INTEGRITY POLICY

1. GENERAL

Polygone Gestion Riviera(We or Us) manages your personal data in association with the provision of webpages, loyalty programme and mobile apps (“the Services”) that can be accessed via different media or devices and that are made accessible by Us. We put great importance on the protection of personal data. Here, personal data mean all information that enables a person to be identified, directly or indirectly.

This Integrity Policy (“the Integrity Policy”) is intended to inform you of how We collect and process your personal data that you submit or reveal by visiting or using our Services.

Please read this Integrity Policy carefully. By using our Services and providing Us with your personal data you hereby confirm that you have been notified of our use of your personal data in accordance with this Integrity Policy. If you do not wish your personal data to be used by Us in accordance with this Integrity Policy, please do not disclose your personal data to Us. Please note that in which case, you may not be able to access and/or use Certain functions of the Services or some of the Services.

To access the Services stated, you must be over eighteen (18) years of age.

2. HOW WE COLLECT PERSONAL DATA

We collect your personal data in several different ways:

2.1 Registration information that you submit to Us. Several of our Services require you to register to open an account, and in particular our loyalty programme and Certain functions that are accessible via our mobile apps or websites. If you choose to create an account by completing the registration form, you will be asked to provide contact details and identity data ( your title, first name, last name, date of birth, postcode, email address, mobile number and other relevant information that you give Us).

2.2 Registration information that you allow social networks to send to Us. If you wish to create an account using your social network account (i.e. Facebook, Google+ or Twitter) and have already given your consent for this, your social media will send us your personal data (first name, last name, user name, profile image, email, gender, date of birth, education, school, title), information on your address (Country, Town, address, postcode, phone number), my “likes” (websites, favourite films, favourite music, favourite TV programmes) and friends list..

2.3 Personal information that We collect from the way you use our Services.



(i) When you use your loyalty card, We collect and process:

  • information concerning your shopping profile,
  • frequency and duration of your,
  • data on your purchasing behaviour, and
  • information on your interactions with the loyalty service in social media if you are registered with the loyalty programme via your social network account..

(ii) When you use our mobile apps or website services as a verified user, We collect and process: :

  • personal data that you enter in your profile (i.e. user name or nickname, profile image and password),
  • personal data that are included in the content you enter, upload, contribute to or otherwise make accessible at or via the Services, such as your timeline, your likes, photo library, wish list, contact list,
  • if you connect to the Services Via your social network account, information on your interactions with the Services in social media,
  • information on the frequency of your visits, your visit routes and location within the shopping mall, provided we have your consent. You can read more about such usage in the section “Geolocalisation” below;
  • technology data.

(iii) When you visit our website, We can use cookies and similar technology to collect information on how you use our website. You can read more about this in the section “Cookies” below.

3. HOW WE USE YOUR PERSONAL DATA

We use your personal data that We collect to:

(i) manage and supply the Services we provide to you,

(ii) analyse how you use the Services and, if you have given your consent, to amalgamate your personal data that have been collected from your use of our different Services (i.e. loyalty card, our mobile apps and our website) to gain a better understanding of your expectations and needs and to develop new functions and services,

(iii) provide tailored information and advertising to you. We will only use your personal data to send advertising material if We have been given your consent. When you register for any of our Services that collect personal data you will then have the opportunity to agree to Our using your personal data for the purpose of sending you advertising material,

(iv) measure, test and monitor statistics on our services and how efficient they are, and

(v) assure the technological operation of the Services and to protect your personal data against loss, damage or unauthorised access.

4. HOW WE SHARE AND DISTRIBUTE YOUR PERSONAL DATA

We share the personal data We collect via the Services as follows:

(i) Sharing with a third party

We can come to share your personal data with:

  • companies within the same group as Us in order to develop and test new services and functions,
  • business partners that have stores in our shopping centre to give them the opportunity to deliver advertising that they think would be of interest to you,
  • external service providers that help us provide the Services to you and process your personal data on our behalf. Any such service providers will always be bound by security and confidentiality requirements in line with this Integrity Policy and applicable law,
  • our partners, in unidentified form and in a way that means it is no longer possible to identify you,
  • to comply with legal or regulatory requirements, court rulings, writs or legal processes, if such is necessary to meet applicable regulations.

(ii) Sharing with parties you choose

  • Sharing with other users of the Services. All information or content that you have voluntarily provided via our mobile apps or web services will become available to all users of the Services. You can also share all or some of your content and personal data with selected individual users in your contact list by changing your settings in these Services.
  • Sharing with social networks. If you choose to access the Services via your social network account (i.e. Facebook, Google+ or Twitter) or by clicking on one of the plugin buttons or links in social networks (e.g. a Facebook “Like” button or Google “+” button) that are accessible via the Services, your content and personal data will be shared with that particular social network. You understand that such information can be published on your social network under your account. You understand and accept your social networks processing your personal data, including information that is shared with the social networks via the Services, that will be governed by their respective integrity policies. If you do not want the social network to collect data on you, please read the integrity policy for the relevant social network with respect to this and/or log out from the social network concerned before you use our Services.

5. HOW TO CHANGE YOUR SETTINGS

Via your settings in the Services, you can update your account information, change your settings, subscribe/unsubscribe to communication you receive from Us and set your sharing preferences for the Services, including location-based function services.

Please note that if you wish to restrict or change access to, or share your personal data with social networks, please check your account settings on the social network.

6. HOW WE KEEP YOUR PERSONAL DATA SECURE

Protecting your integrity and your personal data is our priority. If you are given a password as a registered user, you should keep this secret, restrict access to your computer or mobile device and log out after using the Services. Read more about your responsibilities at User terms and conditions.

We take all appropriate security measures to protect your personal data against accidental loss, deletion, abuse, damage and unauthorised or illegal access. However, We kindly advise you to be aware that no information transfer via the internet or storage technology can be guaranteed to be 100 percent secure.

7. HOW YOU CAN ACCESS AND UPDATE YOUR PERSONAL DATA

We take all reasonable measures to ensure you can correct and update your personal data. In accordance with current legislation, you are entitled, on written request to Polygone Gestion Riviera, to access your personal data, request correction of errors in your registered personal data and at any time, withdraw your consent to the use of your personal data. You can do this by contacting Polygone Gestion Riviera, or and attaching a copy of your passport, driving licence or similar ID. We will respond once we have verified your identity..

8. COOKIES

8.1 What are cookies

Cookies are small text files that are placed on your computer or mobile phone when you browse websites . They are used to help websites work more effectively. Cookies help the website recognise your device and remember information about your visit (e.g. language preference, font size and other settings)..

8.2 How We use cookies

We do not use cookies to track you individually or to identify you, but to permit Us to drive the Services you have requested, to simplify how you navigate our website and give you the best surfing experience.

We use the Google Analytics tool to help us measure traffic and user statistics in order to understand how visitors access and use our website. We use the information collected via cookies to help improve our services and to obtain statistics on how our website is used by visitors. Please note that in this context Google collects your personal data via Google Analytics on our website. Read more about how Google uses Google Analytics and how the tool collects and processes data at www.google.com/policies/privacy/partners/.

Information collected via cookies is saved for a maximum of two (2) years.

8.3 How to manage your cookies preferences

In most browsers, you can manage your cookies preferences by editing the settings in your browser. If you agree to Us using cookies but wish to change this at a later date, you can delete cookies that have been stored and edit the browser settings to block additional cookies. For help in doing the above, click “Help” in your browser. Alternatively, click on the links below for instructions on managing your cookie settings in some of the most popular browsers:

If you do not want Google Analytics to be used in your browser, you can also install the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.

You can also go to www.aboutcookies.org for more comprehensive information on how you can do this on several other browsers.

Please note that if you block cookies, you might not be able to access all functions and pages on our website.

9. GEOLOCALISATION

9.1 Basic idea

If you have given your consent, data related to your location within our shopping centre can be collected and processed by Us while you are verified on our mobile apps to measure how often you visit and where you go to in our mall and/or to provide the Meet My Friends Service.

9.2 How We use data on your geolocation

To be located within the mall, you need to activate Bluetooth on your mobile device. However, if you only want to look at the map and where your friends are located via Meet My Friends this is not necessary. Please note that We will not locate you outside our mall and you will not be able to share your location outside the mall via Meet My Friends. Localisation is only activated by the transmitters/receivers that are only installed in the public areas in the mall.

We will collect and process data on your location in the mall provided We have been given your consent to be localised.

9.3 What is the Meet My Friends Service

Meet My Friends enables you to share your location in our mall with users of the Service or just your friends who also use the service. This means that when you visit the mall, you can locate your friends who are also there and meet them in a certain place or propose where to meet.

9.4 How are your geolocalisation data shared in Meet My Friends

To provide the Meet My Friends Service, certain functions can require data on your geolocation being shared with other users of the Services or only your contacts, depending on how you have configured the settings.

If you used your account with Facebook, Google or Twitter to create your account with Us, you will also be able to find your contacts from these social networks who also use Meet My Friends and ask them to share their locations with you.

We can also share information on your geolocation with recipients listed in the section “how we share and distribute your personal data” above.

9.5 How to manage your preferences for geolocalisation

(i) In your mobile settings

The first time you are verified in our mobile app, We will ask you to agree to allowing geolocalisation of your mobile device.

If you agree to geolocalisation of your mobile device, this will be done immediately and on subsequent connections to our mobile app and on subsequent visits to our shopping centre.

You can deactivate geolocalisation of your mobile device at any time via your mobile settings.

(ii) The Meet My Friends Service

The first time you connect to the Meet My Friends Service we ask you to agree to enable geolocalisation of your mobile device and to share your data on geolocalisation.

If you agree to the geolocalisation of your mobile device and to share your data on geolocalisation, this will be effected immediately and on subsequent connections, except if you use the function “visible/not visible” that you can find on the map to temporarily change your settings for geolocalisation. You can deactivate geolocalisation at any time via your profile settings.

Please note that users of Meet My Friends will be visible to other users of Meet My Friends as the default setting. You can configure your settings for geolocalisation in the Service by selecting one of the following alternatives:

  • to be visible to all other users of Meet My Friends, or
  • only visible to your contacts, or
  • to be not visible to any users of Meet My Friends.

Your settings will then be registered and applied each time you use the mobile app. You will also always be able to toggle between “visible/not visible” directly on the map to temporarily change your settings during the current session.

10. LINKS TO OTHER WEBSITES

We can send you suggested links to third party websites or internet sources via the Services or in communication via the Services. We do not check and nor can We accept liability for third party integrity procedures or content. We advise you to carefully read their integrity policy to find out how they collect and process your personal data.

11. UPDATING OUR INTEGRITY POLICY

We can amend or update this integrity policy from time to time. Any changes to this integrity policy will come into force on publication of the updated Integrity Policy via the Services. If We make changes that We consider to be of importance and require your consent by law, We will notify you via the Services and where applicable, request your approval.