information about you when you interact with us or third parties that we work with. For example when you visit the St Enoch Shopping Centre, our Website or social media pages.
2.2 We also gather information about you when you enter a competition or register for an event.
2.3 We may also receive information about you from law enforcement agencies, for example when the police are involved with incidents relating to any of our properties.
3. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
We may collect the following personal data from you.
3.1 Information collected when you visit the St Enoch Shopping Centre, including:
(a) CCTV and body mounted camera (BMC) images;
(b) information relating to security incidents, for example, where the police or our third party security provider are involved with incidents or receive reports relating to any of our sites; and
(c) information that you provide our third party Wi-Fi provider, when you sign up to use Wi-Fi in the St Enoch Shopping Centre.
3.2 Information that you provide to us, including:
(a) when you engage with us via Section 10 (Contact Us) on our Website – including your email address, name and telephone number, along with the contents of your message;
(b) when you provide feedback – you do not need to provide your name or contact details for general enquiries but you will need to provide an email address if you want us to reply to you;
(c) when we send you newsletters, where you have consented to us contacting you in this manner – we may require your name and email address;
(d) when you phone us – we will collect personal data you provide to us during the call;
(e) when you contact us via post – we will retain your letter, postal address, and other personal data that you may provide to us;
(f) when you interact with us, including when visiting the St Enoch Shopping Centre, or on social media – we may collect any personal data disclosed in those interactions; and
(g) when you use the cark park facilities at St Enoch Shopping Centre – Automatic Number Plate Recognition (ANPR) systems are used to process your number plate and administer car parking fees, and your credit card details will also be processed if you opt for this method of payment.
3.3 Information relating to your visit to our Website, including:
(a) your Internet Protocol (IP) address; and
(b) information collected by cookies used on our Website, such as statistics and details relating to how you use the Website (please see our Cookie Policy for more information available from: http://st-enoch.com/cookies-policy/).
3.4 Where you operate a business in the St Enoch Shopping Centre, or are a member of staff employed by a business in the centre, we may collect personal data from you including:
(a) emergency contact details;
(b) key holder listing details; and
(c) any personal information that may be required in the context of signing or renewing a lease.
4. HOW AND WHY DO WE USE YOUR PERSONAL DATA?
4.1 We use your personal data for the following purposes and according to the corresponding legal bases.
| PURPOSE | LEGAL BASES |
| To operate our business and provide services to our customers and tenants | (a) Necessary for our legitimate interests in operating the St Enoch Shopping Centre, including to provide customer service/support, provide car park facilities, provide WiFi throughout the centre, personalise St Enoch products and services, lease space to businesses in the centre, and understand usage patterns (such as foot traffic) |
| To comply with applicable laws and regulations, and comply with demands or requests made by regulators, governments, courts and law enforcement authorities | (a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests to protect our visitors, tenants, employees and properties from crime, damage or loss |
| To protect St Enoch Shopping Centre and its visitors, tenants, employees and properties from crime, damage or loss | (a) Necessary for our legitimate interests to protect our visitors, tenants, employees and properties from crime, damage or loss |
| To prevent, detect or investigate unlawful acts and criminal offences that occur on or around St Enoch Shopping Centre | (a) Necessary for our legitimate interests to protect our visitors, tenants, employees and properties from crime, damage or loss (b) Necessary to comply with a legal or regulatory obligation |
| To interact with you, including to (i) respond and resolve any complaints or feedback, and (ii) inform you of upcoming events | (a) Necessary for our legitimate interests in operating our business, including to provide customer service and support (b) When you have provided us your consent |
| For the establishment, exercise or defence of legal claims or proceedings | (a) Necessary to comply with a legal or regulatory obligation |
| To promote and market our products and services directly to you if you have indicated that you would like to receive marketing from us, and to send you newsletters | (a) When you have provided us your consent |
5. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
5.1 We retain personal data for as long as necessary to provide the products and services that you request, or for other essential purposes such as complying with legal obligations, resolving disputes, and enforcing our terms and conditions. We retain certain categories of data for the following periods:
(a) personal data relating to our newsletters for as long as you are subscribed to receive the newsletter, after which we will retain the data for 1 year;
(b) personal data relating to complaints that St Enoch believes may relate to potential legal disputes for five years;
(c) personal data relating to feedback that you may provide for 1 year;
(d) personal data relating to queries received via social media for six months after we respond to your query;
(e) personal data relating to a competition or promotion you have entered for 1 year; and
(f) personal data collected when you use our car park facilities for 1 year (including registration number and credit card details if you opt for that payment method).
5.2 Data recorded by our surveillance systems (such as CCTV and BMC) is retained by St Enoch for no longer than 31 days from the date of recording unless an incident or suspected incident has occurred. After this time, we will automatically erase all data, unless we need to retain the data for one of the purposes outlined above in Section 4 (How and why do we use your personal data?).
6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
6.1 We may share your personal data with:
- members of the St Enoch group of companies;
- the following trusted third parties:
- our service providers including third parties that may be involved with:
- our security providers who provide security services at St Enoch Shopping Centre;
- our property managers who provide operational and management services at St Enoch Shopping Centre;
- our professional advisors, insurers, agents and auditors; and
- with a prospective seller or buyer, as part of a merger, business or asset sale, or a prospective lender as part of a financing;
- courts, regulators, governments and law enforcement authorities, including the police.
7. CCTV AND BMC
7.1 We use CCTV and body mounted camera (BMC) systems at St Enoch Shopping Centre. We have a separate CCTV Privacy Notice which provides more information in relation to our use of CCTV and BMC surveillance systems, which is available here
8. COOKIES
8.1 We use cookies on our Website. Cookies are small files that are downloaded to your device to improve your experience on a website. We use the following cookies on our Website:
(a) email related cookies so the Website remembers if you have already registered to receive newsletters;
(b) form related cookies so when you submit data through a form such as our contact page then cookies may remember your details for future correspondence; and
(c) certain cookies provided by trusted third parties, including to provide statistics and details relating to how you use our Website.
8.2 For more information on the cookies that we use on our Website please see our cookie policy: http://st-enoch.com/cookies-policy/
9. YOUR RIGHTS
9.1 Data privacy laws provide you with a number of rights over your personal data. You may be entitled to:
- ask us about the processing of your personal data, including to be provided with a copy of your personal data;
request the correction and/or deletion of your personal data; - request the restriction of the processing of your personal data, or object to that processing, however this right is limited and will depend upon the lawful basis on which we are processing your personal data;
- withdraw your consent to the processing of your personal data (where we are processing your personal data based on your consent). This includes opting out of receiving any marketing information which we send you, which will always include an ‘unsubscribe’ option; and
- request receipt or transmission to another organisation, in a machine-readable form, of the personal data that you have provided to us.
10. CONTACT US
10.1 If you have any questions or requests about our processing of your personal data or would like to exercise any of the rights set out in this Privacy Notice you can contact us at: enquiries@st-enoch.co.uk
10.2 Should you wish to stop receiving marketing please click the unsubscribe link in a marketing email or contact us using the email address above.
10.3 While we hope that we can resolve any issues that you have in respect of our processing of your personal data, you also have the right to make a complaint about our handling of your personal data to the UK Information Commissioner’s Office.
11. DATA CONTROLLERS
11.1 The following entities are each a controller of your personal data, and can be contacted via the email address in Section 10 (Contact Us):
(a) St Enoch Centre Unit Trust; and
(b) St Enoch Trustee Company Limited.
This Privacy Notice was last updated in August 2021.