Introduction
This Privacy and Cookie Policy explains how we (Virgin Strauss Water UK Limited trading as Virgin Pure) collect, use, share, disclose or otherwise process personal information we hold about you across all areas of the business. Understanding our audience’s preferences allows us to personalise content, show relevant adverts, and generally improve your experience of our products and services.
Collection of information
The types of information about you that we may collect include the following:
Identity Data: name, title, gender, details in any social media profile when you contact us via social media.
Contact Data: address, email and telephone number),social media handles.
Usage Data: device IP address, details of the pages of the website you visit and other website usage information, your use of social sharing features such as Likes, comments and links that you share (e.g. on Facebook or Instagram).
Technical Data: data relating to your device e.g. an IP or Mac address, network information, the type of operating system, platform and browser you use, location.
Marketing Data: your marketing preferences and any information that you provide to us in reviews or feedback.
Correspondence Data: data we obtain in our correspondence and contact with you including in emails that you send to us.
Financial Data: if you purchase any products/services or subscription from us your payment details (e.g. bank account details and payment card details) will be collected by us or by an external payment service provider.
Further information regarding the ways in which we collect and use information about you are as follows:
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
We may collect information from cookies placed on your device. See the section on Cookies for more information about our use of cookies. With your consent, we may also collect the specific location of your device or request access to data from other applications to provide certain services you have requested.
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 TikTok, 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.
Credit Reference Data
We obtain information about you from credit reference agencies such as your financial history.
Our Legal Bases for Using Personal Information
All organisations need a legal basis to use your personal information. If they don’t have one, they can’t use it. There are a number of legal bases that enable data processing. The following are the legal bases that we rely on when using your personal information.
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 can opt-out at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on consent before withdrawal or the lawfulness of processing based on other legal bases.
To enter into and fulfil a contract
We process your personal information in order to fulfil and manage a contract we have with you including responding to enquiries and recovering debts.
In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at Experian, TransUnion and Equifax.
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, to manage our relationship with you, to respond to your enquiries, complaints and requests for support. We also rely on legitimate interests to manage our business (e.g. to keep financial and accounting records, to monitor potential criminal activity, to exercise our rights under a contract with you including recovering debts owed to us and in the context of a business reorganisation, sale or restructuring exercise) and to carry out some marketing and advertising. We only rely on legitimate interests if the reason for using your information is fair and lawful and we put in place appropriate safeguards to protect your data and to ensure that your interests or rights and freedoms are not overridden by our interests.
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, and to verify identity and prevent fraud and criminal activity
Please that we may process your personal data on more than one lawful basis depending upon the specific purpose for which we are using your personal data. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
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 consent 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 TikTok) 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.
Service messages
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.
If you choose to pay through Klarna, we may share information with them and they will collect data from you directly as well. Virgin Pure does not directly control this third party, so we recommend you review their terms to understand how they use your data: https://www.klarna.com/uk/terms-and-conditions/.
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 third parties including payment processors and other 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.
Disclosure to Credit Reference Agencies
We disclose your information to credit reference agencies and such information may be accessed by other companies.
To record calls
We may record and keep a log of any call made to our customer service desk for training and monitoring purposes. We do so in the interest of offering a good service to our customers and we may use the recording for training staff or any other operational purpose including to keep a record of any complaints.
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 customerservice@virginpure.com.
You can change your mind about receiving direct marketing or other communications you receive from us, by contacting us at customerservice@virginpure.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 customerservice@virginpure.com 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.
Other rights
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 or to transfer your personal data to another organisation– 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 customerservice@virginpure.com. These rights are not absolute in all situations and may be restricted by law and subject to conditions, 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 and we may not be able to delete your personal data where we need to keep it for accounting purposes or in order to comply with our legal obligations.
Complaining to the Regulator
If you have a comment, concern or suggestion, please contact us at customerservice@virginpure.com. 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?
How do we use cookies?
Types of Cookies we use
Manage cookie preferences
Cookie SettingsYou can change your cookie preferences any time by clicking the above button. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent right away.
In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.
Chrome: https://support.google.com/accounts/answer/32050
Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc
If you are using any other web browser, please visit your browser’s official support documents.
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 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
What information
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 (office@virginpure.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 10th October 2024