Last updated: 10 January 2022
VIA Outlets (the “VIA”) is committed to protecting your privacy. This Privacy Policy explains how VIA collects and uses personal data about you if you:
a) Access and use the website located at www.viaoutlets.com (the "site")
b) Contact us in relation to any of the above.
Please note that other privacy policies apply in relation to our use of your personal data other than in connection with the types of interaction listed above. We will direct you to these policies at the time of such other interaction.
Please read this Privacy Policy carefully to find out about:
- Who we are
- Personal data we collect about you, how it is used and why, including the legal basis for our processing
- Who we share your personal data with
- How we use cookies
- How long we keep your personal data for
- Our policy on children’s personal data
- Your rights
- Links to other websites
- Changes to this Privacy Policy
- How you can contact us
If you have any questions about this Privacy Policy or you wish to exercise any of your rights in relation to your personal data, please contact us at privacy.via@viaoutlets.com
When you interact with VIA for one or more of the reasons set out at the start of this Privacy Policy, the personal data that VIA collects from you, or that you provide to VIA, is controlled by VIA Outlets BV, a private company with limited liability under the laws of the Netherlands, having its seat in Amsterdam the Netherlands and its address at WTC Building Schiphol, 4th floor Tower F, Schiphol Boulevard 153, 1118 BG Schiphol, The Netherlands, registered with the Chamber of Commerce of Amsterdam under number 76586537 (“VIA OUTLETS BV”).
References in this Privacy Policy to “we” or “us” are to this company.
2. Personal data we collect about you, how it is used and why, including the legal basis for our processing
The section “Details of the personal data we collect about you, how it is used and why, including the legal basis for our processing” at the end of this Privacy Policy describes the types of personal data we collect about you, how it is used and why. It also sets out the legal basis for us processing personal data about you in this way.
You entitle us to combine the personal data we collect about you through the different channels you use to interact with us (for example, browsing our Site or contacting us). In addition, we may combine the information we hold about you with information about you held by our selected partners and/or retail outlets where you have agreed that they can share your information with third parties. It is in our legitimate interests to do this so that we can form a clearer picture about our customer base and as a result improve our services and marketing activities (which could also benefit you).
3. Who we share your personal data with
For the purposes set out in the section “Personal data we collect about you, how it is used and why, including the legal basis for our processing”, we sometimes provide your personal data to other companies within the VIA Outlets portfolio and certainservice providers who perform certain business operations on our behalf. This includes:
a) Codilink UK Ltd (trading as Coniq) incorporated and registered in England and Wales with company number 06269999 whose registered office is at James Cowper Kreston 8th Floor South, Reading Bridge House, George Street, Reading, England RG1 8LS, who assist us with storing and combining data;
b) Codilink Dooel Skopje (a subsidiary of Codilink UK Ltd) incorporated and registered in Macedonia with company registration number 7274980 and registered address at 8 mi Septemvri Blvd, 16, Hyperium Business Centre, Skopje, 1000, Macedonia. In order to ensure your data is access and processed securely, the appropriate safeguards in the form of ‘model clauses’ (please see below) are in place.
c) service providers who help us with our information technology systems (including security);
d) a cloud provider who hosts the information stored in our customer database.
In some cases, the personal data we collect from you may also be accessed or processed outside the EEA. Such destinations may not have laws which protect your information to the same extent as in the EEA. We have obligations to ensure that your personal data is only accessed or processed from territories outside the EEA where the European Commission has decided that the territory in question ensures an adequate level of protection (known as a ‘white listed’ territory) or, in the absence of a decision by the European Commission, there are appropriate safeguards in place to protect your personal data. For example, if your personal data is accessed or processed from a territory outside the EEA which is not white listed, the appropriate safeguards may be provided by standard data protection clauses adopted by the European Commission (known as ‘model clauses’).
We also have obligations to ensure that your personal data accessed or processed by us or by our service providers and processors 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 Privacy Policy.
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 the section “How you can contact us”).
In addition, we may share your personal data with other organisations in the following circumstances:
a) if we are required by applicable law or a public authority to share information about you;
b) if we need to share information about you in order to establish, exercise, defend or protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, exchanging information with other organisations for the purposes of fraud protection; and
c) to successors in title or replacement operators of all or part of our respective businesses.
4. How we use cookies
We use cookies to enable our systems to recognise your device so that we can personalise and improve your customer experience whilst using our Site and provide you with relevant online advertising. Please see the section “Personal data we collect about you, how it is used and why, including the legal basis for our processing” and our Cookie Policy available at https://www.viaoutlets.com/cookie-policy/to find out more.
5. How long we keep your personal data for
We retain your personal data for no longer than is necessary for the purposes for which the information is collected (see the section “Personal data we collect about you, how it is used and why, including the legal basis for our processing” for details of the relevant purposes). When determining the relevant retention periods, we will take into account factors including:
a) legal obligation(s) under applicable law to retain data for a certain period of time, for example, accounting obligations;
b) statute of limitations under applicable law;
c) (potential) disputes; and
d) guidelines issued by relevant national data protection regulators.
Otherwise, we securely erase your information once this is no longer needed for the purposes for which the information is collected.
6. Our policy on children’s personal data
We do not knowingly collect the personal data of children under 16 years of age, without the prior consentor authorisation of the holder of parental responsibility over the child.
7. Your rights
By law, you have the following rights with regard to your personal data. Further information and advice about your rights can be obtained from your national data protection regulator.If you wish to exercise any of your rights in relation to your personal data, please contact us at privacy.via@viaoutlets.com.
Right to be informed
What does this mean? 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 Privacy Policy.
Right of access
What does this mean? 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 Privacy Policy). This is so you’re aware and can check that we’re using your personal data in accordance with data protection law.
Rightto rectification
What does this mean? You are entitled to have your personal data corrected if it’s inaccurate or incomplete.
Right to erasure
What does this mean?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.
Right to restrict processing
What does this mean? 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.
Right to data portability
What does this mean? You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your personal data between our IT systems and theirs safely and securely, without affecting its usability.
Right to object to processing
What does this mean? You have the right to object to certain types of processing
Right to withdraw consent
What does this mean? You have the right to withdraw your consent at any time. The withdrawal does not affect the lawfulness of previous processing, but from the time you withdraw your consent we will not process any further personal data. As noted above, if you withdraw consent then we may not be able to provide you with all the benefits that may be offered by VIA.
Right to lodge a complaint
What does this mean? You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.
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 will respond to your request 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 will let you know.
To find out how to submit a request, please see the section “How you can contact us”.
8. Links to other websites
The Site may contain links to other websites operated by unrelated companies and persons (“Third Party Website”). These links are provided for your information only. The inclusion on the Site of any link to a Third Party Website does not mean that we accept any responsibility for that Third Party Website, its content or use, or the use of any features, products and/or services made available through that Third Party Website. We have no control over Third Party Websites or any information or materials contained on them and have not investigated, monitored or checked any Third Party Websites for accuracy, completeness or conformance with applicable laws and regulations. We are not responsible for any damages or injuries caused as a result of your use of, or reliance on, Third Party Websites or any information or materials contained on them. You access and use Third Party Websites at your own risk.
9. Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy at any time, so please check our Site regularly to keep informed of changes.
10. How you can contact us
If you have any questions about this Privacy Policy or you wish to exercise any of your rights in relation to your personal data, please contact us at privacy.via@viaoutlets.com.
Type of interaction with us:
- Accessing and using our Site
Types of personal data we collect:
- We collect cookies from your device when you visit our Site.
- Please see our Cookie Policy available at https://www.viaoutlets.com/cookie-policy/to find out more.
Purpose of processing (how and why we use your personal data):
Cookies enable our systems to recognise your device so that we can:
a) Please see our Cookie Policy available at https://www.viaoutlets.com/cookie-policy/ to find out more, including how to accept or reject new cookies and to delete existing cookies.
b) Visiting our Site with your browser settings adjusted to accept cookies tells us that you want to use our Site and that you consent to our use of cookies as described in this Privacy Policy and our Cookie Policy available at https://www.viaoutlets.com/cookie-policy.
c) Provide important features and functionality on our Site;
d) Improve the way our Site works by providing you with personalised access and an enhanced Site;
e) Monitor and analyze usage of our Site to improve its performance;
f) Deliver online advertising that we believe is most relevant to you; and
g) Measure the effectiveness of our marketing communications.
Please see our Cookie Policy available at https://www.viaoutlets.com/cookie-policy/ to find out more, including how to accept or reject new cookies and to delete existing cookies.
Legal basis for processing:
Visiting our Site with your browser settings adjusted to accept cookies tells us that you want to use our Site and that you consent to our use of cookies as described in this Privacy Policy and our Cookie Policy available at https://www.viaoutlets.com/cookie-policy/.
Controller(s) of your personal data:
VIA Outlets BV
Type of interaction with us:
Contacting us
Types of personal data we collect:
If you contact us regarding this Privacy Policy by, for example, email, we may keep a record of that correspondence and any personal data that you provide, such as your name and email address.
Purpose of processing (how and why we use your personal data):
We use your personal data so that we can respond to your communications.
Legal basis for processing:
It is in our legitimate interests to collect and use the personal data referred to in the section above so that we canserve our customers’ needs.
Controller(s) of your personal data:
If you contact us regarding any of the interaction types described above, the data controllers of any personal data you provide are the companies listed beside the relevant interaction type.