The Bicester Collection

Website, App and Cookies Privacy Notice

Commitment to Privacy

We are committed to protecting your privacy, including when you use our Websites and our Village App. You should read this Privacy Notice fully to understand the basis upon which we process your personal data, how we use it and to whom it will be disclosed.

Who We Are and How to Contact Us

Please click here to see who we are. The entities listed are the owners and operators of retail outlet villages (Villages) within The Bicester Collection brand. References in this Notice to “we”, “us” or “our” are to the entities listed. Each of the listed entities are joint data controllers and are committed to protecting your privacy.

If you have any questions about how we use your personal data or to exercise your rights set out in this Notice, please contact us at Notices@ValueRetail.com

Information We Collect About You

When you use our Websites or App, there are a number of purposes for which you can choose to share your personal data with us, or for which we may collect your personal data. Further information regarding those purposes including how and why we collect, manage, store, share and use your personal data is available below.

What this Privacy Notice does not apply

The Privacy Notice does not apply to other third-party websites that you may reach through links on the Website or App. If you access other third-party sites using the links provided, the operators of these sites may collect your personal data and use it for their own purposes or in accordance with any privacy policy they may have, which will differ from our privacy notices.

1. Websites

The Bicester Collection and Village websites offer a number of bookable services, such as Shopping Packages, Guest Services, Gift Card, Travel Industry Registration and Event bookings. We will process your personal data to facilitate these services.

What personal data we collect about you Typically, we request your name, email, address, car registration, and phone number. In some circumstances our partners process your network traffic data including IP addresses. When you book a chargeable Guest Service you will be required to provide a billing address. When purchasing a Gift Card, you can provide a recipients’ name, address and email, where you choose for them to receive the Gift Card and are authorised to process their information.

We also process Cookies when you browse our Village websites. For more information, please read Cookies below.

We use Transive to support booking information for chargeable Guest Services and payment information is processed securely by third party payment operators.

For Travel Industry Registration and Event bookings, we request the lead bookers name, business contact information and the group’s main country of residence.

How we use your personal data We process the personal data you have provided in order to identify a booker or offer a personalised and tailored service. This may include translation services.

We may combine information regarding booked services with a Membership or Private Client account where you have one, which may include spend and visit tracking. We will also track Gift Card spend. For more information, please read the relevant Village Privacy Notice Notice where you are a Member or Private Client, available on the Village website.

When registering as a Travel Industry or booking an Event, we will use the information provided to generate a business record in our database. We do this so that we may record details of visits, services, promotions and numbers of visitors per booking.

How long we keep your personal data for

Where you have booked a chargeable Guest Service or purchased a Gift Card, we will process the data in line with tax laws in the country of purchase or, if longer, the duration of the Gift Card validity and subsequent service period.
Where you have registered as a Travel Industry or booked an Event, we will process the data for as long as the business record remains active.
Where your booking is linked to a Membership or Private Client account, we will process the data for as long as the account remains active.
Your network traffic data is processed by the content delivery network for no more than 180 days.

Who we share your personal data with We share your personal data with our Villages, so they may support fulfilment of your booking and your visit to the Village. We may also provide your personal data to our suppliers and processors who perform the services you have booked, such as Chauffeur, Shopping Express and Gift Card. They may act as a data controller in relation to the booking information.

We may share your personal data with providers of our website or internet infrastructure, such as content delivery networks, who may act as data controllers in respect of the technical data they process.

We may transfer your personal data to service providers outside of the European Economic Area where local laws do not contain equivalent legal rights. Where these transfers occur we apply appropriate safeguards to ensure that the standards described in this Notice remain in place.

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 Who We Are details here.

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. 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. While we strive to protect your personal information, we cannot guarantee the security of information that you submit online, and you do so at your own risk. We urge you to keep any usernames, passwords or any other log-in details in a safe place.

The legal basis for us using your personal data In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of sending you marketing communications.

Where you have booked a chargeable service, we process your personal data to fulfil a contractual arrangement in providing that service. Please note that chargeable Guest Services are subject to Terms and Conditions which are available to view at the time of booking.

It is in our legitimate interest to collect and use the personal data referred to above so that we can:

provide you with a service that is enjoyable including personalising your visit and link booked services, spend and visit information to your Membership or Private Client account where you have one;
better understand our customer base so that we can improve our marketing activities (which could also benefit you);
to maintain and improve our services, and
to notify you about changes to our services.

2. Village App

When you use our Village App (“App”) on your mobile device, we will collect your personal data in connection with providing information and services to you through the App.

Where you link your Membership account to our App, we may share your personal information with other data controllers as part of your Membership. See our Membership Privacy Notice for more information.

What personal data we collect about you

If you have given us your consent to do so, this will include collecting data about the frequency of your visits to Village.

we process data when you make use of the APP virtual concierge (a chatbot), which responds to simple queries directly and forwards more complex queries you submit for our customer services team to respond;
we gather information about your use of the App including the type of personal device, your location data (where we have consent from you to do so), so that you can use the in-Village map;
we may send you marketing communications when you are in the proximity of a Village (if you have given us your consent to do so);
we may combine this personal data with other personal data we hold about you including through the different channels you use to interact with us (for example, our website or our App), in particular, where you link your Membership account to our App; and
if you download the App on a device running an Android operating system, the App will also ask for consent to access to your photographs, call records and other media stored on your device. This is solely to enable certain features of the App to function (such as allowing you to receive calls whilst using the App and by caching images used in the App to ensure the App runs smoothly), and your photographs, call records and other media will not leave your device and are not otherwise used by us.

How we use your personal data We are processing your personal data to be able to provide you with access to our App.

We use your personal data to:

• provide you with our virtual concierge, a chatbot, to answer your queries relating to a Village and our services (in accordance with our Village Privacy Notice).

• provide you with information about a Village that you are in or near (e.g. showing you where you are on our in-Village map and, where we have permission to do so, tell you about special offers)

• if you have linked your Membership account to our App, provide you special offers about brands sold in a Village and to offer you treats and rewards (as set out in our Membership Privacy Notice), as well as to allow you to manage your Membership account and your personal code, which can be used in village stores for offers and promotions.

• manage and improve our App, including by collecting information about how you use and interact with the App in order to develop improvements;

• better understand your shopping behaviour in order to develop and improve our products and services so as to provide you with an enhanced shopping experience through your use of the personal code in our villages;

• analyse the effectiveness of our marketing and to help us provide more relevant offers, advice and information to you and our other guests;

• build up a clearer picture of our App users both as a group and as individuals and thereby provide you with a seamless, relevant and consistent service;

• ensure that the information we hold is kept accurate and up to date;

• to contact you, (where we have your consent) from time to time, for the purpose of conducting surveys or focus groups; and

• notify you about changes to our services

How long we keep your personal data for
We will process the data as long as you continue to have the App downloaded.

Who we share your personal data with
If you’ve linked your Membership account to the App, then we share your personal data with other Villages as set out in the Membership Privacy Notice.

We may also provide your personal data to our suppliers and processors who perform certain business services for us, such as host and maintain our App and where you have given your consent for us to do so, use your location to deliver specific electronic messaging to you.

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 at Who We Are.

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. 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.

While we strive to protect your personal information, we cannot guarantee the security of information that you submit online, and you do so at your own risk. We urge you to keep any usernames, passwords or any other log-in details in a safe place.

The legal basis for using your data
In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of sending you marketing communications; and using your location to deliver specific messaging and content to you (including push notifications).

In most cases, it is in our legitimate interest to collect and use the personal data referred to above so that we can:

a. provide you with a service that is as useful, 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 to your specific preferences, and contacting you using your preferred method of communication;

b. better understand our customer base so that we can improve our services and marketing activities (which could also benefit you);

c. to maintain and improve our App.

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 where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not use your personal data unless there is another legal basis for us to do so (either that it is necessary for us to perform our contract with you, or on the basis of your consent). For example, we believe that collecting your location data may be intrusive, and so we will only do so with your consent.

The legal basis for using your data
Our App works best when we are free to communicate with you to share details of treats, rewards and other offers you might be interested in.

If you no longer wish to receive such or certain communications, you can let us know by using the details at [Who We Are](https://www.thebicestercollection.com/en/legal/who-we-are "Who We Are").

If you want to turn off push communications, you can do so through your mobile device configuration. Please note that opting out from push communications will not by itself cancel any subscription to our newsletters, emails or any other communications methods you may have accepted at any time.

If you no longer wish to use our App, you may uninstall it at any time. You may also ask that we stop using your personal data, including information that we may retain after you have uninstalled the App (see Your Rights below).

3. Membership

If you sign up as a Member, we will collect your personal data in connection with that purpose and will handle your personal data in accordance with our Membership Privacy Notice.

4. Jobs' Portal

If you use our online jobs portal to search or apply for jobs in the Village boutiques, we will collect your personal data in connection with that purpose and will handle your personal data in accordance with our Careers Privacy Notice.

5. In the Village

We may also collect your personal data when you visit our Villages and will handle your personal data in accordance with our Village Privacy Notice, available on the website of the Village you have visited.

6. Cookies

What are Cookies? Cookies are small files that are stored on your device when you visit a website. Devices include your computer, mobile or tablet.

Website cookies do lots of different jobs, such as letting you navigate between pages efficiently and enhancing the experience when visiting a website, for example they can remember your preferences.

Cookies can't look into your device or read any personal information and they can't carry viruses or install anything harmful on your device. Cookies do not contain confidential information such as your home address, telephone number or credit card details.

For more information about Cookies, please visit https://www.allaboutcookies.org/

How do we use Cookies When you browse our Websites or use our Village App, we use Cookies to enhance and personalise your experience, including to provide you with personalised content, deliver targeted advertising and to analyse visitors to our website. We do not exchange Cookies with any third-party websites.

We use three types of cookies on our websites and our app:

Functional Cookies enable the website to provide enhanced functionality and personalisation (such as showing you products that you may be interested in).
Targeting Cookies are used by our advertising partners to build a profile of your interests and show you relevant adverts on other sites by uniquely identifying your browser and internet device.
Performance Cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our site.

To find out more about these Cookies, please click here./

The legal basis for us using your personal data Where we have a justifiable reason: We use Strictly Necessary Cookies in order for our website to operate and to provide services you have requested. These Cookies will always be deployed to ensure our website operates as intended.

Where we have your consent: We use cookies placed by our partners to help us improve your overall web browsing, such as functional, targeting and performance Cookies. To find out further information about the partners we use, the information they collect through the use of cookies, who they share the data with and including how long the cookie remains on your device please, and to manage your Cookie preferences, click here.

All popular browsers (e.g. Chrome, Internet Explorer, Edge and Safari) allow you to amend your Cookie settings so that Cookies are no longer enabled across all websites that you visit:

• Turn off cookies in Internet Explorer

• Turn off cookies in Chrome

• Turn off cookies in Safari

• Turn off cookies in FireFox

• Turn off cookies in Safari iOS

Changes to our use of Cookies Our Cookie tool monitors changes to partner Cookies and provides information on those partners.

Any changes to our use of cookies for our websites will be posted here and, if necessary, signposted from our web pages highlighting any changes.

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’re providing you with the information in this Notice.

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

If you ask us, we’ll confirm whether we’re 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’re 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’ll tell you before we lift any restriction 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’ve 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

- 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’s 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.

Country, Supervisory and Website

The UK
The Information Commissioners’ Office (ICO) www.ico.org.uk

Ireland
The Data Protection Commissioner (DPC) https://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: Bavaria
Bayerisches Landesamt für Datenschutzaufsicht (BayLDA) www.lda.bayern.de

Germany: Baden-Württemberg
Der Landesbeauftragte für den Datenschutz Baden-Württemberg www.baden-wuerttemberg.datenschutz.de