For the purposes of relevant data protection legislation, Virgin Red Limited is the data controller of the personal data that we hold and process about you.
Your data is very important to us and so is your trust. That's why we want to be open and clear about the data we hold on you and how we may use it. We want you to be confident that we'll use your personal data safely and responsibly (when we talk about "personal data" we mean any data that can be used to identify you - this might be your name, email address, or other digital identifiers relating to you, such as cookies, IP addresses or logs).
Our philosophy and approach to data privacy is that we will do our best to:
1. comply with relevant data protection legislation and all other applicable laws;
3. only collect personal data that may be required in relation to the App;
4. make sure you can access, update or remove your personal data and exercise your other rights under relevant data protection legislation;
5. protect your personal data and keep it secure;
6. train our staff on the importance of privacy and making them aware of the correct processes to follow in relation to privacy and the handling of personal data; and
7. make sure our partners and suppliers are aware of our privacy standards, where our members are involved.
We are proud to provide you with access to the App and, in return, we collect, use and share your personal data as is necessary for us to give you the best user experience and to perform our contract (the Red t&c) with you. We also process your data so that we can make the App more relevant to you and our other members. This may include requesting personal data from you to help us run and develop the App, deliver products or otherwise talk to you.
Below we'll explain in more detail what personal data we may ask you for, how we use it, and how you can check and update it.
How do we collect personal data?
You may provide us with your personal data (i) when you sign up to become a Virgin Red member, (ii) when you use the App, or (iii) when you use products and services made available on the App.
For example, we may collect personal data when you:
- Register for an account, whether using your email address or social media login
- Visit the app (through a cookie)
- Enter any promotions, competitions or prize draws through one of our services
- Participate in our quizzes, games and challenges on the App
- Redeem or buy whether it's directly with us or through us with one of our partners online, over the phone or redeeming in a store
- Verify that you're a customer of another Virgin company on the App;
- Update your account or personal data; or
- Enable your device's geo-location technology
Sometimes we receive this information when you enter it on the App, and sometimes we receive it from other Virgin companies or third party partners when you engage with them in relation to the App or one of our offers or for verification purposes. We may also match anonymous information about the lifestyle behaviours of people in your area, which we may collect from third parties (such as Experian).
What type of personal data do we hold?
Depending on whether you agree to share it with us, we may collect the following types of data:
- Virgin Red account profile your name, address, postcode, mobile number, gender, age, email address and existing memberships of other Virgin companies and third party partners;
- Social media profile if you choose to sign up to Virgin Red using Facebook when you first create an account with us (see "what happens when I connect through a social network");
- Who you are including name, address, postcode, mobile number, gender, age, existing memberships with partners
- How you use the App where you use the App (if you have enabled geo-location for the app on your device), how and what features, content, communications and products you view and User Content you chose to provide (for example whether you complete a quiz, tell us what you prefer through "This or That" or share content as part of "Show & Tell");
- Your purchases - what and when you have purchased from us and our partners; and
- Your history with Virgin i.e. whether you have been invited by or verified that you are a customer of one or more of the other Virgin companies. We may also hold information that we have received from that Virgin company if they have shared something to help us improve the App for you based on your relationship with that Virgin company. For example what Virgin products you own, your spend or usage.
Will we use your personal data for marketing?
We'll only use your personal data for marketing if you give us your consent on the 'Permissions' page on the App. These types of marketing may include receiving our newsletter by email, getting push notifications from the App, or getting targeted marketing on selected third party platforms like Facebook. If you give us your consent to market to you, the types of marketing messaging you may receive from us could include:
- alerting you to offers, events and new features on Virgin Red that we think you might like; or
- letting you know about products and services from our carefully selected partner companies that we think you'll be interested in and, in some cases, that are near your location.
But don't worry, you can withdraw your consent to direct marketing like this at any time by following the unsubscribe link in the emails or changing your preferences in the Permissions page on the App. You control which channels you're happy for us to use in our marketing. If a channel isn't listed in the 'Permissions' section of the App then we're not currently using that channel in our marketing. The only exception to this is that you may receive marketing from Virgin Red via push notifications (however, as with all push notifications from apps, these can be turned off at any time via your phone's settings).
Of course, as you'd expect from Virgin Red, you'll still see offers and prize draws in the app from us, as well as other Virgin companies and third parties.
How else will we use your personal data?
We use the data that we collect from you to run, develop and improve the App, and to keep in touch with you (if you want us to!).
More specifically, this means we may use your data to:
- Give you access to the App when you log in with your account info;
- Deliver products and services to you, from us or our partners
- Tailor the content you see on the App and improve our service (for example we may provide specific offers based on your This or That responses);
- Promote User Content that you have posted within the App to other members within the App. This would include content such as 'Show & Tell' - see "What happens to the User Content I post?" below (if we have your consent to do so);
- Enable you to make purchases through our system and deliver anything you order to an address provided by you;
- Verify your memberships you have with any of our Virgin company partners e.g. Virgin Trains;
- Contact you about the App and our services (e.g. if they've changed), orders you've placed or to talk to you about any issues or questions that you might have regarding the service;
- Respond to your questions and customer service queries; or
- Conduct research, analysis and write reports (either ourselves or with selected third parties, like Facebook) to understand our customers, how to make the App better, and how best to grow our Virgin Red community (which will only be done on an anonymised and aggregated basis).
What happens when I connect through a social network?
We understand that social networks are a big part of many of our members' lives and so we offer members the option to login through social media networks and share their experiences with friends and family. When you share information on these social networks (via the App) please refer to the privacy settings of your social network to understand and manage how this information is shared. Where you do login using a social network, we will not be provided with your password or other account login details for those accounts.
By connecting to the service using a social network, you will be asked to grant us permission to access some of your personal data so that we can create your account (for example if you sign up to Virgin Red using Facebook, the email address associated with your Virgin Red account will be the same one associated with your Facebook account).
What about privacy on other services that we link to?
What happens to the User Content I post?
To engage with the wider Virgin Red community, we would like members to see how much fun the community is having and to showcase it within the App. To do this we may use your User Content (for example anything shared through 'Show & Tell') to promote certain aspects in the App.
User Content is information in the public domain, so it may be seen by other members within the App. Please also be aware that when you post User Content we may also display your first name and profile picture (if you have one) next to your post. This means that if you choose to post some User Content (for example, as part of a Virgin Red challenge or a Show & Tell campaign), we have to state that you do so at your own risk.
Occasionally, we may also ask you if we can use your User Content to engage our community or promote the App on our social media networks. In this instance, and only where you provide us with your consent, this means your User Content:
We are obliged by our legal eagles to state that, to the maximum extent permitted by law, neither we nor any Virgin group company will be liable to you or to any third party for any loss or damage resulting from any User Content posted on the App, or, if you agreed for it to be so posted, on our social media sites. Please read our Terms and Conditions for more information about posting User Content. If you register as a member, you'll need to comply with our Terms and Conditions.
Will we share your personal data with anyone else?
We only share anonymous, summary statistics and profiling reports with our partners, unless specifically explained below.
For what purposes do we share personal data?
We will not release your personal data to any company unless it is for the following reasons:
- to provide you with access to exclusive and personalised deals, or other relevant marketing on the app;
- to complete your order purchase (which may include sharing your personal data with our payment processor) and to deliver your goods;
- to help us, or one of our suppliers, run our services (for example IT vendors, payment services, customer service centres), send emails or marketing; or
- to verify or reward you for your existing custom with one of our partners, and to help them improve their goods and service offerings to you and others.
When do we share personal data with other Virgin companies?
We may share your personal data with other Virgin companies in order to verify any relationships you might have with any other Virgin company in the 'My Virgin' section of the App.
This is to check with the relevant Virgin company that you are indeed one of their customers. In this scenario, we will ask you to enter the relevant information relating to your relationship with that Virgin company (which may include your membership, card or customer ID or your email address). We'll then send this to them (or their sub-contractor) to securely check if you are a customer (or not) and when they confirm that you are, we can award you extra points and show you more relevant content.
When do we share personal data with third party service providers?
If we do share your information, we will only share it with our carefully selected, reputable partners and suppliers, and we require all such partners to treat your personal data as confidential and to fully comply with all applicable data protection laws and consumer legislation. As at 23rd May 2018, these third parties include:
When do we share personal data with other third parties?
We may also be obliged to share your personal data in order to comply with applicable law or regulations, if requested by a public authority or law enforcement agency or at the directions of the courts, a public authority or a law enforcement agency, or if we think that you or other people are at risk.
Although we try to keep all of our suppliers within the EU, like many other companies, we may use some suppliers based in the US and elsewhere outside of the European Economic Area. If this is the case, all such suppliers are expected to treat your information in-line with applicable EU and UK laws by putting in place appropriate legal safeguards.
How do we keep the information safe?
We follow strict security procedures as to how your personal data is stored, accessed and transferred to help stop any unauthorised person getting hold of it.
All personal data that you register on the App will be located behind a firewall. We also follow identity management procedures to ensure that only qualified and necessary personnel have access to the personal data they need for their roles.
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. On that basis we can't accept any liability for the loss, theft or misuse of the personal data which you've registered on this service if there is a security breach. However, we will take the appropriate measures to respond to and manage any incident, in accordance with relevant data protection legislation as best we can. This includes taking measures to contain the incident, attempting to recover the information, assessing the risks and notifying those affected.
How long do we keep hold of the personal data?
There are certain reasons that we have to keep hold of some of your personal data. Naturally we keep your personal data while you are a member so that we are able to provide you with access to the App, but we 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 personal data we are holding and the purpose for which we need it. We also have to take into account our legal obligations in respect of that data. For example, we may need to keep some non-personal data for financial reporting or to comply with our legal obligations.
We may also keep data about how you have used the App to help us improve it for other members, though we will remove any identifiable (or personal) information.
You can request that we delete your personal data at any time (please see the "What are my rights?" section below).
How can I check and update my personal data?
It's your data - please make sure you check it, update it and that you're comfortable with providing it to us. You can go to the App "Settings" and then the 'Me' profile to check and update it.
Please remember, if you choose not to share certain personal data you might not be able to use certain parts of the App. For example if you don't share your address, you won't be able to receive certain competition prizes or if you do not share your geo-location, you won't be able to see your nearest locations for in-store deals and you may not be shown local offers.
What are my rights?
You have the right to stop using the service and terminate your Virgin Red membership at any time. When you do so, you will no longer be able to use the App. 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 the personal data?" section.
You also have the following rights when it comes to our handling of your data:
- Right of access - you have the right to request a copy of the personal data we have on you and to request supporting information explaining how the personal data is used
- Right of rectification - you have the right to request that we rectify inaccurate personal data about you
- Right of erasure - you have the right to request that we erase all personal data about you (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 - including what and when you have purchased from us and our partners
- Your history with Virgin - 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 - you have the right to object to certain processing of your personal data (unless we have overriding compelling grounds to continue processing) and the right to object to direct marketing
- Right to data portability - where we are relying on your consent to use your information, you have the right to require us to provide you with a copy of your information for your use or transfer to another service provider.
Please get in touch with us at the address below if you would like to exercise any of these rights:
Virgin Red Limited
The Battleship Building
179 Harrow Road
London W2 6NB
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 to us. 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.
What is our legal basis for processing your personal data?
The majority of data processing activities that we conduct are required in order to perform our obligations under the Terms and Conditions. Where we request your consent, we are processing your data on the basis of that consent and for all other purposes we are relying on our legitimate interest to operate and improve our service.
Where we refer to our "legitimate interests", we mean our interests in managing the Red service 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 below.
Cookies are used to help us better understand how applications and websites work and to optimise user experiences. They 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. By cookies we are actually referring to a broader range of technologies than just cookies, including web beacons, clear gifs, pixels and other similar technologies.
Strictly necessary cookies: these are cookies that are essential for the App to function, such as our own Virgin Red cookie (access token) which helps us to understand when people start and finish their app sessions.
Performance cookies: these types of cookies collect data for statistical purposes to monitor usage of the App and are used to improve your user experience. Some of the cookies used by our App may be set by us, and some are set by third parties who are delivering services on our behalf.
Conversion pixels: these are set by our partners on their websites to send information back to Virgin Red when a purchase has been made via the App. This allows us to track whether you go on to purchase a product or service with our partners after redeeming an offer or reward on the App.
Advertising cookies: these are used to deliver adverts more relevant to you and your interests. They are also used to measure the effectiveness of the advertising campaign.
Mobile attribution providers, such as Adjust, use unique URL tracking links to identify a particular advertisement (email or online) in combination with your mobile device advertising ID to attribute app downloads and usage to an advertisement.
Some of our partners use affiliate marketing networks, which provide a link between their advertisement and companies such as Virgin Red who publish their ad. In these instances Virgin Red may place cookies on behalf of a network, for example Affiliate Window or Doubleclick. When you visit certain retailers from the App or the website you will be doing so using an affiliate link along with the cookies they set.
Virgin Red is not responsible for the marketing networks used by our partners, which may vary and change. To find out more about which companies work with web providers to collect and use information for online advertising and control your preferences, please visit http://www.youronlinechoices.com/uk/your-ad-choices.
To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit http://www.aboutcookies.org/. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on 'Limit Ad Tracking'. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on 'Opt out of interest-based ads'.
You may be able to avoid certain cookies by configuring your browser settings or opting-out directly with the party that operates and controls the cookie. Please check your browser settings for more information.
Please note however, that (as with other websites and apps) by blocking or deleting cookies used on our App you may not be able to take full advantage of our App.
Finally - If in doubt, talk to us