Privacy & Corporate Policies

 

At Irgen Retail Management, we take the privacy of your data seriously. We understand that by providing your personal information – whether through our website, the Cilento Fashion App or at our infopoint desk – you are trusting us with your information.

We have developed this policy to give you full transparency about the information we collect from you, why we collect it and how we use it.  We also need to ensure that you understand the rights you have over your personal data, including your rights of access to that data, how you can correct it and, if necessary, how you can erase it.

If you wish to learn more about the data we hold, including your rights, please read the sections below:

POLICY INTRODUCTION:

This mobile app (“Cilento Fashion App”) is controlled and operated by Irgen Retail Management (referred to in this Privacy Policy as “ Irgen Retail Management “, “we“, “us” or “our“).

Irgen Retail Management develops and manages Commercial and outlet centres in the South of Italy.  We work with our other Group Companies to provide services at these centres and to facilitate and enhance your experience at these centres and on this site.

This Privacy Policy (“Policy“) explains what personal information we and our Group Companies collect and record about you and what we do with that information, including when you visit this site. It set outs a description of your data protection rights, including your right to object to some of the processing which we carry out. This Policy also explains what personal information we collect and record on our in-centre computers and devices and in certain cases offline, and what we do with that information.

For the purposes of this Policy: “Group Company” means our parent company and any subsidiaries of our parent company, including us. This includes our subsidiary management companies operating in each of our locations. A list of these Group Companies and their locations can be found at the end of this Policy. We may change this list from time to time; “Centre Owner” means an owner of one of the Commercial and outlet centres which we manage (“Centre”).

 

THE INFORMATION WE COLLECT:

We collect, receive, store and process the following information about you:

• information that you provide via the site, including information you provide when you register with the site (e.g. name, address, telephone numbers, email address and date of birth), join our Cilento Fashion App, purchase a gift card, enter into competitions or complete surveys;
• information that you provide to us for the purpose of subscribing to direct marketing;
• information about your computer and about your visits to and use of this site, such as Internet Protocol (IP) addresses, date and time that you visited the site, the type of Internet browser and computer operating system, referral source, length of visit, page views and website navigation paths;
• information relating to any purchases you make via our site (e.g. gift cards) or any other transactions that you enter into through our site (including your name, address, telephone number, email address, card details and transaction history);
• information contained in or relating to any communications that you send to us or send through our site (including the communication content and meta data associated with the communication);
• information we obtain from private social media companies (see also Social Media below);
• information collected through transactions or interactions offline or on our in-centre computers or devices, including information you provide when signing up to our Cilento Fashion App, when purchasing gift cards, when completing surveys, entering into competitions and when using in-centre computers and devices.

• lweocation visit data: we collect your visits to the centre in order to provide you with loyalty services including rewarding you for visits to the shopping centre and providing you with location-based marketing relating to visits to the shopping centre.

 

HOW AND WHY WE COLLECT YOUR INFORMATION:

Use of your information

We use your personal information for the following purposes:

• to administer our site, business and the Centres;
• to enable your use of the products and services available on our site or otherwise made available offline or on our in-centre computers and devices;
• to provide and administer our Cilento Fashion App;
• to manage and run competitions or offers;
• to confirm booking of products through Click&Collect service ;
• to respond to your questions or requests for additional information and communicate with you about the site and the Centres;
• to provide you with information that you have specifically requested or that we have asked if you would like to receive;
• for internal research and analysis so that we can see how our site and the Centres’ and/or our Group Companies’ products and services are being used, understand how we can improve our site and the Centres’ and/or our Group Companies’ products and services and decide our and our Group Companies’ marketing strategies;
• to deal with enquiries and complaints made by or about you relating to us, our site and the Centres;
• to keep our site and systems secure and prevent fraud;
• where relevant, to meet legal, regulatory and compliance requirements;
• where relevant, for the establishment, exercise or defence of legal claims;
• to monitor and analyse the use of any account to prevent, investigate and/or report security incidents or crime;
• verify compliance with the terms and conditions governing the use of our site and in-centre computers and devices;
• to protect the rights, property, or safety of us, Group Companies, our customers, Centre Owners or others;
• to understand your interests and preferences so we can tailor the content, offers and promotions we surface on our site to better match your interests and preferences – see also our Cookie Policy
• to understand and identify the features of our customer base for insight purposes and in order to better target our advertising (e.g. reaching out to a similar demographic on social media);

We will also inform you from time to time of other products and/or services we offer which we consider may be of interest to you by email / phone / SMS / post, where permitted by applicable law (which may require that we obtain your consent). As well as unsubscribing within communications, you may email us at any time at [email protected] to indicate that you do not want to receive direct marketing communications from us.

We may combine information we collect about you through transactions or interactions offline or on our in-centre terminals or our email and SMS communications with the customer profile we hold about you in order to tailor our subsequent communications and communication channels to better match your interests and preferences and provide you with a better customer experience.

SOCIAL MEDIA

We also use personal information we obtain from social media sites online including, Facebook, Instagram and YouTube for our (and our businesses’) research and analytics purpose. Where appropriate, and in line with their own policies, we may match information from these sites to better understand, and improve, our customers’ experience. This includes posts or other information made public or made available to us where you use hashtags or tags relating to us, our Group Companies, our business, the Centre Owners, the Centres and our industry. Information from these sites may include information which has been held outside the European Union.

INFORMATION SHARING

We disclose or transfer personal information to other parties as follows:

• to any Group Company for the purposes identified in this Policy, including those uses set out above (a list of our Group Companies and their locations can be found at the end of this Policy);
• to third party service providers that perform functions on our behalf in relation to the site and the purposes set out in this Policy (for example, website hosting, social media analysis providers, marketing email service providers, data analysts website developers);
• media agencies and their advertising partners in order to run targeted marketing campaigns as described above;
• 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 terms and conditions or other agreements or to protect the rights, property, or safety of Irgen Retail Management, the Group Companies, our customers, or others;
• to government authorities, and to other third parties when compelled to do so by government and law enforcement authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of our site, or anyone else that could be harmed by such activities. Additionally, we cooperate with law enforcement inquiries and other third parties to enforce laws, intellectual property rights and other rights;
• to sellers or buyers as part of a sale or merger of our business or assets;
• in compliance with and to the extent permitted by data protection regulation, to an applicable Centre Owner or one of its group companies or to buyers as part of a sale or merger of a Centre Owner or Centre.  In addition, if we or one of our Group Companies ceases the role as a manager of a commercial or outlet centre, we will need to transfer your personal data to the Centre Owner or the replacement manager to ensure the continuity of our, or our relevant Group Company’s products and services; and

In addition, with your consent where required by law, we share your personal information with carefully selected third parties so that they can send you information about special promotions and offers.

We also share information about visitors to this site in an anonymous or aggregate form with third parties including advertisers, business partners, and sponsors, to understand customer trends and patterns and manage and improve our business relationships.

If you would like a list of the third parties with whom we share personal information, please contact [email protected]

 

SECURING YOUR INFORMATION

We take reasonable steps to protect your personal information as you visit and use the site and to protect such information from loss, misuse, unauthorised access, disclosure, alteration or destruction. Unfortunately, no data transmission can be guaranteed to be 100% secure. As a result, we cannot warrant the security of any information you provide to us and you do so at your own risk.

 

RETAINING YOUR DATA

We retain personal information used to send you direct marketing for as long as we can lawfully market to you. Where we no longer have grounds to market to you (e.g. because you opt-out) or the details we hold are no longer up-to-date (e.g. the email address we hold is invalid) we will delete personal information we hold about you from our marketing data base but retain some information on a ‘suppression list’ on an ongoing basis so we can manage your preferences going forward.

Personal information captured for competition purposes, or for the processing of gift cards, is cleansed regularly.

LEGAL BASIS FOR PROCESSING YOUR INFORMATION

We process your personal information with your consent when you agree that we may place Cookies, when you agree to receiving direct marketing or on other occasions where we ask you for consent, for the purpose which we explain at that time. Where we do process personal information based on consent, your consent is revocable at any time (without affecting the lawfulness of processing based on consent before its withdrawal).

We process your personal information when we are required to do this by law, including in response to requests by government or law enforcement authorities conducting an investigation or court orders.

We process your personal information when it is necessary for the performance of a contract to which you are the party or in order to take steps at your request prior to entering into a contract. This applies in any case where we provide or deliver products and services to you pursuant to a contract, such as when you purchase a gift card, process your registration on the site or enter into a competition. If you do not provide the personal information that we need in order to provide or deliver the service, we will not be able to provide or deliver services to you.

We also process your personal information when it is necessary for the purposes of a legitimate interest pursued by us or a third party (when these interests are not overridden by your data protection rights).

YOUR RIGHTS

You may ask us for a copy of your information and, where applicable, to correct it, erase it or to transfer it to other organisations at your request. You also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent. Where we process your personal information because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your personal information.

We hope that we can satisfy queries you may have about the way we process your personal information. However, if you have unresolved concerns you also have the right to complain to data protection authorities. You can bring the complaint in your member state of residence, place of work or where an alleged infringement of data protection law occurred.

To protect your privacy and security we will take reasonable steps to verify your identity when dealing with requests.

CHANGES TO THIS POLICY

We reserve the right to modify this Policy at any time. Changes to this Policy will be posted on the site. You should review this Policy frequently.

OUR GROUP COMPANIES

Name of entity	Country
Irgen RE Eboli Srl	Italy
Irgen Re Pompei Srl	Italy
Consorzio Bari Santa Caterina	Italy
Consorzio Operatori centro Commerciale Maximall	Italy
Consorzio Operatori Maximall Retail Park Oplonti	Italy
Irgen Retail Management Srl	Italy

 

CONTACT INFORMATION

If you have any queries, comments or requests in relation to your personal information or this Policy, you can email us at [email protected]