Privacy Policy

Privacy Policy

 

 

This Privacy Policy (“Policy”) was last updated on October 31, 2017. 

 

PLEASE READ THIS POLICY CAREFULLY.  This Policy sets forth our general rules and policies regarding the collection, use and disclosure of information arising out of your use (“Use”) of our websites, including but not limited to Starwood owned or operated websites (“Sites”), wireless internet access hotspots, and other online technology, products, services and programs (collectively “Services”) owned by Starwood Retail Property Management, LLC, Starwood Retail Partners, LLC, SRP Property Management, LLC, and its subsidiaries, affiliates and related entities (“Starwood”, “we”, “us”, and “our”).  By accessing and using the Services, you agree to be bound by the terms and conditions of this Privacy Policy. 

 

Starwood is committed to protecting and respecting your privacy.  Please read this Policy carefully to understand how we will treat your information and how you can control your preferences.  Remember that your Use of the Services is at all times subject to this Policy and Starwood’s Terms of Use http://www.starwoodretail.com/terms, which incorporate this Policy. 

 

If you choose to access any third party content (including other websites, resources or services) from using our Services, we recommend you review the privacy policies of those third party companies, as our Policy will not apply.  Starwood does not accept any responsibility or liability for any information that may be collected by such third parties. 

 

Information We May Collect About Users:

 

Starwood has the ability to collect two types of information from Users who utilize our Services:

 

  1. Aggregated Information – We may record certain non-personally identifiable information that does not personally identify you, consisting of the media access control address (“MAC Address”), browser type, device type, operating system, Internet protocol (IP) address, Internet service provider (ISP), referring/exit pages, date/time stamp, clickstream data, geolocation, the number of Users, and information about traffic patterns, such as the webpages accessed by Users and the time spent by Users utilizing our Services (“Aggregated Information”). 

 

  1. Personal Information – We may record certain personally identifiable information, as defined by applicable laws, including any information that may be used to specifically identify or contact you, such as your name, postal or email address, phone number, and other information which may identify you (“Personal Information”).

 

How Your Information May Be Collected and Used

 

Aggregated Information is collected through various methods when you Use our Services, for example:   

 

  • Cookies: A cookie is a piece of information that the computer or device hosting our Services gives to your browser when you access the Services. Cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Services may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Services. In all cases in which we use cookies, we will not collect Personal Information except with your permission.  We may provide our analysis and certain Aggregated Information to third parties such as our affiliates, retailers or trusted vendors who provide services to Starwood. Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent. If you disable your cookies setting or refuse to accept a cookie, some parts of the Starwood website may not function properly. Starwood cannot control the use of cookies by third-parties.
  • Beacons:  A web beacon is an electronic image placed in the code of a web page. We use web beacons to monitor the traffic patterns of Users from one page to another and to improve site performance.
  • IP Addresses:  An IP address is a number that is automatically assigned to your computer by your Internet provider whenever you're surfing the Web. We collect IP addresses for the purposes of system administration, to provide aggregate data about the volume of use of, and number of Users on, the Starwood website and to audit usage.  We do not link IP addresses to anything personally identifiable, so although your session will be logged, you will remain anonymous to us.  We may use your IP address to help diagnose problems with our server, to administer our Sites and to improve the Services we offer to you.  We may also use your IP address to gather broad demographic information, or to determine which domain you are coming from to more accurately gauge our Users’ demographics.
  • URLs: URLs are Uniform Resource Locators or addresses of websites on the world wide web.  An example of a URL is http://www.starwoodretail.com.   Like IP addresses, we use URLs to analyze trends, administer the Site and Services, track Users’ activity, and gather demographic information.

    Location Information:  If you Use certain features of our Services, including but not limited to Use of our Sites and Wi-Fi, we, or a third party we hire on our behalf, may collect your location information (such as your ZIP Code, city, state, or latitude/longitude coordinates), that is provided by your Internet service provider (ISP) or mobile device, in order to provide you with specific services, such as locating a nearby mall, or to communicate with your device and identify its location.  For example, we may use Bluetooth (BLE) beacons and Wi-Fi technologies within our malls that may communicate with your device and identify its location if your device is Bluetooth and/or Wi-Fi enabled and you have these radio(s) on.  We may use the location information gathered to send you special deals and discounts via your mobile device based on your location (for more information, see the “Mobile Devices” section of this Policy below).  We may also generate reports to determine foot traffic at our malls, which we may share with retailers and third parties to improve the consumer experience at our malls. We may also use this information to send you news about the mall, such as promotions from mall retailers, and to provide advertisements about goods and services that may be of interest to you.

     

  • Video and Camera Surveillance:Starwood’s locations and parking lots may be under video and camera surveillance. When entering Starwood’s locations and parking lots, your Personal Information and images may be collected by Starwood or by third parties on its behalf, and Starwood may collect your Personal Information and images from third parties (for example, the police, retailers or third party service providers). This information may be used by us in connection with the management and security of our locations, or for measuring and analyzing shopping behavior in order to improve Services. This information may be provided to law enforcement, government bodies, subcontractors, insurers, retailers and service providers for those purposes.

     

  • Social Media Widgets: Our Sites and Services may also include social media widgets, which allow you to visit, share and interact with Starwood on social media platforms.  These features may collect your IP address, which pages you are visiting, and may set a cookie to enable features to function properly. Your interactions with these features are governed by the privacy policy of the company providing the feature.

     

    Personal Information may also be collected when you Use our Services. Whether or not you provide this information is your choice; however, in many instances this type of information is required for our Services to function properly:

     

  • Gift Cards:You must provide us with certain Personal Information in order to Use Starwood American Express Gift Cards, and we may use this information to activate your gift card, and for fraud detection purposes.  By using Starwood American Express Gift Cards, you also agree to the privacy policy of our business partner who assists with providing you with these Services, available at https://www.americanexpress.com/us/content/legal-disclosures/privacy-center.html?inav=footer_privacy_statement.

     

  • Email Program:  When you Use our Services and provide us with your email address, you agree to receive our email newsletters and other Starwood communications via email.  You may opt-out of such newsletters and communications by following the instructions at the bottom of the email.

     

  • Mobile Devices:When you visit a Starwood location, we and our third party providers may automatically collect certain information such as, without limitation, the operating system of your mobile device (for more information, see the “Location Information” section of this Policy above). Personal Information will be collected only when you voluntarily provide us that information via your mobile device in order to Use certain Services. This information will be used to measure and analyze shopping behavior in order to improve our malls and otherwise in connection with our business.  When you Use our Services and provide us with your mobile number, you agree to receive text message communications from us.  However, you may choose to opt-out of collection of mobile device data by clicking here: http://www.smartstoreprivacy.org/, or by texting STOP to 55800.  By using Starwood Services via mobile device or text message, you also agree to our Administrator’s (PlaceWise Media) privacy policy, available here: https://www.placewise.com/privacy-policy.

     

  • User Accounts: When you sign up to Use certain Services, our registration process asks you to provide us with a limited amount of Personal Information to create an account, which may include: name, address, phone number, e-mail address, date of birth, billing information (credit card number, shipping address).

  • Promotions: When you interact with us directly by telephone, mail, email or other entry methods to participate in campaigns, promotions, contests or sweepstakes (collectively, “Starwood Promotions”).  Starwood Promotions that involve mobile device or text message methods of entry are administered by a third party (“Administrator”) (for more information, see the “Mobile Devices” section of this Policy above).
  • Rewards Program:  If you sign up for our rewards program, Oh So Simple Rewards, you will provide us with some information to create your account, which may include your name, email address, mobile number, zip code, birth date, gender, anniversary date and credit or debit card information.  By providing us with this information, we can track the transactions you make, keep track of your rewards progress, and enable you to earn cash back through our partner, Spring.  By participating in Oh So Simple Rewards, you must also agree to Spring’s privacy policy, available here:  https://www.springrewards.com/pages/privacypolicy.html. You can modify the information you have provided us in connection with Oh So Simple Rewards by signing in to your Spring account and clicking “Profile.”  You can delete your account by clicking “Delete Spring Marketplace Account” at the bottom of the “Profile” page.  You will then receive a message containing a link with instructions to opt-out on our Site.

 

  • Social Media:  We may integrate certain parts of our Sites and Services with social networking platforms such as Facebook and Twitter, which allow you to post to our community forms. By directly integrating these platforms, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant social networking platform.  When you do so, we will collect relevant information necessary to enable our Services to access that social networking platform and your Personal Information contained within it.  As part of such integration, the social networking platform will provide us with access to certain information that you have provided to it, and we will use, store and disclose such information in accordance with this Policy. However, please remember that the manner in which social networking platforms use, store and disclose your information is governed by the policies of such third parties, and Starwood shall have no liability or responsibility for the privacy practices or other actions of any social networking platforms that you enable within our Services. You may also have the option of posting your Services activities to social networking platforms when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to Use this feature, your friends, followers and subscribers on any social networking platforms you have enabled will be able to view such activity. 

     

  • Business Partners:  We may work with other third parties (including contractors, consultants, vendors, service providers and business partners) who operate their own websites, mobile applications or services to provide Users with more options to utilize Starwood’s Services.  These third party business partners may have access to the Personal Information you submit to us, but only for the purpose of performing their contracted services with Starwood and to provide you with Services.  Starwood may also engage third parties to fulfill your requests, such as to process your request for a gift card. The third party will be provided Personal Information necessary to fulfill that request.

     

  • Wi-Fi: Our Services, including Wi-Fi at all Starwood locations, are provided either directly by us or by one of our third party Wi-Fi partners. You may logon and Use the Wi-Fi by providing your name, email address or phone number. We will use this information to keep you informed about upcoming Starwood events, activities, promotions, including sponsor and retailer promotion, to send you emails or text messages. In order to provide Wi-Fi to you, certain data may be collected from any Wi-Fi enabled device that is turned on, with its Wi-Fi radio set to look for available wireless networks that comes into contact with the Starwood Wi-Fi network (regardless whether or not the device successfully connects and/or authenticates onto the network). Such data that Starwood and its third party providers may collect will include: MAC address, date/time stamp, wireless access point / VLAN location (which can be associated with an actual physical location), device operating system, radio channel, radio signal strength and radio band. This data may be retained indefinitely by Starwood and its third party providers. We may also use information gathered from your Use of Wi-Fi to generate reports, such as foot traffic at our malls, which we may share with retailers and third parties to improve the consumer experience at our malls (for more information, see the “Location Information” section of this Policy above).  We may also use this information to send you news about the mall, such as promotions from retailers, and to provide advertisements about goods and services that may be of interest to you.
  • Legal Requirements:  We will not provide any Personal Information to any other persons or entities, except if we are required to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or for other reasons required by law. You hereby authorize us to disclose any such information in those circumstances.

 

Advertising

 

We may employ third-party advertising companies, advertising networks, ad-tech partners and others to engage in advertising on our behalf and on behalf of mall retailers, including contextual advertising and interest-based advertising, and to re-target you later on with other third party websites. These companies may use cookies and Aggregated Information about your visits and usage of the Services and other websites in order to provide advertisements about goods and services from us or our mall retailers that may be of interest to you.  Advertising agencies are instructed to follow industry guidelines with regard to interest-based advertising, and should have a mechanism to opt-out. If you would like more information about this practice and how to opt-out of receiving communications from these third-party advertising companies, please visit this link http://www.networkadvertising.org/choices/.  Some mall retailers may also employ their own advertising campaigns and adhere to differing practices. You may learn about a specific retailer's practices by reviewing that retailer's privacy policy.

 

Surveys

 

From time to time, the Sites may request information from you via survey. Participation in these surveys is completely voluntary and you have a choice whether or not to disclose the requested information, which may include personal information.  The purpose of these surveys is to send the User information about Starwood and its activities. Users may opt-out of receiving future mailings as detailed in the choice/opt-out section below. Other data collected by online surveys is used to educate Starwood about the interests and concerns of its supporters and general site visitors.

 

Security of Your Information

 

The security of your Personal Information is very important to us, and Starwood takes reasonable steps to protect the information you provide us with from loss, misuse, unauthorized access, disclosure, alteration, or destruction. We follow generally accepted industry standards to safeguard your information, however, no data or email transmission is ever fully secure or error free.  Therefore, please take special care in deciding what information to send us. We have safeguards in place to protect your information, and we have taken the following security measures:

 

  • Transport Layer Security (TLS) - We use TLS encryption when transmitting certain kinds of information, such as financial services information or payment information.  An icon resembling a padlock is displayed in most browsers during TLS sessions.

     

  • Secure Storage - We deploy industry standard physical, technical, and procedural safeguards that comply with relevant regulations to protect your personal information.

     

  • Vendors and Partners - To protect the security and privacy of your information, we may provide information to partners and vendors who work on our behalf or with us under confidentiality agreements. These companies do not have any independent right to use or share this information without your consent.

     

  • Access to Information - We limit access to your Personal Information to those employees who reasonably need access to such information in order to provide you with Services and process your information appropriately. 

 

It is not possible, however, to guarantee the security or integrity of such information, particularly when transmitted through the Internet. Starwood may use a third party service provider or providers to process credit card transactions and fulfill online gift card orders, which service provider(s) may share information and credit card numbers with a ticket agent, a credit card processing company, a fraud detection service, an issuing bank, the card network issuer, a shipping/fulfillment company and/or other parties in order to complete an order.  Starwood does not have control over the information processed by such third parties.

 

We urge you to take every precaution to protect your Personal Information when you are on the Internet. If a password is used to help protect that information, it is your responsibility to keep your password confidential. If you are sharing a computer with anyone, we suggest you log out before leaving a site or service in order to protect subsequent Users from gaining access to your information and decline to have your Internet browser remember your password.

 

If you have questions or concerns about the privacy or security of your Personal Information, please contact us at the address listed below. 

 

Collection and Storage of Information for Children Under 13:


Starwood is committed to complying fully with the Children's Online Privacy Protection Act of 1998 (“COPPA”). We may collect and store personal information about children under 13 if it is submitted to us by a parent or legal guardian, with their verifiable consent, in adherence with COPPA. Starwood only knowingly collects information about children under 13 in connection with parents or legal guardians who choose to submit such information to us in connection with registration for the Starwood MallStars Kids Club program (“MallStars”).  Please refer to the MallStars Kids Club Terms, available at: https://starwoodretail.com/mallstars.

 

To be eligible for MallStars, children must have their parent or legal guardian present at one of our participating properties to apply in person for MallStars.  After a parent or legal guardian gives their permission and registers their child for Mallstars, we may collect and store the personal information provided by the parent or legal guardian about his or her child (name and date of birth) and about the parent or legal guardian (name, preferred mailing address, and email address).

 

The information that a parent or legal guardian provides us may be used to: (a) allow the child to participate in certain MallStars activities at our shopping malls (for example, arts and craft activities or holiday meet and greet events); and (b) allow us to send the parent or legal guardian promotional materials, including information about MallStars, special offers, and other events of interest.  We may also use the information for our internal marketing and demographic studies, so that we can constantly improve the products and services we provide our visitors and to better meet their needs.

 

Please note that we will not condition a child's participation in a MallStars activity on the child's disclosure of more personal information than is reasonably necessary to participate in the activity.

 

A parent or legal guardian who has already given us permission to collect and use his or her child's personal information can, at any time, do the following: review, correct, or have deleted the child's personal information; and/or, discontinue further collection and use of the child's personal information. To do so, please contact us at the address below and be sure to include your child's name, your name and email address.

 

We urge children to check with their parent or legal guardian before entering any information on any of our Sites, and we urge parents and legal guardians to discuss with their children the implications regarding the online release of their personal information to anyone they don't know.

 

Starwood currently does not disclose to third parties personally identifiable information that parents or legal guardians provide us about their children, except from time to time, we may transfer, disclose or share such information with third parties who may be engaged by us only as necessary to handle and deliver certain online activities (e.g. conducting contests and sweepstakes). Such third parties have access to personal information needed to perform their functions, but may not use it for other purposes. We may also disclose personally identifiable information to third parties in order to comply with law or requests by law enforcement agencies, to enforce our Terms and Conditions or to protect the rights, property or safety of the Sites, Users of the Sites and Services, and others, or as part of a sale or other disposition of our assets (including our customer records).  Parents and legal guardians may consent to Starwood’s collection and internal use of their child’s personal information while refusing to allow Starwood to disclose the personal information of their child to third parties. 

 

Starwood only retains personal information collected from parents or legal guardians about their children under the age of 13 for as long as is necessary to fulfil the purpose for which it was collected.  Afterward, we will delete the information using reasonable measures to protect against its unauthorized access or use.

 

California Residents

 

California Civil Code Section 1798.83 permits Users that are residents of California to request and obtain from us once a year, free of charge, a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law for such third parties’ direct marketing purposes in the preceding calendar year.  If you are a California resident and would like to make such a request, please email or write us at the contact information noted below.

 

The California Online Privacy Protection Act (“CalOPPA”) requires Starwood to disclose how it responds to Do Not Track signals set in a User’s browser.  Starwood supports Do No Track browser settings.  If you enable Do Not Track privacy settings in the browser you are using, we will use commercially reasonable efforts to stop collecting the information that allows us to tailor the Sites to User preferences based on Users recent Use of the Sites or Services.  Consequently, we will not store or use information about any other websites you visit, other than our Sites.

 

Changes to this Privacy Policy

 

Starwood reserves the right to update or modify this Policy at any time and without prior notice, as our Services and our business may change from time to time.  This Policy was last updated on the date indicated above, and we will notify you if we make any material changes to this Policy by posting a prominent notice on our Sites or by sending you an email at your last known email address.  In the event that Starwood materially modifies or amends any of the provisions regarding the manner in which it collects, uses or discloses a child’s personal information, Starwood will provide notice to the parent of such child utilizing the contact information for the parent that Starwood has in its records.  Each parent or legal guardian should ensure that Starwood has such parent’s or guardian’s current email address.  Starwood will apply material changes to this Privacy Policy in conformance with COPPA and other applicable law, including any provisions thereof requiring consent from a parent or guardian.

Correcting/Updating/Accessing/Removing Personal Information:


If a User's personal information changes, or if a User no longer desires our Services and/or wishes to stop receiving future communications from us, you may correct, update or remove that User's personal information previously provided by contacting Customer Support through:

 

Sending an email to: info@starwoodretail.com

 

Sending mail to the following postal address:
           

Starwood Retail Partners

1 East Wacker, Suite 3600,

Chicago, Illinois 60601

 

Calling Starwood’s telephone number:  312-242-3200.

 

In certain circumstances, we may not be able to completely remove your information from our systems.  For example, we may retain Personal Information for legitimate business purposes, our customer requirements, or if required by law. All Personal Information that we keep will continue to be subject to the terms of the Privacy Policy to which you have previously agreed.

 

If you have any questions about this Policy, the practices of our Sites, or your dealings with the Services, please contact us at the contact information provided above.