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 * Privacy notice


PRIVACY NOTICE



This privacy notice describes how The British Land Company PLC and other members
of our group of companies (which we will call 'we' or 'us') collect and process
personal information about you, how we use and protect this information, and
your rights in relation to this information.

This privacy notice applies to all personal information we collect or process
about you. Personal information is information, or a combination of pieces of
information that could reasonably allow you to be identified.

This privacy notice is effective from and including 12th August 2022. It may
vary from time to time so please check it regularly.

1. Personal information we use

We will collect personal information about you from a variety of sources,
including information we collect from you directly (e.g. when you contact us)
and information we collect about you from other sources, described below.

Note that we may be required by law to collect certain personal information
about you, or as a consequence of any contractual relationship we have with you.
Failure to provide this information may prevent or delay the fulfilment of our
obligations. We will inform you at the time your information is collected
whether certain data is compulsory and the consequences of the failure to
provide such data.

1.1. Information we collect directly from you
 1.  When you visit our websites the web server collects some basic information
     such as your browser type, MAC or IP address, internet service provider’s
     domain name, which pages you accessed on the site, and when. Details of
     cookies that we use on our websites can be found in our Cookies Notice.
 2.  Where you sign up for a newsletter, fill out a feedback form, complete a
     “contact us” form or enter a competition or promotion we collect personal
     information such as your email address, name, contact number, postcode and
     date of birth and for student events, we ask you to indicate that.
     Not all fields are mandatory and provision of the information in the non
     mandatory fields is optional, but if you provide less information this may
     limit your use of our online services.
     Where you enter into a competition or promotion we may share your details
     with the retailers from time to time at the property to which the
     competition relates. This will be made clear to you at the time you sign up
     to the competition or promotion.
 3.  Where you register online or place an order for a gift card we, or a third
     party service provider on our behalf, collect your name email address,
     billing and delivery address, phone number and credit or debit card
     details. These details may be shared with others, such as those providing
     merchant acquiring services and card issuers, but only where this is
     necessary to take a payment. In some circumstances these entities will be
     data controllers in respect of these details.
 4.  When we send emails to you we review whether these have been opened and
     whether you have clicked on any links within these.
 5.  When visiting some of our centres or other buildings we collect information
     from your mobile device and identify its location. This occurs whether or
     not you have used the Wi-Fi at the centre or other building. To opt out of
     the collection of your MAC or IP address and location turn off your
     device’s Wi-Fi and Bluetooth capabilities.
 6.  You may be asked to complete a survey or questionnaire either directly at
     our centres or other buildings or via email, SMS or post and in doing so we
     may ask for details such as your age, gender and postcode. The information
     captured is for research purposes and so we can understand the type of
     visitors coming to our centres and other buildings.
 7.  We occasionally stream videos on social media, such as Facebook live, and
     take and display photos of members of the public using and enjoying our
     centres and other buildings. Where we do so, we inform members of the
     public of this possibility through the signs placed around the centre or
     building.
 8.  We operate CCTV at our office buildings for the purposes of safety, crime
     prevention and prosecution, insurance, and property management. At some of
     our office buildings we also operate Body Worn Cameras for the purposes of
     safety, crime prevention and prosecution. We may also share our CCTV and
     Body Worn Camera footage with the companies that rent space in our office
     buildings to assist them with their own security and crime prevention
     management.
 9.  Where we own a building, we capture personal data within the system which
     controls access to our buildings. This comprises personal data of people
     who work in a building and those who visit it and includes name,
     occupation, employer and contact details. In relation to access control and
     visitor data where the data relates to us, we consider ourselves to be the
     data controller. Where the personal data relates to our tenants’ staff,
     contractors or visitors, our tenants may also be data controllers depending
     on the circumstances.
 10. Where we do not own a building but we provide property management services
     for the building owner and/or we provide access control system services for
     the building owner we capture personal data within the access control
     system. This comprises personal data of people who work in a building and
     those who visit it and includes name, occupation, employer and contact
     details. The data controller in these situations will be the building owner
     or the tenants of the building owner and we are a data processor.
 11. Where we own a building or we provide property management services for a
     building owner we collect data on accidents in order to comply with health
     and safety legislation.
 12. Where you are a tenant living at one of our buildings you provide us with
     personal data such as references and financial information, identity
     documentation, your contact details and the contact details of your next of
     kin, bank account details and information relevant to health and safety
     matters at the building (such as any difficulty you may have in using the
     stairs in the event of a fire). This is so that we can assess your
     suitability to be a tenant, allow you to pay the sums due under your lease
     and manage our buildings.
 13. Where you are a commercial tenant of at one of our centres or other
     buildings you provide us with personal data such as financial and business
     information, contact details and bank account details. This is so that we
     can assess your suitability to be a tenant, allow you to pay the sums due
     under your lease and manage our buildings.
 14. Where you work for a tenant of one of our centres or other buildings, we
     may be provided with your contact details by your employer if we need to
     liaise about estate management matters.
 15. Where we provide property management services for a third-party landlord
     (who is not us) we can be provided with personal data on tenants and their
     employees where this is necessary for us to carry out these services. We
     are not the data controller in these circumstances and are a data processor
     for the third party landlord.
 16. When using our BL Connect App, you provide us personal data when
     registering an account. You may also provide us a photograph as part of
     your account details. You are able to provide your consent to marketing and
     notifications.
 17. When signing up to an event via the BL Connect App, you provide us with
     contact details, including your mobile number, that enable the delivery of
     your tickets or other method of entry to the event.
 18. When purchasing products from our designated vendors available through the
     BL Connect App, you will provide your contact and delivery details to us.
     Payment for the products and/or services are processed directly with the
     payment provider.
 19. When using the BL Connect App for building access, the email provided to
     register for the App will be further processed in order to facilitate
     access control.
 20. When registering for the community forum, either directly or via the BL
     Connect App your name and email address are collected to create your
     account. You can optionally provide a photograph, your particular interests
     topics within the forum, your date of birth, ethnicity information, your
     job title, employer and department.
 21. When providing you operational notifications in relation to the campus and
     its buildings via the particular version of the BL Connect App you are
     using.
 22. Where enabled and in line with your marketing preferences, your device ID
     will be collected to provide push notifications for marketing / promotional
     materials.
 23. When utilising our Free WiFi service available at some of our retail and
     campus sites, you will be asked to connect and accept Terms of Service as
     provided by the service operator. We also collect a session identifier that
     ensures your WiFi connection works throughout the asset. This is deleted
     every 24 hours.
 24. When purchasing a residential asset from British Land, such as an apartment
     at our Canada Water development, we will collect personal data to effect
     the sale and to conduct our Know Your Customer (KYC) checks and any other
     legally required checks, such as Anti-Money Laundering. The data collected
     will be your full name, current address, email address, telephone numbers,
     data of birth and country of birth. Personal ID documents such as passport,
     driving license or other photographic ID documents will also be processed
     to ensure such checks are accurately conducted.

1.2 Information we collect from other sources
 1. If you use one of the Wi-Fi networks in our centres or other buildings, the
    Wi-Fi provider will collect personal information about you, such as your
    name, email address and postcode, which is required in order for you to log
    onto the Wi-Fi network. This is then shared with us. In some cases, the
    Wi-Fi provider makes the provision of your email address and your consent to
    receive marketing communications a mandatory field and you cannot access the
    Wi-Fi without providing this. We will however give you the opportunity to
    unsubscribe from all marketing communications from us in each email that we
    send to you.
 2. If you access one of the Wi-Fi networks in our centres or other buildings
    using your social media, such as Twitter or Facebook, or other online
    accounts, we are also provided with the data that is shared by your social
    media/online provider. Information on what personal data is being shared
    should be available to you from your own social media/online provider.
 3. Through your use of the Wi-Fi networks in our centres or other buildings
    data is also collected and shared with us which shows how often, how long
    and from which centre/building you are accessing the Wi-Fi and your
    movements within a centre/building and your browsing history.
 4. Third party car park operators which are not part of British Land operate
    CCTV and ANPR (Automatic Number Plate Recognition) cameras at some of the
    car parks at our properties. There are signs at the locations where this is
    used showing that it is in operation at that car park. Our car park
    operators can obtain the name and address of an individual from the Driver
    and Vehicle Licensing Agency (DVLA) for parking enforcement purposes. In
    most cases our car park operators are controllers of your number plate data
    when they use it to manage the terms and conditions of use of car parks at
    our sites including using it to apply parking charges for cars which outstay
    their allotted time. When car park operators are controllers for these
    purposes we are not responsible for the way in which our car park operators
    use your ANPR data. Please see their privacy notices for further information
    on how they handle your personal information.
 5. Number plate data is shared with us which shows frequency and duration of
    visits to a centre or other building and we obtain further information from
    the DVLA, including postcodes, in order to understand more about our
    customers and where they are coming from. This in turn helps us to better
    tailor our centres and other buildings to appeal to our customers and to
    manage our estate. We never use this information to identify the name or
    address of an individual.
 6. Our footfall operators use detectors to count the volumes of customers using
    our centres and other buildings by entrance and time of day.
 7. We use social media such as Facebook, either ourselves or through third
    party advertising agencies, to carry out digital advertising on the profiles
    of users who we think may be interested in our advertising campaigns based
    on events of ours that they have attended, what marketing communications
    they have subscribed to and which parts of our website they have visited or
    users who are in a similar demographic to such persons. Information on how
    advertising is shown to you should be available from your own social media
    provider.
 8. Where our mobile pass is enabled through the use of the BL Connect App, your
    mobile device operating system provider requires Location Services data to
    be enabled. Your location data is not collected or processed by British Land
    and is required only by your device operating provider.
 9. When accessing other geo-location based services, such as weather, transport
    information or parking services, your mobile device operating system
    provider requires Location Services data to be enabled. Your location data
    is not collected or processed by British Land and is required only by your
    device operating provider.

2. How we use your personal information and the basis on which we use it

We use your personal information to:

 1.  provide and personalise our services;
 2.  deal with your enquiries and requests;
 3.  comply with legal obligations to which we are subject and cooperate with
     regulators and law enforcement bodies;
 4.  contact you with marketing and offers relating to products and services
     offered by us and/or other members of our group (unless you have opted out
     of marketing, or we are otherwise prevented by law from doing so);
 5.  personalise the marketing messages and offers we send you to make them more
     relevant and interesting;
 6.  to contact you for research purposes, where you have consented to us doing
     so, in order to understand what you think of our sites and how we can
     improve them;
 7.  maintain the quality of our websites and to analyse the use of our websites
     in order to help guide improvements;
 8.  to better design and optimise our properties to improve the experience of
     our consumers;
 9.  allow you to pay for parking services;
 10. provide you with access passes to our buildings where this technology is
     enabled;
 11. drive our insights, research and data analytics programme. This is used for
     research, analysis, testing, monitoring, risk management and administrative
     purposes and to develop our business, inform business decision making and
     support the purposes identified elsewhere in this section by collecting
     statistics, traffic patterns, information on the movement around our
     centres and other buildings, demographics, customer satisfaction,
     geographic catchment, shopper analysis, retail mix, centre and building
     performance including footfall and identifying shopping trends; and
 12. we contract with third parties which in certain circumstances will be
     controllers of your personal data and responsible for managing it properly
     and in others will be processors who deal with your personal data in
     accordance with our instructions. Whether a third party supplier (who is
     not us) is a processor or controller of your personal data depends on the
     facts and where we appoint a third party processor of your personal data we
     will put a framework around what we expect them to do with it and how they
     manage it. We have identified in paragraphs 1.1(c) (payments), 1.1(i) and
     (j) (access control) and 1.2(d) (number plate data) certain cases where
     third parties are controllers of your personal data.
 13. We use your name and email address to register your account on the
     community forum
 14. We aggregate your access data to analyse the usage of the community forum.
 15. If you have consented to provide your ethnicity data, we aggregate this to
     analyse diversity of our offering in line with our diversity programme. You
     can withdraw the use of your data at any time by updating your profile
     within the forum.
 16. For investigating and protecting the integrity and security of the WiFi
     Service. Where required by applicable law, we may disclose any information
     as necessary to: (a) satisfy any law, regulation, court order, legal
     process or lawful governmental or police request; (b) if Company believes
     that doing so may protect your safety or the safety of others; (c) to
     operate the Service properly; (d) to enforce the Terms of Service; and/or
     (e) to protect Company legal rights.
 17. To send operational push notifications to your device when using the BL
     Connect App detailing instructions on how to unsubscribe from marketing or
     promotional material, services updates to the App or other service based
     communications as necessary.
 18. To send marketing / promotional push notifications to your device when
     using the BL Connect App where you have provided your consent to receive
     such notifications.

We must have a legal basis to process your personal information. In most cases
the legal basis will be one of the following:

 1. 1. Contract - to fulfil our contractual obligations to you, for example to
       fulfil the terms of a competition or promotion that you have entered or
       to provide you with information you have requested;
    2. Legal obligation - to comply with our legal obligations to you, for
       example health and safety obligations while you are on our premises, or
       to a third party (e.g. the police);
    3. Legitimate Interest - For example to understand how you use our services
       and our centres and other buildings and to enable us to derive knowledge
       from that which in turn enables us to develop new services and further
       tailor our centres and other buildings to appeal to a wide variety of
       persons. When we process personal information to meet our legitimate
       interests, we put in place robust safeguards to ensure that your privacy
       is protected and to ensure that our legitimate interests are not
       overridden by your interests or fundamental rights and freedoms; and
    4. Consent - We may obtain your consent to collect and use certain types of
       personal information when we are required to do so by law (for example,
       in relation to our direct marketing activities, cookies or when we
       process special category data). If we ask for your consent to process
       your personal information, you may withdraw your consent at any time by
       contacting us using the details at the end of this privacy notice.

3. Your rights and submitting a Data Subject Rights request

You have certain rights regarding your personal information, subject to local
law. Your rights under UK GDPR are

 * access your personal information
 * rectify the information we hold about you
 * erase your personal information
 * restrict our use of your personal information
 * object to our use of your personal information
 * receive your personal information in a usable electronic format and transmit
   it to a third party (right to data portability)
 * lodge a complaint with your local data protection authority.

In order to exercise those rights, you need to submit a Data Subject Rights
request (DSR) To make this straight forward for you and to help us respond to
that request quickly and accurately, please use the following link:

Submit my Data Subject Rights Request

(Please note that the form will open up in a new window).

3.1 Third Party Requests

Third parties are able to request personal data for law enforcement purposes,
insurance claims or other purposes as defined under the regulation. If you are a
third party requesting personal data, please use the following form to submit
your request:

Third Party Personal Data Request

(Please note that the form will open up in a new window).

4. Automated decisions about you

We make automated decisions about you based on your personal information in the
following circumstances:

 * to select personalized offers, discounts or recommendations to send you based
   on your browsing history; and
 * to personalise the marketing messages we send you to make them more relevant
   and interesting.

These types of decisions will not have legal or similar effects for you, but you
can still contact us for further information.

5. Information Sharing

We may share your personal information with third parties under the following
circumstances:

 * Service providers and business partners. We may share your personal
   information with our service providers and business partners that perform
   marketing services and other business operations for us. For example, we may
   partner with other companies to process secure payments, fulfil orders,
   optimize our services, send newsletters and marketing emails, support email
   and messaging services and analyse information.
 * British Land group companies. We work closely with other businesses and
   companies that fall under the British Land group family. We may share certain
   information about you with other British Land group companies for marketing
   purposes, internal reporting and in order to carry out the purposes listed in
   this notice. A list of companies within the British Land group is published
   annually in our most recent Annual Report and Accounts. These are available
   on our website: www.britishland.com.
 * Law enforcement agency, court, regulator, government authority, insurer or
   other third party. We may share your personal information with these parties
   where we believe this is necessary to comply with a legal or regulatory
   obligation, or otherwise to protect our rights or the rights of any third
   party or to put in place insurance for our centres and other buildings.
 * Asset purchasers and joint venture partners. We may share your personal
   information with any third party that purchases one or more of our properties
   or the companies with which we might jointly own a property.
 * We may share non-personally identifiable information with third parties such
   as partners, customers, tenants and suppliers, for example to show trends on
   the use of our centres and other buildings.

Because we operate as part of a large business, the recipients referred to above
may be located outside the jurisdiction in which you are located (or in which we
provide the services). See the section on "International Data Transfer" below
for more information.

6. Information Security and Storage

We implement technical and organisational measures to ensure a level of security
appropriate to the risk to the personal information we process. These measures
are aimed at ensuring the on-going integrity and confidentiality of personal
information. We evaluate these measures on a regular basis to ensure the
security of the processing.

We will keep your personal information for as long as we have a relationship
with you. Once our relationship with you has come to an end, we will retain your
personal information for a period of time that enables us to

 * Maintain business records for analysis and/or audit purposes or risk
   management purposes;
 * Comply with our business record retention requirements;
 * Defend or bring any existing or potential legal claims; and
 * Deal with any complaints regarding the services.

We will delete your personal information when it is no longer required for these
purposes. If there is any information that we are unable, for technical reasons,
to delete entirely from our systems, we will put in place appropriate measures
to prevent any further processing or use of the data.

7. International Data Transfer

Your personal information may be transferred to, stored, and processed in a
country that is not regarded as ensuring an adequate level of protection for
personal data under European Union law / by the European Commission. Where this
is the case we have put in place appropriate safeguards (such as contractual
commitments) in accordance with applicable legal requirements to ensure that
your data is adequately protected. For more information on the appropriate
safeguards in place, please contact us at the details below.

8. Contact Us

The British Land Company PLC is the controller responsible for the personal
information we collect and process (save in circumstances where we specify
otherwise).

If you have questions or concerns regarding the way in which your personal
information has been used, or would like to contact our Data Protection Officer,
please contact data.privacy@britishland.com .

We are committed to working with you to obtain a fair resolution of any
complaint or concern about privacy. If, however, you believe that we have not
been able to assist with your complaint or concern, you have the right to make a
complaint to the data protection authority of the United Kingdom using their
website https://ico.org.uk/.

9. Changes to the Policy

You may request a copy of this privacy notice from us using the contact details
set out above. We may modify or update this privacy notice from time to time.

Version 7.0 – 13th May 2022

Date Changes 25th May 2018 Updates in line with GDPR requirements 21st August
2019 Update to potential use of enhanced CCTV technology 6th November 2019
Update in relation to Body worn cameras 14th January 2021 Inclusion of the data
processed via the Broadgate App 8th July 2021 Processing of Device data to
facilitate access to the Guest
WiFi and additional data processed for student events 21st November 2021
Additional collection of geo-location data by third parties where such services
are switched on and the use of push notifications and associated data in the BL
Connect App. 13th May 2022 Updates to Community Forum registration and updated
references: Changing “Campus App” to BL Connect App 12th August 2022 Additional
section added 1.1 (x) in relation to the collection of Personal Data for
residential purchases


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The British Land Company PLC. Registered in England. Company No: 621920.
Registered Office: York House, 45 Seymour Street, London , W1H 7LX