Collection of information
Registration, forms and your dealings with us
We collect information about you when you provide it to us; for example, when you fill out our online forms or enquire about our products and services by phone or email. We may record phone calls or customer enquiries via online chat for quality, training and management purposes.
Information from devices
Public information and posts
Any information about yourself or others that you post on our social media pages, on platforms like Facebook, Instagram, Twitter and Tik Tok, will be viewed by other people (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this may be collected and used by third parties.
Our Legal Bases for Using Personal Information
All organisations need a legal reason to use your personal information. If they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.
With your consent
There are some activities where we process personal information with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. However, if you opt-out or withdraw consent, we may still need to send you communications to allow us to fulfil the product or service you have requested.
To enter into and fulfil a contract
We process your personal information in order to fulfil a contract we have with you.
For a legitimate interest
We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help allow us to fulfil our service fully. We only rely on legitimate interests if the reason for using your information is fair and lawful.
To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims.
How We Use Personal Information
To provide products and services and improve experience
We will use your information to provide you with products and services you have asked for and to manage our relationship with you.
We may use your information to monitor, improve and protect our products, services and website. We may also provide you with help and support where we believe it is required. For example, if you have provided your contact information, we may contact you when a checkout journey is not completed or to send you direct marketing
Where we have your permission or a legitimate interest as defined by the Information Commissioners Office, we may send you direct marketing. This may include communications by post, telephone, email, messages (including push notifications) to your mobile devices, through social media (such as Facebook, Instagram, Twitter and Tik Tok) and on our website, or on other websites, as you browse the internet. The communications may contain information about our products, services and offers.
You will be able to opt-out of direct marketing by following the instructions in the communication.
To send you product-related communications
As part of the products and services you have with us, you are entitled to receive newsletters, bulletins, and other “in-life” communications that relate to those products and services, including triggered emails, such as updates you make.
You will be told about the types of communications you will receive when you sign up and you will be able to unsubscribe at any time. However, if you do, you may not get the most out of the products and services you have signed up to.
We may send you service messages by email, SMS, post, or other channels, containing important information about changes to our service or your account. These communications are a fundamental part of our products and services. For example, we may contact you to tell you about changes to the product or service.
To conduct market research and perform analytics
We may use your information to conduct market research to improve the services we offer and to develop new products and services. You will be able to opt-out of receiving market research surveys by following the instructions in the communication.
To disclose your information as permitted by law
Your information may be disclosed where we are permitted by law to do so, for example where we get police requests or regulatory inquiries. We may also disclose your personal information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
To ensure our services are used appropriately
If you post or send offensive or objectionable content, or otherwise engage in disruptive behaviour anywhere on or to any of our websites, social media pages or apps, we may use your information to stop such behaviour. This may involve informing and responding to relevant third parties such as law enforcement agencies about the content and your behaviour.
As part of the sale of our business
If we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business for the purposes set out in this Policy and to ensure continuity of your selected services.
To take payments, check your identity and conduct credit checks
Customer information will be used to take payment for products and services and may be used to verify credit details related to this payment. Permission to do so is implicit in providing financial details to process payment. Direct debit or continuous payment authority information, including card details, may be retained in accordance with our regulatory requirements, by us or our payment processors for ease of renewal of services. Additionally, we may receive updated payment details from your bank or payment provider from time to time, which we will use to ensure that your details are kept up to date and to allow us to take future payments.
If we provide a service to you that is dependent on age or residency, and we have an obligation to verify this information then we may pass your details to a third party to carry out the verification for us.
To help us make decisions about your suitability for our subscription service, prevent fraud, check your identity and prevent money laundering, we may search the files of credit reference agencies who will record any credit searches on your file whether or not your application succeeds.
To ensure that our products and services conform to agreed industry standards
We may share your information with auditors for the purposes of verifying that we comply with relevant standards. This may require them to access your information in our systems.
Disclosure to our processors
We may pass your information to our processors – companies that we use to provide services on our behalf, for example service delivery companies. These processors can only use your information in accordance with our instructions and for no other purpose.
Access & Control of Your Information
Updating your information
Please ensure you update your personal information or tell us if it changes or is inaccurate. You can update your details, for example your contact number, via email to our Customer Services team at firstname.lastname@example.org.
Preference centre: controlling direct marketing
You can change your mind about receiving direct marketing or other communications you receive from us, by contacting us at email@example.com.
Withdrawing consent for processing
Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. Please contact us at firstname.lastname@example.org with details of your request. In some instances, we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.
You may request a copy of your personal information from us. You can also ask us to correct any inaccuracies in your personal information.
You may have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.
To exercise any of these rights, please contact us at email@example.com. These rights may be restricted by law, for example we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.
Complaining to the Regulator
If you have a comment, concern or suggestion, please contact us at firstname.lastname@example.org. If you have a personal data related complaint and we cannot resolve the matter, you have the right to complain to the Information Commissioner’s Office in the UK https://ico.org.uk/.
Retention of Personal Information
We will retain your information for as long as necessary for the uses set out in this Policy, or while there is a legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.
If you ask for your account to be closed, we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with legal obligations, prevent fraud, collect any fees owed and to resolve disputes.
Cookies and Similar Technologies
What are Cookies?
Cookies and other online tracking technologies are small bits of data or code that are used to identify your devices when you use and interact with our website. They are often used for remembering your preferences and to remember you’re logged in.
Our legal bases for cookies and similar technologies
Using information collected from cookies: where we want to use the information that cookies and similar technologies collect, we either need your consent or a legitimate interest. In practice it will not always be practical to get opt-in consent as doing so with cookie banners and pop-ups would disrupt your use and enjoyment of our sites and content. This is why we usually rely on our legitimate interests to use the data collected by cookies. To do this we conduct an assessment to make sure the purposes for which we use your data are fair and that your privacy rights are considered. We only rely on legitimate interests where your rights do not override our interests in using the data.
What Cookies Do We Use and Why?
Essential cookies and similar technologies
These are vital for the running of our services on our websites and apps. Without the use of these cookies, parts of our websites would not function.
Analytics cookies and similar technologies
These collect information about your use of our websites and apps, and enable us to improve the way they work. For example, analytics cookies show us which are the most frequently visited pages on our website. They help us record how you interact with our websites, such as how you navigate around pages and from page to page, identifying improvements we can make to the customer journey. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.
Tracking, advertising cookies and similar technologies
Third party cookies are set by an organisation that does not own the site that the user is visiting. These are normally cookies set by specialist marketing or analytics organisations.
We may use the following third-party cookies (for more information, please check the privacy policies of the relevant services).
To receive these types of adverts you will be asked to provide consent via a form on our website. If you do not provide consent then you will not receive these adverts.
Facebook & Instagram
Changes to This Policy
Data protection privacy notice (Recruitment)
This notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you during the application process. We are required to notify you of this information, under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.
Who collects the information
Virgin Pure trading as Virgin Strauss Water UK Ltd (‘Company’) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our affiliated entities and group companies, namely Strauss Water Ltd (our ‘group companies’) and so, in this notice, references to ‘we’ or ‘us’ mean the Company and our group companies.
Data protection principles
We will comply with the data protection principles when gathering and using personal information, as set out in our data protection (recruitment) policy.
About the information we collect and hold
We may collect the following information up to and including the shortlisting stage of the recruitment process:
- Your name and contact details (ie address, home and mobile phone numbers, email address);
- Details of your qualifications, experience, employment history including job titles, salary and interests;
- Information regarding your criminal record
- Details of your referees.
We may collect the following information after the shortlisting stage, and before making a final decision to recruit:
- Information about your previous academic and/or employment history, including details of any conduct, grievance or performance issues, appraisals, time and attendance, from references obtained about you from previous employers and/or education providers
- Information regarding your academic and professional qualifications;
- Information regarding your criminal record, in criminal records certificates (CRCs) and enhanced criminal records certificates (ECRCs)
- Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information;
- A copy of your driving licence.
In order to enter into your contract of employment you may be required to provide the categories of information listed above to us to enable us to verify your right to work and suitability for the position.
How we collect the information
We may collect this information from you, your referees (details of whom you will have provided), your education provider and the Home Office.
Why we collect the information and how we use it
We will typically collect and use this information for the following purposes
- to take steps to enter into a contract;
- for compliance with a legal obligation (e.g. our obligation to check that you are eligible to work in the United Kingdom);
- for the performance of a task carried out in the public interest; and
- for the purposes of our legitimate interests, but only if these are not overridden by your interests, rights or freedoms.
We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.
How we may share the information
We may also need to share some of the above categories of personal information with other parties, such as HR consultants and professional advisers. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information as required to comply with the law.
Where information may be held
Information may be held at our offices and those of our group companies, and third party agencies, service providers, representatives and agents as described above.
How long we keep your information
We keep the personal information that we obtain about you during the recruitment process for no longer than is necessary for the purposes for which it is processed. How long we keep your information will depend on whether your application is successful and you become employed by us, the nature of the information concerned and the purposes for which it is processed.
We will keep recruitment information (including interview notes) for no longer than is reasonable, taking into account the limitation periods for potential claims such as race or sex discrimination (as extended to take account of early conciliation), after which they will be destroyed. If there is a clear business reason for keeping recruitment records for longer than the recruitment period, we may do so but will first consider whether the records can be pseudonymised, and the longer period for which they will be kept.
If your application is successful, we will keep only the recruitment information that is necessary in relation to your employment. For further information, see our data protection privacy notice (employment)].
Your rights to correct and access your information and to ask for it to be erased
Please contact us (email@example.com) if you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask us for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. We will provide you with further information about the right to be forgotten, if you ask for it.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope we can resolve any query or concern you raise about our use of your information. If not, contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.
Last Update 2 June 2023