Privacy policy
Last updated on: 7 June 2023
Virgin Red Limited Privacy Policy
Applicability of this Policy
We are Virgin Red Limited (“VR”, “we”, “our” or “us”) and this is our Privacy Policy. This policy sets out how we and the products and services we collect and use your personal information. Please take the time to read this Privacy Policy as it is important for you to understand how we collect and use your personal information.
This Privacy Policy applies to:
Our terms and conditions for each of the above services can be found by following the links above.
References in this Privacy Policy to ‘personal information’, 'personal data' or 'information' mean information that relates to you, and that identifies or can reasonably be used to identify you. For example: your name, email address, or other digital identifiers, such as cookies, IP addresses or logs. The details of how we use your personal information may differ depending upon which of our services you are using (and you may be using them all!) so this policy is separated into following sections:
Section 1 - All about us
Section 2 - Virgin Red
Section 3 - Virgin Trains Ticketing
Section 4 - Flying Club.
Section 5 - Virgin.com
Section 6 - Virgin ID
Section 7 - Cookies and Social Media Targeting
Section 8 -Important Information
By using any of the services, you acknowledge that you have read and understood this Privacy Policy. If you have questions about this privacy policy, please contact us at membersupport@virgin.com
We may change this policy from time to time at our discretion, including to ensure that it remains clear and accurate. If we change this policy, the latest version will always be available on our platforms. If we implement a material change to the way in which we use your personal information, we will update this policy and notify you.
Contents
Section 1 - All about us
1.1 Who we are and what do we do
1.2 Our commitment
1.3 Our legal basis for using your personal information
Section 2 - Membership of Virgin Red
2.1 How we collect information on Virgin Red members?
2.2 The information we collect on members of Virgin Red
2.3 Why we need and how we use your information as a member of Virgin Red
2.4 Examples of how and why we use Virgin Red member information
2.5 More information on how we use your personal information for marketing
Section 3 - Virgin Trains Ticketing
3.1 How do we collect information on Virgin Trains Ticketing users
3.2 The information we collect on Virgin Trains Ticketing
3.3 Why we need and how we use your information on Virgin Trains Ticketing
3.4 Examples of how and why we use your information on Virgin Trains Ticketing
Section 4 - Membership of the Virgin Atlantic Flying Club Programme
4.1 When do we collect information on Flying Club members?
4.2 The information we collect on Flying Club members
4.3 Why we need and how we use Flying Club member information?
4.4 Examples of how and why we use Flying Club member information
4.5 How is the personal information of members of Flying Club used for marketing?
Section 5 - Virgin.com
5.1 How do we collect information on Virgin.com users?
5.2 The information we collect on virgin.com
5.3 What do we need your information for?
Section 6 - Virgin ID
6.1 How do we collect your personal information for Virgin ID?
6.2 The information we collect on Virgin ID users
6.3 Why we need and how we use your information as a Virgin ID user
6.4 Examples of how and why we use your personal information
Section 7- Cookies and Targeting (including via social media)
5.1 What are cookies?
5.2 How we use cookies
5.3 Examples of how we use cookies
5.4 What third parties do we use in relation to cookies?
5.5 Social media targeting
5.6 Can I opt out of the use of cookies and social media targeting?
Section 8 - Important Information
6.1 Personal information relating to under 18s
6.2 Websites to which we link
6.3 How will we share your personal information?
6.4 How do we keep your information safe?
6.5 How long will we retain your personal information?
6.6 How can I check and update my personal information?
6.7 What are my rights?
6.8 Your California privacy rights
6.9 Changes to our business
6.10 Finally - if in doubt, talk to us
Section 1 - All about us
1.1 Who we are and what do we do?
We own, manage and operate the member-based rewards programme called Virgin Red and the Virgin Points currency which you can use as a member of Virgin Red or Flying Club. Our platforms record all Virgin Points balances and transactions.
We also own, manage and operate Virgin Trains Ticketing which you can use as a member of Virgin Red, or as a guest.
In addition to this, we manage the virgin.com website and operate Virgin ID. For the purposes of certain data protection laws, we are a ‘data controller’ of personal information that we collect, use and process in connection with the services described in this Privacy Policy. That means, among other things, that we control how the personal data relating to you that we hold is used, and we have certain obligations under data protection laws in doing so.
If you are also a member of Flying Club, run by Virgin Atlantic Airways Limited (“Virgin Atlantic”) Virgin Atlantic also manages your data in accordance with its own privacy policy, available on its website.
VR and Virgin Atlantic are each an independent data controller with their own responsibilities for managing separate aspects of your personal information associated with Flying Club.
You can get in touch with us by writing to: Virgin Red Limited, Data Protection Officer, 66 Porchester Road, London W2 6ET or you can contact the Data Protection Officer directly at: red.dpo@virgin.com.
For individuals based in the European Union: Since we do not have an establishment in the European Union, we have appointed an EU based representative to serve as a direct contact for data protection authorities and individuals on our behalf, who can be contacted at virginred@mcf.ie or MCF Legal Technology Solutions Limited, Riverside One, Sir John Rogerson's Quay, Dublin 2, Ireland (Tel: 00353 01 829 0000).
1.2 Our commitment
We take your privacy seriously and are committed to protecting the privacy of any personal information you give us, and will comply with all relevant data protection legislation when processing your data. Protecting your personal information is important to us. We always aim to be open and clear about the personal information we hold on you and how we may use it. Where you have choices or rights, we will explain them to you and will respect your wishes in relation to those rights. We believe you should be in control in relation to how we use your personal information.
1.3 Our legal basis for using your personal information?
Data protection law requires us to have a legal basis to process your data. We rely on the following legal bases when using your information:
Contract performance. If we have agreed to provide a service to you, we will process your personal information in order to provide that service. For example, to enable you to earn or redeem your Virgin Points, to enable to buy tickets from Virgin Trains Ticketing, or to enable you to access your accounts with other Virgin companies using your Virgin ID.
Legitimate interests. We are allowed to use your personal information where, on balance, the benefits of us or third parties doing so are legitimate and do not outweigh your interests or legal rights. For example it’s in our legitimate interests to improve our business activities or to know what you like so we can offer you better products and services, whether that's with the best spend ideas for your Virgin Points, the best pricing on train travel, or to give you a better, more tailored experience with Virgin companies based on your engagements with another Virgin company tied together through Virgin ID. Where we rely on legitimate interests, we take into account the impact that this use has on you. Where we are using your personal information on the basis of legitimate interests you have the right to 'opt-out' of that processing at any time.
Legal obligation. We might be required by law to process your personal information. For example to retain a record of transactions or where necessary, provide your personal information to law enforcement agencies.
Consent. In some cases we may obtain your consent to use your information for certain purposes. For example, you may agree to give us access to your location while using our products/services, or you might opt-in to receive marketing about all things Virgin or the Virgin.com newsletter. Where we are using your information on the basis of Consent you have the right to 'opt-out' of that processing at any time.
Section 2 - Membership of Virgin Red
2.1 How we collect information on Virgin Red members?
We collect, use, share and store your information when you use our services or interact with us, Virgin Points or our partners. The information we collect will vary depending upon how you use our services and we obtain information directly from you and others for example, when you:
Sign up for a Virgin Red account or provide additional information to update or enhance your membership.
Visit our app, open messages from us or enable geo-location technology.
Earn or spend Virgin Points or link/verify your account with a partner or party associated with Virgin Red.
Use the Virgin Trains Ticketing app as a member of Virgin Red (e.g. to checkout).
Enter a promotion, competition or prize draw.
Contact us in any way e.g via social media, website, post, email, messaging services or interact with social media by following or liking our posts, or tagging us in your posts.
Register your marketing preferences with us.
Interact with us in any other way, online or offline, including through our services and via cookies that collect information on your internet use.
We may receive information on you from third parties including:
From our partners on the transactions involving your earn or spend of Virgin Points.
Any information from a third party where that third party is authorised to provide us with your personal information.
From advertisers, social media networks and companies that conduct market research and behavioural analysis.
Identity and contact information from publicly available sources.
Information collected by agencies or service providers working on our behalf.
Information from government and law enforcement agencies.
2.2 The information we collect on members of Virgin Red
Some examples of the categories and types of personal information we may hold about you include but are not limited to:
Account information. We collect information in connection with your Virgin Red account. E.g. Member ID; Name; Postal/Zip Code; Mobile number; Date of birth; Email address; Virgin Points transaction data; Relationships you may have with our partners (including linked accounts); Marketing preferences; Your propensity to earn or spend Virgin Points on particular products/services.
How you use our services. The device you use to access our services; your browsing behaviour, such as your searches, links you may click on, content and websites viewed by our use of cookies and similar technologies; your location (where you have provided consent to us using your geo-location)
Your response to our communications (such as email or SMS). Your activity associated with a message from Virgin Red, such as opening an email, text or push notification or activity with our contact centre.
Your entry into promotions and competitions. We may collect information on your propensity to interact with Virgin Red, enter competitions and if you’re a lucky winner!
Your social media activity. We may collect information on your interactions via social media e.g. if you tell us you really like something or you really don’t like something. This could also include any photos that you might share.
Your use of Virgin Trains Ticketing. We will collect information about the bookings you make with Virgin Trains Ticketing when you use this service as a member of Virgin Red.
To see further categories of personal information we collect, click here.
2.3 Why we need and how we use your information as a member of Virgin Red
There are many ways in which we will use your personal information to provide and improve our services to you, in particular we use your personal information to understand your relationships with our Virgin Red Partners and to enable us to build a reward programme that is personalised for you, to enable you to earn and spend Virgin Points on rewards you might like.
We need some information from you to enable you to access and use our products and services. Other information you provide is optional e.g. you may wish to provide additional information to further personalise your relationship with us.
2.4 Examples of how and why we use Virgin Red member information
Account transactions and support
Account access and use. We need your information when you sign-up and login, to enable the creation, access and security of your account.
Virgin Points transactions. We receive information either directly from you or via our partners when you earn and spend Virgin Points. E.g. 1. If you buy a case of wine and earn 3,500 points, the wine retailer sends us details of your transaction (e.g. how many points earned; on what product or service). 2.You then spend these points on a ‘hot beverage’ QR code from one of our partners. You exchange your code for a coffee. The vendor sends us details of your purchase.
To provide you with support and improve our customer service. We use information to resolve queries (e.g. missing Virgin points) and to improve our processes.
To contact you in relation to our services. We’ll contact you with information relevant to the Virgin Red programme and the services we provide. E.g you can no longer spend Virgin Points with a particular partner.
Exchanging information with partners and suppliers.
Account linking with a Virgin Red partner. If you link a Virgin Red and partner account your transactions and account information may be shared to enable the display of one Virgin Points balance across both accounts, and/or to enable the two accounts to operate together. E.g. if you link your account with a wine retailer account and earn 3000 points on a wine purchase, this information is shared between the wine retailer and Virgin Red. The transactions display in both accounts and you may also receive more relevant wine offers in the future.
Sharing information on your behaviour. We may track, or receive information from our partners on your behaviour on digital or other channels e.g. websites or apps. We use this to enable linked accounts to operate together and/or to tailor and show you more relevant offers. E.g. if you browse offers on the partner’s website, we may receive insight on the offers that interest you and use this to show you offers you may like.
Sharing information on your membership status, product or service usage. Where permitted, we may exchange additional information with our partners (e.g., purchases, spend or usage). This information is used to tailor our services to you, such as showing you more relevant, or removing irrelevant offers.
For prizes and competitions. If a competition is facilitated or a prize is supplied by a third party, we’ll exchange your information for the purposes of your participation in the competition and/or to enable prize fulfilment.
Using your information for marketing.
Sending you marketing communications. Unless you’ve told us that you don’t want to hear from us, we will use your information to keep you up-to-date with our latest news, exclusive rewards, and to provide details of offers and prizes from Virgin Red and/or our partners. We may tailor our marketing communications to you. Please see section 2.5 below for further information on how we use your information for marketing purposes.
Using your information to personalise our services to you.
We may use your information to understand your habits and preferences in order to personalise, enhance, and improve your Virgin Red experience and our communications with you. We may use the information we hold on you, such as browsing history, membership info, earn and spend activity, to learn about you, personalise our interactions with you and give you a tailored experience, both online and offline. We may combine your personal information, collected through various sources, including our services, to develop a profile which may be used to determine your propensity to do something, so that we can tailor our services to you. E.g. you look at an offer, or earn or spend points on a cruise. We review your browsing history and your earning and spending activity and offer you an exclusive deal on a future cruise.
Using cookies and other online identifiers
We use cookies and online identifiers. We use these tools when you visit our digital platforms to help us better understand how our members use our applications and websites, to optimise user experiences, for advertising and to personalise our services. Please see section 5 below for further information on how we use cookies and online identifiers.
2.5 More information on how we use your personal information for marketing
When you join Virgin Red via a Virgin Red owned and/or operated channel, we will send you marketing about Virgin Red unless you tell us not to. You’ll be given the option to opt out of marketing when you first join and can change your preferences at any point via logging into your account or clicking unsubscribe in the message we send you.
The types of marketing that we may send to you may include emails which may (amongst other content) tell you about the best ways to earn and spend Virgin Points. You can also consent to receive push notifications from the Virgin Red app or to receive targeted marketing on select third party platforms (for example, Facebook, Instagram).
You can determine the channels via which you are happy to be contacted with marketing when you sign up to Virgin Red and change your preferences at any point via logging into your account. If a channel is not listed in the 'Permissions' section of the app then we are not currently using that channel in our marketing. The only exception to this is push notifications within our mobile application. As with all in-app mobile push notifications, these can be turned off at any time via your phone's settings.
We will use the information that we hold about you to create more personalised and relevant offers based on your interactions with us. If you do not wish to receive tailored offers in this way you may opt out of personalisation by contacting us directly.
If you reside outside of the UK you may request to receive updates by email from VR about any new launch destinations. You may opt out of receiving these emails at anytime by contacting VR atmembersupport@virgin.com or by clicking the unsubscribe link in any of the emails that we send you
Section 3 - Virgin Trains Ticketing
3.1 How do we collect information on Virgin Trains Ticketing users
We collect and store personal information about you when you use Virgin Trains Ticketing. When you purchase tickets through Virgin Trains Ticketing you can checkout as a member of Virgin Red and earn Virgin Points on qualifying transactions or you can checkout as a guest.
3.2 The information we collect on Virgin Trains Ticketing
Some examples of the categories and types of personal information we may hold about you include but are not limited to:
Your booking information. We collect information about the bookings that you have made such as date of travel, destination, number of passengers, email address.
How you use our services. The device you use to access our services; your browsing behaviour, such as your searches
3.3 Why we need and how we use your information on Virgin Trains Ticketing
We will use your personal information in order to provide the Virgin Trains Ticketing services to you and to improve the experience you have when interacting with Virgin Trains Ticketing.
As a reminder, if you use Virgin Trains Ticketing services as a member of Virgin Red, please refer to sections 2.3 and 2.4 above for details on how we use your information.
3.4 Examples of how and why we use your information on Virgin Trains Ticketing
Here are some examples of how we use your information
To fulfil your ticketing transactions. To provide you with a ticket that you have purchased.
To provide you with support and improve our customer service. We use your information to resolve queries and to improve our processes.
To contact you in relation to our services. We’ll contact you with information relevant to Virgin Trains Ticketing e.g.changes to your ticket.
Using cookies and other online identifiers. We use these tools when you visit our digital platforms to help us better understand the use of our Virgin Trains Ticketing app, to optimise user experiences, for advertising and to personalise our services. Please see section 5 below for further information on how we use cookies and online identifiers.
Section 4 - Membership of the Virgin Atlantic Flying Club Programme
4.1 When do we collect information on Flying Club members?
Your information is provided to us (either by you, Virgin Atlantic, a partner of Flying Club or one of our or Virgin Atlantic’s service providers) to enable you as a member of Flying Club to earn and spend Virgin Points and for us to record and manage your Virgin Points balance. E.g. when you:
Sign up for (or have an existing) Flying Club account, to enable us to open a Virgin Points ‘wallet’ for you or operate your existing wallet.
Earn or spend Virgin Points with a partner associated with Flying Club.
Update your Flying Club account or personal information.
Provide information to Flying Club partners, in relation to Virgin Points.
Interact with us in any other way, online or offline, including through our services.
4.2 The information we collect on Flying Club members
Account information. We collect information in connection with your Flying Club account. E.g., Flying Club number; Name; Postcode; Email address; Contact number; Date of birth; Tier Status; Household member ID (if applicable); Purchases made with partners of Flying Club; Virgin Points balance and transaction information; Relationships you may have with Flying Club partners using Virgin Points, including any linked accounts with those partners.
To see all of the categories of personal information we collect, click here.
4.3 Why we need and how we use Flying Club member information?
There are many ways in which we will use your information to provide and improve our services to you. We will use your personal information as a member of Flying Club to enable you to use Virgin Points and otherwise provide services associated with Virgin Points to you. Some information is essential to enable us to provide our services (e.g. to create a wallet that stores Virgin Points) and other information you provide is optional and is used to enhance and personalise the service we offer.
4.4 Examples of how and why we use Flying Club member information
Use of Virgin Points
To manage your Virgin Points as part of your Flying Club account. We use your information to create a Virgin Points wallet and to allocate and manage Virgin Points, when you earn and spend with our partners..
To support and improve our customer service. We use information to resolve queries (e.g. missing Virgin Points) and to improve our processes.
To contact you in relation to our services. We may send you service-related messages about Virgin Points.
Exchanging your information with partners and suppliers.
Exchanging information with Flying Club partners. We share information with partners of Flying Club to award Virgin Points and to optimise the use you can make of Virgin Points. Some partners with which you have a relationship may periodically share additional information about you (e.g. your product holdings, spend or usage) which we may then use to personalise or show you more relevant deals using Virgin Points. Third party partner privacy policies will also apply to use of your information in this manner.
Avoiding telling you about products and services that you already use. For example, we may let a partner know if you are already using Virgin Points, so that they avoid sending you a Virgin Points offer which is not relevant to you.
To personalise your use of Virgin Points.
Personalising, enhancing, modifying or otherwise improving Virgin Points. To optimise and tailor the way in which you use Virgin Points, we may combine the information we collect on you through various sources (including via our services) and develop a customer profile which may be used to calculate your propensity to do something (e.g. to respond to a Flying Club offer). We may use and supply this information to our partners so you may receive tailored offers as a member of Flying Club.
4.5 How is the personal information of members of Flying Club used for marketing?
Please seeVirgin Atlantic’s Flying Club privacy policy for details of how Virgin Atlantic uses your personal information (including in respect of marketing) as a member of Flying Club.
We may make recommendations to Virgin Atlantic on the types of products or services in which we believe you may be interested, based on your interaction with Virgin Points. Virgin Atlantic and VR may use this information to tailor the Virgin Points offers that you receive as a member of Flying Club.
Section 5 - Virgin.com
5.1 How do we collect information on Virgin.com users?
We collect, use and store personal information about you when you interact with us on Virgin.com (the "Website"). The information we collect will vary depending upon how you use our services, for example when:
You consent to receive the Virgin.com newsletter;
You enter a Virgin.com promotion, competition or prize draw;
You contact us in any way, for example via the Website, post email, messaging services or interact with social media by following or liking our posts, or tagging us in your posts; or
You interact with us in any way, online or offline, including through our services and via cookies that collect information on your internet use.
Virgin Enterprises Limited is separately a data controller of your personal data when you contact them via the "Report a Scam" page of the Website.
Similarly, Virgin Management Limited is separately a data controller of the personal data sent through to Virgin Management Limited managed mailboxes when you contact them using the "Book a Branson" and "Contact us" pages of the Website or when you contact the Virgin Press Office. The address for both Virgin Enterprises and Virgin Management is 66 Porchester Road, London W@ 6ET and you can contact their data protection officer at dpo@virgin.com
5.2 The information we collect on Virgin.com
Some examples of the categories and types of personal information we may hold about you include but are not limited to:
Contact Information - If you enter a competition or promotion we may collect your name, email address, telephone number or postal address.
Your entry into promotions and competitions - We may collect information on your propensity to interact with us, enter competitions and if you're a lucky!
Cookie data or similar technologies - When you browse the Website we will collect certain information about your browsing behaviour, provided you have consented for cookies to be deployed. You can read more about the cookies that are applied on our Website in the Cookie Policy
Your social media activity - We may collect information on how you interact with us via social media. For example, if you tell us that you really like something or you really don't like something. This could also include any photos you might share.
Newsletter - When you sign up to receive the virgin.com newsletter we will collect your first name, email address and location (country) so that we can provide you with the service requested, in addition, you may also voluntarily provide your surname, postcode/zipcode and interests.
5.3 What do we need your information for?
We will use your personal information for the following purposes:
to help us make the Website and other related content available to you (please see the 'How will we share your personal information?' section below for more information);
to make the Website more relevant for you and other visitors. This includes sometimes requesting personal data from you to help us run and develop our site and associated functions, and may also include matching data held about you across other initiatives we operate such as understanding if you are a member of Virgin Red or not;
to carry out occasional surveys to analyse our user base. Ultimately we want to ensure that the Website provides everything that you, our audience, are looking for;
to check whether you are eligible for a competition and to contact you if you win;
to comply with the law; or
as we feel necessary to prevent illegal activity or to protect our interests.
Section 6 - Virgin ID
6.1 How do we collect your personal information for Virgin ID?
We collect, receive, use, store and share your personal information when you use our services or interact with us, or other companies that use Virgin ID ("Virgin Partners"). The information we collect or receive will vary depending upon how you use our services, and we may obtain information directly from you and/or others, for example when you:
Are allocated a Virgin ID
Engage with other Virgin Partners
Register your marketing preferences with us; or
Interact with us in any other way, online or offline, including through our services and via cookies that collect information on your internet use.
We may also receive information on you from third parties including:
From Virgin Partners you have engaged with;
From advertisers, social media networks and companies that conduct market research and behavioural analysis;
Identity and contact information from publicly available sources;
Information collected by agencies or service providers working on our behalf; or
Information from government and law enforcement agencies.
Virgin Partners may receive your personal data about how you have engaged with us and other Virgin Partners using your Virgin ID to connect the information to you. These companies will act as separate "data controllers" in respect of their use of this personal data. You should review their privacy policies to contact them directly in relation to any questions about how they may use your personal data.
6.2 The information that we collect on Virgin ID users
Some examples of the categories and types of personal information we may hold about you include, but are not limited to:
Account information. We collect your name, email address, telephone number, date of birth, postcode/zipcode, communication and content preferences and information about how your interact and engage with Virgin Partners. This may include your transaction history and your service preferences. You can read more about Virgin ID in our Virgin ID and Web Terms of Use.
Transactional information. We collect information on transactions that you carry out with Virgin Partners and that are assigned to your Virgin ID
How you use our services. We collect, use and share your personal data so that we can operate Virgin ID and otherwise improve or personalise your experience with Virgin Partners, and in order to give you a better more tailored experience across the Virgin Group.
6.3 Why we need and how we use your information as a Virgin ID user
Virgin ID is your touchpoint for all things Virgin. This includes:
allowing you to use a single set of log-in details to access or create memberships and/or accounts with Virgin Points;
personalising your experience with the Virgin Partners you interact with including the sharing of information about you to support this personalisation;
where we have your permission, sending you marketing information, and/or our newsletter about all things Virgin
6.4 Examples of how and why we use your personal information
In operating Virgin ID, we may use your personal information for the following purposes:
Managing your account
When you are allocated your Virgin ID, we use your personal information to create your Virgin ID.
When you use your Virgin ID to access your account or membership with a Virgin Partner, we use your personal information so that they can recognise and authenticate you.
We also use your personal information to process account transactions and provide support
Sharing your personal information with Virgin Partners:
When you create an account or membership with Virgin Partners, we may share your personal information with other Virgin Partners you interact with. This is so we can provide you with a more tailored and personalised experience across the Virgin Group.
If you give them them permission the Virgin Partner may use the personal information we have shared to contact you with marketing
We will share and receive information about how you engage with Virgin Partners in order to provide you with support and improve our processes.
Contacting you:
If you give us consent to do so, we will send you news and updates about all things Virgin
We may contact you with information about Virgin ID and the services we provide. For example, if there's a new Virgin Partner you can use Virgin ID with
Personalising our services to you:
We may use your personal information to understand your habits and preferences. This is so we can personalise, enhance and improve your Virgin experience and our communications with you. For example we may use your browsing history of your use of Virgin ID to learn more about you, personalise our interactions with you, and give you a more tailored experience both offline and online.
We may combine your personal information, collected through various sources (such as Virgin Partner), including our services, to develop a profile which may be used to determine your propensity to do something. This is so we can tailor our services to you.
You can opt out of sharing your personal data at any time by changing the setting in your account space
Section 7 - Cookies and Targeting (including via social media)
7.1 What are cookies?
Cookies are unique identifiers, usually made up of small bits of text or code, and are usually stored on your device or in your web browser and send certain information back to the party who served the cookie. When we refer to cookies we are actually referring to a broader range of tracking technologies than just cookies, including web beacons, clear GIFs, pixels and other similar technologies. For mobile apps, software development kits, known as SDK's are embedded into the app itself. Whenever we refer to cookies in this policy we are referring to all of these technologies.
To find out more about how cookies work, including how to see what cookies are on your computer or device and how to block and delete cookies, please visithttp://www.aboutcookies.org.uk/.
7.2 How we use cookies
We may use cookies to help us understand how you use our apps and websites, to optimise your user experience and to personalise the services we provide to you, including the offers, marketing and advertising you may see when you interact with us. Cookies also help us to measure how effective our advertising is. We may also combine data we collect through cookies from multiple devices, with other data sources we retain, for example your Virgin Red transaction data.
We have a number of online channels. Below are further examples of how we use cookies in these channels.
Virgin.com
We operate the Virgin.com website, via which you can also access Virgin Red. Details of how we use cookies when you visit the Virgin.com website are separately detailed in the Virgin.com cookie policy.
Member support
We use cookies whilst you use our online member support platform. The cookies we use are (i) necessary cookies, which are essential for the platform to function; and (ii) performance cookies, which collect data for statistical purposes to monitor website usage and improve user experience.
Virgin Red app
We use cookies on our Virgin Red app to help us to optimise your user experience and to personalise the services we provide to you, including the offers, marketing and advertising you may see when you interact with us and to measure the effect of our advertising. The cookies we use are (i) strictly necessary - if you want to use our app, you need these for it to function, so you can’t turn these off; (ii) functional cookies, which make your experience on our app better such as remembering choices you make and provide enhanced, more personal features by showing you content that we think you’ll be interest in; (iii) analytical and performance cookies, which help us give you a personalised experience of our app across multiple visits and provide us with insight as to how you use our app and help us to make improvements: (iv) third party and advertising cookies, which allow us to show you adverts that we think you’ll like on sites away from our app and help us to measure how effective advertising campaigns are. This includes third party cookies, which allow you to let the world know what you’ve been doing in our app, including your social networks. We don’t control these cookies - please refer to the privacy policies of the separate social networks for further details.
Virgin Trains Ticketing app
Details of how we use cookies when you use the Virgin Trains Ticketing app are separately detailed in the Virgin Trains Ticketing cookie policy.
7.3 Examples of how we use cookies
We create a unique ‘user identifier’ to collect information in relation to your use of our apps e.g. your mobile network carrier, your app version, when you last logged in and updated, your device, device orientation, device resolution, and app usage information e.g. when, how often and what you browse when you use the app.
We may personalise adverts shown to you on other apps and websites based on your interactions with Virgin Red or Virgin Trains Ticketing by using data about your transactions with us. We analyse how members use our apps which helps us measure performance and enables us to personalise and improve our services and marketing.
When you visit and use our referral programme, powered by Mention Me, cookies are applied that enable the referral processes to work. You can read more about which cookies are applied by Mention Me within their policies. As these cookies are necessary you can't turn them off, but they won't be applied unless you visit these pages.
When you use (or link via) Virgin Red to earn points on goods and/or services with a third party retailer, your transaction is recorded via a unique ID and code on the third party website/app. We receive this information so we know the transaction has taken place and we can allocate Virgin Points to your account.
7.4 What third parties do we use in relation to cookies?
We use third party analytics providers to help us analyse how users interact with and use our apps or websites, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used may collect information such as your IP address, time of visit, whether you are a return visitor, what device and version of software you are using and any referring website or app.
The information generated will be transmitted to and stored by the third party and may be subject to their privacy policies. The third parties that we work with are contractually forbidden to sell any of the data collected on our behalf.
Links to the third party websites are listed below:
7.5 Social media targeting
In digital marketing, “targeting” refers to the ability to choose the people who are shown adverts. We may base our targeting on demographic and behavioural data, like age ranges or interest and behaviours and other information that we hold about you
We use your personal information to place advertising relevant to you on online media channels. We may work with service providers, including online media and social media channels to facilitate targeted advertising online. E.g. as a member of Virgin Red, you may see an advert for products and/or services related to Virgin Red if you use a particular social media site. We may confirm or ‘match’ your personal information such as email address with our service providers to facilitate this.
We will use your personal information to create “lookalike” audiences. We may use your information and details of your activity with Virgin Trains Ticketing to create customer profiles and then target people with similar profiles online (for example, via social media platforms like Facebook).
To interact with you online. If you choose to interact with us online, such as liking a social media page, we may send you a direct communication via that online channel.
7.6 Can I opt out of the use of cookies and social media targeting?
Apps
You can decide which cookies you are happy to accept when you initially use the apps or by visiting the 'Settings' section within the apps at any time. There are some cookies that are necessary to make the app function and these cannot be turned off.
Websites
You may be able to block certain cookies by configuring your browser settings. Please check your browser settings for more information. Please note however that by blocking or deleting cookies you may not be able to take full advantage of our services. Our services do not currently change the way they operate upon detection of a Do Not Track or similar signal.
You can also opt out directly by visiting the cookie banner on virgin.com - further details can be found in the Virgin.com Cookie Policy here.
Social media targeting
Social media marketing will be subject to the terms of use with the individual social media platform that you use. E.g you can update your ad preferences to turn off personalised ads but you can’t turn off ads completely in social media channels (as this is how the social media channel is funded).
Section 8 - Important Information
The following relates to all the services we provide.
8.1 Personal information relating to under 18s
The Virgin Red programme is available to those aged 18 years or over, so we do not collect personal information on children as members of Virgin Red.
Virgin Trains Ticketing is available to those aged 18 years and over, or those aged 16 and 17 with parental consent. Virgin Red may collect and retain limited personal information on those under the age of 18 where purchases are made using the Guest checkout facility of Virgin Trains Ticketing.
The Flying Club programme is available to those under the age of 18 with parental consent. VR may collect and retain personal information on those under the age of 18, where they have been permitted to join Flying Club
Virgin.com is only intended for the use of those that are 18 years or over, so please do not attempt to use the Website and please do not provide us with your name, contact details or any other information about yourself. To find out more, please read the Virgin ID and Web Terms of Use for more information about this.
Virgin ID is available to those aged 18 years or over. Please read the Virgin ID and Web Terms of Use for more information about this.
8.2 Websites to which we link
Our apps or website may contain links to other third party websites or apps. This policy only applies to services offered by us so you should read the privacy policies for any other services, applications or websites that you visit via clicking on links within our services. We have no control over, and are not responsible for, the data that may be collected by those websites and we cannot take any responsibility for any information you give to them.
8.3 How will we share your personal information?
We do not sell or rent personal information.
In connection with the purposes and on the lawful grounds described above, we will share your personal information with a number of third parties including programme partners which enable you to collect and spend Virgin Points, participating Virgin Partners in the operation of Virgin ID, and suppliers that provide services to help us run our business, including but not limited to the following:
Partners that offer Virgin Points or are associated with Virgin Red
Partners that provide services to us
IT companies and hosting providers
Third-party software companies that provide us with applications
Companies that manage our customer service enquiries
Advertising providers including online and social media platforms such as Facebook, Twitter and Instagram
Marketing agencies that run our marketing and research campaigns
Mailing houses and printers
Website and app analytics providers
Delivery services, such as couriers
Payment providers
Fraud detection agencies and credit card screening companies
We will only share your personal information with carefully selected, reputable partners and suppliers, and we require all such partners to treat your personal information as confidential and to fully comply with all applicable information protection laws and consumer legislation. These trusted third parties would only be permitted to use your personal data for the purposes we specify.
Like many other companies, we have partners and suppliers worldwide. This means that to provide our services it is often necessary for us to send your personal information outside the UK and the EEA. We put the necessary safeguards in place when your information is shared outside the UK and the EEA and do not allow any of our data processors to use your information for their own purposes. They must only use the information as instructed by us for the specified purposes we have agreed.
You also agree that we may share your information with:
Any other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure is permitted or required by law.
Where necessary, with regulators and governmental bodies including HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers based inside and outside the EU, who require reporting of processing activities in certain circumstances.
We may also share some broader statistics and customer profiling information with third parties and other Virgin entities - but we'll keep it anonymous so you won't be identifiable from that data.
To see all of the categories of personal information we share, click here.
8.4 How do we keep your information safe?
We have put in place appropriate security procedures in relation to how your personal information is stored, accessed and transferred to help stop access by any unauthorised person.
All personal information that you provide to us or that we hold is located behind a firewall. We also follow access management procedures to ensure that only qualified and necessary personnel have access to the personal information required for a role.
We regularly monitor our systems for possible vulnerabilities, and we carry our testing to identify ways to further strengthen our security posture.
We regularly review the best way for our customers to access their accounts, whether that be passwords, one-time passcodes or biometrics (such as face ID or fingerprint ID on your mobile device). Where the use of biometrics is available it will be your choice if you choose to use it.
Whilst we take appropriate technical and organisational measures to protect your information, it is important that you keep your email account and access to your devices secure against unauthorised access. Please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. If you suspect an unauthorised use or security breach of your personal information, please contact us immediately.
We may use your information to make sure our services are secure, to comply with legal obligations and to protect our business interests. We will use your information to operate our services securely, including to investigate and deter fraud, unauthorised or illegal activities, for systems testing, and for maintenance and development.
8.5 How long will we retain your personal information?
We will only retain your information for as long as is necessary to fulfil the purposes for which we are processing it. Naturally, we keep your personal information while you are a member of Virgin Red and/or using Virgin Points as part of Flying Club so that we are able to provide you with access to Virgin Red and/or the use of Virgin Points, but we also keep it for a period after your membership ceases, though only for as long as we need it and are justified in doing so.
If you have a Virgin ID, we will retain the information we process in connection with your Virgin ID while you are a customer of any participating Virgin Partner so that we can provide you with the services associated with your Virgin ID as well as for a period after you finish being a customer, though only for as long as we need it and are justified in doing so.
How long we keep your information depends very much on the type of personal information and the purpose for which we are justified in keeping it, as well the need to comply with any relevant legal obligations. You can request that we delete your personal information at any time. Please see the "What are my rights?" section below.
8.6 How can I check and update my personal information?
It is your information - please make sure you check it, update it and that you're comfortable with providing it to us. You can contact membersupport@virgin.com to update your personal information.
8.7 What are my rights?
You have the right to stop using our services and terminate your Virgin ID, Virgin Red and/or use of Virgin Points at any time. When you do so, you will no longer be able to use your Virgin ID or, earn or spend Virgin Points.
You also have the right to object to our use of your information for our legitimate interests. However, your objection to this sort of processing may affect our ability to carry out some or all of the services provided as part of your Virgin ID, your membership of Virgin Red and/or your use of Virgin Points as part of Flying Club or Virgin Trains Ticketing.
Please note that, in these circumstances, we may still keep your information for a reasonable period afterwards, as per the "How long will we retain your personal information?" section. You also have the following rights when it comes to our use of your personal information:
Right of access. You have the right to request a copy of your personal information and to request information explaining how your personal information is used. Please note that sometimes we may ask you to provide proof of identity before we show you your personal information. This is so we can protect unauthorised access.
Right of rectification. You have the right to request that we rectify inaccurate personal information about you.
Right of erasure. You have the right to request that we erase all personal information about you. Please note that we may be able to reject or restrict the request in some circumstances, depending on the type of information and our lawful reason to retain it.
Right to restrict processing. In some situations, you have the right to request that we do not use the personal information you have provided (for example, if you believe it to be inaccurate).
Right to object. You have the right to object to certain processing by us of your personal information where the processing is based on our "legitimate interests" (unless we have overriding compelling grounds to continue processing) and the right to object to direct marketing by us.
Right to information portability. You may have the right to request that we provide you with certain information that you have provided to us in an electronic format, or to provide that information to a third party.
You also have the right to not receive discriminatory treatment for exercising any of the above privacy rights. If you would like to exercise any of these rights please get in touch with us, directly or through an authorised agent, by writing to us at Virgin Red Limited, 66 Porchester Road, London, W2 6ET UK or emailing us at membersupport@virgin.com Alternatively, you can contact our Data Protection Officer at red.dpo@virgin.com. You have the right to complain to the UK's information protection regulator, the Information Commissioner's Office (ICO), about our use of your information. You may wish to use the relevant section of the ICO website to do this: https://ico.org.uk/concerns/.
8.8 Your California privacy rights
We do not share personal information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our services. Please be mindful that this would not ensure complete removal of the content posted by you on our services. To make any request pursuant to California privacy law, please contact us.
8.9 Changes to our business
As mentioned above under ‘How will we share your information’ , if ownership of all or part of our business or assets changes or is likely to change, or our business is or may be subject to a merger or sale or we undergo a reorganisation (including without limitation a merger or transfer between Virgin companies) you agree that we may transfer your personal information to any potential or actual new owner or successor, to enable the continuation of all the services provided.
6.10 Finally - if in doubt, talk to us
If you have any questions, comments or complaints regarding this Privacy Policy, just get in touch. You can contact us using any of the details set out in the "What are my rights?" section above.