POPIA

WILLOWBRIDGE SHOPPING CENTRE

CUSTOMER PRIVACY NOTICE

1              ABOUT THIS PRIVACY NOTICE

We at Willowbridge South Co-Owners, the owners of Willowbridge Shopping Centre (“Shopping Centre”), are committed to protecting our customers’ privacy and ensuring that their personal information is collected and used appropriately, lawfully and transparently.  This Privacy Notice sets out briefly how we use your personal information in accordance with the Protection of Personal Information Act (“POPIA”).

“Personal Information” means any personal information that identifies or relates to a person, as defined in POPIA. If you provide Personal Information to us about another person (like family members or potential customers), you must inform that person about this Privacy Notice and get their permission (where possible) for sharing their Personal Information with us.

This Privacy Notice does not form part of any contract to provide our services to our customers and we may update it at any time.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

If you have any questions about this Privacy Notice or any of our privacy practices, please contact our Information Officer using the details set out below.

2              GROUNDS FOR PROCESSING PERSONAL INFORMATION

To provide our products and services and run our business, we collect, use and disclose your Personal Information. Where we do this, we will either rely on your consent or on lawful grounds set out in POPIA, for example:

• preparing to enter into or performing a contract with you;

• complying with obligations placed on us by law;

• protecting your legitimate interests;

• us having a legitimate interest to require your Personal Information.

3              WHAT PERSONAL INFORMATION WE COLLECT

The types of Personal Information that we may collect from you includes, without limitation, the following:

• general identification and verification, demographic, vehicle license plate and contact information;

• information about your gender and birth date;

• payment information, such as bank account details or card details or your pension status;

• transactional data, e.g. when you use our vouchers or discount;

• information which you provide to us on our website or apps /or use our WiFi services (“Sites”) or information about your use of our Sites;

• information about your use of the Shopping Centre;

• information which you provide to us by entering in or participating in any of our competitions or participate in any of our events;

• marketing or communication such as your personal preferences, Iikes or dislikes;

• other information we require to provide our services or products to you.

We may collect special (sensitive) categories of Personal Information about you, such as details about your race or health. Please note we do not generally collect special Personal Information unless you have agreed, you provide it to us in connection with the services we are providing to you, it is necessary to exercise your or our rights in, or is required by, law or it is public information.

4              WHERE WE MAY GET PERSONAL INFORMATION FROM

We collect and record your Personal Information from a variety of sources, but mainly directly from you.  We may also collect some of your Personal Information from third parties, such as our tenants, your bank, our brand sponsors or other third parties from whom we are legally entitled to collect your Personal Information.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

5              HOW WE USE YOUR PERSONAL INFORMATION

We will only collect your Personal Information for specific and lawful purposes, for example to:

• support and maintain our relationship with you and communicate with you;

• provide our products or services to you;

• carry out transactions or services you have requested;

• administer our Sites and to analyse your use of our Sites and gather feedback to enable us to continually improve our Sites and your user experience;

• process payments;

• enhance our services and offerings;

• monitor our shopping centre (and car parks) for security purposes; 

• confirm and verify your identity;

• carry our market research and analysis;

• comply with applicable legal and regulatory requirements;

• detect and prevent fraud, crime, money laundering or other malpractice;

• where you have agreed:

  • market our products and services or those of third parties (such as our tenants);

  • tell you about our promotions, competitions or events and new tenants in the Shopping Centre;

  • to analyse your purchase habits and preferences to personalise our marketing or services to you.

6              WHO WE MAY SHARE PERSONAL INFORMATION WITH

We use third party service providers who provide certain services on our behalf and may share your Personal Information with them, for example storage providers, website or database hosting companies and auditors.  In the event any of your Personal Information is shared with the above third parties, we have appropriate contracts in place with them to ensure the confidentiality and security of your Personal Information and that your Personal Information is only used for the purposes we have specified.

We have to share your Personal Information with entities such as regulatory and industry bodies, government and law enforcement agencies where we are under a legal, regulatory or professional obligation to do so.

We may also share Personal Information about you with certain third parties, but only for the purposes collected, where you have consented or where it is otherwise lawful. These third parties include:

• to affiliated or subsidiary companies of Willowbridge South Co-Owners;

• our tenants;

• third parties sponsoring or hosting events, competitions, promotions and the like;

• attorneys, tracing agents, debt collectors and other persons that assist with debt collection or the enforcement of agreements;

• your bank or payment processors;

• legal and regulatory bodies;

• law enforcement and fraud prevention agencies;

• third parties who conduct market research or statistical analysis, but only aggregated or anonymous information.

7              OUR SERVICES, PRODUCTS AND OFFERINGS

We would like to use your Personal Information to keep you informed about our products and services, promotions, events and competitions or those of our tenants or other business partners which may be of particular interest to you.

You may opt out at any time if you don’t want to receive any or only some  communications of this nature by sending an email to Lizelle@willowbridgecentre.co.za.         

8              RETENTION OF YOUR PERSONAL INFORMATION

We keep your Personal Information only as long as is necessary to fulfill the purposes for which the information was collected or as required by law or to meet regulatory or legislative requirements or as otherwise permitted by law. Personal Information will be securely disposed of when it is no longer required.

9              AUTOMATED DECISION MAKING

Sometimes, as part of our business operations, decisions are taken about you using automated computer software and systems. These decisions do not involve human input. We will only use such automation where appropriate and, when we do, ensure your privacy and data protection rights are respected and upheld.

10          SECURITY OF PERSONAL INFORMATION

We use appropriate technical and physical security measures to keep your Personal Information safe and secure. When we provide your Personal Information to a third party or engage a third party to collect Personal Information on our behalf, the third party will be selected carefully and required to use appropriate security measures to protect the confidentiality and security of your Personal Information.

11          TRANSFER ACROSS BORDERS

Sometimes we will process your Personal Information in other countries, either to carry out your instructions or for ordinary business purposes. These countries may not have the same level of protection. We will only process your personal information with your consent. If necessary, we will ask the party to whom we transfer your Personal Information to agree to our privacy principles, associated policies and practices.

12          YOUR RIGHTS

You have a number of rights under POPIA in connection with our use of your Personal Information. These rights include:

• a right to access your Personal Information;

• a right to correct inaccurate Personal Information;

• a right to erase data or suspend our use of Personal Information;

• a right to object to our use of your Personal Information;

• a right to withdraw consent; and

• a right to complain to the Information Regulator at the following addresses:

Please bear in mind that if you erase or suspend our use of your Personal Information or if you object or withdraw consent, this may affect our ability to carry out the tasks mentioned above for your benefit.

If you would like to exercise any of your rights set out above, please contact our Information Officer at the contact details provided.