This Policy describes the personal information handling practices of West Edmonton Mall Property Inc. or its subsidiaries and affiliated companies (“WEM”, “We” or “Us”) with respect to the WEM App and any related web services related thereto including without limitation the MyWEM Earn & Burn Loyalty Portal at (the “Portal”). We know how important your personal information is to you and we take your privacy seriously.  Please read the following to learn more about our Privacy Policy.

  1. Acceptance. By using or accessing the WEM App and/or Portal in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
  2. Terms of Use.  Your use of the WEM App and/or Portal is at all times subject to the Terms of Use which incorporates this Privacy Policy.  Any capitalized terms we use in this Privacy Policy without defining them have the definitions ascribed to them in the Terms of Use.
  3. Personal Information. This Privacy Policy covers our treatment of information about an identifiable individual ("Personal Information") that we gather when you are accessing or using the WEM App and/or Portal.  This Privacy Policy does not cover information that is not “Personal Information”, nor does it cover the collection, use or disclosure of Personal Information by companies we do not own or control.
  4. Collection and Use of Personal Information. We collect various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information in connection with your use of the WEM App and Portal, including providing access, personalizing and improving our services, allowing you to set up a user account and profile, allowing users to use the functionality, and to analyze how you use the WEM App and the Portal. In certain cases, we may also share some Personal Information with third parties as described below.
  5. Minors. As noted in the Terms of Use, minors who are under the age of majority in the place of residence are not permitted to use the WEM App or Portal without the permission of their parent or legal guardian. If you are a minor, please do not register for the WEM App or Portal without the consent of your parent or guardian.
  6. Cancellation.  You may disable your account at any time by signing in and cancelling either through the WEM App or via the Portal.  This means that your account will no longer be active, your data will be stored in compliance with our Retention Policy. [Note:  for confirmation from client as to whether client is proceeding on this basis].
  7.  What Information is Collected?

    1. Information Provided To Us

      We receive and store any information you provide to us or that we are able to collect from your WEM App or Portal account. This might include Personal Information such as your name (first and last), date of birth, email address, mailing address, and phone number.  

      If you provide your third-party social-media account credentials to us for sign-in purposes ("Third Party Account Information"), you understand some content and/or information in those accounts may be transmitted into your WEM App or Portal account if you authorize such transmissions, and that Third Party Account Information transmitted to WEM is covered by this Privacy Policy.

      If you have provided us with a means of contacting you, we may use such means to communicate with you. For example, we may send you updates about our services, informational updates, surveys or promotional offers (either on our own behalf, or on behalf of other businesses), or communicate with you about your use of the WEM App or Portal. Also, we may receive a confirmation when you open a message from us. This confirmation helps us make our communications with you more relevant and improve our services. If you do not want to receive communications from us, please indicate your preference by clicking the unsubscribe preferences at the bottom of the email you received.  Please note that you may not be able to opt out of certain service-level communications that we deem critical to your use of the WEM App or Portal.

    2.  Information Collected Automatically

      Whenever you interact with the Portal, we may use “cookies” to receive and record information on our servers, logs and databases from your browser, such as IP address, location details, "cookie" information, mobile device, operating system, the type of browser, and other indicators of how you are interacting with the WEM App.  "Cookies" are identifiers we transfer to your device that allow us to recognize your browser, and tell us how and when various pages and features in the WEM App or Portal are visited or used and by how many people. You may be able to change the preferences on your browser, application or device to prevent or limit your device's acceptance of cookies, but this may prevent you from taking advantage of some of our features.

  8. Sharing of Personal Information. Any sharing of your Personal Information with third parties would only occur as permitted by this section:

    1. Aggregated Personal Information.  We, or partners on our behalf may anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners or use that information for your participation in our Earn and Burn Loyalty Program, marketing or promotional items. We may also provide aggregate information to our partners, who may use such information to understand how often and in what ways people use the WEM App and Portal. However, except as described below, we do not disclose aggregate information to a partner in a manner that would identify you personally, as an individual.

    2. Advertisers. We may allow advertisers and/or merchant partners ("Advertisers") to choose the types of users who will see their advertisements and/or promotional offers. You agree that we may provide any of the information we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers.  We may share such aggregated personally identifiable information with Advertisers in order to deliver targeted advertising or offers to users of the WEM App.  

    3. Our Partners, Other Businesses and Third Parties. In certain situations, our partners, businesses or third party websites ("Third-Parties") may offer items or provide products or services to you through the WEM App  or Portal (either alone or jointly with us). You will have the option of conducting a transaction directly with that Third-Party. We will share your Personal Information with that Third-Party only to the extent that it is related to such transaction or service, and to the extent that you have explicitly accepted incremental terms with that Third-Party whereby you acknowledge and authorize us to share your Personal Information. These incremental terms may be presented as part of promotional offers (either on the Third-Parties' site or on WEM-branded properties including our ecommerce site, or within customized setup steps that appear in the WEM App or on the Portal).

      We have no control over the policies and practices of Third-Parties as to privacy or anything else, so if you choose to take part in any transaction or service relating to an Third-Party, please review all such business' or websites' policies. If you decide you no longer want to share Personal Information with a Third-Party, you may no longer be entitled to receive certain benefits from the Third-Party or have access to MyWEM without establishing a new account or relationship with us.

    4. Agents. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
    5. Business Transfers. We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a Third-Party.

    6. Data Storage Notification.   Your information may be transmitted and stored  on an international basis with our partners and Service providers who assist us with the WEM App and Portal, along with the operation of the Earn and Burn Loyalty Program.  By using the WEM App and any related web services, including without limitation the Portal, you acknowledge and agree that our collection, use , disclosure and processing of your information may occur on such basis.  In addition, you acknowledge and agree that we may share your information with our partners and service providers for the purposes described in this Privacy Policy and acknowledge our partners and service providers are based in international territories (i.e. _______ ) which  have data protection and law enforcement rules and standards  that are different to these in your country of residence.

    7. Protection. We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of SmartThings, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction

  9. Opt In / Opt Out. You can choose not to opt-in, or you can opt not to disclose information to us, but some Personal Information may be needed to register with us or to take advantage of some of our special features or to use the WEM App or Portal in any form.

  10. Changes. We may need to change this Privacy Policy from time to time in response to changes to the WEM App or our other services. We will alert you to changes by placing a notice on the WEM App and/or by sending you an email. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the WEM App, and you are responsible for reading and understanding them. You are bound by any changes to the Privacy Policy when you use the WEM App at the time and after such changes have been posted. Use of the Personal Information we collect now is subject to the Privacy Policy in effect at the time suchinformation is used.

  11. Contact. You can view, update, and delete your Personal Information as permitted within the WEM App. If you have any questions about this Privacy Policy or viewing or updating your Personal Information we have on file about you, please contact us at