Privacy Policy
Updated December 2022
This Privacy Policy governs the use of data that is collected by The Virgin Foundation (operating as Virgin Unite). The Virgin Unite website at www.virgin.com/unite (the “Website”) is hosted by Virgin.com Limited but its use is governed by its own Privacy Policy which is set out in the document below. Where users navigate from Virgin Unite onto the Virgin.com website (which is separately managed and operated), the Virgin.com Privacy Policy will apply and is available here.
The Virgin Foundation (operating as Virgin Unite) is an independent UK charity. There are several other not-for-profit or charitable organisations in other jurisdictions that use or refer to the “Virgin Unite” brand and may have similar objectives; however, they are separate and independent to Virgin Unite’s UK entity. The Website may include content relating to those organisations, and the Website may provide a means to donate to them.
Here at The Virgin Foundation (operating as Virgin Unite) ("Unite", "we" or "us"), 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.
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 using the details set out in the “Talk to us” section of this Privacy Policy below.
Please take the time to read this Privacy Policy as it is important for you to understand how we collect and use your data as part of your use of the Website and our provision of related services and projects. This Privacy Policy explains how we collect, use and store the personal data you provide to us. References in this Privacy Policy to 'personal data' means data that relates to you and that identifies or can be used to identify you, which might be your name, email address or other identifiers relating to you, such as cookies, IP addresses or logs.
For the purposes of relevant data protection laws, Virgin Unite is a “data controller” of personal data we hold and process about you, including data collected, used and/or otherwise processed in conjunction with your 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. We are registered on the public register of fee payers maintained by the Information Commissioner in the UK. See the "Talk to us" section below for details of how to contact us.
This Privacy Policy may change from time to time and, if it does, the most up-to-date version will always be available on the Website.
We are proud to give you access to the Website, to work with you in relation to your support of Unite and to assist with related services and projects 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:
for our legitimate interests (for example to provide the Website and its features and in order to give you the best user experience);
where you have consented (for example, by actively signing up to receive our newsletter); or
where we are under a legal obligation to do so (for example in order to comply with UK or EU law).
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.
Cookie Policy
For details of our Cookie Policy, click here.
What information will we collect from you?
You may give us information (including personal data) about you by filling in forms on the Website or by communicating with us verbally, by phone, by email, by your actions or otherwise. This includes information you provide when you create an account, make a donation, request to get involved in a project or an event, update your profile information, enter a competition, promotion or survey and when you report a problem with the Website. The information you give us may include the following:
contact details including your name, email address and phone number;
personal details including gender, date of birth and location where you are based;
professional details including your role, skills, years of experience and CV;
community trip details including passport details, emergency contact details, medical history and dietary requirements;
financial information including bank account details, card details, details of donation(s); and
project and donation history information including whether you've taken part in a project or donated before.
If you do decide to make a donation to Unite, our donors due diligence policy requires that we collect some further information to ensure the legitimacy of the origin of the donation. As part of this due diligence, we may be required to collect information such as, your nationality, your home address or other addresses at which you reside and information on your business activities. It is your decision as to whether you give us this information but in the event that you choose not to share this information with us, we may not be able to accept your donation. We may also seek information independently through publicly available information (e.g. by carrying out searches on the internet).
We may also collect your information (including personal data) about you through our use of cookies (see “Cookie Policy” section of this Privacy Policy above).This type of information may include the following:
information about your device, operating system and IP address;
your login information;
browser type and version;and
information about your visit on our website, including URL, clickstream (i.e. your journey to, through and from our site), length of visits to certain pages, and page interaction information.
Will we use your information for marketing?
If you provide your consent to receive information around donation opportunities or community trips, we may communicate with you in relation to them. You may withdraw your consent to these communications at any time by clicking the “unsubscribe” link at the end of each of these communications, or contacting us using the details set out in the “Talk to us” section of this Privacy Policy below.
How else will we use your information?
We may also use your information (including personal data) for the following purposes:
to help us make the Website and related content, services and projects available to you (please see the "Will we share your information with anyone else?" section below for more information);
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 the Website and associated functions;
to arrange an event, trip or project that you may want to take part in;
to process any donation you have given;
to send you our newsletter if you have signed up to receive it;
if you have consented, to market community trips or projects to you, or to ask you to donate;
to carry out occasional surveys and to analyse our user base — ultimately we want to ensure that the Website provides everything that you — our audience — is looking for;
to check whether you are eligible for a competition and to contact you if you win;
to comply with the law; or
as we feel is necessary to prevent illegal activity or to protect our interests.
How long do we keep hold of the information?
There are certain reasons that we have to keep hold of some of your information (including personal data). Naturally we keep your information while you are a member of Unite so that we are able to communicate with you and provide you with the information set out above, but we may also keep it after you've left us (though only for as long as we need it). How long we keep it depends very much on the type of information we are holding and the purpose for which we need it (as well as complying with our legal obligations).
We may also keep information about how you have used the Website to help us improve our offering for other members, though we will remove any identifiable (or personal) data.
You can request that we delete your personal data at any time. For more information on your rights, see the “What are my rights” section of this Privacy Policy below.
Will we share your information with anyone else?
We may share your information:
if you specifically request this, such as when you submit information to enquire about projects or donations through the Website;
where 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;
where it is reasonably necessary to prevent illegal activity or to protect our interests;
to other Virgin entities’ where their products and services, or the activities of other Virgin Unite branded organisations may interest you, and where we have followed all the legal requirements to do so;
to other members of the Virgin group, Virgin Unite branded organisations or other third parties to arrange (or help run smoothly) an event, trip or project that you may want to, or are confirmed to take part in and in which we are involved; or
to help 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 - please see details of our trusted third party service providers below. We may also share your information with MailChimp, who securely host emails. We 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.
As at December 2022, the trusted third party service providers with whom we currently share personal data are:
our payment processing agents (currently MasterCard and Stripe); and
our supporter and finance database providers (currently Salesforce and Unit4).
If you sign up to attend an event, we may also share your personal data with third parties we use in organising and managing that event, including providers of accommodation, travel operators, an e-signature platform and a survey platform.
If we do share personal data with other third party service providers in the future, we will update this Privacy Policy as soon as possible to include them.
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.
We will never rent or sell our users’ details to any other organisation or individual.
How will we make sure the Website is secure?
We (and Virgin.com Limited) 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 on 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.
Will we take steps to transfer data outside the UK/EU?
Countries outside the UK/European Union may have a lower standard of protection for personal data than that required by UK/EU data protection laws. The information we collect from you may be transferred to, and stored, outside the UK/EU (including for example in the United States) and may also be processed by people operating outside the UK/EU who work for us or one of our suppliers. If we need to transfer your data to a company based outside the UK/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 UK/EU law and we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy Policy. In these cases, we rely on approved data transfer mechanisms (such as standard contractual clauses) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the UK or the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.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).
What are my rights?
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 "How long do we keep hold of information?" section.
You also have the following rights when it comes to our handling of your personal data:
Right of access
– 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.
Right of rectification
– you have the right to request that we rectify inaccurate personal data about you that we have.
Right of erasure
– 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).
Right to restrict processing
– in some situations, you have the right to request that we do not use the personal data you have provided (e.g. if you believe it to be inaccurate).
Right to object, including to direct marketing
– 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.
Right to data portability
– 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.
We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. 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):
Virgin Unite c/o Virgin Management Limited 66 Porchester Road London W2 6ET
Email: contact@virginunite.com
Alternatively, you can contact our data protection officer at dpo@virgin.com.
You have the right to complain to the UK's data protection regulator, the Information Commissioner's Office (ICO), about our handling of your data. You can use the relevant section of the ICO website to do this: https://ico.org.uk/make-a-complaint/. If you have such concerns we request that you initially contact us (using the contact details above) so that we can investigate, and hopefully resolve, your concerns.
What about personal data relating to minors?
Protecting the online privacy of children is especially important to us. If you are under 18 years old, please do not provide us with your name, contact details or any other information about yourself. To find out more, please read our Terms and Conditions.
Are you protected by this Privacy Policy outside the Website?
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.
Talk to us
If you have any questions, comments or complaints regarding this Privacy Policy, just get in touch. You can contact us: (i) through the Contact Us section of the Website; or (ii) using the details set out in the “What are my rights?” section above.