Privacy policy<p>
<b>Last updated on: 05 July 2021</b>
</p>
<p>
<b>The Virgin.com website (the “Website”) is managed and operated by Virgin Red Limited.
This Privacy Policy applies in relation to your use of Virgin.com.
There is a separate privacy policy for the Virgin Red Rewards Programme and the use of Virgin Points (including the website pages for that programme available at </b>
<b>virgin.com/virgin-red</b>
<b>) which will apply both to your use of those web pages and your use of the Website if you are logged into your Virgin Red account. .
The Virgin Red and Virgin Points Privacy Policy can be found by </b>
<b>clicking here</b>
<b>.</b>
</p>
<p>Here at Virgin Red Limited (<b>"we"</b> or <b>"us"</b>), we take your privacy seriously.
We're committed to protecting the privacy of any personal data you give us and we will comply with all relevant data protection legislation.</p>
<p>We have a philosophy about the way we use the data you share with us and the way that we communicate with you.
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 by using the details set out in the “Talk to us” section below.
</p>
<p>Please take the time to read this Privacy Policy as it is important for you to understand how we collect and use your data when you use Virgin.com.
This Privacy Policy explains how we collect, use and store the personal data you provide to us in relation to your use of the Website.
References in this Privacy Policy to <b>“personal data”</b> mean data that relates to you and that identifies or can be used to identify you, which might be your name, email address, or other digital identifiers relating to you, such as cookies, IP addresses or logs.</p>
<p>For the purposes of data protection laws, Virgin Red Limited is a “data controller” of personal data that is collected, used and/or otherwise processed in conjunction with the use of the Website.
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.
Our address is Virgin Red Limited, Data Protection Officer, 66 Porchester Road, London W2 6ET, and you can contact the data protection officer by emailing <u>dpo@red.virgin.com</u>.
If you'd like to contact us about our newsletter, please email <u>membersupport@red.virgin.com</u>
<u>
</u>
</p>
<p>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 the 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 The Battleship Building, 179 Harrow Road, London W2 6NB and you can contact their data protection officer at <u>dpo@virgin.com</u>
<u>.</u>
</p>
<p>This Privacy Policy may change from time to time and, if it does, the most up-to-date version will always be available on virgin.com.</p>
<p>There is a separate privacy policy for when you become a member of Virgin Red and/or use Virgin Points and that can be found by clicking here.</p>
<p>We are pleased to give you access to the Website and, in return, we may collect, use and share your personal data.
We will only use your personal data for our purposes in a manner permitted by relevant data protection legislation, which may include:</p>
<ul>
<li>
<p>for our legitimate interests (for example to provide the Website and its features and in order to give you the best user experience);</p>
</li>
<li>
<p>where you have explicitly consented (for example, by actively signing up to receive the Virgin.com newsletter).
or </p>
</li>
<li>
<p>where we are under a legal obligation to do so (for example in order to comply with applicable law).</p>
</li>
</ul>
<p>By “legitimate interests”, we mean our interests in managing the Website 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.</p>
<p>
<b>Cookie Policy</b>
</p>
<p>We use cookies to improve your experience on the Website, and to recommend content that may be of interest to you.
You can find out more by reading our Cookie Policy which forms part of the Privacy Policy.</p>
<p>
<b>What information do we collect if you sign up for our newsletter?</b>
</p>
<p>If you want to sign up to receive our newsletter we will collect personal data from you as is necessary for the newsletter service, namely your email address, city, name and what you are interested in hearing more about.
We aim to send our newsletter on a weekly basis.
This is in addition to the information we collect in accordance with the cookie policy above.</p>
<p>Until August 2021, Virgin Red Limited will distribute the newsletter as a Data Processor for Virgin.Com Limited.
Prior to August 2021, if you signed up to receive Virgin.com Limited's newsletter, you will be contacted to ask if you would like to subscribe to the newsletter with Virgin Red Limited as the Data Controller.
if you do not choose to do so, you will cease to receive the newsletter.
From September 2021, Virgin.com Limited will irretrievably delete any person data that it holds relating to the newsletter and Virgin Red Limited will send the newsletter as Data Controller to those that have consented to sharing their data with Virgin Red Limited for the purpose of receiving the newsletter.
You can unsubscribe from the newsletter at any time by clicking on the ‘unsubscribe’ link in the email or by emailing us at<b>
</b>
<u>
</u>
<u>membersupport@red.virgin.com</u> or <u>dpo@red.virgin.com</u>.</p>
<p>
<b>How else will we use your information?</b>
</p>
<p>We may also use your information (including personal data) for the following purposes:</p>
<ul>
<li>
<p>to help us make the Website and other related content available to you (please see the "Will we share your information with anyone else?" section below for more information);</p>
</li>
<li>
<p>to make the Website more relevant for you and our other visitors.
This includes sometimes requesting personal data from you to help us run and develop our site and associated functions;</p>
</li>
<li>
<p>to send you our newsletter if you have signed up to receive it;</p>
</li>
<li>
<p>to carry out occasional surveys to analyse our user base, ultimately we want to ensure that the Website provides everything that you, our audience is looking for;</p>
</li>
<li>
<p>to check whether you are eligible for a competition and to contact you if you win;</p>
</li>
<li>
<p>to comply with the law.
or</p>
</li>
<li>
<p>as we feel is necessary to prevent illegal activity or to protect our interests.</p>
</li>
</ul>
<p>
<b>How long do we keep hold of the information?</b>
</p>
<p>There are certain reasons that we have to keep hold of some of your information (including personal data).
We will only keep your information 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).
For example if you have registered to receive the newsletter, we will keep your information while you are a subscriber to the newsletter so that we are able to provide that service to you, and then delete it after you have unsubscribed.</p>
<p>You can request that we delete your personal data at any time.</p>
<p>
<b>Will we share your information with anyone else?</b>
</p>
<p>We may share your information only if:</p>
<ul>
<li>
<p>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;</p>
</li>
<li>
<p>we feel it is reasonably necessary to prevent illegal activity or to protect our interests;</p>
</li>
<li>
<p>we feel that other Virgin entities’ products and services may interest you.
or</p>
</li>
<li>
<p>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.
If you subscribe to the Virgin.com newsletter via Virgin.com Limited, we will also share your information with its newsletter supplier,<i>
</i>Mailchimp<i>
</i>who securely host emails and act as a supplier to distribute that newsletter.
Mailchimp will provide this service for Virgin.com Limited.
If you subscribe to the Virgin.com newsletter via Virgin Red (as described in 'What information do we collect if you sign up for our newsletter?' above), <b>Sendgrid</b> will provide those hosting and distribution services for Virgin Red Limited.
We contractually 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.</p>
</li>
</ul>
<p>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.</p>
<p>We will never rent or sell our users’ details to any other organisation or individual.</p>
<p>
<b>How will we make sure our site is secure?</b>
</p>
<p>We follow strict security procedures to manage how your personal data is stored and used, and who sees it, and to help stop any unauthorised person getting hold of it.
All personal data you register with the Website 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 the Website if there is a security breach.
</p>
<p>
<b>Will we transfer any personal data outside the UK and/or the EU?</b>
</p>
<p>Countries outside the UK and the European Union (EU) may have a lower standard of protection for personal data than that required by UK and EU data protection laws.
The information we collect from you may be transferred to, and stored, outside the UK an/or the EU (including for example in the United States) and may also be processed by people operating outside the UK and/or the EU who work for us or one of our suppliers.
If we need to transfer your data to a company based outside the UK and/or 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 applicable laws.
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).</p>
<p>
<b>What are my rights?</b>
</p>
<p>You have the right to stop using the Website at any time.
Please note that, in these circumstances, we may still keep your data for the reasons set out in the <b>"How long do we keep hold of information?"</b> section.</p>
<p>You also have the following rights when it comes to our handling of your personal data:</p>
<ul>
<li>
<p>
<b>Right of access</b> – 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.</p>
</li>
<li>
<p>
<b>Right of rectification</b> – you have the right to request that we rectify inaccurate personal data about you that we have.</p>
</li>
<li>
<p>
<b>Right of erasure</b> – 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).</p>
</li>
<li>
<p>
<b>Right to restrict processing</b> – 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).</p>
</li>
<li>
<p>
<b>Right to object, including to direct marketing</b> – 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.</p>
</li>
<li>
<p>
<b>Right to data portability</b> – you may have the right to request that we provide you with certain information that you have provided to us in electronic format or to provide that information to a third party.</p>
</li>
</ul>
<p>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 data):</p>
<p>Virgin Red Limited,
66 Porchester Road,
London W2 6ET,
UK.</p>
<p>Email:<u>
</u>
<u>
</u>
<u>
</u>
<u>
</u>
<u>
</u>
<u>membersupport@red.virgin.com</u>
<u> </u>
</p>
<p>Alternatively, you can contact our data protection officer at <u>dpo@red.virgin.com</u>.</p>
<p>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: ico.org.uk/make-a-complaint.</p>
<p>
<b>What about personal data relating to minors?</b>
</p>
<p>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 of Use.</p>
<p>
<b>Are you protected by this Privacy Policy outside Virgin.com?</b>
</p>
<p>The Website contains links to other websites.
Obviously, we don't have any control over those websites and we cannot take any responsibility for any information you give them.
Other sites have different privacy and security policies and terms and conditions, so we advise you to read them before using those sites.
</p>
<p>
<b>Talk to us</b>
</p>
<p>If you have any questions, comments or complaints regarding this Privacy Policy, just get in touch.
You can contact us using the details set out in the “What are my rights?” section above.</p>