Privacy policy

By “info” we mean all of the personal info about you that we collect, use, share and store. It can include but isn’t limited to:

• Info about you and your contact details (e.g. your name, date of birth, address, phone number and email address).
• Info that the law sees as being in a special category because it’s sensitive to you. We can only collect and use this info if you’ve given us permission, or it’s allowed by law. This sort of info includes:
  - Race or ethnicity.
  - Religious or philosophical beliefs.
  - Trade union membership.
  - Genetic and bio-metric data.
  - Health info and data (needed for some insurance products and to protect vulnerable customers).
• Criminal convictions and offences (needed for preventing fraud, anti-money laundering and to meet our legal duties).
• Unique identifiers and reference numbers that we or others have allocated to you (e.g. your P Number or any FCA reference number).
• How you access and use our intermediary website or other digital services (e.g. your IP address, your location and the device and software being used).

Sometimes, we ask for your info as we need it to provide the product or service you’ve asked for or to do something the law requires us to do (like check you are who you say you are). Without that info we’ll not be able to provide some products or services requested.

We collect info directly from you and from others. We collect info in the following ways:

• When you register for appointment to our Panel.
• When you submit business to us on behalf of your clients through any means.
• Applications, emails, letters, phone calls (including info provided on your behalf by someone else, e.g. an employer, network, club, partner or others in your organisation who are authorised to deal with us).
• Entries into our competitions, surveys, promotions, and conversations with us on social media.
• From your use of our websites or applications, including through cookies that collect info about your internet use.

We also get info from:

• Public registers and records (e.g. the FCA Register, Companies House).
• Credit reference agencies (e.g. Experian) and fraud prevention agencies (e.g. CIFAS).
• Advertisers, social media networks and companies that do market research, statistical and behavioural analysis (e.g. Google and Facebook).
• The Government and their agencies (for example, HM Revenue & Customs, Financial Conduct Authority).
• Other companies that provide a service to us (e.g. surveyors and lawyers).

Data Protection law requires us to have one or more of the following reasons for using your info:

1. ‘Contract' – where the info is needed to administer our panel and process business in accordance with our Terms.
2. 'Legitimate interest' – we’re allowed to use your info where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights.
3. ‘Legal obligation’ – where the law requires us to process your info, for example to prevent and detect money laundering.
4. 'Consent' – in some cases we may obtain your consent to use info in a particular way or where the law requires consent to be obtained.

These are the main ways we’ll use your personal info (and the reasons for doing so):

To assess your appointment to our Panel. (Legal Obligation; Legitimate Interest) When you first register for the Panel we will assess the application and your eligibility based upon the info available to us.

To administer our Panel and your relationship with us. (Contract; Legitimate Interest) This includes all communication and administration we perform or is needed for the management of our relationship in accordance with or anticipated by our Terms. This includes the allocation and administration of any relevant passwords, usernames or other unique identifiers that are needed to enable Advisors to submit business to us through any means, payment of procuration fees and communication of changes to our range of products and service availability.

Obeying the law, stopping financial crime (including fraud and money laundering) and funding terrorism (Legal Obligation; Legitimate Interest) The law requires us to help combat the threats posed to our society by terrorism and money-laundering and other financial crime. We also have a legitimate interest in avoiding losses caused by financial crime such as fraud. We may check and share relevant info held by us with fraud prevention agencies, law enforcement and other government agencies for the purpose of preventing, detecting and prosecuting financial crime and the funding of terrorism.

To improve our services and systems. (Legal Obligation; Legitimate Interest) We have a legitimate interest in improving how we provide our services and to improve the security and resilience of our computer systems. We must also respond to any changes in law or regulation that relates to the protection of the info we hold. We may use the info we hold to help us develop and test our systems (including new technologies and services) to ensure that they are safe and will work in the ways in which we expect them to. When we do this we’ll use processes and technologies that are designed to keep this info secure.

Manage and organise our business. (Legal Obligation; Legitimate Interest) We have a legitimate interest in organising and running our business in a correct and commercially sensible way and to comply with our legal and regulatory responsibilities to the UK financial system. We may use the info we hold to analyse how well our marketing is working, train our team members, analyse trends or behaviours we can see, assess the profitability (or other indicators) of a particular product, service, sector or element of it when compared to others to inform our future commercial strategy and to report to and communicate with our regulators, auditors and governmental agencies.

Administration of marketing, offers and other promotional activity. (Legitimate Interest; Consent) The range of products and services we offer is constantly evolving. We have a legitimate interest in telling you about our products, services and any new developments that we think may interest you, but only where we are allowed. We’ll also invite participation in promotions, prize draws and competitions from time to time (which may include those partners set out in Appendix 1). For some marketing activity we will need to ask for your consent to use your info. You have a legal right to tell us at any time that you don’t want us to use the info we hold in this way or to withdraw any consent that you have given to us. We’ll only get in touch in the ways you’ve told us we can. If you’ve said you don’t want to see marketing info, you wont. You can opt in to, or out of, receiving marketing info at any time by contacting us in the usual way.

We may also use the info we hold for any other purposes that you have consented to at any time or, in some circumstances, when the law requires or permits us to.

Extra protection is given to special categories of info and criminal offence info. We’ll only use special categories of info if we have one or more of the following additional reasons:

1. ‘Explicit consent’ – where you have given us explicit consent to use the info.
2. ‘Vital interests’ – where we need to protect your vital interests e.g. if you have a severe and immediate medical need whilst on our premises.
3. ‘Public interest’ – where it is in the substantial public interest.

We’ll only use criminal offence info where the law allows us to for example for the purposes of preventing or detecting crime.

Using special categories info

We use the following special categories info for the reasons below:

Health info

• If we identify that you have a health-related vulnerability, we’ll share that in our organisation to the extent needed to protect your interests and offer you services that are suitable for you.
• If we need to provide you with urgent medical help when you’re on our premises.

Racial and ethnic background

• We may ask you about your racial and ethnic background as we need to make sure everything is fair and equal when it comes to the service we offer.

If we need to share this info with anyone, we’ll treat it as confidential. We may share it with the following who are also required to keep the info confidential, safe and secure:

• The companies within our group.
• Other companies, commercial partners, agents and professionals who provide products, services and administrative support to our group.
• The companies, organisations and individuals with whom you have a professional or regulatory association or who provide other services to you.
• Anyone we may transfer our rights and duties under any arrangement to.
• Anyone else with your permission.

We may also share info we hold with the following types of organisations:

• Credit reference agencies.
• Fraud prevention agencies.
• UK and overseas regulators, authorities and their service providers (e.g. the Financial Conduct Authority).
• UK and overseas tax authorities (e.g. HM Revenue & Customs).
• UK and overseas law enforcement agencies (e.g. the National Crime Agency).

We may need to share your info outside the UK and EEA with others. This can include Group companies, service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not offer the same protection as in the UK and European Economic Area e.g. USA.

In these cases, we’ll do everything we can to make sure your info is protected to UK standards.

This could be by only letting transfers take place with countries the EU Commission thinks offer enough protection for your info (an adequacy decision) or, we’ve put our own measures in place to make sure there’s enough security as set out by data protection law.

These measures include having recognised safeguards in place with our commercial partners, like carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators like the EU style model clauses or where our commercial partner is a signatory to a recognised and binding code of conduct. For more info about standard contractual clauses as shown by the ICO, check out ico.org.uk Link opens in a new window and search for ‘International Transfers’.

To learn more about how your info is used in countries outside the EEA, the adequacy decision for that country or the measures we’ve put in place, please get in touch with our Data Protection Officer.

We’ll hold info for no longer than is necessary and this will mean that we’ll continue to hold some info for a period of time after our relationship has ended. This is to comply with our legal and regulatory obligations to keep records of our relationship, to resolve disputes or where it may be needed for future legal proceedings.

We use cookies to track how you use our website. If you’ve given us permission, we may also use cookies to tailor marketing messages when you’re logged in. For more info about how we use cookies, visit https://uk.virginmoney.com/cookies/ Link opens in a new window

The law guarantees you rights in relation to your personal info. We have set out details of your rights below:

Access to info

You have the right to ask whether we hold info about you. And if we do, what the info is, why we’re holding it and the ways it’s being used. You’re also entitled to a copy of the info.

Rectification of information

We want the info we hold to be up to date and accurate. If any of the info we hold is either incorrect or out of date then please tell us and we’ll fix it.

Erasure of info

You have the right to ask us to erase or delete info where you consider there is no longer any justification for us holding it, either because:

• The info is no longer needed for the reason we collected it.
• We held and used the info based only on your consent, which you have now withdrawn.
• You have previously objected to a way in which we use info.
• We have been using the info unlawfully.
• There is a legal obligation on us to erase the info.

When you make a request for info to be erased we’ll have up to one month to respond. If we reject your request, we will tell you and set out the reasons why we’ll not erase or delete the info.

Objecting to us using your info

Where we have told you that any use of info is based on ‘legitimate interest’ you can objection to that use. When you object we’ll have up to one month to respond to you. We’ll stop using the info in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

Remember, you can always simply opt out of receiving marketing communications at any time. You can do this by contacting us in the usual way.

Restricting some uses of info

In certain circumstances you have a right to block or limit the use of info by us. This may arise where:

• You have challenged the accuracy of the info we hold and we are verifying this.
• You have objected to a use of info (see above) and we are considering whether your objection is valid.
• We have been using your info unlawfully but you want us to continue to hold the info rather than erase it.
• We no longer need to keep the info but you have asked us to hold it because of legal claims you’re involved in.

If you wish to make a Rights Request, you can do so by emailing DSARCCA.Queries@cybg.com or writing to the team at
Virgin Money,
Sunderland,
SR43 4JB
We will respond within a month and there is no need to send a reminder during that period.

If you’d like to contact our Data Protection Office directly regarding a data protection concern, you can email the team at DPO@virginmoney.com or contact them via the postal address above, addressing the letter to The Data Protection Office.

If for whatever reason you are unhappy with any way we are using your personal info you should contact us in the first instance so that we can understand your issue and try and resolve it. We may ask our Data Protection Officer to look at your situation. If we can’t resolve the issue you have the right to complain to the Info Commissioners Office (ICO). The ICO is the UK's independent body set up to uphold info rights. For further info visit ico.org.uk Link opens in a new window

If you have any further questions please contact us:

Phone or email:

Please call or email your dedicated Business Development Manager Link opens in a new window

Address:
Intermediary Sales,
Virgin Money,
Jubilee House,
Gosforth,
Newcastle upon Tyne,
NE3 4PL

We’ll keep this info up to date and it will always be available on the Virgin Money Website or on request at any time.

List of our providers for the administration of marketing, offers and other promotional activity:
Virgin Active
Virgin Atlantic
Virgin Experience Days
Virgin Galactic
Virgin Hotels
Virgin Limited Edition
Virgin Media
Virgin Music
Virgin Pulse
Virgin Radio
Virgin Records
Virgin Red
Virgin Trains
Virgin Voyages
Virgin Wines