Effective Date: October 1, 2020


This Privacy Policy explains the privacy practices governing information collected through TheShopsOnElPaseo.com (the “Site”) owned and operated by Chartwell Properties, Inc. (“Chartwell,” “we,” “our” or “us”).

Please read this Privacy Policy carefully because when you submit information to or through the Site, you are consenting to the collection, processing and retention of your information as described in this Privacy Policy.

If you do not agree with any part of this Privacy Policy, please do not use the Site.

I. Information We Collect

Information You Provide to Us. When you use the Site, we or our service providers may collect information that could reasonably be used to contact you or to identify you personally, such as your name, email address, telephone number or mailing address (“Personal Information”).

Information We Collect Automatically. Whenever you visit or interact with the Site, we may use a variety of technologies that automatically or passively collect information about how you access or use the Site (“Usage Information”). Usage Information may include your browser type, operating system, the page served, the time, and sites you visit before and after visiting the Site. However, this information does not identify you as an individual user. We do not treat Usage Information as Personal Information unless it is combined with other data that, once linked, can be used to identify you.

Device Identifiers. We may also automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Site. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Site, help diagnose problems with our servers, analyze trends, track users’ web page movements, and gather broad demographic information for aggregate use. We may share your Device Identifier with third parties so that they can recognize you when you are close to The Shops on El Paseo and show you relevant advertising based on your location. If you do not want to us to have access to your geolocation information in this manner, please configure your Device settings to turn off geolocation sharing (or limit it to specific apps or sites) or otherwise adjust your advertising settings.

Cookies and Do Not Track. We may collect information about you or your use of the Site through cookies, tracking pixels, mobile identifiers or other technologies. We use this information to better understand, customize and improve the Site, services and offerings as well as to manage our advertising. The information we collect through cookies, tracking pixels or mobile identifiers may help us understand how visitors use and engage with the Site. If you have provided us with your Personal Information, for example, when you requested information from us, we may associate this Personal Information with information we have collected through cookies, tracking pixels, mobile identifiers or other technologies.

  • A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Site. When you use the Site, neither we nor any third parties collect Personal Information about your online activities, over time or across third party websites. The Help section of your browser may tell you how to prevent your browser from accepting cookies.
  • DoubleClick Cookie. Google, as a third party vendor, uses cookies to serve ads on our Site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Site or other sites on the Internet. See “Your Rights and Opt-Out Choices” below to learn how to opt-out of the use of the DoubleClick Cookie.
  • Tracking Pixels. A “tracking pixel” also known as an Internet tag, pixel tag, web beacon or clear GIF, links web pages to web servers and their cookies, and may be used to transmit information collected through cookies back to a web server. We use a tracking pixel generated by Google’s DoubleClick Campaign Manager to improve our advertising. If you would like to opt-out of the use of this pixel, please visit the Google Ads Settings page to configure your web browsing settings (see “Your Rights and Opt-Out Choices, below).
  • Mobile Identifiers. We may use software development kits (“SDKs”) or mobile advertising identifiers (for example, “IDFA” on Apple mobile devices or “Advertising ID” on Android mobile devices), which function similarly to cookies on mobile devices. You may reset your IDFA or Advertising ID in the settings on your mobile device.
  • Do Not Track. Currently the Site is not designed to respond to “Do Not Track” signals sent from your browser.

II. How We Use Your Information

Any information collected on the Site may be used for a variety of purposes, including, for example, to:

  • respond to your questions and requests;
  • provide you with access to certain features of the Site;
  • verify your identity;
  • improve the Site;
  • communicate with you;
  • in our discretion, to make changes to the Site or any of our policies.

We will only use the information you provide to us in a manner that is consistent with this Privacy Policy or where we have otherwise obtained your consent.

We may use your Personal Information to send you relevant promotions, personalized information, or updates or newsletters with information that you have requested or that may interest you.

III. How We May Share Your Information

Service Providers. We may share your Personal Information with third parties that perform functions on our behalf (“Service Providers”) to carry out your requests, respond to your inquiries or make various features of the Site available to you. These Service Providers may help us to host or operate the Site, analyze data, provide customer service, conduct marketing, serve relevant ads to you, or administer surveys or questionnaires.

Business Transfers. We may share your information, including your Personal Information, with our affiliates for internal reasons, primarily for business and operational purposes. We may share or transfer your information, including your Personal Information in connection with a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Chartwell or any affiliated company (in each case, whether in whole or in part).

Legal Disclosure. We may transfer and disclose information, including your Personal Information, to third parties to comply with a legal obligation, when we believe in good faith that the law requires it, at the request of governmental authorities conducting an investigation, to verify or enforce our Privacy Policy or other applicable policies, to respond to an emergency or otherwise to protect the rights, property, safety, or security of Chartwell, third parties, visitors to the Site or the public.

IV. Your Rights and Opt-Out Choices

You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, updates, emails or other communications by:

  • sending us an email at [email protected]; or
  • following the removal or unsubscribe instructions in the communication that you receive.

If you wish to verify, correct, or update any of your Personal Information collected through the Site, you may contact us at the email or postal address included in the Contact Us section below. In accordance with our routine record keeping, we may delete certain records that contain Personal Information that you have submitted through the Site. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups or other technology-related reasons.

If you prefer not to receive targeted advertising, you can opt-out of some network advertising programs that use your information. Below are the steps you can take to opt-out of targeted advertising:

  • Visit the Digital Advertising Alliance (DAA) Opt-Out Page (http://www.aboutads.info/choices). The DAA Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.
  • You can visit Google’s Ads Settings page (https://adssettings.google.com) to opt-out of the use of the DoubleClick Cookie for interest-based advertising and to opt-out Google Analytics for Display Advertising and customize Google Display Network ads. You may need to sign in to your Google account to control settings for personalized ads across all your browsers and Devices. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your browser (https://tools.google.com/dlpage/gaoptout/). Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
  • Update the privacy settings in the help section of your browser, or in the settings tab on your mobile device.
  • You may also click on the ad choices icon in the advertisement.
  • You may opt-out of additional third party advertising networks by going to the Network Advertising Initiative’s Website (http://www.networkadvertising.org/managing/opt_out.asp) and following the directions provided.

Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive.

Please note that even if you choose to remove your information or “opt-out,” you will still see advertisements while you are browsing online; however, those advertisements will no longer be tailored to your interests. Additionally, information regarding your usage of the online services may still be collected for research, analytics or internal operations purposes. We are not responsible for the effectiveness of any such opt-out options.

V. Links to Other Websites

The Site may contain links to other sites that we do not operate. These include sites of retailers located on El Paseo, social media sites, and others. These links are provided only as a convenience to you. These other sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. The Shops on El Paseo has no control over, and is not responsible for any content, products or services offered by or found on third party sites, or their privacy policies. Links to third party sites do not constitute an assumption of liability for or sponsorship, endorsement or approval of these sites or the content contained on these sites.

VI. Children

We do not knowingly collect information from children under 13 years of age. If we learn that a child under the age of 13 has provided us with any Personal Information without first receiving their parent or guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site. We will then dispose of such Personal Information in accordance with this Privacy Policy. If you believe we may have any information from or about a child under the age of 13, please contact us at [email protected] or at the mailing address shown below.

VII. Accessing our Site Globally – Transfer of Data

The Site is governed by and operated in, and in accordance with the laws of the United States. We make no representation that the Site is governed by or operated in accordance with the laws of any other nation. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Site, or providing us with any information, you (a) acknowledge that the Site is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

VIII. Your California Privacy Rights

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2018 will receive information about 2017 sharing activities). At this time, we do not share personally identifiable information with third parties for their direct marketing purposes. However, if we do so in the future, we will give you choices prior to sharing your information with third parties for their direct marketing purposes. If you are a California resident and you have questions about our practices and your choices regarding sharing of information with third parties for their direct marketing purposes, send an email to [email protected] or write to us at the postal address below.

IX. Security Measures

We use certain reasonable security measures to help protect your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Site and provide us with your information at your own risk.

X. Changes

We may update and post revisions to this Privacy Policy from time to time and will update the Effective Date when we do so. If our Privacy Policy changes in a way that significantly affects how we handle your Personal Information, we will not use the Personal Information we currently maintain without providing you notice or obtaining your consent, where appropriate. We encourage you to review this page for the latest information about our privacy practices.

XI. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us by email at [email protected] or write us at:

The Shops on El Paseo
73-061 El Paseo, Suite 200
Palm Desert, CA 92260