This privacy policy is provided by Total Turnover Solutions, and explains what information we collect about you (“personal information”) and what we use it for.
Total Turnover Solutions is a company registered in England and Wales with company number 04312617, whose registered address is The Farmhouse, Farm Road, Street, Somerset, BA16 0FB (“we” or “us”).
Total Turnover Solutions are a real estate asset management business, specialising in the retail and leisure property sector, and provide certain asset management related services to the Centre.
From time to time, as part of running our business, we collect and use certain personal information about guests who visit and interact with the Centre, including online and in person (we refer to such individuals as “Guests”), as well as individuals who work for businesses that work with the Centre (we refer to such individuals in this policy as “Business Contacts”). In this privacy policy, we refer to Guests and/or Business Contacts as “you”.
Under data protection law, we have certain legal responsibilities about how we collect, use and share your personal information.
This policy explains our privacy practices and covers the following:
- Details of personal information that we collect (including types of individuals whose data we collect)
- Sources of your personal information
- How we use your personal information
- Parties who we share your personal information with
- How long we retain your personal information for
- Transfers of your personal information
- How we legally justify using your personal information
- Automated decision making
- Your rights in relation to your personal information
- Other relevant information, including how to contact us
1. Details of personal information we collect
We collect and use personal information relating to the following types of individuals:
Guests – Guests may include the following individuals:
- Guests who sign up for Centre’s newsletter and other marketing emails – we collect and use personal information of people who sign up to receive our the newsletter and other marketing emails, including via the Centre website.The personal information collected consists of: your name and email address, and where you inform us, your gender. If you choose to tell us your gender we can tailor the information in emails and newsletters accordingly, please see paragraph 8 below for more information.
- Guests who we interact with on social media – occasionally we may direct message Guests via Facebook or Instagram regarding a competition that we are running.The personal information collected consists of: your name and email address.
- Advertising, events and competitions – some Guests may wish to participate in certain events, promotions or competitions which we run. These could be online or at the Centre itself. The personal information collected consists of: your name, email address and mobile phone number.
Business Contacts
In addition, we collect and use the name, job title, place of work, business email address and business mobile number about Business Contacts who work for various businesses involved with the Centre, notably: tenants who run retail units at the Centre, potential tenants, agents who provide services to the Centre, investors in the Centre and our clients who are involved with the Centre.
2. Sources of the personal information
- From you directly – in most instances, we collect your personal information from you directly, including where you sign up for our newsletter, competitions and to receive other marketing emails and promotional information.
- Wi-Fi services provider – we use a third party provider of Wi-Fi services, who initially collects your name and email address if you register to use the Centre’s Wi-Fi. The Wi-Fi services provider may send us your name and email address so we can add you to our marketing database.
- Other third parties with whom we partner for promotions – we may partner with a business for joint promotions. For example we may run a competition with a local radio station – in such circumstances, we may receive details of your name and email address from the third party.
3. How we use your personal information
- Guests – we use personal information collected about Guests for the following purposes:
- Research – we analyse personal information (post codes, email addresses, age and gender of Guests) for research purposes, which enables us to operate more efficiently and so that we can tailor future services and events for Guests according to certain demographics such as age and gender;
- Running competitionsand promotions – from time to time we run different promotional events and competitions relating to the Centre;
- Direct marketing purposes – including notifying Guests about upcoming events at the Centre, sending our newsletter and other details of news and special offers at the Centre. However, we only send such marketing information where Guests have agreed to receiving such communications from us.
- Tailoring our marketing to suit you – please see paragraph 8 below, regarding our automated marketing services tool and how this enables us to tailor marketing emails to suit your preferences and other personal information.
- Business Contacts:
- We use personal information of Business Contacts to send them newsletters and invites to specific events, e-brochures and other marketing emails.
4. Parties who we share your personal information with
- IT service providers – suppliers who provide hosting of our IT services or who provide support and maintenance services for our IT systems may occasionally have access to parts of our IT systems which contain personal information.
- Our marketing agency – we use an agency called Intereurope Communications Group (ICG) to carry out marketing services on our behalf. In particular, they deliver creative and digital services to Total Turnover Solutions by designing, building and project managing the fulfilment of all of our marketing and digital marketing activities. ICG are based in Preston, Lancashire. Please see under paragraph 7 below for information about the overseas based sub-contractors that Intereurope Communications Group appoint, who may also receive your personal information and the steps in place to ensure that your personal information is protected.
We have data sharing agreements in place with these third party providers, which restricts what they can do with the personal information and requires them to have in place appropriate security measures to protect your personal information.
5. How long we retain your personal information for
The length of time that we retain your personal information for varies, according to the type of individual whose personal information we have collected, and what this is being used for:
| Type of individual | Applicable retention period |
| Guests |
For personal information used for research purposes – 2 years, which enables us to compare search results for subsequent years. For running competitions and other promotions – for the period in which the competition or promotion is running, plus 3 months (unless you have opted in to receiving general marketing communications). For direct marketing purposes – we review marketing consent periodically and will seek your renewed consent every 12 months.If you do not renew your consent we will delete your personal information, on the assumption that you are no longer interested in receiving such marketing communications from us. |
| Business Contacts | We review personal information of Business Contracts held for marketing purposes, on an annual basis.If we reasonably consider that you are no longer interested in receiving marketing emails from us, for instance, if your business has ceased to be involved with the Centre, we will delete your personal information. |
6. Transfers of your personal information
Under data protection law, when personal information is being transferred from the UK to a country outside the European Economic Area (EEA), then we as data controller, are under an obligation to ensure that such transfer is performed in a manner which is compliant with data protection law.
We use certain marketing services providers (who are sub-contractors of our marketing services provider ICG), and they are located outside of the EEA. In such situations, we only transfer personal information to these overseas third parties where we have put in place suitable measures to protect your personal information.The particular details are as follows:
Mailchimp
Mailchimp are a marketing services provider and they store and use names and email addresses of Guests and Business Contacts.Their services allow individuals to be tagged and categorised, so they can receive relevant email messages.Mailchimp are registered with the US Privacy Shield framework, which is a valid method under data protection law for ensuring that personal data transferred to the US is afforded adequate safeguards.You can find out more information on Mailchimp’s certification with Privacy Shield via the following link: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active
Campaign Monitor
Campaign Monitor are a marketing services provider and they store and use names and email addresses of Guests and Business Contacts.Their services allow individuals to be tagged and categorised, so they can receive relevant email messages.We have put in place the EU approved model contract clauses between us and Campaign Monitor, to ensure that the transfer of your personal information to them is adequately protected in accordance with data protection law. If you would like a copy of the signed EU model contract clauses between us and Campaign Monitor, please get in touch with us and we can provide you with a copy.
Our websites use Google analytics and Google’s re-marketing technology. This technology enables users who have already visited our online services and shown interest in our services to see targeted advertising on Google partner network websites. Likewise, users that are similar to the visitors of our websites can be addressed. The advertising will be displayed through the use of web cookies. Using cookies, the user behaviour on a website can be analysed and subsequently utilised to provide targeted product recommendations and advertising based on the user’s interests. If you would prefer to not receive any targeted advertising, you can deactivate the use of cookies for these purposes through Google. Alternatively, users can deactivate the use of cookies by third-party providers by visiting the Network Advertising Initiative’s deactivation website. Please note that Google has its own data protection policy, which is independent of our own. We assume no responsibility or liability for their policies and procedures. Please read Google’s privacy policy before using our websites. How Google uses data.
LinkedIn Insight Tag
Our website utilises the “Insight Tag” conversion tracking service of LinkedIn Corp. This allows us to re-target users on LinkedIn after they have visited the Total Turnover Solutions site. This is also an analytics tool that allows us to record the effectiveness of LinkedIn advertisements. The collected data remains anonymous. This means we cannot see the personal data of any individual user. The collected data is saved and processed by LinkedIn. LinkedIn is able to connect the data with your LinkedIn account and use the data for their own advertising purposes, in accordance with LinkedIn’s data use policy.
7. How we legally justify using your personal information
Every use that we make of your personal information must meet a legal ground in the list set out by data protection law. The legal grounds which we rely on are as follows:
| Type of individual | Relevant use of personal information | Legal condition relied upon |
| Guests | For research purposes. | That such processing is necessary for the purposes of our legitimate interests and where such interests are not overridden by your interests, rights or freedoms. Our specific legitimate interests for research purposes are to seek to improve the services we provide (and/or that the Centre provides) to Guests and to enhance your experience at the Centre. |
| For running competitions and other promotions. | Where you have given your consent. | |
| For direct marketing purposes. | Where you have given your consent. | |
| Details of your gender and other preferences so that our automated marketing software can send you tailored marketing communications. | Where you have given your consent. | |
| Business Contacts | For direct marketing purposes. | Our legitimate interests, where such interests are not overridden by your interests, right or freedoms.Our specific business interests for marketing to Business Contacts is to keep you informed about events, special offersand promotions at the Centre. |
8. Automated decision making
We use a software tool which, based on a Guest’s gender and other preferences, enables us to tailor email content and other advertising content for you – in our experience men and women have different preferences when it comes to shopping and entertainment and our software tool enables us to send Guests emails and other marketing information which are suited to your gender and likely preferences.It does this by making automated decisions based on such characteristics, to determine the content of the marketing emails and communications which we send to you, for example whether you would be interested in a particular genre of film or eating at specific restaurants or shopping at a particular shop.However, we only collect and use such personal information of yours in this manner where you have given your consent to this.
9. Your rights in relation to your personal information
If you have any questions in relation to our use of your personal information, you should first contact us using the contact details in paragraph 10 below. Under certain conditions, you may have the right to:
- a) require us to provide you with further details on the use we make of your personal information;
- b) require us to provide you with an electronic copy of personal information that you have provided to us;
- c) require us to update any inaccuracies in the personal information we hold;
- d) require us to transfer a copy of your personal information to another data controller, in a structured, machine readable and commonly used format;
- e) require us to delete any personal information that we no longer have a lawful ground to use;
- f) require us to restrict our use of your personal information;
- g) where the processing of your personal information is based on us receiving your consent, the right to withdraw your consent at any time;
- h) if we indicate that we use your personal information for direct marketing purposes, a right to object to receiving any further direct marketing from us at any time;
- i) complain to the Information Commissioner at any time;
- j) object to our uses of your personal information which are based on the ‘legitimate interests’ legal ground, if indicated above.If any of our uses of your personal information based only on this legal ground are causing you undue harm, then we must cease using your personal information for that purpose.
Your exercise of these rights is subject to certain conditions and exemptions, for example to safeguard the public interest in investigating crimes, or protecting legal privilege. If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to you, you can complain to the contact listed at paragraph 10 below.
10. Other relevant information, including how to contact us
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to your personal information, by contacting us as set out below.
From time to time, we may make changes to our operations and the services we provide and consequently our privacy policy may change at any time in the future. We therefore encourage you to review it from time to time to stay informed of how we are using your personal information.
Our website may use cookies about visitors to the website – please see our separate cookies policy for more information on our use of cookies.
We are required to employ adequate technical and organisational security measures to protect your personal information from any loss, destruction, damage or unlawful disclosure. However, no transmission of personal information over the internet can ever be guaranteed as secure. Consequently, please note that we cannot guarantee the security of any personal information which you transfer to us over the internet or which we transfer to you.
If you have questions about either this privacy policy, please contact Mark Watts the Total Turnover Solutions Data Protection Officer whose contact details are as follows: [email protected] or by post at Total Turnover Solutions, The Farmhouse, Farm Road, Street, Somerset BA16 0FB