Personal Information we collect and use.

This privacy notice describes how Havelock City Mall collects and processes personal information about you, how we use and protect this information, and your rights in relation to this information. This privacy notice applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

This privacy notice is effective from (date). It may vary from time to time so please check it regularly. We will collect personal information about you from a variety of sources, including information we collect from you directly (e.g. when you contact us or sign up for our Newsletter or join our loyalty programme) and information we collect about you from other sources, described below.

Note that we may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of our obligations. We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.

Personal Information we collect and use.

When you visit our website the web server collects some basic information such as your browser type, MAC or IP address, internet service provider’s domain name, which pages you accessed on the site, and when.

Details of cookies that we use on our websites can be found in our Cookies Notice Where you sign up for our newsletter, fill out a feedback form, complete a “contact us” form or enter a competition or promotion we collect personal information such as your email address, name and contact number.

Not all fields are mandatory and provision of the information in the non-mandatory fields is optional, but if you provide less information this may limit your use of our online services.

Where you enter into a competition or promotion we may share your details with the retailers from time to time at the property to which the competition relates. This will be made clear to you at the time you sign up to the competition or promotion.

Where you register online or place an order for a gift card we, or a third party service provider on our behalf, collect your name email address, billing and delivery address, phone number and credit or debit card details. These details may be shared with others, such as those providing merchant acquiring services and card issuers, but only where this is necessary to take a payment. In some circumstances these entities will be data controllers in respect of these details.

When we send emails to you we review whether these have been opened and whether you have clicked on any links within these.

When visiting our Mall, we collect information from your mobile and identify its location. This occurs whether or not you have used the Wi-Fi at the centre or other buildings. To opt out of the collection of your MAC or IP address and location turn off your device’s Wi-Fi and Bluetooth capabilities.

You may be asked to complete a survey or questionnaire either directly at our Mall or via email or SMS and in doing so we may ask for details such as your age and gender. The information captured is for research purposes and so we can understand the type of visitors coming to our Mall and other buildings.

We may occasionally stream videos on social media, such as Facebook live, and take and display photos of members of the public using and enjoying our Mall and other buildings. Where we do so, we inform members of the public of this possibility through the signs placed around the centre or building. In addition, we do not use customer or visitor photos without their explicit permission.

We operate CCTV at our Mall for the purposes of safety, crime prevention and prosecution, insurance, and property management. We may also share our CCTV footage with the companies that rent space in our Mall to assist them with their own security and crime prevention management.

When signing up to an event via our App, you provide us with contact details, including your mobile number, that enables the delivery of your tickets or other method of entry to the event. When purchasing products from our designated vendors available through the App, you will provide your contact and delivery details to us. Payment for the products and/or services are processed directly with the payment provider.

Where enabled and in line with your marketing preferences, your device ID will be collected to provide push notifications for marketing / promotional materials.

Information we collect from others

When utilising our Free Wi-Fi service available at our Mall, you will be asked to connect and accept the Terms of Service as provided by the service operator. We also collect a session identifier that ensures your Wi-Fi connection works throughout the Mall. This is deleted every 24 hours.

In all cases, the Wi-Fi provider makes the provision of your email address and your consent to receive marketing communications a mandatory field and you cannot access the Wi-Fi without providing this.
We will however give you the opportunity to unsubscribe from all marketing communications from us in each email/SMS that we send to you.

If you access the Wi-Fi network in our Mall using your social media, such as Twitter or Facebook, or other online accounts, we are also provided with the data that is shared by your social media/online provider. Information on what personal data is being shared should be available to you from your own social media/online provider.

Through your use of the Wi-Fi networks in the Mall, data is also collected and shared with us which shows how often, how long and your movements within the Mall and your browsing history.

Third party car park operators which are not part of the Mall operate CCTV cameras at the Mall Car Park. There are signs at the locations where this is used showing that it is in operation at that car park. Please see their privacy notices for further information on how they handle your personal information.

Our footfall equipment use detectors to count the volumes of customers using the Mall by entrance and time of day.

We use social media such as Facebook, either ourselves or through third party advertising agencies, to carry out digital advertising on the profiles of users who we think may be interested in our advertising campaigns based on events of ours that they have attended, what marketing communications they have subscribed to and which parts of our website they have visited or users who are in a similar demographic to such persons. Information on how advertising is shown to you should be available from your own social media provider. You have the explicit right to opt-out of these communications.

We use your personal information to:

• provide and personalise our services;

• deal with your enquiries and requests;

• comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;

• contact you with marketing and offers relating to products and services offered by us and/or other members of our group (unless you have opted out of marketing, or we are otherwise prevented by law from doing so);

• personalise the marketing messages and offers we send you to make them more relevant and interesting;

• to contact you for research purposes, where you have consented to us doing so, in order to understand what you think of our sites and how we can improve them;

• maintain the quality of our websites and to analyse the use of our websites in order to help guide improvements;

• to better design and optimise our properties to improve the experience of our consumers;

• allow you to pay for parking services;

• provide you with access passes to our buildings where this technology is enabled;

• drive our insights, research and data analytics programme.

This is used for research, analysis, testing, monitoring, risk management and administrative purposes and to develop our business, inform business decision making and support the purposes identified elsewhere in this section by collecting statistics, traffic patterns, information on the movement around the Mall, demographics, customer satisfaction, geographic catchment, shopper analysis, retail mix, centre and building performance including footfall and identifying shopping trends; and we contract with third parties which in certain circumstances will be controllers of your personal data and responsible for managing it properly and in others will be processors who deal with your personal data in accordance with our instructions.

Whether a third party supplier (who is not us) is a processor or controller of your personal data depends on the facts and where we appoint a third party processor of your personal data we will put a framework around what we expect them to do with it and how they manage it. We have identified certain cases where third parties are controllers of your personal data.

For investigating and protecting the integrity and security of the Wi-Fi Service. Where required by applicable law, we may disclose any information as necessary to: (a) satisfy any law, regulation, court order, legal process or lawful governmental or police request; (b) if the company believes that doing so may protect your safety or the safety of others; (c) to operate the service properly; (d) to enforce the Terms of Service; and/or (e) to protect company legal rights.

To send operational push notifications to your device when using the APP detailing instructions on how to unsubscribe from marketing or promotional material, services updates to the App or other service based communications as necessary.

To send marketing / promotional push notifications to your device when using the App where you have provided your consent to receive such notifications.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

Contract - to fulfil our contractual obligations to you, for example to fulfil the terms of a competition or promotion that you have entered or to provide you with information you have requested;

Legal obligation - to comply with our legal obligations to you, for example health and safety obligations while you are on our premises, or to a third party (e.g. the police);

Legitimate Interest -For example to understand how you use our services and our centres and other buildings and to enable us to derive knowledge from that which in turn enables us to develop new services and further tailor our centres and other buildings to appeal to a wide variety of persons.

When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms; and

Consent - We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, cookies or when we process special category data). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.

Your Rights
You have certain rights regarding your personal information, subject to local law. Your rights under the Sri Lanka Data Privacy Act of 2022 which are:

• To access your personal information

• to rectify the information we hold about you

• to erase your personal information

• to restrict our use of your personal information

• to object to our use of your personal information

• to receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)

• to lodge a complaint with the data protection authority.

In order to exercise those rights, you need to submit a Data Subject Rights request (DSR) To make this straight forward for you and to help us respond to that request quickly and accurately, please use the following link:
Submit my Data Subject Rights Request

Automated decisions
We make automated decisions about you based on your personal information in the following circumstances:

• to select personalized offers, discounts or recommendations to send you based on your browsing history; and

• to personalise the marketing messages we send you to make them more relevant and interesting.

• These types of decisions will not have legal or similar effects for you, but you can still contact us for further information.

Sharing your data with third parties
We may share your personal information with third parties under the following circumstances:

Service providers and business partners. We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfil orders, optimize our services, send newsletters and marketing emails, support email and messaging services and analyse information.

We work closely with other businesses and companies that fall under Law enforcement agency, court, regulator, government authority, insurer or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party or to put in place insurance for the Mall.

We may share non-personally identifiable information with third parties such as partners, customers, tenants and suppliers, for example to show trends on the use of our centres and other buildings.

How we store keep your information secure
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to

Maintain business records for analysis and/or audit purposes or risk management purposes; Comply with our business record retention requirements;
The Havelock City Mall is the controller responsible for the personal information we collect and process (save in circumstances where we specify otherwise).

Contact us
If you have questions or concerns regarding the way in which your personal information has been used, or would like to contact our Data Protection Officer, please contact data.privacy@havelockcitymall.lk.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of Sri Lanka using their website……………………

Defend or bring any existing or potential legal claims; and deal with any complaints regarding the services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.