1/ Data Controller
VM is the data controller and is responsible for your personal data and Hanzo is a data processor of your personal data.
Email address: firstname.lastname@example.org
Postal address: Data Protection Officer at Virgin Money, Jubilee House, Gosforth, Newcastle upon Tyne NE3 4PL
We may ask our Data Protection Officer to look at your situation. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2/ The Information we collect about you
By personal data we mean all of the personal information about you that we collect, use, share and store. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, title and age-range and may include your gender.
Contact Data includes address and email address andmay include telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
Profile Data includes your username and password, your interests, university course, preferences, feedback and survey responses.
Usage Data includes information about how you use our Website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3/ Where we collect information from
We collect information directly from you and others.
You may give us information by corresponding with us by email or otherwise. This includes personal data you provide when you:
- create an account on our Website;
- send us visual content (your “Content”) by uploading it to the Website;
- subscribe to publications or request marketing to be sent to you;
- enter a competition, promotion or survey and conversations with us on social media;
- give us feedback or contact us;
- use our Websites or applications, including through cookies that collect information on your internet use;
We’ll also analyse and combine the information collected (sometimes automatically) to understand the way you use your account and our services as well as what you might like and what you might do. Through our analysis we may create a profile of you to help us predict your account behaviour and preferences so we can provide services to you (‘profile information’).
4/ How we use your data
Data Protection law requires us to have one or more of the following reasons for using your information:
‘Contract performance‘ – e.g. the information needed to deliver your account or the LifeStart Websites.
‘Legal obligation‘ – We are required by law to process your information, e.g. to verify your identity.
‘Legitimate interest‘ – We’re allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights e.g. we have an interest in knowing what you do and don’t like so we can offer better services.
‘Consent‘ – in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained. Whenever ‘consent’ is the only reason for us using the information you have the right to change your mind and change or withdraw your consent.
These are the main ways we’ll use your personal information (and the reasons for doing so):
- Manage your account and relationships with us (Contract performance; Legal obligation) including:
- administering your participation in LifeStart project(s) and the administration of the Content you submit on the Website;
- helping to resolve any problems or complaints you may have;
- providing you with information about LifeStart prizes, activities, modules and challenges;
- administering any Competitions you’ve agreed to participate in;
- Providing you with information and obtaining your views and input on VM’s future banking proposals and Virgin Start Up (Legitimate Interest); and
- We may share your personal information where required to do so by law, or if we believe that the response is reasonably necessary to protect the values and objectives of the Website or other users (Legal Obligation, Legitimate Interest); and
- We may disclose your name and contact details to a third party who is claiming that Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy, although we will try to notify you first before doing this by using the contact details you have provided (Legitimate Interest).
- For marketing and market research purposes subject to receiving your consent (Consent):
- Where you have confirmed that you are happy to receive marketing communications, we may use your information to keep you informed by post, telephone, email or other means of products and services which may be of interest to you.
- We may also use your data to undertake market research or data analysis work to help us improve the services that we provide to you. We may contact you in order to conduct such market research. Your personal data may also be used for the purposes set out here after you cease using the Website. If you do not want your personal data to be used for marketing purposes, you are able to unsubscribe by using the unsubscribe link in every marketing email we send you, or by contacting the Data Protection Officer at the details set out in the “Data Controller” section above.
5/ Disclosures of your Personal Data
When using the information we hold about you, we may share it with other people or organisations.
We’ll treat the information we hold as confidential and may share information with the following who are also required to keep the information confidential, safe and secure:
- The companies within the Virgin Money Group.
- Other companies, commercial partners, agents and professionals who provide products, services and administrative support to the Virgin Money Group, such as Hanzo.
- The companies, organisations and professionals who provide other services to you.
- Anyone we may transfer our rights and duties to under any arrangement.
- Anyone else with your permission.
6/ Using information outside the European Economic Area (EEA)
All countries within the EEA, which currently includes the UK, have similar standards of legal protection for your personal information. To provide some products and services we transfer and process information in countries outside the EEA (e.g. the United States) where there aren’t similar standards.
In these cases we’ll take all reasonable steps necessary to make sure your information is protected to UK standards. This may be through only allowing transfers to countries which have been officially recognised as having an adequate legal framework for the protection of information (an ’adequacy decision’). It may be through having recognised safeguards in place with our commercial partners, such as using standard terms in the contracts we have with them that are recognised and approved by our regulators as imposing high standards for the protection of information or where our commercial partner is a signatory to a recognised and binding code of conduct.
To find out more about any particular uses of information in countries outside the EEA, the existence of an “adequacy decision” for that country or the safeguards we have put in place, please contact our Data Protection Officer.
7/ How long we hold information
We’ll retain information for no longer than is necessary to manage your relationship with us and this may mean that we’ll continue to hold some information for a period of time after you close your account or our relationship has ended. This includes where we need to keep the information to comply with legal and regulatory obligations, to resolve disputes or where it may be needed for future legal proceedings.
8/ Your legal rights in relation to your information
The law guarantees you rights in relation to your personal information. We have set out details of your rights below under individual headings.
Access to information
You always have the right to ask whether or not we hold information about you. And if we do, what the information is, why we’re holding it and the ways it’s being used. You’re also entitled to a copy of the information.
Rectification of information
We always want the information we hold to be up to date and accurate. If any of the information we hold is either incorrect or out of date then please tell us and we’ll fix it.
Erasure of information
You have the right to ask us to erase or delete information where you consider there is no longer any justification for us holding it, either because:
- The information is no longer needed for the reason we collected it.
- We held and used the information based only on your consent, which you have now withdrawn.
- You have previously objected to a way in which we use information.
- We have been using the information unlawfully.
- There is a legal obligation on us to erase the information.
When you make a request for information to be erased we’ll have up to one month to respond. If we reject your request we will tell you and set out the reasons why we won’t erase or delete the information.
Portability of information
You have the right to get some of your information that you provided from us in a machine-readable format.
Objecting to us using your information
We have told you about the ways in which we use the information we hold.
Where we have told you that any use of information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection we’ll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.
Remember, you can always simply opt out of receiving marketing communications at any time. You can unsubscribe from emails by clicking the unsubscribe link in the footer of any email you receive from us, or by contacting us at email@example.com.
Restricting some uses of information
In certain circumstances, you have a right to block or limit the use of information by us. This may arise where:
- You have challenged the accuracy of the information we hold and we are verifying this.
- You have objected to a use of information (see above) and we are considering whether your objection is valid.
- We have been using your information unlawfully but you want us to continue to hold the information rather than erase it (See “Erasure of Information” above).
- We no longer need to keep the information but you have asked us to hold it because of legal claims you’re involved in.
A cookie is a small text file which we transfer to your hard drive through your web browser when you visit our Website or open certain emails. It enables our own system to recognise you when you visit our Website again and improve our service to you. This information can be used to enhance the content of our Website and make your use of it easier. For information on how you can configure your browser to reject cookies or for information on how to control your online behavioural advertising preferences, please visit http://www.youronlinechoices.com/uk/.
10/ Use of other Technologies: Web beacons and pixel tags
These are similar to cookies and allow us to collect information about how you use our Website and help us to offer you the best service. We may use web beacons and pixel tags alongside cookies both on our Website and in any emails we send to you.
Again, web beacons and tags are commonly used across many websites and do not harm your computer system.
Further information can be found at http://www.allaboutcookies.org/web-beacons/
11/ Information security
The Website employs enhanced encryption techniques which seek to ensure that all of your confidential data (such as, name, address and other information) cannot be intercepted, unscrambled or copied when being transmitted between our server and you.
13/ Making changes to this information