Last Revised: November 15, 2017
2. Types of Information We Collect
3. How We Collect Information
4. How We Use Your Information
5. How We Respond to “Do Not Track” Signals
6. Communications with You
7. Information Sharing with Third Parties
9. Protection of Personally Identifiable Information
10. Updating Your Information
11. Opt-out Policy
12. Notice of Privacy Rights of California Residents
2. TYPES OF INFORMATION WE COLLECT
We may collect personally identifiable information from you, such as non-public information about you that helps SCP identify you, refers to your name or contact information, or other information that is maintained in a manner that links the information to your name or contact information. This information may include, without limitation, first and last name, birth date, email address, home address, telephone number, credit card number or other payment method information, Social Security number, driver’s license number and issuing jurisdiction, identification number or other identifying information issued by a government agency, your likeness and actions as may be photographed, recorded and live streamed (see Photography Policy), and other information that is not otherwise publicly available. We also may collect non-personally identifiable information about you, such as information regarding your use of the Sites, your IP address, MAC address, Site usage statistics, time stamps, browsing history, general geographic location, type of device you use to connect to the Sites or Wi-Fi Services and information identifying your device, type of operating system you use (e.g., Microsoft Windows, Google Chrome OS or Mac OS), the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, and your Internet location when you see SCP’s digital ads and whether you click on such ads. “Non-personally identifiable information” refers to information that does not personally identify the individual to whom the information relates, such as information that is aggregated by SCP or a third party, or information that is not linked to contact information or other personally identifiable information of an individual. In addition, we may collect information from or about you, such as your password, preferences and interests, income, education level, occupation, ethnicity, marital status, homeowner status, shopping habits, Site and Wi-Fi usage, age and gender, purchase and cash or credit payment information, participation in SCP promotions, and visits to South Coast Plaza. In the event that such information is maintained in a manner that identifies the name of, or contact information for, the individual to whom such information relates, it will be treated as personally identifiable information; otherwise, such information will be treated as non-personally identifiable information,
3. HOW WE COLLECT INFORMATION
We may collect personally identifiable information and/or non-personally identifiable information from you when you: visit the South Coast Plaza shopping center, use the Sites or register to receive emails or newsletters; use the Wi-Fi Services; contact, communicate or otherwise interact with SCP via the Sites or offline; make a payment to SCP; apply for a job at SCP; or register, enroll or participate in any events, promotions, sweepstakes, surveys, questionnaires, or other activities (collectively, “Activities”) that may be offered on the Sites or offline.
We may obtain personally identifiable and/or non-personally identifiable information from third parties such as the owners or operators of the websites or applications where our advertisements appear, and our affiliates, suppliers, vendors, merchants, licensors, or Activities partners or sponsors, and other sources (e.g., offline records or publicly available information). Non-personally identifiable information may also be obtained through these other sources, as well as from inferences based upon the sites you visit; third party data; information you share on other sites, social media platforms and applications; or demographics derived from profiles or accounts that you create.
If you make a purchase or receive a gift from SCP, we may obtain personally identifiable and/or non-personally identifiable information about you from you (for example, you may be asked to present the receipt from your purchase) or from the payment method provider used for the purchase. Please review the privacy policies for your payment method provider before using it to make a purchase from SCP.
We may combine personally identifiable information we collect with information that we obtain from the owners or operators of the websites or applications where our advertisements appear, as well as from our affiliates, suppliers, vendors, merchants, licensors, or Activities partners or sponsors, and other sources (e.g., offline records or publicly available information). We will treat any such combined information as personally identifiable information.
SCP automatically receives and records non-personally identifiable information on our server logs from your browser as well as through other analysis of the Sites. We also may collect information using cookies, web beacons, pixels, gifs, tags or other technologies (“Collection Technology”), or through third parties using similar technologies. Collection Technology may operate as a piece of data stored on your browser or device, or may identify, compile, aggregate and/or collect information through other means. When you visit the Site or use the Wi-Fi Services, your web browser may use Collection Technology to better enable you to navigate the Site during your visit and upon your return. You may use the Site even if you choose to reject or delete certain Collection Technology. Collection Technology also may be used by some of the other websites for which a link is placed on the Site. We may combine this non-personally identifiable information with personally identifiable information, and, if so, will treat the combined information as personally identifiable information.
SCP may use certain features of Google Analytics based on Display Advertising, such as:
• “Demographics and Interest Reporting” to analyze information regarding the interests and demographics of users of the Site. We use such non-personally identifiable information in the same manner as we use other non-personally identifiable information as described below.
• “Remarketing with Google Analytics” to place ads on other sites directed to people who have accessed the Sites.
• “Google Display Network Impression Reporting” to report how people’s interactions with our ads relate to their visits to the Sites.
• Integrated services that require Google Analytics to collect data via advertising cookies and identifiers.
4. HOW WE USE YOUR INFORMATION
We may use the information we collect:
• To provide information to third parties that may provide you with general or personalized content and advertising about their stores, restaurants, Activities, products and services.
• To alert you to new features, terms, Activities, stores, restaurants, products or services.
• To send emails or newsletters, and to provide you with general or personalized content in the newsletters.
• To monitor and analyze information regarding your browsing and viewing preferences.
• To analyze our users’ and visitors’ demographics and interests.
• To plan, improve and administer Activities.
• To process and respond to your inquiries.
• To administer, support, operate or improve the Sites or the Wi-Fi Services.
• To promote and improve the services we offer.
• To monitor activity at the South Coast Plaza shopping center.
• For the purposes for which you provided the information.
• For fraud prevention, security, internal operations, legal compliance, and other public purposes.
• To alert you to other information regarding SCP or any of the foregoing via email, direct mail, telephone or other means.
In addition to the uses discussed above, SCP may use non-personally identifiable information in any manner so long as SCP uses such information in its de-identified form. These uses may include, without limitation, uses for administration of the Sites; analysis of website trends and how the Sites are used; improving navigation of the Sites; analysis of the performance of the Sites and diagnosis of problems; improving the services we offer; analysis and developing advertisements and advertising campaigns; and providing you with special offers and promotions and determine the effectiveness of same.
SCP also may use your non-personally identifiable information to present you with targeted content and advertisements (including on third party websites and applications). Such targeted content and advertisements may include marketing for SCP and its services, and SCP’s business and advertising partners. Your non-personally identifiable information also may be used to optimize and determine the effectiveness of content and advertisements, and to analyze interactions with content and advertisements.
Some of SCP’s third-party partners may participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising or the Network Advertising Initiative Consumer Opt-Out, which allow consumers to opt-out of targeted advertising based on web activity tracking. For more information regarding the foregoing, please visit click here and here. Please note that even if SCP’s third-party partners participate in these programs, if you opt out of targeted advertising based on web activity tracking, you still may receive standard advertisements from us and targeted advertisements from third parties. You may need to re-click the links and follow the instructions provided again if you delete cookies or other Collection Technology or use a different computer, device or browser.
5. HOW WE RESPOND TO “DO NOT TRACK” SIGNALS
SCP does not alter the practices detailed herein based upon your selection of the “Do Not Track” setting or other “opt out” setting or feature that may be offered by your browser; however, SCP reserves the right to do so in the future.
6. COMMUNICATIONS WITH YOU
You authorize SCP to transmit email or postal mail to you or to telephone you. If you participate in Activities, you agree that SCP is authorized to contact you by telephone, send information, documents and prizes to you by email or postal mail, and publish the names of prize winners; see applicable rules for more details. Unsubscribe instructions are included in each promotional email from SCP. Please note that such requests may take up to ten (10) business days to become effective. You may not opt out of receiving communications regarding your dealings with SCP, the Wi-Fi Services, or the Sites or technical information about the same.
7. INFORMATION SHARING WITH THIRD PARTIES
We also may use and share non-personally identifiable information with third parties. Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with advertisers, business partners, and/or third parties. If we do so, we will ask our contracting parties to agree to keep the data in its de-identified form.
The Site also may contain plugins for social media websites, such as Facebook, Twitter, Instagram, WeChat and Weibo. We recommend reviewing the privacy policies that apply to these plugins, prior to clicking on such plugins.
9. PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION
SCP uses reasonable administrative, physical and electronic security measures to protect against the loss, misuse and alteration of personally identifiable information. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of SCP to intercept or access transmissions or private communications unlawfully. While we strive to protect personally identifiable information, neither SCP nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk.
Information collected by SCP may be stored and processed by or for SCP, or shared with third parties, in the United States in accordance with the laws of the United States, or in other jurisdictions. By using the Sites or Wi-Fi Services, or by submitting your personally identifiable information to SCP online or offline, you expressly consent to the storage, processing and sharing of your personally identifiable information in the United States in accordance with the laws of the United States, or in other jurisdictions.
10. UPDATING YOUR INFORMATION
You are responsible for keeping your information current. You may update your information by contacting us at email@example.com. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to SCP’s internal reporting, processing and retention policies and all applicable legal obligations.
11. OPT-OUT POLICY
SCP has adopted a policy of not sharing your personally identifiable information with third parties for their direct marketing purposes if you request that we do not do so (“Opt-Out Policy”). You may make such a request by sending us an email at firstname.lastname@example.org. When contacting us, please indicate your name, address, email address, and what personally identifiable information you do not want us to share with third parties for their direct marketing purposes. Please note that there is no charge for controlling the sharing of your personally identifiable information or for processing this request.
12. NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS
California residents who have provided personal information to a business that does not have an Opt-Out Policy may be entitled by law to request certain information regarding disclosures of personally identifiable information by the business to third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year (“Disclosure Request”). However, please note that due to SCP’s Opt-Out Policy, SCP is entitled by law to respond to your Disclosure Request by notifying you of your right to prevent the disclosure of personal information pursuant to our Opt-Out Policy (which is cost free to you). If you are still interested in making a Disclosure Request, send an email to email@example.com, specifying that you seek your “California Customer Choice Privacy Notice.”