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Effective URL: https://www.simon.com/legal/privacy/california
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CALIFORNIA PRIVACY NOTICES


LEGAL NOTICES

Terms of Use Privacy Policy California Privacy Rights Canada Privacy Rights
Colorado Privacy Rights Cookie Policy Web Accessibility Statement API Terms of
Use Code of Conduct Code of Business Conduct & Ethics Digital Assets Terms of
Use Directories & Screens Privacy Policy Diversity & Inclusion Policy Mobile
Text Terms of Use Opt Out/Unsubscribe Assistance Retailer Showcase Terms of Use
Social Media Guidelines Suppliers Code of Conduct Tax Documents Access Agreement
User Generated Content Terms of Use VIP Passport Participation Agreement Wi-Fi
Terms of Use
 * Terms of Use
 * Privacy Policy
 * California Privacy Rights
 * Canada Privacy Rights
 * Colorado Privacy Rights
 * Cookie Policy
 * Web Accessibility Statement
 *  
 * API Terms of Use
 * Code of Conduct
 * Code of Business Conduct & Ethics
 * Digital Assets Terms of Use
 * Directories & Screens Privacy Policy
 * Diversity & Inclusion Policy
 * Mobile Text Terms of Use
 * Opt Out/Unsubscribe Assistance
 * Retailer Showcase Terms of Use
 * Social Media Guidelines
 * Suppliers Code of Conduct
 * Tax Documents Access Agreement
 * User Generated Content Terms of Use
 * VIP Passport Participation Agreement
 * Wi-Fi Terms of Use

Last Updated: November 16, 2023

These California Privacy Notices supplement the information in the Simon Privacy
Policy and applies solely to California residents providing personal information
to us. This California Notice uses certain terms that have the meaning given to
them in the California Consumer Privacy Act (“CCPA”) of 2018 (as amended by the
California Privacy Rights Act (“CPRA”) of 2020) and related regulations.

We collect this personal information directly from residents of California, as
well as from social media platforms (e.g., if the individual has connected a
social media account to an account on our Sites); referrals; joint marketing,
co-branding, co-promotional, or Advertising Ventures; and sources of demographic
and other information, including through devices you used to interact with us
through our Sites. All sources of personal information collected are noted in
the “Personal Information We Collect,” “How We Use Your Personal Information,”
“How We Collect Personal Information,” and “Who We Disclose Personal Information
to and Why” sections of the Simon Privacy Policy.


CATEGORIES OF PERSONAL INFORMATION COLLECTED, DISCLOSED, SHARED, OR SOLD

The categories of personal information that we collect, disclose, share, or sell
are in the table below and categories of third parties to whom each category of
personal information is disclosed, shared, sold, or processed for the purpose of
targeted advertising. The purposes for processing these types of personal
information are listed below the table.

Category of personal information

To whom may we disclose such information

Sold or Shared to

Identifiers, such as name, IP address, e-mail address, and online and device
identifiers

Service providers that we use to provide you the Sites.

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

Advertising and Data Technology Vendors.

Internet or other electronic network activity information, such as hardware
model, device software platform/OS and firmware, mobile carrier, preferred
languages, and in some cases, browser type, Internet service provider,
referring/exit pages and URLs, and clickstream data

Service providers that we use to provide you the Sites (including, without
limitation, cloud-based customer service and survey tools we use, and payment
processors).

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

Advertising and Data Technology Vendors.

Characteristics of protected classifications under California or federal law

Service providers that we use to provide you the Sites (including, without
limitation, cloud-based customer service and survey tools we use, and payment
processors).

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

N/A

Commercial information, including financial information, products or services
purchased, or other purchasing or consuming histories or tendencies

Service providers that we use to provide you the Sites (including, without
limitation, payment processors and point-of-sale providers).

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

Advertising and Data Technology Vendors.

Audio, electronic, visual, and other similar information, such as

(1) CCTV camera footage taken from our centers and/or on-site weapons detection
systems or

(2) photos taken by shoppers on our interactive directories, which we store (so
that they can be shared back with the user that took it via a public weblink)

Service providers that we use to provide you the Sites (including, without
limitation, providers of Security Services, providers or hosts of websites or
applications, that are active when you interact with or receive advertisements
or images back to yourself at our Directories, Screens, Sites or Apps).

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

To the General Public or Other Users to the extent you have provided such
information in a public forum or associated with an account profile on our
Sites.

N/A

Non-Precise Geolocation Data

Service providers that we use to provide you the Sites.

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

Advertising and Data Technology Vendors.

Professional or employment-related information

Service providers that we use to provide you the Giftcard volume purchase site,
employment application and lifecycle management, or any part of the Sites for
which you may register an account or post such content yourself.

Affiliates for whom we may be a service provider to provide you the Giftcard
volume purchase site, employment application and lifecycle management, or any
part of the Sites for which you may register an account or post such content
yourself.

Government, regulatory, or law enforcement agencies.

To the General Public or Other Users to the extent you have provided such
information in a public forum or private forum associated with an account
profile on our Sites.

N/A

Education Information

Service providers that we use to provide you the Giftcard volume purchase site,
employment application and lifecycle management, or any part of the Sites for
which you may register an account or post such content yourself.

Affiliates for whom we may be a service provider to provide you the Giftcard
volume purchase site, employment application and lifecycle management, or any
part of the Sites for which you may register an account or post such content
yourself.

Government, regulatory, or law enforcement agencies.

To the General Public or Other Users to the extent you have provided such
information in a public forum or private forum associated with an account
profile on our Sites.

N/A

Communications with us, preferences, and other information you provide to us

Service providers that we use to provide you the Sites.

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

To the General Public or Other Users to the extent you have provided such
information in a public forum or private forum associated with an account
profile on our Sites.

Advertising and Data Technology Vendors.

Sensitive personal information, including precise geolocation

Service providers that we use to provide you the Sites.

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

N/A

Biometric Information

Service providers that we use for security purposes.

Government, regulatory, or law enforcement agencies.

N/A

Inferences, such as information used to create a profile about a consumer
reflecting the consumer’s preferences

Service providers that we use to provide you the Sites.

Affiliates for whom we may be a service provider or advertiser or who may be a
service provider to us.

Government, regulatory, or law enforcement agencies.

Advertising and Data Technology Vendors.


PROCESSING PURPOSES:

We, our Service Providers, and our Advertising Ventures may use your personal
information to provide the Sites and may use this personal information for the
purposes, including commercial purposes, as listed below:

 * to operate, manage, and maintain our business;
 * to send you ongoing marketing communications;
 * to provide our Sites;
 * to accomplish our business purposes and objectives, including developing,
   improving, repairing, and maintaining our Sites;
 * for personalizing advertising and marketing;
 * to collect analytics and conduct research;
 * for quality and safety purposes;
 * to implement security controls and monitoring;
 * to detect and prevent fraud;
 * to verify your identity;
 * for audit, and other internal functions;
 * to comply with law, legal process, and internal policies;
 * maintaining records; and
 * exercising and defending legal claims.

We do not knowingly sell for monetary value, share, or process personal
information of children under 16 years of age.


YOUR CALIFORNIA PRIVACY RIGHTS

Right to Know and Access personal information: You may request to access
information we have collected about you, the categories and categories of
sources of personal information we have collected about you, the
business/commercial purpose for collecting, sharing, or selling your personal
information, and the categories of personal information about you that we sell
or otherwise disclose, as well as the categories of third parties to whom we
sell or otherwise disclose your personal information. If your request is
granted, we will provide you with a copy of the personal information in a
portable manner. Requests to access your personal information may be submitted
up to two times in a rolling twelve-month period. Please note that, in some
instances, we may decline to honor your request or only honor your request in
part, where, for example, we are unable to verify your identity or an exception
to this right applies.

Deletion of personal information: You may request that we delete the personal
information we have collected from you. Please note that, in some instances, we
may decline to honor your request or only honor your request in part, where, for
example, we are unable to verify your identity or an exception to this right
applies.

Opt Out of Certain Selling or Sharing Practices: You may request to opt out of
the sale or share of your data for cross-context behavioral advertising/targeted
advertising, and profiling in furtherance of solely automatized decisions that
produce legal or similarly significant effects. You may also limit the use or
disclosure of your sensitive personal information such as precise geolocation
information.

Correction of Inaccurate personal information: You have a right to request the
correction of inaccurate personal information that we may have on file about
you. Please note that, in some instances, we may decline to honor your request
or only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination
for exercising your above-listed rights under the CCPA.

Right to Appeal: You may appeal our determination not to act on your request
within a reasonable period after receipt of our notice. In order to appeal you
must click here. We will inform you within 45 days after receipt of your request
(extended by an additional 60 days where reasonably necessary, taking into
account the complexity and number of requests serving as the basis for the
appeal), and we will include a written explanation of the reasons in support of
our response. If we require the 60-day extension, we will inform you within 45
days after receipt of the appeal, together with the reasons for the delay. 


TO EXERCISE ANY OF THESE RIGHTS:

In order for you or your authorized agent to exercise this right, go to the
footer of our website and select the “Do Not Sell or Share My Personal
Information and Opt Out of Targeted Advertising” link, call us at phone at +1
(888) 914-9661; enter the required PIN number of 187828 when prompted, or submit
a request through the linked form here. You can also contact us by any of the
methods listed in the Contact Us section of the main Simon Privacy Policy. You
can also go to Settings > Adjust Data & Privacy Settings to change privacy
settings in the Simon mobile app.

When you make a request, you will be asked to answer a few questions about
yourself to help us verify your identity. Third-party identification services
may help us with verification to prevent disclosure of your personal information
resulting from fraudulent requests. In the event more documentation is necessary
to verify your identity, we will notify you directly.

Additionally, we may need to obtain information about you or your specific
request in order to verify your identity and respond including, without
limitation:

 * First name*, Middle initial, Last name*
 * Address*
 * Email address*
 * Phone number

*Required field


AUTHORIZED AGENT

You may use an authorized agent acting on your behalf to exercise a privacy
right discussed above. If you are an authorized agent acting on behalf of a
Colorado resident to communicate with us or to exercise a privacy right
discussed above, you must be able to demonstrate that you have the requisite
authorization to act on behalf of the resident and have sufficient access to
their laptop, desktop, or mobile device to exercise these rights digitally. If
you are an authorized agent trying to exercise rights on behalf of a company,
user, or consumer, please contact us at the contact information in the “To
Exercise Any of These Rights:” section above with supporting verification
information, which includes proof that you have access to the consumer’s
interface and proof of your own identify.


FINANCIAL INCENTIVES

We provide account and loyalty-based discount, incentive, and community programs
for users of our Sites (e.g., Simon Mall Insider®, VIP Shopper Club®, the Simon®
co-branded credit card) and occasionally run a survey, contest, or sweepstakes
(each a “Program”) where participants can provide personal information in
exchange for a chance to win one or more prizes, such as gift cards, cash,
shopping sprees, goods or services, or receive other benefits like product
discounts or points redeemable for goods or services, any of which may be
considered a “financial incentive” under California law. When you sign up for
any Program, you are provided with the Terms and Conditions of the Program and
are asked to provide your opt-in consent to participate in the Program, which
you can withdraw from the Program at any time. We believe the exchange of data
for the chance to win the Program prize(s) or to receive the benefits of the
Program represents a fair value to the consumer, based on a good-faith estimate
of the value of the consumer’s data as such data relates to such prize(s) or
benefits. This is based on an analysis including the retail value of the Program
prize(s) or benefits multiplied by (respectively) either the likelihood of
winning the Program prize(s) (in the aggregate) or the number of benefits the
consumer has or is likely to receive during the consumer’s participation in the
Program. The value of the consumer data collected in relation to these Programs
is limited based on the limited amount of data collected from each consumer, the
categories of Personal Information collected, the limited transferability of
such Personal Information, the limited use of such Personal Information in
connection with marketing activities pursuant to this Notice, considering the
volume of consumers participating in the Program overall, and that we do not
sell this data outside of the context explained in the section above entitled
“Categories of Personal Information Collected, Disclosed, Shared or Sold.”

The CCPA also requires that consumers continue to receive the benefits of the
Programs, if possible, even if they exercise their opt-out and deletion rights.
Since, for example, we offer some Program prizes (e.g., digital gift cards) via
e-mail delivery to winners of a Program, we cannot provide such
digitally-delivered prizes to you without you providing us your e-mail address.
Additionally, you may be required to provide additional information such as your
phone number, e-mail address, mailing address (for physically delivered prizes),
date of birth, full legal name, etc. in order for us to verify your eligibility
and to deliver any prize(s) you may have won should you try to claim any Program
prize(s) notwithstanding any Program opt out you may have previously
communicated to us. You will only be permitted to register for or continue to
use our parts of our Sites that require registration of an account, including
without limitation, any shopping or discount club or credit card account, if you
agree to our Terms of Use and Simon Privacy Policy and provide the minimum
necessary personal information for us to properly maintain such account and
deliver any benefits on a commercially reasonable fashion. You will still have
the right to request deletion of your data, in any event, as described above.


SHINE THE LIGHT DISCLOSURE

California residents also have the right to request that we provide you with (a)
a list of certain categories of personal information we have disclosed to third
parties for their direct marketing purposes during the immediately preceding
calendar year and (b) the identity of those third parties. To exercise this
right, contact us at the address below. We do not disclose personal information
of California residents as defined by California Civil Code § 1798.83 (the
“Shine the Light Law”) with third parties, other than our Affiliates, for their
direct marketing purposes absent your consent. If you are a California resident,
you may request information about our compliance with the Shine the Light Law by
sending an e-mail to privacy@simon.com or by mailing a letter to:

Simon Media Properties, LLC
Attention: Data Privacy Officer
225 W Washington St
Indianapolis, IN 46204-3435 USA

Any Shine the Light Law request must include “Request for California Privacy
Information” in the subject line and include your name, street address, city,
state, and ZIP code. Please note that we are only required to respond to one
request per customer each year, and we are not required to respond to requests
made by means other than through the e-mail address or mailing address
referenced above.

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