VIP Room Privacy Notice
#### Who collects your personal data?
Please click [here](https://vrdigitalprodcmsmedia.blob.core.windows.net/prod01-wv/8602/privilege-who-we-are-final-27022018.pdf) to see who we are. The entities listed are the owners and operators of retail outlet villages (Villages) within the Bicester Village Shopping Collection brand. References in this Notice to “we” or “us” are to the entities listed. Each of the listed entities are committed to protecting your privacy and are joint data controllers within the meaning of data protection laws applicable in the European Union (“EU”) 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. These arrangements reflect our respective roles and responsibilities in relation to you, and considers which entity is in the best position to fulfil each obligation to you. This arrangement between us does not affect your rights under data protection law. You have a number of rights when it comes to your personal data (see Your Rights section below). For any data protection queries or to exercise any of these rights, please speak to your VIP Room Host or contact us here
#### What information do we collect about you and how do we use it?
We collect your name and contact details (email and/or telephone number and/or address) when you first register for the VIP Room. We also collect any personal data that we require in order to provide you with any services you request from us (for example, if you receive personal shopping services we may collect information about your clothing or shoe size). We are processing your personal data in order to:
• provide you with information about events, special offers, promotions and other relevant matters concerning the VIP Room (if you have given your consent for us to do so);
• provide any services which you may request or which we may offer; and
• ensure we give you the best possible experience and opportunities when you use the VIP Room.
When we interact with you (for example, when you are using services we provide) we may learn certain details about you that do not fit into one of the categories above. We may record this information in order to ensure we can remember important details about you and your preferences in future. We ensure that only a small number of authorised personnel have access to this personal data and we will not use it for any purpose other than to build an ongoing relationship with you, our valued customer, when you visit us or when we interact with you.
If you receive a service from us, we will collect your personal data in accordance with the privacy notice specific to that service. We may collect and record your preferences about the way the service was delivered so that we can improve your experience next time.
#### How long we keep your personal data for
We will keep your personal data for as long as you continue to interact with us (for example, if you read or click on an email we send you, make a purchase from a Village, or attend an event we host). If we do not have any interaction with you for three years, we will attempt to contact you to see if you still want us to hold your records. If we do not hear from you (or if you tell us, at any time, that you no longer want us to hold your personal data) then we will delete your personal data from our records. There may be some personal data we only need to collect in order to provide you with a particular service (for example, if you receive valet parking services from us, we will need to collect your vehicle license plate number in order to deliver the service). We will delete such personal data in line with our retention policies. We may still retain your preferences about the way the service was delivered so that we can improve your experience next time (for example, if you have particular dietary requirements we may retain this information for the next time you eat with us).
#### Who we share your personal data with
Your personal data will be shared with and used by our VIP Room Hosts in accordance with the descriptions above. If your VIP Room Host thinks you might be interested in an event or offer available at another of our Villages we may contact you on their behalf and may share your personal data with that Village so that we give you the best possible experience and opportunities when you use the VIP Room in that Village (if you have given us your consent to do so). This allows you to benefit from the Bicester Village Shopping Collection VIP experience at all Villages across Europe.
If you request a service from us, we may also provide your personal data to our suppliers who we contract to perform that service (for example, if you request transport to a Village, we share certain personal data with our chauffeur service providers). For this purpose, we enter into agreements with our suppliers pursuant to which the suppliers have obligations to process your personal data only in accordance with our instructions, and which ensure an adequate level of protection for your personal data.
In addition, we may disclose your personal data:
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others; and
• to successors in title or replacement operators of all or part of our respective businesses.
In some cases the information we collect from you may also be processed outside the EU, and such destinations may not have laws which protect your personal data to the same extent as in the EU. We have obligations to ensure that your personal data processed by us or by our suppliers and partners operating outside the EU is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Notice. You can click [here](https://vrdigitalprodcmsmedia.blob.core.windows.net/prod01-wv/8974/vip-who-we-share-your-data-with.pdf) for a list of the suppliers and processors we currently use, and other parties to whom we disclose your personal data. The link also has information about how these parties use your personal data, any processing they perform outside the EU, and the safeguards that are used to protect your personal data if this happens.
#### The legal basis for us using your personal data
If we use your personal data to communicate with you about offers available through the VIP Room, we do so only with your consent (which you may withdraw at any time by speaking to your VIP Room Host). If we use your personal data to provide a service you have requested, it may be necessary to process that personal data for the performance of the contract between us in relation to that service. In other cases, it may be in our legitimate interests to do so to ensure you have a smooth and enjoyable experience with us, including when you are receiving services from us.
When we rely on our legitimate interests in order to collect and use your personal data, we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue only if we decide that your interests, rights and freedoms do not override our legitimate interests. We have considered these matters, and we are satisfied that the legitimate interests we are relying on are not overridden by your interests or fundamental rights and freedoms.
#### What happens if you do not provide us with the information we request?
You are not obliged to give us any information we ask for. However, if you don’t, then we may not be able to provide you with all the benefits of the VIP Room. If you no longer want us to communicate with you (or want to update your preferred contact details) just let us know.
You have a number of rights when it comes to your personal data.
Rights What does this mean?
1. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Notice.
2. The right of access
You have the right to obtain access to your personal data (if we’re processing it), and certain other information (similar to that provided in this Privacy Notice).
This is so you’re aware and can check that we’re using your personal data in accordance with data protection law.
3. The right to rectification
You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
7. The right to object to processing
You have the right to object to processing for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests.
8. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your relevant data protection regulator.
9. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your 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.
Requests to us
We will act on your requests and provide information free of charge, except where your requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.
Generally we’ll respond to you within one month after receiving your request, but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above) please speak to your VIP Room Host or email us at VIP@wertheimvillage.com