THE TRAFFORD CENTRE LIMITED’S PRIVACY POLICY
We are committed to safeguarding your privacy, so please read this privacy policy to understand how information we hold about you will be treated on our website(s) the “Site(s)”), when you visit us in person and when you otherwise interact with us. If you would like this website privacy policy in another format (for example: audio and large print) please contact us (see ‘How to contact us’).
We occasionally update this privacy policy so you should return to this page and read it through again from time to time.
Last updated: 28 February 2024 (Version 2.0)
This is the privacy policy for The Trafford Centre Limited (referred to in these terms as The Trafford Centre, we, us, our etc.) (the shopping centre we operate being the “Centre“).
The Trafford Centre Limited (registered with the Information Commissioner’s Office with registration number Z6948723) is the controller of your personal data.
We collect, use and are responsible for certain personal data about you. When we do so we are regulated under data protection legislation and we are responsible as ‘controller’ of that personal data for the purposes of those laws.
If you have any questions in relation to this privacy policy, please email or write to the Data Protection Officer at The Trafford Centre, Manchester, M17 8AA.
3. Information we collect about you and our collection methods
“Personal data” is information about you from which we can identify you (either on its own, or by piecing it together with other information). Personal data does not include aggregated data where you cannot be identified (e.g. statistics about usage in general or in categories).
We may, from time, collect your personal data in ways other than those set out in this privacy policy, where we do so we will provide you with relevant privacy notices at the appropriate time. This privacy policy supplements the other notices and is not intended to override them.
The types of personal data we collect about you are:
Contact data
- Information provided when you interact with us directly including when registering on the Site with us, signing up to use WIFI at our Centre, using our in-store services (shopmobility, fun buggies, high chairs and pushchair hire), participating in promotions and competitions, or completing customer surveys – this may include your title, name, postal address, email address, telephone number(s), and information about your use of our Centre;
Preferences & Profile data
- Information about your preferences, including brands and content you like, dislike, click on or share with others;
- Information provided when you interact with us directly (e.g. telephoning, writing or emailing us, buying gift cards or services from us, participating in promotions and competitions);
- Demographic information;
- Data collected when you interact with us or otherwise make accessible via third parties, including:
– through brand partners and social media platforms (see section 8 below), and
– through third party surveys and market research you participate in;
– Other information which you give us when dealing with us or interacting with us in any way including via third parties.
Financial data
- Your credit and/or debit card number and expiry date may be collected if you make a purchase from us.
Image data
- CCTV footage, including Body-worn Video (BWV), featuring your image; BWV may also include audio recording;
- Vehicle registration number and details (via Automatic Number Plate Recognition (ANPR) systems where it is in operation at our Centre car parks).
Technical / Usage data
Information about your use of the Sites or use of WiFi at our Centre. Some of this information may be automatically collected, such as your Internet Protocol (IP) address, unique device identifier, browser type, browser language and access times (for further information, please see our Cookies policy);
- Technical Data from analytics providers;
- Details you provide when using our WiFi in a Centre;
- Information about your location. We may automatically collect pseudonymised location information at our Centre if you have WiFi connectivity turned on on your device. If you do not wish to have pseudonymised location data collected you may prevent this by turning off WiFi connectivity on your devices whilst at our Centre. If you connect to our WiFi at our Centre and agree to receive marketing information we may automatically collect location information when your visit our Centre.
Job Applications
- Information which you provided to us on application for a job either directly to us or a via third party recruiter. We will provide you with a detailed privacy notice for the recruitment and selection process as part of the application process.
4. How we use your personal data
We may use your personal data to:
- Provide you with information, products, services or experiences that you request from us;
- Provide reservation or booking services;
- Provide and personalise our products and services to you, including making predictions about your interests or preferences and to display targeted content, features, deals and offers that match your profile or that we believe will be of interest to you;
- Processing payments you have made via our gift card scheme;
- Keep track of your activity patterns and preferences in order to improve the level of service you receive and to increase the functionality of the Sites or our WiFi provided at our Centre, including monitoring and analysing usage and trends, determining the effectiveness of our content and personalising and improving the Sites or the marketing information which we send you;
- Link or combine with other information we get from third parties to help understand your needs and provide you with better service (through the use of cookies and related technologies, where these are enabled on your device);
- Inform you of products, services, experiences or promotions which we feel may be of interest to you where you have indicated that you wish to be contacted for such purposes by email, SMS, post, telephone, through the Sites or social media platforms, or by other means of electronic communication (and where you have indicated that you are happy to be contacted by specific third parties, you may be contacted about products, services, experiences or promotions by those third parties);
- Ensure that content from our Sites is presented in the most effective manner for you and for your computer/tablet/mobile;
- Send you push notifications;
- Interact with you on social media platforms;
- Allow you to participate in any interactive features of our products, services and experiences, when you choose to do so;
- Manage and administer any of our promotions/competitions which you enter;
- Request feedback from you;
- Respond to your emails, submissions, questions, comments, requests or complaints and provide customer service;
- Send you surveys, updates, security alerts and support and administrative messages and to facilitate your use of, and our administration and operation of, the Sites, including to notify you about important changes;
- To deter and to detect fraud and combat criminal and antisocial behaviour;
- To comply with our legal obligations and keep our centre safe.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected (including for the period of any contract/agreement we have with you, and for a period of time after in the event of any potential issue), unless we are required by law to retain your personal data for a longer period (e.g. where you make a rights request, and we maintain records to demonstrate how e comply with such requests).
To deliver services to you, it is sometimes necessary for us to share your personal data outside the UK with our service providers located outside the UK;
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK
• where the UK has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law
These are explained below.
7. Purposes for which we use your data – summary
We have set out below, in a table format, a broad summary of the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on more than one lawful ground if we are processing the same information for more than one specific purpose.
| Purpose/activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To manage our relationship with you which will include: a) Notifying you about changes to our terms or privacy policy b) Asking you to leave a review or take a survey c) Responding to your requests | a) Contact b) Preferences & Profile | a) Performance of a contract with you b) Necessary to comply with a legal obligation c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services |
| To administer and protect our business (including protecting our Centres, visitors and staff) and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), this may include data collected from on-site visits to Centres | a) Contact b) Preferences & Profile c) Technical / Usage d) Image | a) Necessary for our legitimate interests, for running our business, provision of administration and IT services, network security, to prevent crime and fraud in our Centres and on our Sites, to prevent and manage Health & Safety issues in our Centres, and in the context of a business reorganisation or group restructuring exercise, and in the event that we need to commence and manage any legal proceedings. b) Necessary to comply with a legal obligation e.g. to comply with health and safety legislation |
| To use data analytics to improve our websites, the WiFi we provide at our Centre, products/services, marketing, customer relationships and experiences | a) Technical / Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Sites updated and relevant, to develop our business, to understand customers’ use of our Centre and to inform our marketing strategy) |
| To send marketing communications, including suggestions and recommendations to you about services that may be of interest to you, and to provide you with updates about us and our Centres (which may be personalised based on information we hold about you). | a) Contact b) Preferences & Profile c) Technical / Usage | a) Necessary for our legitimate interests (to develop our products/services and grow our business) b) In certain circumstances, with your consent (see also Direct marketing – how to opt out) |
| To manage and administer any of our promotions and competitions which you enter | a) Contact b) Preferences & Profile | a) Performance of a contract with you e.g. in order send you a prize which you have won from a competition you have entered into. b) Necessary for our legitimate interests (to develop our products/services and grow our business) e.g. in order establish what products you are interested in so we can target marketing and promotional material which we feel may be most relevant to you. |
| To provide a service to you (including services provided through our apps) | a) Contact b) Preferences & Profile c) Technical / Usage d) Financial | a) Performance of a contract with you b) Consent to push notifications, via your device settings |
8. How we keep your personal data safe
We have a number of measures to keep your data safe and secure:
- Your personal data is held on a secure database.
- We have policies, rules and technical measures in place to protect the personal data that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.
- We limit access to your personal data to those who have a genuine business need to know it. All of our employees and data processors that have access to, and are associated with, the processing of your personal data are obliged to respect the confidentiality of your personal data.
- All third parties supporting our Sites as external data processors are engaged under appropriate contractual and confidentiality protections.
9. How we disclose your personal data
We ensure that your personal data will not automatically be disclosed by us to government institutions or authorities. However, if required by law, or when we receive a request from regulatory bodies or law enforcement organisations, we may disclose your information. How we disclose your personal data
We may disclose your personal data to any of the following to the extent necessary to fulfil the purpose for which your data was collected:
- Our staff;
- Our affiliates;
- Our group companies and their staff;
- Suppliers and service providers who may access your personal data when providing products or services to us, in particular providers of platform, data storage, WiFi services, marketing and data security services;
- Purchasers or potential purchasers of our business or any part of it or of a Centre;
- Government bodies and law enforcement agencies and in response to legal or regulatory requests; and
- Auditors or other advisers auditing, assisting with or advising on any aspect of our business or a Centre, including our external legal advisors.
We may also share information or statistics with third parties in an aggregated or anonymised form that does not directly identify you, e.g. we may share aggregated and anonymised or pseudonymised information about your interests and geographic preferences and/or location with advertisers and third party deal sites for marketing purposes.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law and subject to appropriate contractual terms. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
10. Your own sharing of your personal data
When you post in any profile, comments, forums and other interactive features of the Sites, or share personal data with individuals through the Sites or social media platforms, this personal data will be available to other users and in some cases may be publicly available outside of the Sites (e.g. on social media platforms).
11. Our access to your personal data through social media platforms
If you interact with us on social media platforms, (for example, if you ‘Like’ our Facebook Page or post on our Facebook timeline, or if you follow us or mention us in a tweet on Twitter) we can interact with you and send you information via these platforms.
The personal data we have access to through social media platforms will depend on your personal settings on these platforms. We will have access to all public information on these platforms. We may also be able to access personal data that others share about you (because they control how that is shared, not you).
We may collect any data that is accessible to us or that you provide through social media platforms, including but not limited to your Facebook and/or Twitter profile picture, gender, and usernames. We will interact with you through social media platforms in accordance with each platform’s rules but we are not responsible for how the platform owners collect and handle your data. We are not responsible for what third parties post on our social media accounts.
12. Your legal rights with respect to your personal data
Under certain circumstances, you have rights under data protection laws in relation to your personal data, as listed below, to:
- be informed about how we use your personal data;
- request access to your personal data;
- request correction of your personal data;
- request erasure of your personal data;
- object to processing of your personal data;
- request restriction of processing your personal data;
- request transfer of your personal data; and
- withdraw consent to processing of your personal data.
If you wish to exercise any of the rights set out above, please contact us at or write to the Data Protection Officer atThe Trafford Centre, Manchester, M17 8AA.
When writing to us to obtain a copy of your personal data or to update our records, please quote your name and address and provide brief details of the personal data of which you would like a copy of, or which you would like to be corrected, because this will help us more easily locate your personal data.
What we may need from you when you exercise your legal rights
When exercising your legal rights, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that requests are made by the individual themselves and that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.
Fees and refusal to comply with requests
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive we may charge a reasonable fee and/or refuse to comply with your request.
Time limit to respond
We will respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests and it is likely to take us longer than a month to respond, we will notify you of that and keep you updated as to progress.
Your right to make a complaint
In addition to your legal rights set out above, you also have the right to make a complaint at any time to your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html). The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk). We are committed to protecting your personal data and would appreciate the opportunity to address any concerns or complaints you may have before you approach the ICO so that we can remedy them. Any concerns or complaints should be raised with the Data Protection Officer in the first instance.
13. Direct marketing – how to opt out
You have the opportunity to opt-out of receiving marketing communications from us at any time. You can do this by clicking on the unsubscribe link on any communications from us or by emailing .
We take your online privacy very seriously, so if you need any assistance in unsubscribing to future communications please contact us. We will promptly take action to ensure that you are “opted-out” from receiving any further mailing or other information. Although we will remove your name from our e-mail list as quickly as possible, there may be a period of time after you unsubscribe during which you may still receive e-mails from us. Additionally, in order to ensure you do not continue to receive correspondence from us, we may retain your Personal Data on a suspension list.
Our Sites uses cookies, including third party cookies. For further details please read the Cookie Policy.
15. Third parties and the privacy of your personal data
You may be able to access third party websites from the Sites. We are not responsible for the privacy policies and practices of other websites. We recommend that you check the privacy policy of each website and contact the operator of the website if you have concerns or questions.