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PRIVACY POLICY

We want to introduce you to our privacy policy, which explains how we look after the information that you share with us, and what rights you have as a member of Inner Circle. Inner Circle is Virgin Red Limited’s online research community made up of people that want to get involved in the future of Virgin Red Limited. (“Inner Circle”) Inner Circle gives you the opportunity to give feedback on a variety of topics; these can range from products and services to asking about aspects of your spending and lifestyle so that Virgin Red can create a better experience and offering for its members. This information is for the Inner Circle hosted at innercircle.virgin.com ("the Site"), and is designed to ensure you are protected and your privacy respected.

Whilst this might seem formal, we’ve tried to make it nice and clear and as straightforward as possible so that you know what happens with your personal data. It’s here to enable your awareness and enjoyment of being part of Inner Circle. We take our responsibilities of maintaining the security of your personal data seriously and if you’ve ever got any questions please do get in touch with us.

INTRODUCTION

Inner Circle is operated by Virgin Red Limited (“VR”, “we”, “our” or “us”). For the purposes of the UK GDPR and Data Protection Act 2018 ("Data Protection Law"), VR is the data controller. Our registered office address is 66 Porchester Road, London, W2 6ET and registered number is 11490861.

We will share your personal data with STRAT7 Researchbods, a division of STRAT7 Limited (Researchbods) as they are the company that has helped us create our Inner Circle.  We do this so that Researchbods can provide services to us, for example creating research activities for or assisting us if there are any technical issues with the Inner Circle. We share your personal data with Researchbods on the legal basis that it is in our legitimate interests to effectively deliver Inner Circle to you. We ensure that your personal data is shared with Researchbods in accordance with data protection laws who act as a data processor to us. Do be assured that we have a contract with Researchbods which requires us and them to observe your data protection rights.

ACKNOWLEDGEMENT

This policy and the Terms of Use set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our approach and handling regarding your personal data and how we will treat it.

By registering as a member of the Site, you acknowledge you have read and understood this Privacy Policy.

INFORMATION WE COLLECT ABOUT YOU

We will collect and process the following personal data from you:

Information you give us: This is information about you that you give us directly when you interact with us by filling in forms on the Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the Site, participate in discussions, surveys, answer mini polls, suggest ideas on or via the Site, enter a competition, promotion or survey, submit a query, and when you report a problem with the Site.

The information you give us may include your name, address, e-mail and phone number, personal description, photograph, login and password details, responses to surveys, media capture (including video and voice recordings) and other discussions which take place on the Site.

As a user of Inner Circle we will also collect your Virgin Red ID in order to award you with Virgin Points when, for example, you complete surveys.

Information we collect about you from using the Site: We will automatically collect information from you each time you visit the Site. We will collect this information in accordance with our Cookie Policy. This includes:

  • Technical information. This may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • Information about your visit. This may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our helpdesk or social media handle used to connect with our customer service team.

Information we receive from other sources. This is information we receive about you:

  • if you use any of the other websites, apps we operate or the other services we provide.
  • from third parties we work closely with.

We are working closely with third parties (including, for example, business partners, sub-contractors in technical analytics, and search information providers). We will notify you when we receive information about you from them, and if we intend to share your data with them, and the purposes for which we intend to use it for. We will also tell you if we will combine the data collected from third parties with data collected about you, and for what purpose.

COOKIES AND OTHER TECHNOLOGIES

As described in our Cookie Policy, we use cookies and similar technologies (e.g. web beacons and device identifiers) to recognise you and/or your device(s). You can control cookies through your browser settings and other tools. You can also opt out from our use of cookies and similar technologies that track your behaviour.

OUR USE OF YOUR INFORMATION

Information we collect from you may be used for the following purposes:

  • to contact you by email to invite you to take part in specific market, social and satisfaction research activities
  • to obtain your views on products, services and the activities of VR, our Partners and other Virgin Group Companies
  • for entry into free prize draws and to contact you should you win and to send you any prizes
  • for informing you of the benefit/s to you, as a result of your registering to use Inner Circle and participating in surveys
  • to process your answers to surveys and analyse the results:
    • this may be in aggregated form which does not identify you, or
    • at a level which will only be associated with your screen name and will not contain any personally identifiable information or be in a manner which enables us to identify you personally
  • to provide you with information and services that you directly request from us
  • to help us improve our services, for example enabling us to act upon information you provide us or to deal with any complaints or concerns you raise with us
  • to ensure that content from the Inner Circle is presented in the most effective manner for you and for your computer and/or device(s)
  • to notify you about changes to Inner Circle or this Privacy Policy
  • to flag that you are a member of Inner Circle against any other memberships you may hold with VR this will help us ensure you don’t receive too many surveys.

We may combine information we receive from other sources with information you give to us and will use the combined information for the purposes set out above.

Also, if you contact us, we may keep a record of that correspondence.

WHO WE GIVE YOUR INFORMATION TO

We may give your information to:

  • Any member of VR's group, which means its subsidiaries, its ultimate holding company and its subsidiaries, who support our processing of personal data under this policy.
  • Researchbods who will also share your personal data with their third party processors, listed below, all of whom operate under contract to Researchbods


    Sub Processor

    Location of Data Processing

    Services Provided

    Legal Basis of Transfer outside EEA

    Amazon Web Services

    London – EU West 2 Region
    Fail over – Dublin - EU West 1 Region

    Ex-plor platform hosting & back ups

    n/a

    Focus Vision Limited

    AWS - London – EU West 2 Region

    Survey Tool

    n/a

    Freshworks Inc

    Company is based in the US.
    Data hosted in
    Dublin - EU West 1 Region

    Internal and External ServiceDesk and Ticketing Service

    n/a

    J&T Services

    Sofia, Bulgaria

    Scripting Services

    n/a

    KIDStatistics

    Timis, Romania

    Data Support Services

    n/a

    iTracks

    Data hosted in multiple locations across the US & Canada

    Video and text-based discussion room platform.

    Canada – Adequacy Decision

    Living Lens

    Liverpool, UK

    Video Insight Provider

    n/a

    Office 365

    UK

    Cloud File Storage Provider

    n/a

    Zoom

    US

    Video and text-based discussion room platform.

    Standard Contractual Clauses

    Camelia Ghinescu

    Timis, Romania

    Senior Scripter (previously a full-time employee of Researchbods)

    n/a
  • Selected third parties. We may disclose your personal information to our third parties:
    • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
    • If VR or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
    • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of VR, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

WHERE WE STORE YOUR INFORMATION

The data that we collect from you will be transferred to, and stored at, a destination inside the UK or European Economic Area ("EEA").

PUBLIC FORUMS

The Site may make chat rooms, message boards, news groups and/or other public forums available to its users. Any information that is disclosed in these areas becomes public information and you should exercise caution when using these and avoid posting any personal information.

HOW WE PROTECT YOUR INFORMATION

All information you provide to us is stored on secure servers. These use a number of controls to ensure your data is kept secure at all times. As an ISO 27001 certified company, Resarchbods has the administrative, technical and physical controls in place to keep your data secure at all times. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The Site may, from time to time, contain links to external sites. We are not responsible for the conduct, privacy policies or the content of such sites.

HOW LONG WE KEEP YOUR INFORMATION

Data is retained for the life cycle of Inner Circle and in accordance with the contract between us and Researchbods, which may require the data to be stored for a further six months after the closure of Inner Circle. This is in line with data protection legislation and Market Research Society guidelines on retention of data. This may include retention necessary to meet our contractual obligations to you, to identify issues or to resolve legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

YOUR RIGHTS

  • You have the right under certain circumstances:
    • to be provided with a copy of your personal data held by us;
    • to request the rectification or erasure of your personal data held by us;
    • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
    • to object to the further processing of your personal data;
    • to request that your provided personal data be moved to a third party.
  • Your right to withdraw consent: where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us.

You can exercise the rights listed above at any time by contacting us at dpo@red.virgin.com

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see https://ico.org.uk/make-a-complaint).

CHANGES TO THIS POLICY

Any changes we make to this Privacy Policy in future will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail. This policy was last updated in June 2022.

CONTACT US

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to innercircle@virgin.com