The Bicester Collection | The Bicester Collection

The Bicester Collection Membership Programme Privacy Notice

The Bicester Collection membership programme (“Membership Programme”) is governed by the Membership Terms and Conditions available here (Membership Terms and Conditions).

We are committed to protecting and respecting your privacy and want to ensure you understand our processing of your personal data.

You should read through this Privacy Notice to fully understand the basis upon which we collect your personal data, how we use it, where we store it and to whom it is disclosed. Other Privacy Notices may also apply in relation to our use of your personal data other than in connection with the Membership Programme, such as the Village Privacy Notice, which describes the data we collect when you request guest services from us, for example.

Who We Are and How To Contact Us

Click here to see who we are.

The entities listed are the owners and operators of retail shopping Villages (Villages) within The Bicester Collection. References in this Notice to “we” or “us” are to the entities listed. Each of the listed entities is committed to protecting your privacy and are joint data controllers within the meaning of Data Protection laws applicable in the UK and European Economic Area (EEA).

If you need to contact us for any reason (including with any questions in relation to this Notice or to exercise any of your rights as set out below), please contact us at Notices@ValueRetail.com

Primary Village	Contact email address	Website
Bicester Village	MemberEnquiry@BicesterVillage.com	TheBicesterCollection.com/bicester-village
Kildare Village	Membership@KildareVillage.com	TheBicesterCollection.com/kildare-village
Maasmechelen Village	Info@MaasmechelenVillage.com	TheBicesterCollection.com/maasmechelen-village
La Vallée Village	MembershipEnquiry@LaValleeVillage.com	TheBicesterCollection.com/la-vallee-village
Fidenza Village	FReception@FidenzaVillage.com	TheBicesterCollection.com/fidenza-village
Ingolstadt Village	Membership@IngolstadtVillage.com	TheBicesterCollection.com/ingolstadt-village
Wertheim Village	Membership@WertheimVillage.com	TheBicesterCollection.com/wertheim-village
La Roca Village	Membership@LaRocaVilage.com	TheBicesterCollection.com/la-roca-village
Las Rozas Village	Membership@LasRozasVillage.com	TheBicesterCollection.com/las-rozas-village
All Villages	Notices@ValueRetail.com	TheBicesterCollection.com

The Villages in Germany, Ingolstadt Village and Wertheim Village, have appointed a Data Protection Officer for Germany, who can be contacted at DatenSchutzBeauftragter@ValueRetail.com

As joint data controllers, we have arrangements between us to ensure that we handle your personal data correctly and in accordance with Data Protection law. This arrangement between us does not affect your rights under Data Protection law. For more information on these arrangements, feel free to contact us as set out above.

What Personal Data Do We Collect?

Data sets 1
Unique account code, barcode number, name, email, country and city of residence, postcode, gender, date of birth, registration source code (e.g. website, social, app, Village host), Primary Village, date and time of registration, consent preferences, account currency.

Data source
Directly from you.

How your data is used
Membership or Private Client Registration.

Data sets 2
Address, telephone, preferred language, Villages of interest, car registration, nationality, account status and segmentation identifier, grouping profile, membership level, stars and rewards.

Data source
Directly from you.

How your data is used
Membership account or Private Client record Management.
Data sets
Name of spouse, marital status and anniversary, visit notes (such as food allergens and beverage preferences when visiting The Apartment), professional information, such as job title and industry or work, travel arrangements and holiday destinations, number of children and age range, details of any pets, partner or brand referral, nominated Personal Shopper and Personal Shopper notes including; styling and size preferences, social media handle, hobbies and interests.

Data source
Directly and Indirectly from you.

How your data is used
Private Client record notes to support curation of experience when you visit our Apartments or attend events.
Data sets 1
Feedback and survey response, enquiry and complaint.

Data source
Directly from you and where we have your consent (where applicable).

How your data is used
Better understand your experience with us.

Data sets 2
Publicly available data or information about you held by our selected partners, where you have agreed with that partner that they can share your personal data (according to their Privacy Notice and your personal choices with them).

Data source
Indirectly from you (we will always notify you of any data we acquire).

How your data is used
To form a clearer picture of you and the kinds of offers in which you might be interested.

Additionally, we collect personal data from you in other ways:

when you are invited to become a Private Client, we link your Private Client record to your membership account. It is not possible to become a Private Client without a membership account;
when you are invited to visit The Apartment in the Villages, or attend an event; and
when you register to use a guest service in the Village, we will link your service record to your membership account where you have one.

How Do We Use Your Personal Data?

to ensure that the information we hold is kept accurate and up to date;
to better understand your shopping behaviour in order to improve our products and services;
to analyse the effectiveness of our marketing and to help us provide more relevant offers;
to provide you with information about events, special offers, promotions and other relevant matters concerning the Villages, (if you have given your consent for us to do so);
to advertise the Villages on social media and with other partners who may be interested in what we have to offer, and identify similar prospect new guests (lookalike), by sharing your hashed personal data with these partners (if you have given your consent for us to do so);
to exclude you from membership sign up advertising if you are already registered for membership, by sharing your hashed personal data with media partners (if you have given us your consent to do so);
to advertise offers or promotions made available by our third party partners (if you have given us your consent to do so);
to provide any services which you request or which we offer, such as using your address for delivery services; and
use your location to show you targeted website content when you log in to your membership account.

How Long Do We Keep Your Personal Data?

We will keep your personal data for as long as you continue to interact with us (for example, if you open or click on an email we send you, make a purchase from a Village, or book a guest service). If we do not have any interaction with you for three years, we will attempt to contact you to see if you still wish to remain a member or Private Client. If we do not hear from you (or if you tell us, at any time, that you no longer want to be a member or Private Client) then we will delete your personal data from our records.

Who We Share Your Personal Data With

We process your personal data (see “Who We Are” above) by having joint access to a Central database shared by all Villages In Europe, the UK and the US. Each Village shares the personal data of its own members and Private Clients with other Villages by including it as part of our Central database. This allows you, as a member or Private Client, to benefit from membership in all Villages, including by earning stars and redeeming treats or rewards in more Villages (in accordance with the Membership Terms and Conditions).

We use carefully selected third-party partners to help us deliver some of our services. We check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal data. We have written contracts with them which provide assurances regarding the protections that they give to your personal data and their compliance with our data security standards.

We use third-party providers, known as data processors, to support the provision of membership systems and services and prospect member advertising, including:

processing boutique transaction information to determine membership stars, levels, rewards and whether you are eligible for a treat;
validating your registration data and host and operate our database; and
identifying lookalike audiences, in collaboration with media partners and social media platforms, by analysing hashed data sets from our membership database. Using this information, we identify audiences who closely resemble our existing members. These lookalike audiences may be interested in the Villages or Membership Programme. When these audiences have given their consent, we advertise to them through our media partners.

We restrict “Sign up for membership” advertisements to our existing members and instead provide personalised advertising to those members regarding related products.

We use consultants and professional advisors to assist us in our day-to-day business.

Your personal data may be transferred abroad, to EEA countries or to other countries deemed as offering adequate protection by the European Commission and the UK. Where your information is transferred to countries outside the EEA, UK, or locations which are not included in the list of GDPR-adequate countries, we will conduct transfer risk assessments and put in place safeguards such as standard contract clauses issued by European and UK Data Protection authorities.

If you would like more information about our third-party partners, transfers and to request details of the safeguards in place, please contact us using the details provided in the section “Who We Are and How To Contact Us”.

In addition, we disclose your personal data:

if we are under a duty to disclose or share your personal data to comply with any legal obligation, or to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
to successors in title or replacement operators of all or part of our respective businesses.

The Legal Basis For Using Your Personal Data

1. It is necessary for us to process your personal data provided at the time of registration to fulfil our contractual obligations with you:

so we can process your transaction information to determine your account stars, levels and rewards, for performance of the contract between us in relation to the Membership Programme (which is governed by the Membership Terms and Conditions).

2. We also process your personal data after obtaining your consent to do so, for the purposes of:

sending you marketing communications;
advertising with media partners and on social media platforms; and
using your device location to deliver specific messaging and content to you and to monitor the effectiveness of our messaging.

3. In most cases, it is in our legitimate interest to collect and use the personal data explained in this notice, so that we can:

provide you with a service that is as enjoyable and beneficial to you as possible, including by personalising our contact with you, making sure we tell you about all the offers that relate specifically to your preferred Village, tailoring treats and rewards to your specific preferences, and contacting you using your preferred method of communication; and
better understand our guests as whole, so that we can improve our services and marketing activities (which could also benefit you).

When we rely on our legitimate interests in order to collect and use your personal data (including for automated decision-making and profiling, as set out in “Automated Decision-making” below), we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue if your interests, rights and freedoms do not override our legitimate interest or there is another legal basis for us to do so, such as performing a contract which we have entered into with you or if you have given us your consent.

What Happens If You Do Not Provide Us With The Personal Data We Request or Ask That We Stop Processing Your Personal Data?

In order for you to register with or continue using the Membership Programme, we only require the personal data you have provided at the time of registration and your transaction data. However, if you choose to provide us with more personal data, or on our request, we can provide you a better service and experience.

If you ask that we stop using your personal data (see “Your Rights” below) then we will no longer be able to provide you with all the benefits of membership.

How We Contact You

Membership works best when we are free to communicate with you to share details of treats, rewards and other offers you might be interested in.

In order to provide you with the benefits of membership, where we have your consent, we will contact you by e-mail. Where you have engaged with us using mobile messages, telephone, or social media applications, we may maintain that method of communication.

You can update your marketing consent and contact details at any time by selecting the unsubscribe link in any electronic communication sent to you, logging into your membership account, or you can let us know using the detail in the “Who We Are and How To Contact Us” section above.

Automated Decision-making

We use technology which tracks your purchasing behaviour in the Villages, which helps us to determine membership stars, levels and rewards and helps to build a profile of your preferred brands and products. What this means for you is that you will receive rewards linked to your spending and are more likely to receive offers that are tailored to your specific preferences based on your previous transaction activity. It also means that we don’t send the same treats/rewards to all our members so you may not be made the same offers as another member.

If you do not agree with an automated decision that our technology has made in relation to you, you can you can let us know using the details found in the “Who We Are and How To Contact Us” section above.

You may have the right to object to us processing your personal data for the purpose of automated decision-making or to restrict us from doing so (see “Your Rights” below). Please note that the legal basis for us carrying out this automated decision-making (“profiling”) activity is the performing of a contract (see “The Legal Basis For Us Using Your Personal Data”).

How To Access Your Information and Your Other Rights

You have the following rights in relation to the personal data we are processing about you:

Right to be informed of the personal data we are processing about you.

You have the right to be provided with clear, transparent and easily understandable information about how we collect and use your personal data. This is why we are providing you with the information in this Privacy Notice.

Right of access to the personal data we are processing about you.

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data and information about how we use it. If you require additional copies, we may need to charge a reasonable fee.

Right to correct the personal data we are processing about you.

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it corrected (subject to certain exemptions).

Right to delete information the personal data we are processing about you.

This is also known as ‘the right to be forgotten’. You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it, if you withdraw your consent and there is no other legal justification for the use of the information, or if you object to the way we process your information and we have no overriding grounds to use it.

Right to restrict the processing of personal data.

You can ask us to “block” or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you object to us processing it. We will still be able to store your personal data. We will tell you before we lift any restrictions and why we have done so.

Right to portability of your personal data.

You have the right, in certain circumstances, to obtain the personal data you have provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

Right to object to the personal data we are processing.

You can ask us to stop processing your personal data, and we will do so, unless we:

can demonstrate compelling legitimate grounds for the processing; or
we need to use your personal data in connection with any legal claims.

Rights in relation to automated decision-making and profiling using your personal data.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you. This right is not applicable if profiling is necessary for entering into, or the performance of, a contract between you and us.

Right to withdraw your consent to processing of your personal data.

If you have provided your consent to process your personal data and that is our legal basis for processing, you have the right to withdraw that consent at any time (although if you do so, it does not mean that anything we have done with your personal data, with your consent, up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

Right to complain to a Data Protection supervisory authority.

If you have a concern about any aspect of our Data Protection practices, including the way we are processing your personal data, you can report it to your local Data Protection Supervisory Authority. Their contact details are contained in the table below.

Country	Supervisory	Website
UK	The Information Commissioners’ Office (ICO)	www.ico.org.uk
Ireland	The Data Protection Commissioner (DPC)	www.dataprotection.ie
France	Commission Nationale de l’Informatique et des Libertés (CNIL)	www.cnil.fr
Italy	Garante per la protezione dei dati personali (Garante)	www.garanteprivacy.it
Spain	Agencia Española de Protección de Datos (AEPD)	www.aepd.es
Belgium	Gegevensbeschermingsautoriteit (GBA)	www.gegevensbeschermingsautoriteit.be

Germany
Data protection for private sector organisations is overseen by regional data protection authorities. Value Retail operates in two regions within Germany and, therefore, falls under the jurisdiction of two supervisory authorities:

Region	Supervisory	Website
Bavaria	Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)	www.lda.bayern.de
Baden-Württemberg	Der Landesbeauftragte für den Datenschutz Baden-Württemberg	www.baden-wuerttemberg.datenschutz.de

Changes to this Privacy Notice

We make changes to this Privacy Notice from time to time.

To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes to our use of your personal data or when we add new services or facilities. We will also update this Privacy Notice to comply with changes in applicable law or regulatory requirements. If we make substantial changes to the way we process your personal data, we will contact you to the extent this is possible and practical.