For the purpose of the Data Protection Act 1998 (the "Act"), the data controller is Virgin WiFi Ltd ("WiFi", "us" or "we"). Our company number is 4414701.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1 Information We May Collect From You
We may monitor visits to the Website, in order principally, to ensure that it is easy to navigate, identify the areas that are of particular interest to visitors and generally improve the Website and services offered. The information we collect in this process will not identify you as an individual and it does not seek to identify individual visitors unless they volunteer their contact details through one of the forms on the Website.
In some circumstances our records may identify organisations visiting the Website and we may use that information in managing its relationship with those organisations, for example, in considering how to develop the services that it offers.
The personal information Virgin WiFi holds about you will depend on the services you request from Virgin WiFi and the use that you make of those services. We may collect:
Information regarding your use of our services including but not limited to telephone numbers, SMS, MMS, emails and other electronic communications received or made by you and the date, time, cost and duration, of such communications, your browsing history (including web sites you visit) and location data, internet PC location for broadband, address location for billing, delivery, installation or your phone location;
Information that you provide by filling in forms and submitting information over the phone, by post, email, fax or on the Website. This includes information provided on registration for any one of our services, through surveys, by posting material on the Website or by requesting services from us;
Records of communications between you and us relating to services provided by us to you. If you contact us, whether through the Website or otherwise (for example, by post, email, fax, phone, text message) we may keep a record of that correspondence. For example, if you submit a query, a complaint or a refund request, report a problem with our service or Website, or otherwise liaise with our customer service, technical support or any other department in our company we may keep such record;
Your debit or credit card details;
Your account name and account numbers held by financial institutions from which your payments for services provided by us are made;
Information obtained as a result of credit checks which you authorise us to carry out;
Records of use made by you of services provided by us to you;
Calling line identification/connection logs when you connect to our remote access servers;
Your IP address (this is your computer's individual identification number for internet connection) is automatically logged by our web server. This is used to note your interest in our Website; and
Details of your visits to our Website (including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
The above information may include any personal information that relates to and identifies you, including but not limited to your name, date of birth, postal address, e-mail address, telephone number, bank account details, and any other information collected as set out in the above list.
We may check some of the information that you provide against third party databases to confirm that it is accurate.
In some cases, for example where we carry out credit checks or collect information from organisations to whom we outsource functions, your personal information will be collected indirectly.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
2 How We May Use The Information Collected From You
We may process this information for the purpose of:
Providing you with electronic communications services including, without limitation: (i) provisioning or connecting your service; (ii) network routing; (iii) investigating and fixing faults in relation to the services and (iv) investigating complaints;
Following up any payments that you may owe us,
Administering contractual agreements or arrangements necessary to provide services to you;
Informing you about services and events provided or organised by us that may be of interest to you;
Enhancing and personalising the services that we offer to you;
Administering accounts records;
Providing you access to all parts or features of our services or the Website;
Communicating with you on any matter relating to the provision generally of our services;
Dealing with your inquiries and requests, including contacting you if necessary;
Carrying out our obligations arising from any contracts entered into between you and us;
Processing your payment;
Contacting you for your views on our services and notifying you occasionally about important changes or developments to our services or the Website;
Carrying out market research campaigns;
Improving and developing our services or the Website;
Ensuring that content from our Website is presented in the most effective manner for you and for your computer or mobile device;
Performing research and statistical analysis and analysing markets and producing reports; and
Debt recovery or debt tracing, crime, fraud and money laundering compliance.
We may also use your personal information, or permit selected third parties to use your data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about this by email, post or telephone. If you prefer not to receive information from us or from selected third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data, (e.g. the order form or registration form) if applicable, or send an e-mail message to email@example.com at any time.
We contract out part of our communications services plus other ancillary services such as mailing, credit checking, provisioning, billing, printing, verification of sales and fault fixing to external service providers. We may disclose your personal information to these organisations but only so that they can provide you with the services that we have contracted out.
We may disclose your personal information to other telecommunications service and equipment providers, our related corporate bodies, resellers, credit providers, credit reporting agencies, organisations to whom we outsource services, and our business partners and associates. At your request, we may disclose your information to directory providers so that your information can appear in telephone directories. Personal information shared with related corporate bodies may include your name, address, and service history.
We may analyse information about you including your calling, browsing, searching and location data on a personalised basis always in accordance with data protection legislation. We may transfer this data to authorised third parties and we may use it to tailor our (or our authorised third parties) offers, promotions, adverts or commercial communications.
We may also gather this information and statistics on aggregated basis for the purposes of monitoring the usage of the Website and our services and may provide such aggregate information to third parties such as advertisers, telecoms carriers, content providers our affiliated companies or prospective business partners. These statistics will not include information that can be used to identify you.
3 Information Security
If you are aged 16 or under, you will need your parent or guardian's permission before providing any personal data. Otherwise, you are not allowed to provide us with personal information.
The internet is not a secure medium. However, we have put in place various security procedures with regards to the Website and your electronic communications with us, as set out in this policy.
Please be aware that communications over the internet, such as emails/webmails are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. This is the nature of the World Wide Web/internet.
We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control. You must not share your password which give you access to any of our services. Your passwords and any other secret information are your responsibility, and must not be disclosed to any third party.
We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. Our web server is capable of up to 128bit SSL encryption. Note however, that our web server can only choose the highest common level with your browser. If you use older browsers, you may find that it only supports 40bit or 56bit encryption.
All of our employees and data processors that have access to, and are associated with, the processing of your personal information are obliged to respect the confidentiality of our visitors' information.
We may need to disclose your data, if required by law or when requested to by regulatory bodies (e.g. Ofcom) or law enforcement organisations or a court, which may use your data for regulatory purposes.
4 To Whom Will Your Information Be Disclosed?
To other electronic communications service and equipment providers;
To organisations to whom we outsource services, and our business partners and associates; we will reasonably ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it;
To regulatory bodies for the purposes of monitoring and/or enforcing our compliance with any regulatory rules/codes or where required by law, regulation or legal proceedings;
To a competent authority in response to a valid, legally compliant request by a competent authority;
To our employees;
Where we, or an affiliate processing your data on our behalf, are compelled to do so by law;
To third parties from whom you have chosen to receive marketing information;
To auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
To insurance companies and administrators where you decide to take an insurance policy through us;
To our affiliates, including their respective partners, agents and sub contractors (including prospective partners, agents and subcontractors). This may include your name, address, and service history;
To prospective sellers or buyers of our business or any of our assets;
To third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support services) to us; and
In emergency situations when we have a reason to believe that someone's' physical safety is at risk;
5 Data Retention
We will only retain information for as long as this is needed including for billing and for accountancy purposes. However, in certain circumstances and to comply with the Investigatory Powers Act 2016, the Data Retention (EC Directive) Regulations 2007 (SI 2007/2199) (2007 Regulations) and any other applicable legislation, we may retain the information below for a minimum time of 12 months and no longer than 2 years:
Data necessary to trace and identify the source of a communication (telephone number, name and address of subscriber, sender's IP address, etc.);
Data necessary to identify the recipient of a communication (number dialled, name and address of recipient, IP address of recipient, etc.);
Data necessary to identify the date, time and duration of a communication (date of the communication, start and end time of a telephone conversation, logo-on and log-off time of internet access service);
Data necessary to identify the type of communication;
Data necessary to identify users' communication equipment or what purports to be their equipment;
Cell site data necessary to identify the location of mobile communication equipment; and
Digital Subscriber Line (DSL) or other end point of the originator of a communication.
or any other data required to comply with our legal obligations.
6 Your Rights Of Access In Relation To Your Information
You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected. Where appropriate, you may have your personal information erased, rectified, amended or completed. Please write to 1 Park Lane, Hemel, Hempstead, Hertfordshire, HP2 4YJ or email us to firstname.lastname@example.org
Please quote your name and address. We should be grateful if you would also provide brief details of the information of which you would like a copy or which you would like to be corrected (this helps us to more readily locate your data).
We will require proof of your identity before providing you with details of any personal information we may hold about you. We may charge a fee of £10 to cover the administration costs involved in providing you with a copy of your information.
The Cookies We Use
We will use a cookie to count how many times the cookies pop up has been shown to you. Once it has been shown to you a number of times, the pop up will no longer be displayed (unless you removed the compliance cookies from your device).
Cookies for logging in and to remember preferences
These cookies known as Session IDs are used to enable core site functionality. They do not contain any personal information.
Analytic Cookies measuring web traffic
Third Party Cookies
Other companies offering and advertising their products or services on our website, may also download cookies on to your equipment. These companies will have their own privacy policies which will govern the way they use their cookies. We accept no responsibility or liability for these sites to the maximum extent permitted by law.
Cookies for Adverts or logos
How can I manage my cookies?
You can control how your web browser deals with cookies by changing your browser settings.
AboutCookies.org has a great guide on how to do this for all the major browsers, and a lot of other information about cookies.
In the event the purposes for processing personal information change, we will contact you as soon as practicable and seek your consent for the new purposes where such new purposes relate to a new additional purpose for processing which is not compatible or similar to the originally specified purposes.
9 Use Of Your Personal Information Submitted To Other Websites
We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from our Website or by means of our services.
We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.