Last updated on: 8th October 2018
Here at Virgin Unite ("Unite", "we" or "us"), we take your privacy seriously. We're committed to protecting the privacy of any personal data you give us. We will comply with all relevant data protection legislation. For the purposes of relevant data protection legislation, The Virgin Foundation is the data controller of personal data we hold and process about you. We are registered on the public register of fee payers maintained by the Information Commissioner in the UK. See the "Talk to us" section below for details of how to contact us.
We have a philosophy here about the way we use any of your data you share with us. If you hear from us, we will always aim to be respectful, relevant and appropriate. If at any time you don't feel we've lived up to our philosophy, please let us know straight away by getting in touch with us.
We are proud to give you access to the site, to work with you in relation to your support of Unite and to assist with related services and projects and, in return, we may collect, use and share your personal data. We will only use personal data for our purposes in a manner permitted by relevant data protection legislation, which may include:
- where necessary to provide the site and its features and in order to give you the best user experience;
- where we are under a contractual or legal obligation to do so;
- where you have explicitly consented (for example, by actively signing up to receive our newsletter)or
- for our legitimate interests.
By “legitimate interests”, we mean our interests in managing the site and our relationship with you. We will make sure that we take into account any potential impact that such use may have on you. Our legitimate interests will not automatically override your interests and we won’t use your information if we feel that your interests override ours (unless, of course, you provide your consent, or we have a contractual or legal obligation to use your information in that way). If you have any questions or concerns, please contact us using the details set out in the “Talk to us” section below.
What information will we collect from you?
You may give us information (including personal data) about you by filling in forms on the site or by communicating with us verbally, by phone, by email, by your actions or otherwise. This includes information you provide when you create an account, make a donation, request to get involved in a project or an event, update your profile information, enter a competition, promotion or survey and when you report a problem with the site. The information you give us may include the following:
- contact details including your name, email address and phone number;
- personal details including gender, date of birth and location where you are based;
- professional details including your role, skills, years of experience and CV;
- community trip details including passport details, emergency contact details, medical history and food allergies;
- financial information including bank account details, card details, details of donation(s); and
- project and donation history information including whether you've taken part in a project or donated before.
If you do decide to make a donation to Unite, our donors due diligence policy requires that we collect some further information to ensure the legitimacy of the origin of the donation. As part of this due diligence, we may be required to collect information such as, your nationality, your home address or other addresses at which you reside and information on your business activities. It is your decision as to whether you give us this information but in the event that you choose not to share this information with us, we may not be able to accept your donation.
Will we use your information for marketing?
How else will we use your information?
We may also use your information (including personal data) for the following purposes:
- to help us make the site and related services and projects available to you (please see the "Will we share your information with anyone else?" section below for more information);
- to make the site more relevant for you and our other visitors. This includes sometimes requesting personal data from you to help us run and develop the site and associated functions;
- to arrange an event, trip or project that you would like to take part in;
- to process any donation you have given;
- to send you our newsletter if you have signed up to receive it;
- if you have consented, to market community trips or projects to you, or to ask you to donate;
- to carry out surveys occasionally and to analyse our user base — ultimately we want to ensure that the site provides everything that you — our audience — is 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 is necessary to prevent illegal activity or to protect our interests.
How long do we keep hold of the information?
There are certain reasons that we have to keep hold of some of your information (including personal data). Naturally we keep your information while you are a member of Unite so that we are able to communicate with you and provide you with the information set out above, but we may also keep it after you've left us (though only for as long as we need it). How long we keep it depends very much on the type of information we are holding and the purpose for which we need it (as well as complying with our legal obligations).
We may also keep information about how you have used Unite to help us improve our offering for other members, though we will remove any identifiable (or personal) data.
You can request that we delete your personal data at any time.
Will we share your information with anyone else?
We may share your information only if:
- you specifically request this, such as when you submit information to enquire about projects or donations through the site;
- we are required to do so to comply with a contractual obligation or legal requirement or with the directions of the courts or other authorities;
- we feel it is reasonably necessary to prevent illegal activity or to protect our interests;
- we feel that other Virgin entities’ products and services may interest you;
- it helps other members of the Virgin group or other third parties to arrange (or help run smoothly) an event, trip or project that you would like to take part in and we are involved in; or
- it helps our trusted third party service providers to provide and improve our service to you or to carry out surveys and user analysis to understand your needs and preferences - please see details of our trusted third party service providers below. We will also share your information with MailChimp, who securely host emails and act as a supplier to distribute our newsletter. We require these service providers to keep your personal data safe and secure. These trusted third parties would only be permitted to use your personal data for the purposes we specify.
Our trusted third party suppliers: As at October 2018, the providers with whom we currently share personal data are:
- our payment processing agent (currently MasterCard); and
- our supporter database provider (currently Salesforce).
We may 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.
We won't rent or sell our user's details to any other organisation or individual.
What if you post information on the site?
This site contains an opportunity for users to comment on content on the site ("User Content"). It is information in the public domain, so it may be accessed by any person using the web in any part of the world and can be found using independent search engines. So, if you choose to post information to the interactive parts of the site, we have to state that you do so at your own risk. This is the case whether the User Content is uploaded directly onto www.virgin.com or through a connected website.
This means your User Content:
We are obliged by our legal eagles to state that, to the maximum extent permitted by law, neither The Virgin Foundation nor any other Virgin entity will be liable to you or to any third party for any loss or damage resulting from any User Content posted on the site.
Please read our Terms and Conditions for more information about posting User Content. If you register on the site, you'll need to comply with our Terms and Conditions.
If you have any concerns about User Content appearing on this site, please Contact Us.
How will we make sure the site is secure?
We follow strict security procedures as to how your personal data is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal data you register on this site will be located behind a firewall. We take security extremely seriously but as no system is 100% secure, we can't completely guarantee the protection of your personal data, any more than any other organisation can. So we can't accept any liability for the loss, theft or misuse of the personal data which you've registered on this site if there is a security breach.
Will we be transferring any personal data outside the EU?
Countries outside the European Union may have a lower standard of protection for personal data than that required by EU data protection laws. The information we collect from you may be transferred to, and stored, outside the EU (including for example in the United States) and may also be processed by people operating outside the EU who work for us or one of our suppliers. If we need to transfer your data to a company based outside the EU (e.g. if our hosting company is based in the US), we'll take steps to make sure your personal data is handled in line with EU law. If you would like any more details on this please get in contact with us (using the details set out in the “Talk to us” section below).
What are my rights?
- You have the right to stop using the site at any time. Please note that, in these circumstances, we may still keep your data for the reasons set out in the "How long do we keep hold of information?" section.
- You also have the following rights when it comes to our handling of your personal data:
- Right of access – you have the right to request a copy of the personal data we have about you and to request supporting information explaining how the personal data is used. Please note that sometimes we may ask you to provide proof of identity before we show you your personal data - so we can prevent unauthorised access.
- Right of rectification – you have the right to request that we rectify inaccurate personal data about you that we have.
- Right of erasure – you have the right to request that we erase all personal data about you that we have (please note that we may be able to reject or restrict the request in some circumstances, depending on the information we hold and our lawful reason to keep it).
- Right to restrict processing – in some situations, you have the right to request that we do not use the personal data you have provided (e.g. if you believe it to be inaccurate).
- Right to object, including to direct marketing – you have the right to object to certain processing by us of your personal data (unless we have overriding compelling grounds to continue processing) and the right to object to direct marketing by us.
- Right to data 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.
Please get in touch with us at the address below if you would like to exercise any of these rights (including having access to your personal data):
c/o Virgin Management Limited
The Battleship Building
179 Harrow Road
London W2 6NB
Alternatively, you can contact our data protection officer at firstname.lastname@example.org.
You have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), about our handling of your data. You can use the relevant section of the ICO website to do this: https://ico.org.uk/concerns/.
What about personal information relating to minors?
Protecting the online privacy of children is especially important. If you are under 18 years old, please do not provide us with your name, contact details or any other information about yourself. To find out more, please read our Terms and Conditions.
The site contains links to other websites. Obviously, we don't have any control over them and take no responsibility for any information you give them. Other sites have different privacy and security policies, which we advise you to read.
Talk to us