Las Rozas Village Mobile Device Privacy Notice
Your use of the Las Rozas Village mobile app (App) is governed by the terms and conditions available here. This Privacy Notice (Notice) gives you further information about the way we collect and use personal information about you (which is known as “personal data” under data protection legislation).
You should read through this Notice to fully understand the basis upon which we collect your personal data, how we use it, how long we store it and to whom it is disclosed. Other privacy notices may also apply in relation to our use of your personal data, in particular if you have linked your Privilege membership to our App (in which case our Privilege Privacy Notice will also apply).
Commitment to Privacy
We are committed to protecting your personal data and right to privacy. We will always keep your personal data safe and comply with applicable data protection legislation.
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
What does this mean?
1. The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this Notice.
2. The right of access
You have the right to obtain access to your personal data (if we’re processing it), and certain other information (similar to that provided in this Notice).
This is so you’re aware and can check that we’re using your personal data in accordance with data protection law.
3. The right to rectification
You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
4. The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
5. The right to restrict processing
You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in future.
6. The right to data portability
You may have the right to obtain information you have provided to us in a structured, commonly used and machine readable format.
7. The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator in the country where you live, work or where an alleged infringement of data protection legislation has occurred.
8. The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
9. The right to object to processing
You have the right to object to any processing which is carried out because of our legitimate interests.
If we can show compelling legitimate grounds for processing your personal information which override your interests, rights and freedoms, or we need your personal information to establish, exercise or defend legal claims, we can continue to process it.
Please see the section titled Requests to us below, for more information on how we will handle your requests to us.
Who we are
Las Rozas Village is the data controller of any personal information processed Las Rozas Village app.
Where you link your Privilege account to our App, we may share your personal information with other data controllers as part of your membership. See our Privilege Privacy Notice for more information.
What personal data do we collect about you?
We collect the personal data that:
- you provide to us through the App, including through our virtual concierge (a chatbot), where you choose to make use of it. The virtual concierge can respond to simple queries directly and forwards more complex queries you submit to our customer services team to respond to. The virtual concierge is run using Google Dialogflow (see Who we share your personal data with below), and any personal data you submit through the virtual concierge is processed in accordance with our Village Privacy Notice; and we gather through your use of the App and your personal device onto which it is downloaded, including:
- your location data so that you can use the in-village map and (where we have consent from you to do so) we may send you marketing communications when you are in the proximity of a village
- information on your preferences and your use of the App (e.g. the pages you visit if you click through any links to third party websites), in order to tailor our App to your specific preferences and to improve it for users more generally;
- your device type and operating system, in order to monitor and improve the functionality of our App; and
- to authenticate your use of the App through the use of authentication tokens.
We may combine this personal data with other personal data we hold about you including through the different channels you use to interact with us (for example, our website or our App), in particular, where you link your Privilege account to our App. In addition, we may combine all the personal data we hold about you with personal data about you held by our selected partners and/or retail outlets where you have agreed that they can share your personal data with third parties, according to their own privacy policies and your personal choices. We do this to form a clearer picture about the kinds of offers in which you might be interested.
If you download the App on a device running an Android operating system, the App will also ask for consent to access to your photographs, call records and other media stored on your device. This is solely to enable certain features of the App to function (such as allowing you to receive calls whilst using the App and by cacheing images used in the App to ensure the App runs smoothly), and your photographs, call records and other media will not leave your device and are not otherwise used by us.
How we use your personal data
We are processing your personal data to be able to provide you with access to our App, and in particular to do the following:
- provide you with our virtual concierge, a chatbot, to answer your queries relating to a Village and our services (in accordance with our Village Privacy Notice
- provide you with information about a Village that you are in or near (e.g. showing you where you are on our in-Village map and, where we have permission to do so, tell you about special offers)
- if you have linked your Privilege account to our App, to provide you special offers about brands sold in a Village and to offer you treats and rewards (as set out in our Privilege Privacy Notice, as well as to allow you to manage your Privilege account and your personal code, which can be used invillage stores for offers and promotions.
- to manage and improve our App, including by collecting information about how you use and interact with the App in order to develop improvements;
- to better understand your shopping behaviour in order to develop and improve our products and services so as to provide you with an enhanced shopping experience through your use of the personal code in our villages;
- to analyse the effectiveness of our marketing and to help us provide more relevant offers, advice and information to you and our other guests;
- to build up a clearer picture of our App users both as a group and as individuals and thereby provide you with a seamless, relevant and consistent service;
- to ensure that the information we hold is kept accurate and up to date;
- (if we have your consent, where this is required by law) in order that we may contact you, from time to time, for the purpose of conducting surveys or focus groups; and
- to notify you about changes to our services.
How long we keep your personal data for
We will keep your personal data for:
- as long as you continue to have our App downloaded;
- as long as necessary for us to meet the purposes described in this notice, in accordance with applicable data protection legislation;
- if you have linked a Privilege account to the App, in accordance with our Privilege Privacy Notice and
- where you use our virtual concierge, in accordance with our Village Privacy Notice.
Who we share your personal data with
If you’ve linked your Privilege account to the App, then we share your personal data with other Villages as set out in the Privilege Privacy Notice.
For the purposes set out above, we may also provide your personal data to our suppliers and processors who perform certain business services for us. We share your personal data with third parties who:
- host and maintain our App; and
- if you have given your consent for us to do so, use your location to deliver specific electronic messaging to you (including push notifications on your device).
In some cases the personal data we collect from you may also be processed outside the European Economic Area (EEA) and such destinations may not have laws which protect your personal data to the same extent as in the EEA. We have obligations to ensure that your personal data processed by us or by our suppliers and partners operating outside the EEA is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Notice.
You can click here for a list of the suppliers and processors we currently use, and other parties to whom we disclose your personal data. The link also has information about how these parties use your personal data, any processing they perform outside the EEA, and the safeguards that are used to protect your personal data if this happens. This information may be updated from time to time. Please ask us if you would like more information about the safeguards that are used to protect your personal data when it is processed outside the EEA (see Contacting Us below).
In addition, we may disclose your personal data:
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other companies and organisations for the purposes of fraud protection; and
- to successors in title or replacement operators of all or part of our respective businesses.While we strive to protect your personal information, we cannot guarantee the security of information that you submit online, and you do so at your own risk. We urge you to keep any usernames, passwords or any other log-in details in a safe place.
The legal basis for us using your personal data
- In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:
- sending you marketing communications; and
- using your location to deliver specific messaging and content to you (including push notifications).
- In most cases, it is in our legitimate interests to collect and use the personal data referred to above (see What personal data do we collect about you? above) so that we can:
- provide you with a service that is as useful, enjoyable and beneficial to you as possible, including by personalising our contact with you, making sure we tell you about all the offers that relate specifically to your preferred Village, tailoring treats to your specific preferences, and contacting you using your preferred method of communication;
- better understand our customer base so that we can improve our services and marketing activities (which could also benefit you); and
- to maintain and improve our App.
When we rely on our legitimate interests in order to collect and use your personal data, we must consider whether those legitimate interests are overridden by your interests or your fundamental rights and freedoms. We may continue only if we decide that your interests, rights and freedoms do not override our legitimate interests.
We have considered these matters, and where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not use your personal data unless there is another legal basis for us to do so (either that it is necessary for us to perform our contract with you, or on the basis of your consent). For example, we believe that collecting your location data may be intrusive, and so we will only do so with your consent.
What happens if you do not provide us with the personal data we request or ask that we stop processing your personal data?
If you no longer wish to use our App, you may uninstall it at any time. You may also ask that we stop using your personal data, including information that we may retain after you have uninstalled the App (see Your Rights above).
How we contact you
Our App works best when we are free to communicate with you to share details of treats, rewards and other offers you might be interested in.
In order to provide you with this information we may, if we have your consent, contact you by push notification and, in some circumstances, outside of our App (including by e-mail using such contact details as you provide to us from time to time).
If you no longer wish to receive such or certain communications, you can let us know by contacting us using one of the email addresses here. You may also update your preferred contact detailsat any time by contacting us at the above address.
If you want to turn off push communications, you can do so through your mobile device configuration. Please note that opting out from push communications will not by itself cancel any subscription to our newsletters, emails or any other communications methods you may have accepted at any time.
Requests to us
We are required by law to act on requests and provide information free of charge, except where your requests are manifestly unfounded or excessive (in particular because of their repetitive nature) in which case we may charge a reasonable fee (taking into account the administrative costs of providing the information or communication, or taking the action requested), or refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond 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’ll come back to you and let you know.
If you need to contact us for any reason (including to exercise any of your rights in relation to data protection as set out above and/or opt-out from our communications) please send us your request using the details here.
We may make minor changes to this Notice. When we make these changes we will publish the updated notice on the App. If we make any significant changes, we will take additional steps to bring these changes to your attention.