LAST UPDATED: September 2018

Here at Virgin Start Up Limited (“Virgin Start Up”, “we” or “us”), we take your privacy seriously. We are a company registered in England and Wales with company number 03390330 and our registered office is The Battleship Building, 179 Harrow Road, London, W2 6NB. We're committed to protecting the privacy of any personal data you give us and we’ll be sure to comply with all applicable data protection legislation. For the purposes of relevant data protection legislation, Virgin Start Up Limited is the data controller of personal data that we hold and process about you. We are registered on the public register of fee payers maintained by the Information Commissioner in the UK. See the "Talk to us" section below for details of how to contact us if you have any questions or would simply like to get in touch.

Please take the time to read this Privacy Policy as it is important for you to know how we collect and use your data as part of your use of www.virginstartup.org (the “Site”). This Privacy Policy explains how we collect, use and store the personal data you provide to us. 'Personal data' is data that relates to you and that identifies or can be used to identify you – this might be your name or email address, or other digital identifiers relating to you, such as cookies, IP addresses or logs.

This Privacy Policy may change from time to time and, if it does, the most up-to-date version will be available on the Site.

OUR PHILOSOPHY

We have a philosophy here about the way we use the data you share with us and the way we communicate with you. If you hear from us, we will always aim to be respectful, relevant and appropriate. If at any time you don’t feel we’ve lived up to our philosophy, please let us know straight away by getting in touch with us or by contacting us using the details set out in the “Talk to us” section below.

We are proud to give you access to the Site and related services. In return, we may collect, use and share your personal data. We will only use your personal data for our purposes in a manner permitted by relevant data protection legislation, which may include:

  • where necessary to provide the Site and its features available and in order to give you the best user experience;
  • where we are under a contractual or legal obligation to do so;
  • for our legitimate interests;
  • as is necessary to progress any application you make; or
  • when you have explicitly consented (for example, by actively signing up to receive our newsletter).

By “legitimate interests”, we mean our interests in managing the Site and our relationship with you. We will make sure that we take into account any potential impact that such use may have on you. Our legitimate interests will not automatically override your interests and we won’t use your information if we feel that your interests override ours (unless, of course, you provide your consent or we have a contractual or legal obligation to use your information in that way). If you have any questions or concerns, please contact us using the details set out in the “Talk to us” section below.

This statement explains our privacy and data protection practices. When you use the Site, some information is automatically retrieved by your browser if you choose to accept cookies. This is not used to identify any individual user or passed on to any third party. However, if you register as a member on the Site or apply for a loan, you will be asked to provide us with your contact details and other details relating to your business. The information that is collected from you on registration will be passed on to third parties in certain circumstances, as set out in this Privacy Policy. Please see the "Will we use your information for marketing?", "How else will we use your information?" and "Will we share your information with anyone else?" sections below for further information.

WHAT INFORMATION IS COLLECTED ABOUT YOU AND HOW IS IT COLLECTED?

We may collect personal data about you (including your name, address, telephone number, email address, age, image/photograph, financial information, work history, gender and ethnicity) from:

you;

  • the Start Up Loans Company (SULC); or
  • third parties, including SULC’s finance partners and credit reference agencies. Credit reference agent data may include public, electoral register, shared credit and fraud prevention information. The credit reference agent check will leave a footprint on your file which may be seen by other lenders.

We collect information (including personal data) mainly when you sign up to: (i) any of our programmes (e.g. Start Up Loans, CrowdBoost etc.); (ii) our newsletter; or (iii) our mailing list, when you provide us with information within the Site and when you use products and services made available on the Site.

For example, we may collect and receive personal data when you:

  • Register for an account;
  • Apply for funding;
  • Apply for one of our programmes;
  • Acquire a ticket to one of our events;
  • Visit the Site (through a cookie);
  • Enter any promotions, competitions or prize draws through one of our services;
  • Update your account or personal data;
  • Provide information in connection with the mentoring scheme; or
  • Sign up to our newsletter.

WILL WE USE YOUR INFORMATION FOR MARKETING?

Once you have given your consent to marketing, we may display offers, promotions, products or services on the Site which we think will interest you based upon the information we collect from your cookies. We will keep your contact details for marketing purposes or pass your contact details to third parties (for example, SULC’s corporate partners) for as long as we have your consent to do so or until you tell us that you no longer wish to receive marketing materials by email, post or telephone. You may withdraw your consent to direct marketing by any means and at any time by contacting us using any of the methods detailed in the “Talk to us” section below. You can also unsubscribe from the newsletter by clicking on the 'unsubscribe' link included at the bottom of the relevant email.

HOW ELSE WILL WE USE YOUR INFORMATION?

We may also use your information (including personal data) for the following purposes:

  • to help us make the Site available to you and to help us provide related services to you (please see the "Will we share your information with anyone else?" section below for more information);
  • to make the Site more relevant for you and our other visitors. This includes sometimes requesting personal data from you to help us run and develop our website and related services;
  • to obtain a credit reference;
  • to carry out occasional surveys and to analyse our user base — ultimately we want to ensure that the Site provides everything that you — our audience — is looking for;
  • to respond to your questions and customer service queries;
  • to carry out research, analysis and write reports to understand our Site and how to make it better;
  • to check whether you are eligible for a competition and to contact you if you win;
  • to comply with the law;
  • to comply with SULC’s reporting requirements;
  • to comply with our European Regional Development Fund (“ERDF”) reporting requirements; or
  • as we feel is necessary to prevent illegal activity or to protect our interests.

We will only use information about your gender and/or ethnicity where you have provided your consent for us to use such information for the purposes of monitoring and promoting equal opportunities.

We will keep records of any agreements you enter into with us or services or products you receive for up to six years, save to the extent that we are required to hold records for a longer period in order to comply with applicable law. This is so that we can comply with our legal and regulatory obligations and respond to any complaints or disputes that may arise in that period. Please see the "How long do we keep hold of the information?" section below for our retention policy for personal data.

When you apply for a Start Up loan, Virgin Start Up will check the following records about you and others:

  • our own records;
  • those at credit reference agencies (CRAs). When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders. They supply to us both public (including the electoral register) and shared credit and fraud prevention information; and
  • those at fraud prevention agencies (FPAs).

We will make checks such as assessing your application for credit and verifying identities to prevent and detect crime and money laundering. We may also make periodic searches at CRAs and FPAs.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together so you must be sure that you have their agreement to disclose information about them. CRAs also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

Information on applications will be sent to CRAs and will be recorded by them. Where you borrow from us, we will give details of your accounts and how you manage it/them to CRAs. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs and FPAs to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted.

If you give us false or inaccurate information and we suspect or identify fraud, we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.

We and other organisations may access and use the information recorded by FPAs from other countries.

You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They may charge you a small statutory fee. Their contact details are as follows:

CallCredit, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0870 0601414.
Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford, BD1 5US or call 0870 010 0583 or log on to www.myequifax.co.uk.
Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or call 0844 4818000 or log on to www.experian.co.uk.

HOW LONG DO WE KEEP HOLD OF THE INFORMATION?

There are certain reasons that we have to keep hold of some of your information (including personal data). Naturally we keep your information while you are registered with us but we also keep some information after you've stopped working with us, though only for as long as we need it. How long we keep it depends very much on the type of information we are holding and the purpose for which we need it (as well as complying with our legal obligations).

You can request that we delete your personal data at any time.

WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?

We may share your information only if:

  • you specifically request us to;
  • we are required to do so to comply with a contractual obligation or legal requirement or with the directions of the courts or other authorities;
  • we feel it is reasonably necessary to prevent illegal activity or to protect our interests;
  • we feel that other Virgin entities’ products and services may interest you; or
  • it helps our trusted third party service providers to provide and improve our service to you or to carry out surveys and user analysis to understand your needs and preferences, please see the table of our trusted third party advisors below. We require these service providers to keep your personal data safe and secure. These trusted third parties would only be permitted to use your personal data for the purposes we specify.

As at the date this Privacy Policy was last updated (see above), these third party service providers include:

Name

Function

EU or non-EU

Acquia

Hosting

EU

Eventbrite 

Payments

Non-EU

Everwise

Mentor scheme management / hosting

Non-EU

Experian

Credit Reference Agency

EU

F6S

Data hosting / CRM

Non-EU

MailChimp

Email marketing

Non-EU

Pardot

Email marketing

Non-EU

Rackspace

Hosting

EU

Salesforce

Data hosting / CRM

Non-EU

Start Up Loans Company

Finance partner

EU

TEDCO Business Support

Delivery Agency

EU

Airedale Enterprise Services

Delivery Agency

EU

Yorkshire Coast Enterprise

Delivery Agency

EU

Business Enterprise Support

Delivery Agency

EU

Enterprise First

Delivery Agency

EU

Start Up U

Delivery Agency

EU

Street UK

Finance partner

EU

Virgin Red

Competitions and rewards

EU

Virgin Unite

Entrepreneurial charity

Non-EU

 

In particular, we may share your information with SULC (registered in England with company number 08117656) or delivery agencies contracted by Virgin Start Up as part of our funding service. Please refer to SULC’s Privacy Policy for details of how SULC may process your personal data.

We may share some broader statistics and customer profiling information with third parties and other Virgin entities – but we’ll keep it anonymous, so you won’t be identifiable from that data and we contractually require all such partners to treat your personal data as confidential and to fully comply with all applicable data protection law and consumer legislation.

We won’t ever rent or sell our user’s details to any other organisation or individual.

HOW WILL WE MAKE SURE OUR SITE IS SECURE?

We follow strict security procedures as to how your personal data is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal data you register on this Site will be located behind a firewall. We take security extremely seriously but as no system is 100% secure, we can’t completely guarantee the protection of your personal data, any more than any other organisation can. For that reason, we can’t accept any liability for the loss, theft or misuse of the personal data which you’ve registered on this Site if there is a security breach. However, we will take the appropriate measures to respond to and manage any incident, as required by data protection legislation. This includes taking measures to contain the incident, to recover the information, assessing the risks and notifying those affected (if required).

WILL WE BE TRANSFERRING ANY PERSONAL DATA OUTSIDE THE EEA?

The data that we collect from you may need be transferred to, and stored at, a destination outside the European Economic Area (EEA). For example, your data may need to be processed by staff who work for us but operate outside the EEA. Such staff may be engaged in, among other things, analysing and profiling the use made by you (and other users) of our Site. We may also transfer your data to a company based outside the EEA for other reasons (e.g. if our hosting company is based in the US). Countries outside the European Union may have a lower standard of protection for personal data than that required by EU data protection laws. If we transfer your personal data to a company based outside the EEA, we will take all reasonable steps necessary to try and ensure that your personal data is treated securely and in accordance with this Privacy Policy and EU law.  Please see the table of our suppliers in the "Will we share your information with anyone else?" section above for whether they are based inside or outside the EU..

WHAT ABOUT PERSONAL DATA RELATING TO MINORS?

Protecting the online privacy of children is especially important. If you are under 18 years old, please do not provide us with your name, contact details or any other information about yourself. To find out more, please read our Terms and Conditions.

ARE YOU PROTECTED BY THIS PRIVACY POLICY OUTSIDE VIRGINSTARTUP.ORG?

Our Site contains links to other websites. Obviously, we don’t have any control over them and take no responsibility for any information you give them. Other sites have different privacy and security policies, which we advise you to read.

WHAT IS YOUR COOKIE POLICY?

Please take care to read our Cookie Policy, which is part of our Privacy Policy. By registering to use or using the Site, you'll be confirming that you have read and understood and agree to this Cookie Policy.

WHAT ARE MY RIGHTS?

You have the right to unregister from the Site at any time. When you do so, you will no longer be able to access its features. Please note that, in these circumstances, we may still keep your data for the purposes set out in the "How long do we keep hold of the information?" section.

In certain circumstances you will have the following rights when it comes to our handling of your personal data:

  • Right of access – you have the right to request a copy of the personal data we have about you and to request supporting information explaining how the personal data is used. Please note that sometimes we may ask you to provide proof of identity before we show you your personal data – so we can protect unauthorised access.
  • Right of rectification – you have the right to request that we rectify inaccurate personal data about you that we have.
  • Right of erasure – you have the right to request that we erase all personal data about you that we have (please note that we may be able to reject or restrict the request in some circumstances, depending on the information we hold and our lawful reason to keep it).
  • Right to restrict processing – in some situations, you have the right to request that we do not use the personal data you have provided (e.g. if you believe it to be inaccurate).
  • Right to object, including to direct marketing – you have the right to object to certain processing by us of your personal data (unless we have overriding compelling grounds to continue processing) and the right to object to direct marketing by us.
  • Right of data portability – you may have the right to request that we provide you with certain information that you have provided to us in an electronic format or to provide that information to a third party.

Please get in touch with us at the address below if you would like to exercise any of these rights (including having access to your personal data):

Virgin Start Up Limited

The Battleship Building

179 Harrow Road

London, W2 6NB

UK

Email: hello@virginstartup.org

Alternatively, you can contact our data protection officer at dpo@virgin.com

You also have the right to complain to the UK's data protection regulator, the Information Commissioner, about our handling of your data. You can use the relevant section of the Information Commissioner's Office website to do this.

TALK TO US

If you have any queries, comments or complaints regarding this Privacy Policy, just get in touch. You can contact us: (i) through the Contact Us section of the Site; or (ii) using the details set out in the “What are my rights?” section above.