The centre:mk is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
Data protection law says that the personal information we hold about you must be:
We have set out below the main ways in which we collect and use your personal information.
Where you provide information to a store within the centre:mk, we will not have access to that information.
Where third parties operate events at the centre:mk such as the Christmas grotto or the summer beach attraction, they will (unless we tell you otherwise) control how they use your information, and have direct responsibilities for you in terms of how they use your personal information. They will have their own privacy notices giving you information about how they use your personal information.
This notice is separated into the following sections for ease of use. If you have any questions about this notice or how we collect and use personal information about you please Contact Us.
1.1 The centre:mk is owned by Hermes CMK Nominees No.1 Limited and Hermes CMK Nominees No.2 Limited (jointly referred to in this notice as “CMK” / “we” / “us”) and is managed by CBRE Limited.
1.2 Hermes CMK Nominees No.1 Limited (company number 05583763) and Hermes CMK Nominees No.2 Limited (company number 05583770) both have their registered office at
Sixth Floor, 150 Cheapside, London, EC2V 6ET.
1.3 CMK acts as a data controller in relation to the personal information which is used by them in running the centre:mk.
2 CONTACT US
2.1 If you have any questions, our contact details are:
2.1.1 24 Silbury Arcade, Milton Keynes, MK9 3ES
2.1.2 01908 398115
2.1.3 guest.services@thecentremk.com
3 ENQUIRIES, FEEDBACK, COMPLAINTS AND OTHER CORRESPONDENCE
3.1 When you contact us (for example by email, post or SMS) or when you respond to correspondence from us, there will be personal information (such as names and contact details) in that correspondence. This may include enquiries about the centre:mk, reviews, follow-up comments or complaints, or information you write in our guestbooks or feedback forms.
3.2 We will keep and use that information to deal with your issue for our legitimate interests in administering your account and any subscriptions or competitions we operate, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
3.3 We keep this information for up to 6 years.
4 MARKETING TO SHOPPERS
4.1 We may collect your name and contact details (your email address, phone number and address) in order to send you information about the centre:mk and events there which you might be interested in. We may collect this directly from you, or through a third party. We will only send you marketing if you have consented to this, usually through a tick box. If a third party collected your name and contact details, they will only pass those details to us for marketing purposes if you have consented to them doing so.
4.2 We never share your name or contact details with third parties for marketing purposes, including shops at the centre:mk. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
4.3 You always have the right to ask us not to process your personal information for marketing purposes. We will always provide an “opt-out” option on any marketing messages we send you, or you can Contact Us in writing. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. Please note that if you “opt-out” of receiving marketing materials from us you may still receive marketing materials from third parties who operate at the centre:mk, such as shops, parking providers and attraction operators. You will need to let them know if you do not wish to receive marketing materials from them.
4.4 We retain your details on our marketing list until you “opt-out” at which point we add you to our suppression list, which we need to keep indefinitely to for our legitimate interests to ensure we don’t accidentally send you any more marketing.
5 WEBSITE AND APP ACCOUNT INFORMATION
5.1 Where you create an account on our website, or using our app, we will store the information you provide us through that account, including your name, contact details, preferences and searches you submit using our app.
5.2 We use the information associated with your account as necessary for our legitimate interests in providing you with important (non-marketing) updates about the centre:mk or your account personalising and improving your experience on our app and website (including by showing you relevant adverts or suggestions within the app) and to carry out any services we provide through the app.
5.3 Our app allows you to see your location within the centre:mk and plan your route. We do not store this information or use it for any other purpose. You can disable this by turning off the GPS settings on your device.
5.4 We keep this information until you delete it from your account, or delete your account itself.
6 WI-FI
6.1 When you use our free wi-fi, you will need to submit an email address, and we will collect your device’s unique ID, in order to provide you with that service.
6.2 Your email address is needed for us to send a confirmation email (if you do not provide it, we cannot provide you with a free wi-fi service) and your device’s unique ID is needed to grant wi-fi access.
6.3 If you OPT IN we keep this information until you unsubscribe, if you OPT OUT we do not retain the information.
7 PARKING
7.1 Where parking at the centre:mk is provided by a third party (Anchor Security Services Limited), they will be responsible for how they use and store your personal information for parking enforcement purposes. There are notices displayed in the parking areas giving more information about how they use your personal information.
7.2 When you use our car parks we may read and store your vehicle number plate using automatic number plate recognition software. When you pay for your parking, you will need to provide your vehicle number plate, this is necessary for us to provide the parking service. We use this information to operate our service by confirming who has paid for parking, and to automatically let you out of the car park.
7.3 If you pay at the centre:mk for parking, we will also use your card details to process your payment. We do not store these, and they are only used to process your payment. We keep your vehicle number plate, and the time and duration of your stay, for up to 6 years.
7.4 If you pay online, we will collect your name, contact details, vehicle number plate, and the time and duration of your stay. We will also collect and use your card details to process your payment. If you have an account with us, this information will be stored until you delete it from your account (you can also choose not to store your payment details) or your delete your account itself.
8 GUEST SERVICES
8.1 We do not keep records of routine enquiries at guest services.
8.2 If you leave details of a lost property claim, we use your contact details and the description of what you have lost to identify whether we have located your item, and contact you if this is the case. We keep this information until we have reunited you with your item, or for 3 months from when you told us about it, if we don’t find it.
8.3 If you tell us about a lost child, we use the information you provide to help find them, but we only keep this information for 3 months after you contact us.
8.4 Where you use CollectPlus services at our guest service desk, this process is controlled by CollectPlus and is carried out on their systems, we do not keep or use this information. CollectPlus have direct responsibilities for you in terms of how they use your personal information. You can find more details of how they use your personal information on their website – www.collectplus.co.uk
9 ACCIDENTS
9.1 If you have an accident at the centre:mk, or make a claim against us, we will record any relevant information about the incident or claim, which may include your name, contact details and health information about you. This information is stored and used only for our legitimate interest in properly dealing with disputes and for the defence of legal claims (including potential legal claims). It may be provided to our insurers or professional advisors as necessary for that purpose.
9.2 We keep this information for six years from the date of the incident, or, where the incident involves a child (and the period is longer) until the child involved reaches the age of 24.
10 SECURITY AND CCTV
10.1 We operate CCTV surveillance at the centre:mk as necessary for our legitimate interests in maintaining security and properly dealing with disputes, and we only use CCTV footage for these purposes. Any areas where CCTV monitoring is in place will have clear notices setting this out. We only release footage following a warrant or formal request from law enforcement, or as necessary in relation to disputes.
10.2 We keep CCTV footage for 30 days, unless we become aware of an incident in that time, in which case the relevant footage will be kept until that incident is resolved.
10.3 We also keep information on shoplifters and suspected shoplifters, to provide this to law enforcement, and to keep a record of repeat offenders as necessary for our legitimate interests in more effectively assess how to deal with them if they offend again. This information may include details provided by shops in the centre:mk, such as details of the incident and a physical description. We keep this information indefinitely.
11 WEBSITE VISITORS
11.1 When you visit our website we may collect information about you, your visit and your browser using cookies. We may use this as necessary for our legitimate interest to keep our site safe and secure, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
11.2 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them
11.3 For detailed information on the cookies we use and the other purposes for which we use them see our Cookie Notice.
12 FOOTFALL COUNTING
Footfall counting technology is used at the centre:mk to enable us to identify how visitors use and travel through the centre. Visitor numbers are recorded using counting software and target specific tracking based on movement. The visitor counts are recorded as digits and no images of visitors recorded as part of the footfall counting process. The footfall counting technology is provided by Springboard Research Limited (part of the MRI Group) which is a third party service provider.
13 GIFT CARDS
Our gift cards are issued and managed by a third party service provider, Giftify. They control how they use your personal information. Giftify have direct responsibilities for you in terms of how they use your personal information. You can find more details of how they use your personal information in their terms and conditions which are provided with the gift cards.
14 BUSINESS PERSONNEL
This section sets out how we may use your information if you or your organisation deal with us in a business situation.
14.1 Employee information. If you work for one of our tenants, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. We use this as necessary for our legitimate interests in managing our relationship with you or your organisation. In particular, we may send out marketing to tenants and potential tenants as necessary for our legitimate interests in marketing tenant opportunities at the centre:mk, but we will always provide an option for you to opt out. We keep this information for up to 6 years after the end of our relationship with you or your organisation (or, if we do not have a relationship with you or your organisation, for ). If you work for one of our tenants, suppliers or business partners and your contact details are used by another organisation working with us, they will control how they use your information and be directly responsible to you for it.
14.2 Visitor information. We collect information about business visitors to our premises. We may record information on your visit, including the date and time, who you are visiting, your name, image, organisation, contact details and vehicle registration number. We use this as necessary for our legitimate interest interests in managing the security of our premises. We keep this information for up to 4 years your visit.
15 INFORMATION WE RECEIVE FROM THIRD PARTIES
15.1 As well as the information listed above, we may also receive the following types of personal information about you from the following sources:
15.1.1 Our other channels. This is information we receive about you if you use any of the other websites we operate or the other services or products we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.
15.1.2 Our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you.
15.1.3 Businesses we have bought. If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice.
16 HOW AND WHY DO WE USE YOUR INFORMATION?
16.1 We will only use your personal information when the law allows us to do so. We have set out above examples of how we use your information, but we generally use your personal information in the following circumstances:
16.1.1 Where we need to perform a contract we have entered into with you.
16.1.2 Where we need to comply with a legal obligation.
16.1.3 Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
16.1.4 We may also use your personal information where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest although these circumstances are likely to be rare.
16.2 If you fail to provide personal information. If we have (or are entering into) a contract with you, and you fail to provide certain information when requested, we may not be able to perform (or enter into) that contract, or we may be prevented from complying with our legal obligations. We will indicate this when we collect the information, or in this privacy notice.
16.3 Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
16.4 Retaining your information. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
16.5 Anonymous information. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
17 SHARING YOUR INFORMATION
As well as any sharing we have described above, we may also share your information with third parties, including our ground companies, CBRE Ltd and other third-party service providers. We require third parties to respect the security of your personal information and to treat it in accordance with the law. We never sell your data to third parties.
17.1 Why might we share your personal information with third parties?
We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
17.2 Which third-party service providers process your personal information?
Third-party service providers who may process your personal information include contractors and designated agents and other organisations within our group. Guest services, parking services, gift-card services, event organisation, marketing and analytics, CCTV operation, IT services (including managing our app, website and visitor accounts) are carried out by third-party service providers.
17.3 How secure is your information with third-party service providers and other entities in your group?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes unless you have agreed that they may do so or unless they are acting as a controller of your personal information. We only permit our third-party service providers them to process your personal information on our behalf for specified purposes and in accordance with our instructions.
17.4 What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
18 WHERE WE STORE YOUR INFORMATION
18.1 The centre:mk is based at 24 Silbury Arcade, Milton Keynes MK9 3ES and our main data centre is located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
18.2 We may transfer data to countries outside of the UK and the EU which the UK’s Information Commissioners Office (ICO) considers to have an adequate data protection regime in place and to other countries where we have ensured that appropriate safeguards are put in place.
19 DATA SECURITY
19.1 We have put in place measures to protect the security of your information. Our third party service providers will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
19.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website or app. Any transmission is at your own risk.
19.3 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
20 YOUR RIGHTS
20.1 Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:
20.1.1 Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
20.1.2 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
20.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
20.1.4 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
20.1.5 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
20.1.6 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
20.1.7 Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
20.1.8 Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.
20.1.9 Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please Contact Us.
20.2 No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
20.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
20.4 Timescale
Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
21 THIRD PARTY WEBSITES
Our website or app may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
22 CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.