Privacy Notice
Effective September 26, 2024
INTRODUCTION
This Privacy Notice describes the types of personal information Westfield, LLC and its affiliates (“Westfield”) collect, how that personal information is used and disclosed, and your rights and choices regarding our use of your personal information, including how you can access, correct, and delete your personal information.
This Privacy Notice applies if you are a U.S. resident. It explains our privacy and information practices for our websites, mobile applications, emails, and other online services we control (together “Online Services”), our physical shopping centers (“Centers”) (together, the “Services”), and other locations we control subject to this Privacy Notice. Some regions provide additional rights by law. For California-specific terms, please click here.
Your use of the Services is also governed by the Terms and Conditions, and any other applicable terms and agreements, such as the SMS Terms and Conditions.
Please read the complete Privacy Notice below, and contact us if you have any questions.
PERSONAL INFORMATION WE COLLECT
In this section, we describe how we collect personal information about you. By personal information, we mean any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or traced back to a specific individual or household). We collect personal information about you as set out below.
Information You Provide through the Online Services
When using our Online Services, you may be asked to provide personal information directly to us. We collect personal information when you:
- Create an account,
- Fill out a form,
- Sign up for or purchase Smart Parking (if offered),
- Enter a competition, sweepstakes, or event,
- Join a loyalty program,
- Respond to a survey,
- Complete a "contact us" query,
- Use our concierge services, such as wheelchair and stroller rentals,
- Sign up for newsletters or other communications, or
- Apply for a job.
The categories of personal information we collect include:
- Contact identifiers, including your name, email address, postal address, and phone number.
- Account credentials, including your username, password, password hints, and other information for authentication or account access.
- Preferences, including your preferred shopping centers.
- Characteristics or demographics, including your date of birth, gender, and location.
- Vehicle information, including your vehicle’s license plate when you sign up for Smart Parking (if offered).
- Payment information, including your payment instrument number (such as credit or debit card number), expiration date, and security code as necessary to process your payments. This information is processed by our payment processors.
- Commercial or transactional information, including records of products or services you have purchased, obtained, or considered.
- Tax information, such as where required by law when you enter a competition, sweepstakes, or event
- User-generated content, including content within any messages you send to us (such as feedback, questions, or survey responses).
- Professional, employment, or education-related information, including your employment and work history, transcripts, writing samples, references, and other information necessary to consider you for a job.
Please do not provide any information that we do not request.
Information Collected from your Browser or Device when You Use the Online Services
We automatically collect personal information from your browser or device when you use our Online Services. We use cookies and other tracking technologies to collect this personal information. For details on cookies and tracking technologies, see the Cookies and Tracking Technologies section below.
The categories of personal information we automatically collect include:
- Device identifiers, including your device’s IP address and Ad Id.
- Device information, including your device’s operating software and browser (e.g., type, version, and configuration), internet service provider, and regional and language settings.
- Internet activity, including information about your browsing history and interactions, such as the features you use, pages you visit, content you view, purchases you make or consider, time of day you browse, and referring and exiting pages.
- Non-precise location data, such as location derived from an IP address or data that indicates a city or postal code level.
- Precise-location data, such as latitude / longitude, with your consent.
Information Collected when you visit Our Centers
When visiting our Centers, you may be asked to provide personal information directly to us. We collect personal information in the following scenarios:
- Westfield Wi-Fi. If you use one of the Wi-Fi networks in our Centers, we collect your contact identifiers in order to log you on to the network.
- Concierge or other convenience services. If you use our concierge services in Center, or other services offered at your convenience such as mobile charging capabilities, package delivery, wheelchair and stroller rentals, and valet and related parking services, we collect personal information from you to facilitate the products or services you request. This includes contact identifiers, characteristics or demographics, payment information, and commercial or transaction information. Please note that these vary by location—check with your local center to see what services are available and what personal information is required to use those services.
- Competitions, sweepstakes, and events. When you enter a competition, sweepstakes, or register for an event at one of our Centers, you may provide contact identifiers, characteristics or demographics, and commercial and transactional information.
- Management and safety. We collect personal information you provide on incidents and accidents that occur in our Centers.
We also automatically collect personal information about you or from your browser or device when you visit our Centers. We automatically collect personal information in the following scenarios:
- Westfield Wi-Fi. In addition to collecting your contact identifiers, we use tracking technologies to collect your device identifiers, device information, internet activity, and non-precise location data relating to your use of the Wi-Fi.
- Parking. At certain Centers, Westfield may photograph license plate numbers of visitors who use our parking facilities. Westfield collects this personal information to assist drivers in locating their vehicle, monitor available spaces in parking structures, and in certain instances, facilitate the payment of parking. We may also use automated license plate recognition (“ALPR”) technology at certain Centers. For additional information, please see our Automated License Plate Recognition (ALPR) Usage and Privacy Policy (Century City ALPR, UTC ALPR and Valley Fair ALPR).
- CCTV. We collect personal information on incidents and accidents that occur in our Centers through the use of Closed Circuit Television Video (CCTV), video taken from parking lot security cameras, photographs, and other security measures.
- Digital displays and demographic data. Some of our Centers have digital displays with Quividi technology, which uses camera sensors to detect your generic facial features and infer certain demographics, such as age and gender. This demographic data is aggregated among all viewers, and we use the resulting aggregate demographic data to better understand the general demographics of people who viewed the content and advertisements on the digital displayers, and to improve the content, advertisements, and digital display locations moving forward. We do not use facial features data or any demographic data to directly identify any specific individuals, nor do we combine it with any lists, databases, or other datasets that could be used to identify specific individuals. We do not lease, trade, or share in exchange for anything of value, or otherwise profit from the transaction of such data. Facial features data is immediately deleted, and any demographic data is aggregated and cannot be used to link multiple views on a digital display, or visits to a Center across days or across multiple Centers. For more information on the Quividi technology, please visit Quividi’s FAQ.
Information Collected from Professional and Client Relationships
In the course of professional or client interactions involving the purchasing of advertising or the leasing of retail or other real estate space, we may collect personal information about you such as your name, position, entity name and other details surrounding the transaction or potential transaction.
Information Collected from Other Sources
We obtain personal information about you from other sources. The categories of other sources from which we obtain personal information include:
- Social media platforms with which you interact. For example, when you “like”, “post”, “message” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may obtain some personal information including your name, email address, and any comments or content you post relevant to us. We also collect your personal information if you sign up for one of our competitions, sweepstakes, or events or otherwise submit personal information to us through social media sites.
- Vendors that provide services to us, including analytics, advertising, security, and fraud prevention providers.
- Private and public databases.
Information We Infer
We infer new information from other personal information we collect, including using automated means to generate information about your likely preferences or other characteristics. We do not use sensitive personal information to make such inferences.
HOW PERSONAL INFORMATION IS USED
We use the personal information we collect in accordance with the practices described in this Privacy Notice. Our purposes for collecting and using information include:
- Providing the Services. We use the personal information we collect to provide the Services, such as maintaining your account and allowing you to use your accounts.
- Personalizing your experience. We use the personal information we collect to personalize your experience, including by showing you content within the Online Services and Centers that we believe you will find interesting.
- Developing and improving products and services. We use the personal information we collect to develop and improve our products and services, for example through tracking technologies analyzing website traffic on our Online Services and usage patterns (such as foot traffic) within our Centers.
- Communications. We use the personal information we collect to communicate with you about updates, security alerts, changes to policies, and other transactional messages. We also use the personal information we collect to deliver and personalize marketing communications to you, including by email, and, where you opt-in, text and push notification.
- Loyalty Program. If we offer and you sign-up for our loyalty program, we may use the personal information we collect to:
- Credit your account based on eligible purchases
- Offer you program rewards or special offers
- Redeem earned rewards, and
- Notify you of special events or deals unique to Westfield loyalty members.
- Sweepstakes, Competitions, or Events. When you voluntarily enter a sweepstakes, competition, or event, we use the personal information we collect as set out in the official rules that govern the sweepstakes, competition, or event as well as for administrative purposes and as required by law. By entering a sweepstakes, competition, or event, you agree to the official rules that govern, and may, except where prohibited by applicable law, allow us, the sponsor, and related entities to use your name, voice and/or likeness in advertising or marketing materials.
- Advertising. We use the personal information we collect to advertise and market to you. We partner with agencies, ad networks, and other third parties to help us display relevant advertising and to manage our advertising across multiple channels. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services. As part of this process, we incorporate tracking technologies, often offered by third parties, into our own Online Services (including our websites, mobile applications, and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and showing you advertising based upon your browsing activities and interests (“Interest-based Advertising”). For details on cookies and tracking technologies, see the Cookies and Tracking Technologies section below.
- Maintaining a Secure Environment. We use the personal information we collect to investigate, detect, prevent, and report fraud, security breaches, and incidents, and other potentially prohibited or illegal activities. In addition, we use the personal information we collect to comply with applicable laws and regulations, and to protect our customers’ rights, and the security and integrity of our Services.
- At Your Direction or With Your Consent. We use the personal information we collect for additional purposes where you direct us to use it in a certain way or with notice to you and your consent.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose the personal information we collect in accordance with the practices described in this Privacy Notice. The categories of persons to whom we disclose information include:
- Affiliates entities. We disclose personal information to our affiliates and related entities (e.g. relevant shopping centers), including those affiliates and related entities in the Unibail-Rodamco-Westfield family in the US and abroad, including where they act as our service providers or for their own internal purposes.
- Service Providers. We disclose personal information to service providers who provide services on our behalf to help with our business activities, for example:
- processing credit cards and payments,
- hosting, managing and/or servicing our data,
- distributing emails,
- providing CCTV and security services within our Centers,
- managing and operating our loyalty program,
- providing analytics and research, and
- managing brand and product promotions and administering and marketing services and features.
- Vendors for Analytics and Advertising. We disclose personal information to vendors and other third parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your personal information.
- Disclosure for Legal Reasons. We may disclose personal information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with the law, including valid legal requests from private parties, law enforcement, or other government agencies (e.g., subpoena, summons, or court order).
- Change of Ownership. If Westfield is involved in a merger, acquisition, dissolution, or sale of all or a portion of its assets, we reserve the right to transfer your personal information.
- At Your Direction or With Your Consent. We disclose personal information where you direct us to disclose the information. We also disclose personal information with notice to you and your consent.
COOKIES AND TRACKING TECHNOLOGIES
Cookies and Pixels
Cookies are small text files which are placed on your browser when you visit a website. Cookies are widely used to make websites work and for other purposes. Pixels (also known as web beacons) are code embedded in a service that sends information about a browser or device to a server. Pixels provide similar functionality to cookies, but are not always browser-based. When you access a service that contains a pixel, the pixel may permit us or a third party to drop or read cookies on your browser, or collect other information about your browser or device.
We use cookies and pixels for the following purposes:
- Strictly necessary. These cookies and pixels are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies and related pixels, but some parts of the site will not then work.
- Performance. These cookies and pixels allow us to count visits and traffic sources so we can measure and improve the performance of our site and understand analytics. They help us to know which pages are the most and least popular and see how visitors move around the site.
- Functional. These cookies and pixels enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
- Targeting. These cookies and pixels may be set through our site by our advertising partners. They may be used by those third parties to build a profile of your interests and show you relevant adverts on other sites. If you do not allow these cookies and pixels, you will experience less targeted advertising.
- Social media. These cookies and pixels are set by a range of social media services that we have added to the site. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these services.
The cookies management module available on our website allows you to control the use that we and our partners make of the cookies present on the website. You can choose at any time to accept, refuse, or set them all according to our choices by clicking on the appropriate button in the cookies management module, except for cookies strictly necessary for the use of the website that you cannot deactivate.
In addition, most browsers allow you to manage your cookies preferences by changing your browser settings. You may set your browser to:
- Automatically reject or accept all cookies
- Refuse or accept first party cookies and/ or third parties cookies
- Receive a notification before any cookies are saved, giving you the chance to decide whether to accept it.
Your browser's "Help" function should tell you how to do this. Your ability to limit cookies is subject to your browser settings and limitations.
Certain third parties offer opt-out tools relating to cookies and pixels:
- To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.
- The companies we work with to provide you with Interest-based Advertising may be participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To opt out of receiving Interest-based Advertising from the participating companies, please visit https://www.aboutads.info/choices and https://www.networkadvertising.org/choices for website opt outs. Note that opting out through these links only means that you should no longer see interest-based ads from the selected participants on the browser or device from which you opted out, but does not mean that the participants will not process your information for Interest-based Advertising purposes.
Please note that cookie management only applies to our website and not our apps or other parts of the Services. If you use multiple browsers, you will need to instruct each browser separately. If you delete or reset your cookies, you will need to reconfigure your settings.
For app-specific pixels, you can stop all collection of information via an app by uninstalling the app. For Apple iOS, we will only receive access to your device’s Ad ID (known as an IDFA) if you provide consent. You can reset your device’s Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about your device. To opt out of receiving Interest-based Advertising from participating companies with the DAA, please visit https://www.aboutads.info/appchoices.
We are not responsible for the effectiveness of any third party opt outs.
Precise-Location Technologies
With your consent when you launch our app, we may get access to the precise location technologies on your device (such as GPS or Bluetooth) and collect precise-location data from your browser or device. You can stop all collection of precise-location data through an app by uninstalling the app or withdrawing your consent through your device settings.
YOUR RIGHTS AND CHOICES
Region-Specific Rights
Some regions provide additional rights by law. For California-specific terms, please click here.
Account Management
You may access, update, or delete certain personal information that you have provided to us through your account by visiting your account settings. Please note that we will retain personal information in accordance with our data retention practices.
Communications
You may opt out of email marketing communications by clicking "unsubscribe" at the bottom of the email, following instructions provided in the communication, or changing your preferences within your account. If you have opted-in to text messages, to opt-out, text “STOP” in response to any text you receive from us or contact us and specify you want to opt-out of text messages. See Westfield’s SMS Terms and Conditions for details. If you have opted-in to push notifications, you can opt-out through your device settings.
Cookies and Tracking Technologies
For rights and choices relating to cookies and tracking technologies, see the Cookies and Tracking Technologies section above.
CHILDREN
Our Services are not directed to children under the age of 13 and Westfield does not knowingly collect personal information from children under the age of 13. Children under the age of 13 are not permitted to use Wi-Fi networks in Centers. If you have reason to believe that a child under the age of 13 has provided personal information to Westfield, please contact us and we will delete that information from our databases.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Westfield retains the personal information we collect for as long as necessary to provide the products and services you have requested, or for other essential purposes such as complying with legal obligations, general archival purposes, resolving disputes, and enforcing our agreements. If you have any questions about the retention of your personal information, please contact us.
HOW WE PROTECT YOUR PERSONAL INFORMATION
The security of your personal information is important to us. While we follow generally accepted security standards to safeguard the personal information submitted to us, it is not possible to guarantee the security or integrity of personal information. Therefore, we encourage you to take precautions to protect your personal information, including protecting your passwords, using secure networks to access the Internet, and logging out of your account for the Online Services when you are away from your device.
THIRD PARTIES
Westfield's products and services may contain links or references to other websites and services operated or controlled by third parties. For example, we may link to social media networking sites. Links or advertisements do not imply that Westfield endorses or has reviewed such third parties or their privacy practices. For a description of how social networking and other sites handle your personal information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.
In addition, we integrate tracking technologies operated or controlled by third parties into parts of our Service. For details on cookies and tracking technologies, see the Cookies and Tracking Technologies section above. We also work with third parties in our Centers. This Privacy Notice does not apply to those third parties, and we do not control (and are not responsible for) the actions of such third parties. Visit those third parties' websites or contact them directly for details regarding their data practices.
CALIFORNIA PRIVACY RIGHTS
This California Privacy Rights section applies solely to residents of the State of California (“consumers” or “you”). We adopt this notice to comply with California law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CPRA”). Any undefined terms in this section shall have the meaning as defined in either the Privacy Notice or the CPRA. If you are a current or former employee, please contact us for a copy of our employee Privacy Notice.
Notice at Collection
At or before the time of collection of your personal information, you have a right to receive notice of our data practices.
The Personal Information We Collect section above sets out the categories of personal information we have collected and the sources from which we have obtained personal information in the past 12 months.
The How Information Is Used section above sets out how we collect and use this personal information for our business and commercial purposes.
The How We Disclose Your Personal Information section above set out the categories of persons to whom we disclose this personal information.
The How Long We Keep Your Personal Information section above sets out how long this personal information is retained.
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as those terms are defined under the CPRA. A “sale” is broadly defined under the CPRA to include a disclosure for something of value, and a “share” is broadly defined under the CPRA to include a disclosure for cross-context behavioral advertising. We collect, sell, or share the following categories of personal information for commercial purposes: contact identifiers, characteristics or demographics, commercial or transactional information, device identifiers, device information, internet activity, non-precise geolocation data, and inferences drawn from non-sensitive personal information. The categories of third parties to whom we sell or share your personal information include, where applicable, vendors and other third parties involved in cross-context behavioral advertising. For details about your rights regarding sales and shares, please see the “Right to Opt-Out” section below. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents.
Some of the personal information we collect (as detailed Personal Information We Collect section above) may be considered sensitive personal information. For example, precise-location data. To the extent any of the personal information we collect is sensitive personal information, we collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CPRA or without purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.
CPRA Rights
This section describes your CPRA rights and explains how to exercise those rights.
Right to Know, Correct, and Delete
You have the right to request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold or shared;
- The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
- The business or commercial purpose for collecting or selling or sharing the personal information; and
- The specific pieces of personal information we have collected about you.
In addition you have the right to correct or delete the personal information we have collected from you.
To exercise any of these rights, please do one of the following:
- Submit a request to our online webform.
- Call us at our toll free number: (844) 977-CCPA
- Visit any of our California shopping centers’ management offices and submit a request in-person
- If you are a job applicant, you may submit a request via this webform to exercise your rights regarding data collected as part of your application.
We will confirm receipt of the request within 10 business days and provide information on how the business will process the request. We endeavor to respond to verifiable consumer requests within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. You may only make a verifiable consumer request for your personal information twice within a 12-month period. Please note these rights are subject to exceptions.
In order for Westfield to verify your identity, we will request that you provide us with your email address and name. We will then send you a verification email for you to respond to. We may require additional information for verification purposes. Please note that we cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm the personal information that relates to you. We will only use personal information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.
Only you, or a person you authorized in writing may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor.
Right to Opt-Out of Sales and Sharing
To the extent we “sell” or “share” your personal information to third parties as those terms are defined under CCPA, you have a right to opt-out from the sale or sharing, which you can exercise through this Do Not Sell or Share My Personal Information link or the link in the footer of our website. In addition, you may exercise this right by turning on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension.
Note that when you submit an opt-out, your opt-out will only apply to sales and shares of personal information through tracking technologies from the specific browser from which you submitted the opt-out because the connection between your browser identifiers and other personal information we have about you is not known to us.
Authorized Agent
You can designate an authorized agent to submit requests on your behalf. Requests must be submitted through the designated methods listed above. If any authorized agent submits a consumer request on your behalf, we may request additional information as permitted by CPRA to verify the request.
Non-Discrimination
You have the right not to receive discriminatory treatment by us for the exercise of your CPRA rights.
Financial Incentives
We may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent to a separate notice of financial incentives, which you may revoke at any time.
CPRA Request Metrics
For metrics about the requests we received from consumers in 2023, please see below.
Request Type | Total Requests Received | Number Complied With | Number Denied | Median Number of Days to Respond |
---|---|---|---|---|
Know | 1 | 1 | 0 | 1 day |
Correct | NA | NA | NA | NA |
Delete | 36 | 34 | 2 | 2 days |
Opt-Out of Sale or Sharing | NA | NA | NA | NA |
Other California Privacy Rights
Do Not Track Signal
California residents are entitled to know how Westfield responds to "Do Not Track" browser settings. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take actions with respect to “Do Not Track” signals.
Shine the Light
California’s "Shine The Light" law permits California residents to request and obtain from Westfield once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us and specify you are making a “California Shine the Light Request.” Please be aware that not all information shared is covered by the "Shine the Light" requirements and only covered information will be included in our response.
CHANGES TO THIS PRIVACY NOTICE
We may update this Privacy Notice to reflect changes to our personal information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of Westfield products or services after any changes or revisions to this Privacy Notice shall indicate your agreement with the revised terms.
CONTACT US
If you have questions regarding this Privacy Notice, please contact us as follows:
By email: privacy@westfield.com
By mail:
ATTN: Privacy
Westfield, LLC
2049 Century Park East, 42nd Floor
Century City, CA 90067
United States of America
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Last updated September 26, 2024