Privacy policy
Last updated on: 28 October 2024
Virgin Red Limited Privacy Policy
Applicability of this Policy
What does this policy apply to?
Hello! We are Virgin Red Limited (or VR for short), and this is our Privacy Policy. It's like a guide to how we collect and use your personal information. Trust us, it's worth a read to make sure you understand what we do with your personal information.
So, what's this Privacy Policy all about? Well, it applies to:
Virgin.com
Virgin ID, Virgin group marketing and Virgin group data sharing
These are all different services and they come with their own rules. You can find those rules by clicking the links above.
When we talk about 'personal information’, ‘personal data’ or just ‘information’ in this Policy, we mean things like your name, email, or any other information that can be used to identify you. This also includes digital identifiers like cookies, IP addresses, and logs.
The way we use your personal information can depend on the service(s) you’re using (and you might be using them all!) so our Privacy Policy is split into different parts:
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, Virgin group marketing and Virgin group data sharing
Section 7 - Cookies and Social Media Targeting
Section 8 -Important Information
If you're using any of our services, you’re giving us the thumbs up that you’ve read and understood this Privacy Policy.
Got questions? Get in touch at membersupport@virgin.com.
Remember, we might update this policy every now and then to make sure it's clear and accurate. If we make any big changes, we'll let you know. And if you need it, the latest version will always be available on our platforms.
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, Virgin group marketing and Virgin group data sharing
6.1 How do we collect your personal information for Virgin ID or for Virgin group marketing and Virgin group data sharing?
6.2 The information we collect on users that engage with different Virgin entities
6.3 Why we need and how we use your information
6.4 Examples of how and why we use your personal information
Section 7- Cookies and Targeting (including via social media)
7.1 What are cookies?
7.2 How we use cookies
7.3 Examples of how we use cookies
7.4 What third parties do we use in relation to cookies?
7.5 Social media targeting
7.6 Can I opt out of the use of cookies and social media targeting?
Section 8 - Important Information
8.1 Personal information relating to under 18s
8.2 Websites which we link to
8.3 How will we share your personal information?
8.4 How do we keep your information safe?
8.5 How long will we retain your personal information?
8.6 How can I check and update my personal information?
8.7 What are my rights?
8.8 Your California privacy rights
8.9 Changes to our business
8.10 Finally - if in doubt, talk to us
Section 1 - All about us
1.1 Who we are and what do we do?
We are the owner and operator of Virgin Red, Virgin’s member-based rewards programme, as well as the Virgin Points currency that you can use as a member of Virgin Red and/or Virgin Atlantic Flying Club. Our platforms record every Virgin Points transaction and keep track of points balances.
We also own and operate Virgin Trains Ticketing, which you can use either as a member of Virgin Red or as a guest.
Oh, and that's not all. We also make sure Virgin.com is up and running smoothly, and we operate Virgin ID too.
Now, let's get a bit technical. For the purposes of some data protection laws, we're the 'data controller' of the personal information that we collect, use and process in connection with our services. That means we're the ones who decide how to use personal data we hold about you and we have to comply with data protection laws in doing so.
If you're also part of Flying Club, which is run by Virgin Atlantic Airways Limited (or Virgin Atlantic for short), they will also manage your data in line with their own privacy policy. You can check this out on their website. We and Virgin Atlantic are what’s known as independent data controllers when it comes to your personal data that is associated with Flying Club – this means we each have our own responsibilities for managing separate aspects of your personal data.
Got questions or concerns? Get in touch at Virgin Red Limited, Data Protection Officer, 66 Porchester Road, London W2 6ET or contact our Data Protection Officer directly at red.dpo@virgin.com.
Hey, EU-based users: We don’t have an establishment in the EU, but you can get in touch with our EU representative at MCF Legal Technology Solutions Limited, Dublin, Ireland. They act as a direct contact for data protection authorities and EU individuals and can be reached by email at virginred@mcf.ie or MCF Legal Technology Solutions Limited, Riverside One, Sir John Rogerson's Quay, Dublin 2, Ireland or by phone on 00353 01 829 0000.
1.2 Our commitment
We take privacy seriously and we're all about keeping your personal information safe and sound. We follow all relevant privacy laws when we process your personal data.
We always aim to be open and clear, so we'll always tell you what information we have about you and how we might use it. And hey, if you've got choices or rights, we'll make sure you know about them and respect your wishes. It’s your personal data and we believe you should be in control of how we use it.
1.3 Our legal basis for using your personal information?
Under data protection law, we need a good reason (also known as a legal basis) to process and use your data. These are the reasons we rely on when it comes to the services that are covered by this policy:
Doing What We Promised (a.k.a Contract Performance): If we’ve agreed to provide a service to you, like enabling you to earn or spend Virgin Points, to buy train tickets or to access your accounts with other Virgin companies using your Virgin ID, we'll use your information to provide that service.
Our Legitimate Interest: Sometimes, we use your information where we or a third party has a legitimate interest or gains a benefit from doing so and this is not outweighed by your interests or legal rights. For example, if we know what you like, we can make your Virgin experience even better – through better ways to earn or spend your Virgin Points, more favourable pricing on train travel, or a more tailored experience with Virgin companies that are connected using your Virgin ID. Rest assured, we always consider the impact that using your data in this way has on you and you have the right to ‘opt-out’ of this processing at any time.
Playing by the Rules (a.k.a Legal Obligations): If the law says we need to use your information in a certain way, we will. For example, we might need to keep a record of transactions or provide your personal information to law enforcement agencies.
With Your Consent: Sometimes, we'll ask you if we can use your information for certain things. For example, you can agree to access your location when you use our products/services, or opt in to receive marketing about all things Virgin or the Virgin.com newsletter. And if you change your mind, that’s no problem – you can ‘opt-out’ 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 personal information when you use our services or interact with us, Virgin Points or our partners. What we collect depends on what you do. For example, we collect information directly from you and from others, when you:
Sign up for Virgin Red or provide extra information to enhance your membership.
Visit our app, read messages from us, or enable geo-location technology.
Earn or spend Virgin Points, or link or verify your account with a partner or other party associated with Virgin Red.
Use the Virgin Trains Ticketing app as a Virgin Red member (e.g. to check-out).
Enter a promotion, competition, or prize draw.
Get in touch with us via social media (including by following us, liking our posts or tagging us in your posts), our website(s), messaging services, email, or even old-school mail.
Register your marketing preferences with us.
Interact with us in any other way, online or offline, including through our services and through things like cookies on things like what you click or view online.
We may receive information on you from third parties including:
From our partners on transactions involving the earning or spending of Virgin Points
From third parties that are 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
Here are some examples of the categories and types of personal information we may hold about you:
Account information: We gather information in connection with your Virgin Red account, like your Member ID, name, postal/zip code, phone number, when you were born, email, how you use your Virgin Points, your marketing preferences, and your relationships with our partners (like if you’ve linked accounts).
How you use our services: Like, what device you're using, what you search for, what links you click on, and what content or websites you visit – we get this data from cookies and similar technologies. Where you’ve agreed to us using your geo-location, we also collect information about your location.
Your response to our communications: If you read our emails, texts or push notifications, we notice. We also pay attention to how you interact with us, like if you get in touch with our reward genies
Your entry into promotions and competitions: We’ll keep track of the likelihood that you’ll interact with us, enter competitions and if you win!
Your social media activity: We might collect information on how you interact with social media. For example, what you like or don’t like, and potentially any photos you share.
Your transactions with Virgin Points partners: When you collect and spend points, we'll collect information about your transactions, such as transaction dates, type of transaction and products that points have been collected or spent on.
Want to know what other 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
We use your personal information in lots of ways to provide and improve our services to you. One of the main ways we use your information is to understand your relationships with our Virgin Red Partners and to build a reward programme that is personalised just for you so that you can earn and spend Virgin Points on rewards you might like.
To give you access to our products and services, there’s some information that we need from you. Other information is optional but you might want to provide it so that we can provide an even better and more personalised experience for you.
2.4 Examples of how and why we use Virgin Red member information
Account transactions and support
Let's talk about the things we do with your account and how we've got your back:
Account Access and use: When you join us and log in, we need your information to create your account, give you access to it and make sure it's secure.
Virgin Points transactions: Every time you earn or spend Virgin Points, we get information either directly from you or from our partners. Say, if you earn a bunch of points by buying a delicious case of wine, the wine retailer will send us the details (like how many points you earned and on what product). And when you spend those points on a QR code for a hot drink, we get the details of that too.
We've Got Your Back: If you ever need help (like if you’re missing points or have questions), we're here for you and we’ll use your information to resolve the issue and improve our processes.
Keeping You in the Loop: We’ll let you know about things that are relevant to the Virgin Red programme and the services we provide, like if you can no longer spend points with a particular partner.
Exchanging information with partners and suppliers.
We work with our partners and suppliers to bring you even better services. Here's how we share your information with them:
Linking your Accounts: If you link your Virgin Red account with a partner's account, your transactions and information might be shared so you can see your Virgin Points in both places and/or so the two accounts can work together. For example, if you link your account with a wine retailer account and earn points on a wine purchase, this information will be shared between us and the wine retailer – the transaction will show in both accounts and you may also receive more relevant wine offers in the future – cheers to that!
Getting to Know You: We want to know what makes you tick so we can give you a better service. That's why we might track or receive information from our partners about your behaviour online. We use this to help linked accounts work better together and to show you more relevant offers. For example, if you browse offers on a partner’s website, we might receive insights on the offers you’re interested in and use this to show you more things you might like.
Sharing information on your membership status, product or service usage: We're all about making things just better for you. So, where we’re allowed to, we might share additional information with our partners about things like your purchases, spend or usage of products or services. We use this information to tailor our services to you. For example, by showing you more things you like and fewer things you don’t like.
Competition Time! If there's a competition going on, we might need to share your information with our agents, prize suppliers or other third parties involved in administering the competition and fulfilling the prizes.
Using your information for marketing.
Unless you’ve told us that you don’t want to hear from us, we'll use your information to keep you up-to-date with our latest exciting news, exclusive rewards and to share details of any offers or prizes from Virgin Red and/or our partners. These updates may be tailored just for you. Check out section 2.5 if you want more information on how we use your data for marketing purposes.
Personalising our services to you.
Whether you’re into skydiving or more of an afternoon tea kind of person, we want to know about it. We use your information to understand your habits and preferences so we can personalise, enhance and improve your Virgin Red experience and how we talk to you.
We might use things like your browsing history, membership information and your earn and spend activity, to learn about you, personalise our interactions with you and give you a tailored experience, both online and offline.
We might also combine information from different sources, including our own services, to create a profile that might be used to determine the likelihood that you’ll do something and then use this to tailor our services to you. For example, if you look at an offer or earn or spend points on a cruise, we might review your browsing history and your earn and spend activity and offer you an exclusive deal on a future cruise – bon voyage!
Using cookies and other online identifiers
We use these tools when you visit our digital platforms. This helps us better understand how our members use our applications and websites, to optimise user experiences, for advertising and to personalise our services just for you. Check out section 5.6 below for if you want more information on how we use cookies and other online identifiers.
2.5 More information on how we use your personal information for marketing
When you join Virgin Red through a channel that we own and/or operate, we’ll send you marketing about Virgin Red unless you tell us not to.
You’re in charge - if you don’t want our updates, just let us know. You can opt out of marketing when you first join or later, by logging into your account and changing your preferences or by clicking “unsubscribe” in a message we send you.
The types of marketing we might send you include emails that (amongst other things) tell you all 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 certain third party platforms, like Facebook and Instagram.
You can decide which channels you’re happy to be contacted via when you sign up to Virgin Red. You can also change your preferences at any time by logging into your account. If a channel isn’t listed, that’s because we’re not currently using it for marketing. There’s just one exception to this – we do use push notifications, but like all in-app mobile push notifications, these can be turned off at any time via your phone’s settings.
We’ll use the information we have about you to create more personalised and relevant offers for you. If you don’t want tailored offers in this way, just get in touch to let us know.
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. If you're a member of Virgin Red, you can earn Virgin Points when you buy tickets. Or, if you're just visiting, you can buy tickets as a guest.
3.2 The information we collect on Virgin Trains Ticketing
Here are some examples of the categories and types of information we might have about you:
Booking details: We collect information about bookings you’ve made, like when you're travelling, where you're heading, how many people you’re travelling with and your email address.
Railcards: We collect the information that is needed (name, email address, photograph, age) when you buy a Railcard through Virgin Trains Ticketing.
How you use our services: We pay attention to the device you use to access our services, what you search for and other browsing behaviour.
Your marketing preferences: If you agree to receive marketing from us, we'll keep track of your preferences.
3.3 Why we need and how we use your information on Virgin Trains Ticketing
We use your personal information to provide the Virgin Trains Ticketing services, to improve the experience you have with us and to send you marketing if you’ve agreed to this.
Remember, if you’re using Virgin Trains Ticketing as a member of Virgin Red, don’t forget to check out sections 2.3 and 2.4 for more detail 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. We use your details to make sure you get the tickets you have purchased.
To provide you with support and improve our customer service. Got questions? We're here to help and make our service even better based on your feedback.
To get in touch with you about our service. We'll let you know relevant information, like if there's a change to your ticket.
For marketing. If you’ve agreed to it, we'll send you details of discounts, offers and more from Virgin Trains Ticketing.
Cookies and other identifiers. We use these tools when you visit our digital platforms to help us understand how you use the Virgin Trains Ticketing app, to optimise user experiences, for advertising and to personalise our services. Check out section 5 below for more information on how we use cookies and online identifiers.
Exchanging information with partners and suppliers
We work with a number of suppliers that mean we can keep things on track whether that's to take payment for your tickets or to help us, help you get great offers. Where they process your information they're only doing that for us and not for themselves and are contractually obliged to take as good care of your information as we do.
When you by a Railcard through Virgin Trains Ticketing we share information with ATOC Ltd. The contract for your Railcard is with ATOC Ltd and they use the information that you provide when you apply for the Railcard for verification, fraud prevention and to supply you with the Railcard. ATOC act as an independent Data Controller and you can learn more about their Privacy Policy here.
Section 4 - Membership of the Virgin Atlantic Flying Club Programme
4.1 When do we collect information on Flying Club members?
We receive information about you either directly from you, Virgin Atlantic, a partner of Flying Club or one of our or Virgin Atlantic’s service providers. We use this information to enable you to earn and spend Virgin Points and to manage your Virgin Points balance.
For example, we collect information when you:
Sign up for Flying Club, so that we can set up or operate your Virgin Points ‘wallet’.
Earn or spend Virgin Points with a Flying Club partner.
Update your Flying Club account or personal details.
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
When you’re part of Flying Club, we collect information that is linked to your Flying Club account. For example:
Essential details like your Flying Club number, name, postcode, email address, contact number and date of birth.
Your tier status and household member ID if you have one.
Purchases made with Flying Club partners.
Your Virgin Points balance and information on the transactions you’ve made with your points.
Relationships you have with Flying Club partners using Virgin Points and any linked accounts with those partners.
Want to see the full list of categories of information we gather? Check them out here.
4.3 Why we need and how we use Flying Club member information?
As part of the Flying Club, there are many ways we use your information to provide and improve our services to you.
We use your information enable you to use your Virgin Points and to provide services that are associated with points.
Some information is essential and enables us to provide our services (like to set up a wallet to store your Virgin Points).
Other information is optional to provide, but 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: We use your information to create a wallet for your Virgin Points and to manage your points when you earn and spend with partners.
To support and improve our customer service: We've got your back! We use information to resolve any queries that crop up (like if you’re missing Virgin Points). We also use it to improve how we do things.
To contact you about our services: From time to time, we might get in touch with service-related messages about Virgin Points.
Exchanging your information with partners and suppliers.
Exchanging information with Flying Club partners: We share some information with partners to make sure you get your well-deserved Virgin Points and that you can make the most of them. Some partners that you have a relationship with may also give us a heads-up about things like the products you like and how you use your points. This helps us to personalise our services for you and show you even more relevant things you can do with your Virgin Points. Remember that our partners’ privacy policies will also apply to your information when it’s used in this way.
Avoiding telling you about products and services that you already use: We don’t want to waste your time, so we might let a partner know if you’re already using Virgin Points so they don't send you offers that aren’t relevant to you.
To personalise your use of Virgin Points.
Personalising, enhancing, modifying or otherwise improving Virgin Points. We’re always working to optimise and tailor the way you use Virgin Points. To do this, we might use the information we collect about you from various places (including our own services) and create a customer profile that can help us figure out what you might really like and how likely you are to do things like respond to a new Flying Club offer. We may share some of this information with our partners too, so they can also give you offers that are more tailored to you.
4.5 How is the personal information of members of Flying Club used for marketing?
If you want to dive deeper into how Virgin Atlantic uses your information as a Flying Club member (including for marketing), take a look at Virgin Atlantic’s Flying Club privacy policy
We make recommendations to Virgin Atlantic on what things you think you might be interested in, based on how you use Virgin Points. Both we and Virgin Atlantic might use this information to make sure the Virgin Points offers you get as a Flying Club member are tailored to you.
Section 5 - Virgin.com
5.1 How do we collect information on Virgin.com users?
When you interact with us on Virgin.com (the Website for short), we collect, use, and keep information about you. The details we collect depend on how you use our services. For example, when you:
Consent to getting the inside scoop through the Virgin.com newsletter;
Are feeling lucky and enter a prize promotion or competition;
Get in touch with us in any way, including through the Website, email, post, or if you interact with us in another way, online or offline, like through our services or via cookies that collect information on your internet use.
Heads up: Virgin Enterprises Limited are a separate data controller of your personal data if you contact them via the 'Report a Scam' page of the Website. And Virgin Management Limited are also a separate data controller of your personal data if you get in touch using the 'Book a Branson' and 'Contact us' pages of the Website or when you contact the Virgin Press Office.
From time to time Virgin Management may ask to use your personal data within content in our office spaces, website or social media channels. We'll always ask if that's okay and won't be upset if you say no thanks.
You can find both Virgin Enterprises and Virgin Management at 66 Porchester Road, London W2 6ET and you can get in touch with their data protection officer at dpo@virgin.com
5.2 The information we collect on Virgin.com
Here are some examples of the categories and types of personal information we may hold about you if you’re using Virgin.com:
Contact Information - If you’re feeling lucky and enter a competition or prize promotion, we may collect your name, email address, telephone number and/or postal address.
Your entry into promotions and competitions - We may collect information on the likelihood that you'll interact with us, enter competitions and if you're a lucky winner!
Cookie data or similar technologies - When you browse the Website and you’ve consented to cookies, we will collect certain information about your browsing behaviour. You can learn more about the cookies we use in our Cookie Policy
Your social media activity - If you interact with us on social media, we may collect information about this, like if you tell us that you really like or don’t like something. This might also include photos that you share.
Newsletter - Oh, and if you sign up to get the latest scoop through our virgin.com newsletter, we’ll collect your first name, email address and country so that we can send you the newsletter. If you want to, you can also share your surname, postcode or zipcode and your interests.
5.3 What do we need your information for?
Here's how we use your personal information:
to help us make the Website and other related content available to you (check out the 'How will we share your personal information?' section below for more detail);
to make the Website more relevant for you and other visitors – including by sometimes asking for personal data from you to help us run and develop our site. We might also connect the dots between data held about you across different initiatives we operate, like to understand if you are a member of Virgin Red or not;
to carry out surveys from time to time so that we can make sure our Website provides everything our audience (you!) is looking for;
to check whether you are eligible to enter a competition and to let you know if you are a lucky winner;
to comply with the law; or
as we feel necessary to prevent fishy business or illegal activity, or to protect our interests.
Section 6 - Virgin ID, Virgin Group Marketing and Virgin Group Data Sharing
6.1 How do we collect your personal information for Virgin ID or for Virgin group marketing and Virgin data sharing?
When you interact with us or other companies that use Virgin ID (we call these Virgin Partners) or that collect your permission on our behalf to receive general Virgin marketing or share data with us, we will collect, receive, use, and keep information about you. The details we collect depend on how you use our services and we may get information either directly from you and/or from others. For example, when you:
Are allocated a Virgin ID
Engage with other Virgin Partners
Register your marketing preferences with us or with another company acting on our behalf; or
Interact with us in any other way, whether that’s 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 (subject to having the relevant permission, where required) 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 also receive information about how you’ve engaged with us and other Virgin Partners by using your Virgin ID to connect the information to you. These companies will act as separate "data controllers" when they use this personal data. If you want to find out more about how they use your personal data, take a look at their privacy policies or get in touch with them directly with any questions.
6.2 The information that we collect on users that engage with different Virgin entities
Here are some examples of the categories and types of personal information we may hold about you:
Account information. We collect your name, email address, telephone number, date of birth, postcode/zipcode, communication and content preferences and information about how you interact and engage with Virgin Partners. This may include your transaction history and your service preferences. This may include allocating you a Virgin ID and if this is the case, you can check out 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 run Virgin ID and improve or personalise your experience with Virgin Partners, and 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
When we create a Virgin ID we give you the ability to use a single set of log-in details to access or create memberships and/or accounts with Virgin Points – no more juggling passwords;
We personalise your experience with the Virgin Partners you interact with and share information about you to support this;
If you’ve given us the green light, we will also send you marketing information, and/or our newsletter about all things Virgin.
6.4 Examples of how and why we use your personal information
Here’s how we use your personal information when you engage with different Virgin entities or Virgin ID:
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 so we can give you a more tailored and personalised experience across the Virgin Group.
If you give them the thumbs up, our Virgin Partners may use the personal information we have shared to contact you with marketing.
We will also share and receive information about how you engage with our Virgin Partners so we can help you out if you need any support and to improve our processes.
Getting in touch with you:
If you give us the green light to do so, we’ll send you news, offers and updates about all things Virgin by email and other digital channels.
What does other digital channels mean? We're talking about things like social media marketing, like when you see an ad pop up on your Facebook feed.
What does all things Virgin mean? We mean news and offers from companies in the Virgin Group or with a Virgin connection (think Virgin StartUps) or from the Branson family. This could be letting you know about a great offer that a Virgin Red partner or a Virgin company has available, or letting you know about the events or causes that Virgin or the Branson family have been involved in recently.
We may also get in touch to keep you in the loop on Virgin ID and the services we provide – like if there's a new Virgin Partner you can use Virgin ID with.
Personalising our services to you:
We want to personalise, enhance and improve your Virgin experience and our communications with you to give you a more tailored experience both online and offline. To do this, we may use your personal information, like your browsing history with your Virgin ID, to learn more about you and help us understand your habits and preferences.
We may also put together what we know about you from different sources (including out Virgin Partners and our different services) and create a profile that can help us to understand you better and so that we can tailor our services just for you.
If you’re not up for this, no worries, just ask us not to and we won't do this. You can get in touch via membersupport@virgin.com or by changing the setting in your account space (where applicable)
Section 7 - Cookies and Targeting (including via social media)
7.1 What are cookies?
Let's talk about cookies. The cookies we’re talking about here are unique identifiers, usually made up of small bits of text or code that are stored on your device or in your web browser. They send information back to whoever served the cookie.
Cookies also refer to similar tracking technologies, like tags, web beacons, pixels and, for mobile apps, software development kits or SDKs. When we talk about cookies in this policy, we are talking about all of these technologies.
Want to find out more about cookies, including how to see what cookies are on your device and how to block or delete them? Check out http://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. Sometimes, we combine data we collect through cookies from multiple devices with other data sources we have, like your Virgin Red transactional data.
Here are some examples of how we use cookies in our different online channels:
Virgin.com
We operate the Virgin.com website, which is where you can access Virgin Red. You can check out how we use cookies when you visit the Virgin.com website in the Virgin.com cookie policy.
Member support
We also use cookies when you use our online member support platform. The cookies we use are (i) necessary cookies, which are essential for the platform to work; and (ii) performance cookies, that collect data for statistical purposes to monitor website usage and improve user experience.
Virgin Red app
On the Virgin Red app, we use cookies 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, that make your experience on our app better by, for example, remembering choices you make and giving you enhanced, more personal features by showing you content that we think you'll be interested 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 it better;
(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 so please take a look at the privacy policies of the separate social networks if you want more detail.
Virgin Trains Ticketing app
For details of how we use cookies when you use the Virgin Trains Ticketing app, check out the Virgin Trains Ticketing cookie policy.
7.3 Examples of how we use cookies
We Make Things Unique: We give you a special user ID when you're using our apps. This helps us gather information about how you use our apps– things like which version you're using, when you last logged in, how often you log in and what you like to look at when you do, your device, device resolution, mobile network carrier and so on.
Ads Just for You: We only want to show you things you’re interested in, so we might personalise the ads shown to you on other apps and websites based on how you interact with Virgin Red or Virgin Trains Ticketing, using data about your transactions with us. Analysing how members use our apps helps us measure performance and lets us personalise and improve our services and marketing.
Referral Magic: When you use our referral program, powered by Mention Me, cookies make sure the whole referral process works smoothly You can read more about which cookies are applied by Mention Me in their policies. These cookies are necessary so you can't turn them off, but they won't be applied unless you visit these pages.
Connecting the Dots: When you shop with one of our partners through Virgin Red, your transaction is recorded via a unique ID and code on the partner’s website/app. We get this information so we know that a transaction has taken place and so we can credit your well-deserved Virgin Points to your account.
7.4 What third parties do we use in relation to cookies?
We've got some helpers on board to help us figure out how our users (you!) use our apps and websites, pull together reports on related activities and provide other services relating to website and app activity and usage. These are our third-party analytics providers. They collect information like where you're browsing from (your IP address), when you last visited, and if you've been here before. They also check out what device and version of software you're using and if you came to our apps or websites from somewhere else.
The information that gathered will be transmitted to and stored by these third party providers and their privacy policies may apply to the data. But don’t worry, they aren’t sharing any data that they collect on our behalf – in fact, they’re not allowed to sell that information to anyone.
Here are the third party websites we’re talking about:
7.5 Social media targeting
Alright, let's dive into the digital world of ads and targeting. Targeting just means the ability to choose the people who are shown ads. We do this using demographic and behavioural data like your age, interests, what you usually do online and other information we hold about you.
To interact with you online. If you interact with us online (by liking a social media page for example), we might send you a direct communication via that channel.
We use your personal information to create "lookalike" audiences. We might use information about you to create customer profiles and then find people with similar profiles online (like on social media platforms like Facebook) and show them ads we think they might be interested in.
We use your personal information to place advertising we think you’ll like on online media channels. We want to make sure the ads you see are interesting to you and we sometimes team up with service providers like online media and social media channels to help us target our ads online. Like, if you're a Virgin Red member, you might spot ads about products or services related to Virgin Red on social media. We might also confirm or ‘match’ your information (like your email address) with our service providers to facilitate this.
7.6 Can I opt out of the use of cookies and social media targeting?
Apps
In our apps, you're the boss. You can pick which cookies you’re happy with when you start using the apps, or later in the 'Settings' section. Be aware that some cookies are necessary for the apps to work and they can’t be turned off.
Websites
You can opt out directly by clicking on the cookie banner on virgin.com. Check out more details on this in the Virgin.com Cookie Policy here.
You might also be able to block some cookies by playing around with your browser settings. Your browser settings will have more information on this. Just be aware – if you block or delete cookies, you may not be able to get the most out of our services. And just so you know, our services don't currently change when they get a "Do Not Track" signal or similar.
Social media targeting
When it comes to social media marketing it's the rules of each social media platform that will apply. For some social media platforms, you may be able to update your ad preferences to turn off personalised ads altogether, but it might come at a cost. Check out the social media platform's terms to see what the options are.
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 and over, so we don’t collect personal information on children.
Virgin Trains Ticketing is also available to those aged 18 or over, or those aged 16 and 17 with parental consent. We may also collect and keep limited personal information on those under the age of 18 when they make a purchase using the Guest checkout.
The Flying Club programme is available to those under the age of 18 if they have parental consent. We might collect and keep information on those under the age of 18 when they have been allowed to join Flying Club.
Virgin.com is only for those aged 18 years or over, so please don’t try to use it or give us any personal details if you are under 18.
Virgin ID is also only available to those aged 18 or over.
You can find more information about the Website and Virgin ID in the Virgin ID and Web Terms of Use.
8.2 Websites which we link to
8.2 Websites which we link to to which we link
Our apps and websites might have links to websites or apps run by third parties. This policy only covers our services, so if you click on a link and go to another place, make sure to read their privacy rules too. We don't have a say in what data they collect about you, and we can't take responsibility for this or any other information that you might give them.
8.3 How will we share your personal information?
Just to let you know, we don’t sell or rent personal information. That's not our style.
We do share your information for the purposes and on the lawful grounds that we’ve described above. This includes with our programme partners to enable you to earn and spend Virgin Points, with participating Virgin Partners to operate Virgin ID and with suppliers that provides services that help us run our business. The full list includes but isn’t 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
Your trust is incredibly important to us and we only share personal information with carefully selected, reputable partners and suppliers. We require all third parties to treat your personal information as confidential and to follow all applicable data protection laws and consumer laws. They are also only allowed to use your personal data for the reasons we decide.
Like many other companies, we have partners and suppliers all around the world. This means that, to provide our services to you, we might need to send your information outside of the UK and EEA. If we do so, we put all the necessary safeguards in place and don’t allow any of our data processors to use your information for their own purposes. They can only use the information in the way and for the reasons we’ve agreed with them.
We might also share your information with:
Any other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where this is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where this type of disclosure is allowed 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.
Sometimes we also share broader statistics and customer profiling information with third parties and other Virgin entities. But don’t worry, we keep it anonymous, so you won’t be identifiable from that data.
If you want to see all the categories of personal information we share, take a look here.
8.4 How do we keep your information safe?
The safety of your information is our top priority. We’ve put in place appropriate security procedures to make sure the way your information is stored, accessed and transferred is safe and to help stop access by any unauthorised person.
All the personal information we hold about you is located behind a firewall. We also follow access management procedures, making sure that our staff only have access to personal information that is necessary to their role and that they are qualified to access it.
We regularly monitor our systems for possible vulnerabilities and carry out testing to find ways to strengthen our security even further.
When it comes to getting into your account, we’re always thinking about the best way for you to get access – be that through passwords, one-time passcodes or passkeys (such as face ID or fingerprint ID on your mobile phone). Where passkeys are available, it entirely your choice if you want to use them.
Remember though, while we're serious about keeping things safe and putting appropriate technical and organisational measures in place to protect your information, the internet's a big place and no transmission of data over the internet or public network can ever be guaranteed as 100% secure. So, it’s important that you keep your email account and access to your devices secure against unauthorised access. If you ever think something fishy is going on (particularly unauthorised use of your personal information or a security breach), Give us a shout right away.
We may use your information to make sure our services are secure, to comply with our legal obligations and to protect our business interests. We will also use your information to make sure that our services run smoothly and securely and 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 only hang on to your information for as long as we need it to fulfil the purpose that we’re processing it for.
Of course, whilst you are a member of Virgin Red and/or using Virgin Points as part of Flying Club, we’ll hold on to your personal information to make sure we can give you access to Virgin Red and Virgin Points. We also keep your data for a period after your membership ends – but only for as long as we need it and have a reason for holding on to it.
If you have a Virgin ID, we'll hold onto your information as long as you're a customer of any Virgin Partner, so we can provide the services associated with your Virgin ID. We also keep your data for a period afterwards – but only for as long as we need it and have a reason for holding on to it.
How long we keep your information depends on the type of personal information it is and the reason why we’re keeping it, as well as our legal obligations. You can ask us to delete your personal information at any time – check out the "What are my rights?" section below for more details.
8.6 How can I check and update my personal information?
It’s your information so take a moment to look over it from time to time, keep it up to date, and make sure you're comfortable with sharing it with us. If you ever need to make changes or updates, just drop a message to membersupport@virgin.com. Your details, your call.
8.7 What are my rights?
You can decide to stop using our service and say goodbye to your Virgin ID, Virgin Red account, or Virgin Points at any time. Just remember, this means you won’t be able to use your Virgin ID anymore or earn and spend Virgin Points.
You also have the right to object if you're not keen on how we're using your information for our legitimate interests. Bear in mind, this might affect our ability to provide some or all of the services you enjoy with your Virgin ID, your Virgin Red membership, or your use of Virgin Points as part of Flying Club or Virgin Trains Ticketing.
In these circumstances, we may still keep some or all of your information for a reasonable amount of time as we talked about in 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 can ask for a copy of your information and details about how we use it. Sometimes we might need to check your ID first to keep things secure.
Right of rectification. If something's not quite right with your information, you can ask us to fix it.
Right of erasure. You can request that we delete your information. Bear in mind that there could be some situations where we might need to keep it or limit the request, depending on the type of information and our reason for holding onto it.
Right to restrict processing. In some cases, you can ask us to stop using your information – like if you think it’s inaccurate.
Right to object. If we're using your information for our "legitimate interests”, you can object to this, unless we have overriding grounds to continue to use it. You can also object to direct marketing by us.
Right to information portability. You might be able to ask us to give you certain information you’ve provided to us in a digital format or to send it to someone else.
Your data, your choice. If you want to exercise any of these privacy rights, no worries. You have the right to not receive any discriminatory treatment because of it.
To use these rights, just reach out to us – either directly or through someone authorised on your behalf. You can write to Virgin Red Limited at 66 Porchester Road, London, W2 6ET UK, or ping us an email at membersupport@virgin.com. You can also contact our Data Protection Officer at red.dpo@virgin.com. If things still feel off, you can also complain to the UK’s information protection regulator, the Information Commissioner's Office (ICO). You can do this via their website: https://ico.org.uk/concerns/.
8.8 Your California privacy rights
Just so you know, we don't share personal information with third parties for their own direct marketing purposes without asking you first.
If you're under 18 and live in California, you might be able to ask us to take down any personal information or content that you've posted on our services. Remember, this might not remove everything you posted.
If you want to make any request under California privacy laws, just get in touch. We're here to help.
8.9 Changes to our business
As we talked about in the "How will we share your information" section, if things change - like if we sell part of our business, go through a reorganisation or join forces with another company (including another Virgin company) - we might need to pass your information on to any potential or actual new owner or successor so that they can keep things running smoothly for you.
8.10 Finally - if in doubt, talk to us
Got something on your mind? A question, a comment, or even a complaint about this Privacy Policy? No problem at all. You can get in touch with us using any of the details in the "What are my rights?" section above. We're all ears!