Last Updated: May 25, 2018
This Notice sets out the privacy practices of Simon Property Group, L.P. and its affiliates (“Simon“) for their websites (” Sites“), mobile applications (“Apps“) and Internet-based activities (“Web Services“), including the Sites at simon.com, premiumoutlets.com, our e-commerce platform at shoppremiumoutlets.com (“SPO“), business.simon.com, investors.simon.com, careers.simon.com, family.simon.com, dashboard.simon.com, syf.org, traveltrade.simon.com, simonmuse.com, simoninsider.com, simonventures.co and said.simon.com. The Web Services include, for example, e-mail, push notifications and SMS/MMS communications, the Facebook Messenger bot and the Amazon Alexa custom Simon skill. The Sites, together with the Apps and Web Services, are the “Platform.”
The Simon entity that operates a Site or App is identified at that Site or App. The words “user,” “you” and “your” mean users of the Site or App, and the words ” we,” “our” and “us” mean the Simon entity that that operates the Site or App.
This Notice explains the information that we gather about you while you use the Platform, and the ways in which we use and share that information. This Notice does not apply to any information you may provide us, or that we may collect, offline or through other means (for example, at a live event or through the mail).
1. What We Collect
We collect information through the Platform, including personal information about you. Some information you mayprovide to us voluntarily, while other information we gather through various means. We will retain that information for so long as you have an account or we have a legal or business purpose for it, unless otherwise stated herein. Your personal information may be collected, processed and stored on servers in the United States and in other countries. The following explains what we collect and how we collect it.
1.1 Information You Voluntarily Provide
You may provide us with information in order to use, or participate in, certain features of the Platform, such as registering for an account; making a purchase and/or requesting support from the Shop Premium Outlets marketplace; for Simon Giftcard®, Simon Rewardcard Visa Prepaid Card or American Express Simon Rewardcard purchases; retailer gift card purchases ; gift card registrations ; gift card activations ; creating a gift card account ; gift card balance checks ; using one of many contact us forms; applying for a job; registering for or using the Simon retailer showcase program ; using the free in-center Simon Wi-Fi network; signing up for Simon press release news alerts; submitting a survey response; requesting support or assistance ; signing up and/or using the Simon Family program ; leaving a comment within a Simon SAID story; signing up for or using Simon Insider loyalty programs; creating a Premium Outlets VIP Shopper Club account; signing up for e-mail newsletters (a/k/a the Simon Mall Insider ® program); signing up for Simon Muse e-mail newsletters; starting a conversation with the Simon bot for Facebook Messenger; joining or using the Simon Travel Trade community ; signing up for mobile SMS alerts (a/k/a the Mobile Shopper Club® ); making a donation or applying for a scholarship with the Simon Youth Foundation; RSVP’ing to an event; sharing a picture to be featured within a #foundatsimon or Simon SAID image gallery; signing up for the Shop Premium Outlets newsletter; or playing any instant win game or sweepstakes.
Account. If you register for an account, you will need to provide certain information, such as your first and last name, password and e-mail address. You may also have the option to provide additional information for a user profile, such as your photo and birthdate. You may log into your account to access and edit certain information associated with your account, such as your contact information.
Online purchases. If you make a purchase, you will need to provide the following information:
Financial information. To pay for your purchase on SPO you will provide our third party payment processing company, currently Spreedly, Inc., certain financial information, such as your credit card number, type and expiration date, along with your name and address. The payment processor will use and share the information as explained below.
In order to provide information for your receipts and to facilitate future orders you may make, we collect and store your credit card type and the last four digits of your credit card number. We do not collect any other financial information in connection with SPO.
If you purchase items on our other Sites, such as a Simon Giftcard, we collect your credit card number and associated information, which we process in order to fulfill your purchase. In order to provide information for your receipts, past orders and to facilitate future orders you may make, we may store your credit card if you so choose.
Purchase and shipping information. We collect the information in your shopping cart, such as the specific products that you wish to order and the shipping information for those products, including the recipient’s first name, last name, mailing address, e-mail address and telephone number.
Other information. You may have the opportunity to provide information at other areas of the Platform. These include, for example:
- Communications with us. If you provide feedback through a form or contact us via e-mail, we will collect your name and e-mail address, as well as any other content or information you provide.
- Surveys, promotions, etc. We collect information you provide by participating in surveys, sweepstakes, contests, promotions or other solicitations.
- Public postings. We may also collect information you post at other areas of the Platform, such as public areas of the Platform including message boards, blogs and reviews.
Children. The Platform is not directed to children under the age of 18. We do not knowingly collect personal information from children under the age of 18, nor do we knowingly distribute such information to third parties. If we become aware that we received personal information from someone under the age of 18, we will take steps to delete such information from our records. If you believe we have personal information from someone under 18, please contact us at firstname.lastname@example.org.
We use and disclose the information collected as explained in this Notice. How we use and disclose that information may be supplemented in the area where you provide the information.
Terminating Your Account. You may terminate your account by e-mailing email@example.com. If you terminate your account, any association between your account and information we store will no longer be accessible through your account. We may retain the information collected prior to termination for archival and/or legal purposes. Any information you shared in public areas of the Platform will remain in those areas until it is deleted in accordance with our data retention policy.
1.2 Information We Gather
When you access the App using your mobile device, we collect your mobile phone number and the unique device ID number of the mobile device; the unique identifier assigned to your mobile device for advertising purposes, such as your Identifier for Advertising (IDFA) on iOS devices or your Google Advertising ID (AAID) on Android devices; your Bluetooth MAC address (a unique number that is assigned to your Bluetooth radio by the manufacturer); as well as information about your mobile device model, operating system and version, and/or mobile communications carrier.
You may adjust the settings on most devices to allow the Sites or App to gather, or to disable it from gathering, location positioning data. Certain features, such as a mall locator, may not work as effectively if you disable location positioning data.
We also may have arrangements with third parties to collect the foregoing data as service providers to us.
Do Not Track. Do not track is a voluntary program among Internet advertisers that is intended to give users the ability to opt-out of interest-based advertising. There are a few ways in which your computer may transmit a “do not track” signal to certain websites and online services you visit, and currently no standard has been established. We do not respond to do not track signals, and the settings in your browser will have no effect on the Site.
2. How We Use Information
We may create de-identified information records and “aggregate data” reports about how users use the Platform, such as the number and frequency of visitors to the Sites or the Apps, which may be derived from technical and/or personal information. This information cannot be readily tied back to you, your account, your web browser or your mobile device. We may use this de-identified information for business purposes, such as to enhance the content of and improve the Platform, for example by allowing us and third parties authorized by us to ascertain how often individuals use areas of the Platform so that we may focus on and improve those areas.
We may use technical data we gather to enable us or a third party to provide you with information about products and services while you are using the Platform.
Location Information. We may use the location and Wi-Fi information gathered to generatereports, such as foot traffic at our malls, which we may share with retailers and third parties to improve the consumer experience at our malls, and in order to provide specific services, such as locating a nearby mall when you make such a request. We may also use this information to send you news about the mall, such as promotions from mall retailers, and to provide advertisements about goods and services that may be of interest to you. Third parties may process location data as service providers to us, such as to facilitate marketing campaigns or to perform fraud detection and analysis on our behalf.
Advertising. We use analytics services, advertising companies, advertising networks and advertising exchanges to help analyze how users use and navigate the Platform and to engage in advertising on our behalf, on behalf of the retailers for which products and services are available within Shop Premium Outlets and on behalf of mall retailers, including contextual advertising and interest-based advertising. These companies may use data about your visits to the Platform and other websites or mobile applications in order to provide advertisements about goods and services that may be of interest to you which are offered by us or by our retailers. Those companies are instructed to follow industry guidelines with regard to interest-based advertising, such as the Digital Advertising Alliance’s principles for online behavioral advertising. Among other things, the ads that are displayed to you should have the AdChoices icon or a similar mechanism which you may click to direct you to a website where you may opt-out of interest-based advertising. If you would like more information about this practice and how to opt-out of receiving communications from these third-party advertising companies, please visit this link.
3. How We Share Information
We share your information with others as follows.
Other users. If you create an account, information such as your username, photo, birthday and other information you enter may be displayed to other users of the Platform to facilitate user interaction within the Platform. We will not reveal your contact information to other users without your permission.
Some of your activity on and through the Platform is public by default. This may include, but is not limited to, content you post publicly through message boards, blogs or reviews on the Platform. If you choose to provide information using certain public features of the Platform, that information may be governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information.
Promotions. If we sponsor surveys, sweepstakes, contests, promotions or other solicitations for third parties, we may share the information you provide with those third parties. We may also share such information with third parties that provide marketing and advertising on our behalf, as well as with our retailers.
Your transactions. We may share your information to fulfill the purpose for which you provide it, such as to purchase merchandise or a Simon Giftcard and have it shipped to you, or for any other purpose disclosed by us when you provide the information, or with your consent, or to third parties designated by you. We may share financial information with our third-party payment processing company, our credit card gateway and fraud detection company, our remote checkout bot company and any applicable retailers.
To fulfill a purchase on Shop Premium Outlets, we will share your purchase and shipping information with our third party e-commerce enabler, currently Two Tap, Inc., which will provide the information to the retailer(s) from which your purchase is made. The use of your information by these parties is subject to their respective privacy notices. Generally, they will use the information for customer service, fulfillment, shipping and returns. The retailer may pass your information to third parties, such as the shipping carrier (USPS, UPS, FedEx, etc.). We may also share your purchase and contact information with third parties that provide marketing and advertising services on our behalf, as well as with our retailers.
Social Media. We may share certain data, such as your telephone or e-mail contact information, with social media outlets, like Facebook and Instagram, in connection with our agreement to share such information with them, in order to provide more targeted advertisements about goods and services from us or mall retailers that may be of interest to you.
Location data. We may share location data collected from your ISP, Sites and/or the Apps via your mobile device with third parties that provide marketing and advertising on our behalf, as well as for our retailers, and who provide analytics services. We may also share aggregate location data with Shop Premium Outlets Retailers.
Third Party Service Providers. We may share your information with third party service providers that assist us in operating the Platform, for and on our behalf, such as a hosting company or e-mail provider. They are instructed to use the information only to assist us in operating the Platform. We may also share with third parties your information with us, such as sharing your feedback with our vendors to improve the Platform. We may also share your information with third parties that provide marketing and advertising on our behalf, as well as with our retailers.
We may share de-identified data concerning retail consumer behavior with third parties, including entities with whom we have entered into an agreement to provide such de-identified data for analytics or marketing purposes.
We may also share with our retailers de-identified segment information, which is information that does not identify you personally, but allows the retailers to know more generally the products being purchased through, and the consumers who are using, the Platform.
Corporate activity. If we sell assets (or the assets of a division or subsidiary) to another entity or if we are acquired by or merged with another entity, we may share with such entity information about users of the Platform that is related to that part of our business that is sold to or acquired by or merged with the other entity.
Financial information. We do not collect financial information. If you make a purchase on Shop Premium Outlets, any financial information you provide is collected by our payment processor, currently Spreedly, Inc., and is governed by their privacy notice. To process your purchase, the payment processor will pass your information on to a third party e-commerce enabler, currently Two Tap, Inc., which will provide the information to the retailer from which your purchase is made. The use of that information is governed by Two Tap’s privacy notice. The retailer(s) will fulfill your purchase. We ask the retailer to use your information only to fulfill the purchase. You may check the applicable retailer’s privacy notice if you have questions regarding their use of information.
4. Information Security
We endeavor to protect the security of the information collected through the Platform and implement generally accepted standards of information technology security designed to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. It is not possible, however, to guarantee the security or integrity of information disclosed online due to, among other things, technological limitations and the fact that no data accessible through or transmitted via the Internet is completely secure. Shop Premium Outlets orders involve processing of data by third parties, such as retailers, online gift card providers, ticket agents, credit card processing companies, fraud detection service providers, issuing banks, card network issuers, shipping/fulfillment companies, and other parties in order to complete an order. Those parties with which we contract are required to maintain reasonable measures designed to safeguard the security of the data they process; however, we do not otherwise have control over and are not responsible for their handling of such data.
Links to Other Sites
The Platform may have links to third party websites, services and applications, such as websites hosted by third party retailers (collectively, “Third Party Sites“). When you click on such a link, you will leave the Platform and be directed to the Third Party Site and when you leave the Platform, you and are no longer subject to the terms of this Notice. This Notice does not apply to Third Party Sites, and we do not review or endorse, and are not responsible for, any Third Party Sites, the content therein, or their privacy practices. This Notice also does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Simon’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation.
5. Non-U.S. Residents
By accessing the Platform, establishing an account or making a purchase, you consent to the processing of your personal information as provided in this Notice. You may withdraw that consent by contacting us at firstname.lastname@example.org. You are required to provide certain personal information in order to open and maintain an account. Your failure to provide such information may preclude you from establishing an account or may subject your account to termination. An account may be required to make certain types of online purchases, as a guest style checkout option is not always available across all of our Sites and Apps.
If at any point you believe the personal information we process about you is incorrect, you may access your account and modify it there, or otherwise request to see the information and to have it corrected or deleted by contacting us at email@example.com. If you wish to object to or raise a complaint on how we have handled your personal information, you may contact our Data Protection Officer who will investigate the matter. You may also be able to have your personal information transferred by contacting us at firstname.lastname@example.org.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with law, you may complain to the data protection authority in your jurisdiction.
The data controller for personal information collected pursuant to this Notice for:
- shoppremiumoutlets.com is Shop Simon, LLC.
- syf.org is Simon Youth Foundation, Inc.
- all other Sites and Apps is Simon Property Group, L.P.
Our Data Protection Officer is Patrick M. Flanagan and you may contact him at email@example.com.
6. Changes to this Privacy Notice
We may amend this Notice from time to time. All versions of the Notice are dated with the effective date of that version of the Notice (i.e., the date on which the applicable version of the Notice was posted to the Platform). Our use of information we learn about you will be governed by the most recent Notice in effect. Your use of the Platform signifies your assent to the most recent Notice in effect.