Privacy Policy
June 26, 2020
This Privacy Policy describes how The Westfield Group (“Wg”) collects, uses, and shares your information when you use and interact with our Services and applies to all persons who use our Services (“Users”). Our Privacy Policy governs your access to and use of all Wg operated and controlled websites including https://wgusa.com and http://www.westfieldgroupusa.com (the “Website”), all other publicly available online services controlled or provided by Wg (collectively the “Services”).
If you have questions about Wg’s Privacy Policy or practices, or if you need to contact us about the information we collect about you, our contact information is at the end of this Privacy Policy.
Applicability & Eligibility
Applicability: This Privacy Policy applies only to the Services, and Wg’s collection, use, disclosure, and protection of your data. It does not apply to third party websites, applications, or services.
Before accessing, using, or interacting with the Services you should carefully review the terms and conditions of this Privacy Policy.
Eligibility: The Services are not directed to children under the age of 16. You may not use the Services if you are under the age of 16.
Information Collection & Use
Wg may collect data about you and your use of the Services (“Personal Data”) through various means, including when you provide information to Wg in order to utilize the Services. We may use the Personal Data for a variety of different reasons, including to improve the Services and to tailor the Services to you.
Wg processes Personal Data collected through the Services on the lawful basis of legitimate interests to provide the Services to you. Such processing is necessary for the purposes of the legitimate interests pursued by Wg or by our Service Providers related to the Services.
The types of information Wg may collect about you include: first name, last name, title, email address, phone number, and mailing address
If you sign up to attend a conference or event managed by Wg or email us, we may keep your message, email address, and contact information to respond to your requests, provide the requested Services, and to provide notifications or other correspondences to you. If you do not want to receive email from us in the future, you may let us know by sending us an email or by writing to us at the address below. Please note requests to remove your email address from our lists may take some time to fulfill. We may also still contact you as needed to provide important announcements or notifications regarding the Services.
Information We Collect Automatically
Cookies, Web Beacons, Links, And Other Tracking Technologies: Wg may keep track of how you use and interact with the Services through the use of cookies, web beacons, links, and other tracking technologies. We do this to help analyze the use of and improve the Services. Through these technologies we may automatically collect information about your use of the Services and other online activities, including our email correspondences, third-party services, and client applications, and certain online activities after you leave the Services. Link information is generally only analyzed on an aggregate basis. Some Services may not function properly if you disable cookies. Such data may include analytics information, sites visited before visiting the Services, browser type, operating system, and tracking of your interactions with our content and emails.
Unique Identifiers: When you use or access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “Unique Identifiers,” such as a universally unique identifier (“UUID”). A Unique Identifier may remain on your device persistently, to help you log in faster and enhance your navigation through the Services. Some features of the Services may not function properly if use or availability of Unique Identifiers is impaired or disabled.
Log File Information: When you use our Services, we may receive log file information such as your IP address, browser type, access times, domain names operating system, the referring web page(s), pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive log file data when you interact with our Services, for example, when you visit our websites, sign into our Services, or interact with our email notifications. Wg uses log file data to provide, understand, and improve our Services, and to customize the content we show you. Wg may link this log file to other information Wg collects about you via the Services.
Public Information: Wg may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Policy, and may be accessed and collected by Wg. Please be aware that any content or information you share with or provide to third parties using or related to your use of the Services is neither private, nor confidential. Wg is not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it.
Information Sharing
Wg Representatives: Wg’s personnel and contractors may have access to your information as needed to provide and operate the Services in the normal course of business. This includes information regarding your use and interaction with the Services.
Service Providers: Wg works with various organizations and individuals to help provide the Services to you (“Service Providers“), such as website and data hosting companies and companies providing analytics information. We may share your personal information with our Service Providers for the purpose of providing the Services. The information we share to our Service Providers may include both information you provide to us and information we collect about you, including Personal Data and information from data collection tools like cookies, web beacons, log files, Unique Identifiers, and location data. Wg takes reasonable steps to ensure that our Service Providers are obligated to reasonably protect your information on Wg’s behalf. If Wg becomes aware that a Service Provider is using or disclosing information improperly, we will take commercially reasonable steps to end or correct such improper use or disclosure.
Business Transactions: Wg may purchase other businesses or their assets, sell our business assets, or be involved in a bankruptcy, merger, acquisition, reorganization or sale of assets (a “Business Transaction”). Your information, including Personal Data, may be among assets sold or transferred as part of a Business Transaction.
Lawful Requests: We may be required to disclose User information pursuant to lawful requests, such as subpoenas or court orders, or in compliance with applicable laws. We generally do not disclose User information unless we have a good faith belief that an information request by law enforcement or private litigants meets applicable legal standards. We may share your information when we believe it is necessary to comply with applicable laws, to protect our interests or property, to prevent fraud or other illegal activity perpetrated through the Services or using the Wg name, or to protect the safety of any person. This may include sharing information with other companies, lawyers, agents, or government agencies. Nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.
Your Rights and Choices Regarding Your Information
Your Rights
Relevant data protection laws provide you certain rights regarding the protection of your data, including:
- the right to access – Upon request, Wg will confirm any processing of your Personal Data and, and provide you with a copy of that Personal Data in an acceptable machine-readable format;
- the right to rectification – You have the right to have Wg correct any inaccurate Personal Data or to have Wg complete any incomplete Personal Data;
- the right to erasure – You may ask the Wg to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion);
- the right to restrict processing – You have the right to ask Wg to suppress the processing of your Personal Data but Wg may still store your Personal Data;
- the right to object to processing – You have the right to object to your Personal Data used in the following manners: (a) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (b) direct marketing (including profiling); and (c) processing for purposes of scientific/historical research and statistics;
- the right to data portability – you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform fulfillment of member benefits with you. We will give you your Personal Data in a structured, commonly used and machine-readable format;
- the right to complaint to a supervisory authority – You have the right to file a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of Personal Data relating to you infringes upon your rights; and
- the right to withdraw consent – We rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
More information about your rights relating to Wg and the Services is provided via this Privacy Policy.
Access To The Information Wg Has Collected About You
Wg may provide certain tools and settings within the Services to help you access, correct, delete, or modify your personal information associated with the Services. Wg welcomes you to contact us regarding the information we have collected about you, including regarding the nature and accuracy of the data that has been collected about you, to request an update, modification, or deletion of your information, to opt-out of certain Services uses of your information, or to withdraw any consent you may have granted to Wg.
Please note requests to delete or remove your information do not necessarily ensure complete or comprehensive removal of the content or information posted, and removed information may persist in backup copies indefinitely. Please note that if you choose to delete your information or opt-out of the collection and use of your information, you understand that certain features, including but not limited to access to the Services, may no longer be available to you.
We may store the information we collect about you indefinitely, but information generally will be retained only for as long as necessary to fulfill the purposes for which the information was collected, or as otherwise required by law. Following termination or deactivation of an Wg Account, Wg may retain your information and content for a commercially reasonable time for backup, archival, and audit purposes.
Communications From Wg
Users may opt-out of receiving certain communications from Wg by following the unsubscribe process described in an email communication, or by contacting us using the contact information provided below. However, please note you may not opt-out of Services-related communications, such as account verification, changes or updates to features of the Services, or technical and security notices.
Do Not Track
Wg does not currently employ a process for automatically responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Per industry standards, third parties may be able to collect information, including Personal Data, about your online activities over time and across different websites or online services when you use Services. You may opt out of online behavioral ads at http://www.aboutads.info/choices/. You also may limit certain tracking by disabling cookies in your web browser.
Security Of Your Information
Wg takes reasonable efforts to secure and protect the privacy, accuracy, and reliability of your information and to protect it from loss, misuse, unauthorized access, disclosure, alteration and destruction. Wg implements security measures as we deem appropriate and consistent with industry standards. As no data security protocol is impenetrable, Wg cannot guarantee the security of our systems or databases, nor can we guarantee that personal information we collect about you will not be breached, intercepted, destroyed, accessed, or otherwise disclosed without authorization. Accordingly, any information you transfer to or from Services is provided at your own risk.
Additional Provisions Regarding The Services & Your Information
Transfer And Storage Of Your Information
Please note information Wg collects about you may be transferred, processed and/or accessed by us in the United States, or another country where we, or our Service Providers operate. Please be aware Personal Data may be transferred to, and maintained on, computers located outside of your state or country where privacy laws may differ from and may not be as protective as those where you live. If you are located outside the United States and choose to allow us to collect information about you, please be aware that Wg may transfer your Personal Data to the United States and process and store it there.
If you are located in the European Economic Area (“EEA”) or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information to a country or jurisdiction that does not have the same data protection laws as your jurisdiction, as disclosed in this Privacy Policy. It may also be processed by staff operating outside the EEA who work for us or for one of Service Providers as follows:
Website Hosting
Web.com
5335 Gate Parkway
Jacksonville, FL 32256
[INSERT COMPANY NAME AND CITY AND STATE] (data back up)
Safely Using Wg’s Services
Despite Wg’s safety and privacy controls, we cannot guarantee the Services are entirely free of illegal, offensive, pornographic, or otherwise inappropriate material, or that you will not encounter inappropriate or illegal conduct from other Users when using the Services. You can help Wg by notifying us of any unwelcome contact by contacting us using the information below.
Your California Privacy Rights
Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), Wg customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below or at privacy@wgusa.com
with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Changes to Our Privacy Policy
Wg may modify this Privacy Policy from time to time. The most current version of this Privacy Policy will govern our use of your information and will be located at wgusa.com. You may contact us to obtain prior versions.
Contact Wg
Sharon B. Mayer
Data Protection Officer
The Westfield Group
3 Becker Farm Road, Suite 303
Roseland, NJ 07068
privacy@wgusa.com