Virgin WiFi Privacy Policy

At Virgin WiFi Limited ("VM", "us" or "we") we take the safeguarding of your information very seriously. One of the ways we do this is by adhering to the requirements of UK data protection legislation, and this has changed as part of the General Data Protection Regulation (GDPR for short) in force from 2018.

This means we’ve made some changes to our privacy policy, and we want to make sure you understand what these changes mean for you.

The location and venue provider is likely to be the Controller of the information you provide and is collected when you access the WiFi services.

A Controller decides why, when and how your details will be processed.  Sometimes VM will be a joint Controller and then both will agree how to best manage your details.  

Generally VM will be the processor acting on behalf of the location and venue provider.

It is the Controller that you should contact if you have any concerns about how your details are looked after. The Controller’s details should be displayed on the web page that you use to access the WiFi service.

A Controller makes the decisions about your details.

A joint Controller shares the decisions and responsibility for your details.

A Processor uses your details on instruction from a Controller.

If you are not certain who to contact then VM’s contact details are set out below.

Because we gather certain types of information about the users of the WiFi services we provide, we want you to understand the reasons for the collection and what it is used for.

Here you can learn about all the types of information we gather, how we use it, how to correct or change it and how we keep it safe and secure. 

Please take a moment to read it so you know what choices and rights you have about the information we may ask you for or collect about you.

This policy may change from time to time so it's a good idea to come back and read through it again.

The types of information we collect:

Here we explain the types of information we ask you to give us and/or that we collect about you.

We will never hold more information from you than is necessary. The precise types of information we collect will depend upon:

(i)  Whether we collect the information from you or from someone else;

(ii)  How / when we collect that information.

Information collected from you:

1.  Contact Information

When you register for services, create an online account, or contact us with queries we will ask you to give us, where needed, your generic details (i.e. full name), your contact details (i.e. email, postcode, phone number), your financial details (i.e. credit card number).

2. Network Information

When you use our WiFi services, we will use cookies (which are stored on your device(s) – laptop, mobile phone, tablet etc.) to collect information about your use of our online services. We collect information from your device on the IP addresses, internet service providers, browser type, language (where enabled), viewed and exit pages, and date and time stamps. See our Cookies section below for more details.

3. Additional Information

The information of the websites you visit, the transactions you make (including information used to make financial transactions) and responses to any of the surveys we send to you.

4. Device Information

Information about the type of device (mobile phone, tablet, laptop etc.) you are using and the WiFi address (sometimes called a MAC address.)

5. Location Information

If Location is enabled where you are using the WiFi service, we collect information on where in the venue you have been.

How and when we collect your information:

This section explains how and when we collect information about you.

We collect information about you when youse the WiFi service. The personal information VM holds about you depends from which venue you are using the WiFi service or if you have contacted us in other ways.

We may collect:  

• Information that you provide by filling in forms and submitting information over the phone, by post, email, fax or on the VM website. This includes information provided on registration for any of our services, through surveys, by posting material on the VM 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 VM website or otherwise (i.e. 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 WiFi service, or if you liaise with our customer service, technical support or any other department in our company we may keep a record;
  
• Your debit or credit card details, which are collected by secure payment merchants (we don’t actually handle this type of information ourselves);
  
• Your device identifier (sometimes known as your WIFI address or MAC address) which is automatically logged by our server;
  
• Personal information that relates to and identifies you, including but not limited to your name, date of birth,  e-mail address, telephone number, and any other information collected on the WiFi service pages;
  
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

How we use your information

This section explains how we use the information we hold about you (i.e. what we do with it).

We use the information we hold about you for:

• Administering agreements necessary to provide our services to you;
• Providing our services to you;
• Informing you about services and events provided or organised by us that may be of interest to you (if you have given consent by ticking the marketing box on the service); 
• Informing you about services and events provided or organised by selected third parties that may be of interest to you (if you have given consent by ticking the applicable marketing box on the service); 
• Enhancing and personalising the services that we offer to you; 
• Providing you access to all parts or features of our services; 
• 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 agreement 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; 
• Carrying out market research campaigns; 
• Improving and developing our services; 
• Ensuring that content from our services is presented in the most effective manner for you and for your device/s; 
• Performing research and statistical analysis and analysing markets and producing reports;
• Debt recovery or debt tracing, crime, fraud and money laundering compliance. 

There are several reasons why we can process your details:

Where we process your information on the basis of your consent

Whilst we have your permission, where you have ticked a box; you have the right to withdraw your consent at any time.  You can do this by:

• Writing a letter (address in Contacting Us section of this Privacy Policy)
• Sending an email (wificustomerservices@virginmedia.co.uk)
• Or contacting the location and venue provider

When we are operating as a Processor or Joint Controller we will share your details with the organisation that is responsible for your data (the controller) or the Joint Controller.   

With your permission your data may be shared with carefully selected third parties. If you do not want your data to be shared you must withdraw consent using the methods described above.

Where we have a legitimate interest; that is where it is reasonable to expect us to process your details and they are necessary for us to deliver our services to you.  

This enables us to gain customer insights and to review, develop and improve our products, services and special offers to ensure we are giving customers what they want.

Where we have a contract

Where VM is the Controller:

• To provide the service and reconnect when you return to the WIFI location;
• To provide you with service information and updates in relation to the products and services you have used;
• To respond to any questions or complaints you may have regarding our products and services;
• Manage service quality.

If VM is the Processor (so when a third party is Controller, e.g. Heathrow WiFi)

• To provide the service and reconnect when you return to the WIFI location;
• To process your personal data as instructed by the controller;
• To respond to any questions or complaints you may have regarding our products and services.

Are VM WiFi services child friendly?

If you are under 16 years old, you need to get your parent or guardian's permission before providing any personal data.  Children can sign up to use the WiFi service at any of our locations.  However not every venue has family friendly filters on their service.  

Please be warned that once connected, children can sign up to other services (i.e. Facebook, WhatsApp) and may be able to view unsuitable content on the internet.  This is beyond our control and children should be advised on what is appropriate content by their parents or guardians.

For more information on internet safety, please visit the Ofcom website.

Protecting your information

This section explains how we protect your information.

We are committed to ensuring your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard the information we collect on you.

Any information sent to us is protected by:

• Encryption where appropriate
• Regular security assessments and training of staff
• Regular crisis management reviews
• Regular penetration testing
• Updated security controls and policies

Who Has Access to your Personal Information

Your information is shared in the following ways:

• Your data may be used by VM, the location or venue provider you visited or selected third parties, subject to getting permission where required;
• With employees and Processors that have access to and are involved with processing your personal information.  At all times they are required to respect the confidentiality of your information; We may need to provide your data to regulatory bodies (e.g. Ofcom) or law enforcement organisations or a court, which may use your data for regulatory purposes or other lawful reasons;
• To other electronic communications service and equipment providers;
• To any third party where such disclosure is required in order to enforce or apply WiFi terms and conditions and/or other agreements, or to protect the rights, property, or safety of our company, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction; 
• In emergency situations when we have a reason to believe that someone's physical safety is at risk;
• Payment details are processed on our behalf by a Processor the US.  However we take reasonable steps to ensure that your data is processed in accordance with data protection legislation, our privacy policy and approved data transfer agreements. 

Keeping your information

Data is stored on our secure servers. If you do not register at one of our WiFi venues for more than 12 months, all personal data we store about you will be deleted.

Your rights over your information

This section explains the rights you have on the information we hold about you.

You have the following rights regarding your information:

1. The right to be informed - You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Privacy Policy.

2. The right of access - You have the right to obtain access to your information (if we’re processing it), and other certain other information (similar to that provided in this Privacy Policy). This is so you're aware and can check that we're using your information in accordance with data protection law.

3. The right to rectification - You’re entitled to have your information corrected if it’s not correct or incomplete.  If relevant, let us know what needs to be changed.

4. The right to erasure - This is also known as ‘the right to be forgotten’ and, in simple terms, allows you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. 

5. The right to restrict processing - You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.

6. The right to data portability - You have rights to obtain and reuse your personal data for your own purposes across different services. e.g. if you decide to switch to a new provider. If relevant, this enables you to move, copy or transfer your relevant information easily between our IT systems and theirs safely and securely, without affecting its usability, such as your name and address. 

7. The right to object - You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent). 

8. Rights in relation to automated decision making and profiling - We use technology to make decisions automatically or to build profiles about you.  This technology uses logic that analyses your preferences and how you use our products and services, which helps us to improve your customer experience, making it more relevant for you and allowing you to get the most out of our products and services. 

Where VM is the Controller:

If you stop using our services, or your permission to use our services is terminated, we may continue to use and disclose your personal information in accordance with this Privacy Policy (as amended from time to time) and as permitted by law. However, if you wish us to stop e-mailing you with information in connection with our services, please send your request to wificustomerservices@virginmedia.co.uk

Where we are not the Controller then you must contact the applicable location and venue provider to exercise your rights.

Contacting us

For queries regarding VM’s services, please call our team on 0330 3032575. If you have any questions or you are worried about our use of your personal information and/or want to exercise any of your rights you should:

• Write to the address below:
  Data Protection Team
  Virgin Media Limited
  Swansea
  PO Box 333
• Send us an email at either wifiservicedesk@virginmedia.co.uk or at DPO@virginmedia.co.uk

Please quote your name and address. It would be great if you would also provide brief details of the information that you would like a copy of 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.

If you’re not satisfied with our response to your questions, or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO).

Cookies

How We Use Cookies

Cookies are very small text files that are stored on your equipment when you visit some websites' browser, which can be used to identify that you have previously visited a site, or to store small bits of information locally with you. If you want to know more about what cookies are and how to control them, http://www.allaboutcookies.org/ is a great resource, or read on to see what we use cookies for.

We use cookies to make our website easier for you to use. You can remove any cookies already stored on your computer, but these may prevent you from using parts of our website.

The Cookies That We Use

Compliance Cookies: 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: We use cookies for remembering your log in details and your preferences (e.g. if you opt out from receiving marketing communications from us.)

Functional Cookies: 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: We make use of a tool from Google called Google analytics which tells us about the way users are using our site. This tool uses cookies to detect and let us know that someone has been to the site before, so that we know how often people return to our website, how long they keep using it, and which parts of the website they tend to go. We use this information to try find out how people uses our website so we can improve it.

Third Party Cookies: Other companies offering and advertising their products or services on our service 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: We may have a number of spots around the site that show advertisements or logos from other companies. We use cookies to track which adverts have been visited or which logos have been clicked.

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.

Links from WiFi Services to Other Websites

Please be aware that our WiFi services may provide access to web sites or App downloads by linking to them. We are not responsible for the data policies (including data protection and cookies), content or security of these. 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.

Privacy Policy updated by VM on 18 May 2018.