Realm Limited is a company registered in England and Wales with company number 04312617, whose registered address is The Farmhouse, Farm Road Street, Somerset, BA16 0FB (“we” or “us”).
Realm are a real estate asset management business, specialising in the retail and leisure property sector, and provide certain asset management related services to the Centre.
Under the new data protection laws, we have certain legal responsibilities about how we collect, use and share your personal information.
This policy explains our privacy practices and covers the following:
1. Details of personal information that we collect
We collect and use personal information relating to the following types of individuals:
Guests – Guests may include the following individuals:
Guests who sign up for the Centre’s newsletter and other marketing emails – we collect and use personal information of people who sign up to receive our the newsletter and other marketing emails, including via the Centre website. The personal information collected consists of: your name and email address, and where you inform us, your gender. If you choose to tell us your gender we can tailor the information in emails and newsletters accordingly, please see paragraph 8 below for more information.
In addition, we collect and use the name, job title, place of work, business email address and business mobile number about Business Contacts who work for various businesses involved with the Centre, notably: tenants who run retail units at the Centre, potential tenants, agents who provide services to the Centre, investors in the Centre and our clients who are involved with the Centre.
2. Sources of the personal information
3. How we use your personal information
Guests – we use personal information collected about Guests for the following purposes:
Business Contacts – we use personal information of Business Contacts to send them newsletters and invites to specific events, e-brochures and other marketing emails.
4. Parties who we share your personal information with
We share your personal information with the following parties:
We have data sharing agreements in place with these third party providers, which restricts what they can do with the personal information and requires them to have in place appropriate security measures to protect your personal information.
5. How long we retain your personal information for
The length of time that we retain your personal information for varies, according to the type of individual whose personal information we have collected, and what this is being used for:
|Type of individual||Applicable retention period|
|Guests||· For personal information used for research purposes – 2 years, which enables us to compare search results for subsequent years.
· For running competitions and other promotions – for the period in which the competition or promotion is running, plus 3 months (unless you have opted in to receiving general marketing communications).
· For direct marketing purposes – we review marketing consent periodically and will seek your renewed consent every 12 months. If you do not renew your consent we will delete your personal information, on the assumption that you are no longer interested in receiving such marketing communications from us.
|Business Contacts||We review personal information of Business Contracts held for marketing purposes, on an annual basis. If we reasonably consider that you are no longer interested in receiving marketing emails from us, for instance, if your business has ceased to be involved with the Centre, we will delete your personal information.|
6. Transfers of your personal information
Under data protection law, when personal information is being transferred from the UK to a country outside the European Economic Area (EEA), then we as data controller, are under an obligation to ensure that such transfer is performed in a manner which is compliant with data protection law.
We use certain marketing services providers (who are sub-contractors of our marketing services provider), and they are located outside of the EEA. In such situations, we only transfer personal information to these overseas third parties where we have put in place suitable measures to protect your personal information. The particular details are as follows:
Campaign Monitor – Campaign Monitor are a marketing services provider and they store and use names and email addresses of Guests and Business Contacts. Their services allow individuals to be tagged and categorised, so they can receive relevant email messages. We have put in place the EU approved model contract clauses between us and Campaign Monitor, to ensure that the transfer of your personal information to them is adequately protected in accordance with data protection law. If you would like a copy of the signed EU model contract clauses between us and Campaign Monitor, please get in touch with us and we can provide you with a copy.
7. How we legally justify using your personal information.
Every use that we make of your personal information must meet a legal ground in the list set out by data protection law. The legal grounds which we rely on are as follows:
|Type of individual||Relevant use of personal information||Legal condition relied upon|
|Guests||For research purposes.||That such processing is necessary for the purposes of our legitimate interests and where such interests are not overridden by your interests, rights or freedoms. Our specific legitimate interests for research purposes are to seek to improve the services we provide (and/or that the Centre provides) to Guests and to enhance your experience at the Centre.|
|For running competitions and other promotions.||Where you have given your consent.|
|For direct marketing purposes.||Where you have given your consent.|
|Details of your gender and other preferences so that our automated marketing software can send you tailored marketing communications.||Where you have given your consent.|
|Business Contacts||For direct marketing purposes.||Our legitimate interests, where such interests are not overridden by your interests, right or freedoms. Our specific business interests for marketing to Business Contacts is to keep you informed about events, special offers and promotions at the Centre.|
8. Automated decision making
We use a software tool which, based on a Guest’s gender and other preferences, enables us to tailor email content and other advertising content for you – in our experience men and women have different preferences when it comes to shopping and entertainment and our software tool enables us to send Guests emails and other marketing information which are suited to your gender and likely preferences. It does this by making automated decisions based on such characteristics, to determine the content of the marketing emails and communications which we send to you, for example whether you would be interested a particular genre of film or eating at specific restaurants or shopping at a particular shop. However, we only collect and use such personal information of yours in this manner where you have given your consent to this.
9. Your rights in relation to your personal information
If you have any questions in relation to our use of your personal information, you should first contact us using the contact details in paragraph 10 below. Under certain conditions, you may have the right to:
Your exercise of these rights is subject to certain conditions and exemptions, for example to safeguard the public interest in investigating crimes, or protecting legal privilege. If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to you, you can complain to the contact listed at paragraph 10 below.
10. Other relevant information, including how to contact us
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to your personal information, by contacting us as set out below.
We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, no transmission of personal information over the internet can ever be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information which you transfer to us over the internet or which we transfer to you.