LAST UPDATED: August 2022
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 66 Porchester Road, London, United Kingdom, W2 6ET. 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.
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, and where we need to use your data to provide services to you;
- 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, the services we provide 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.
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 and education history, gender and ethnicity) from:
- 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. post-funding support services, services offered via Everwise, 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 or via the services we provide to you.
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);
- Interact with us via social media and this could also include any photos that you might share;
- Enter any promotions, competitions or prize draws through one of our services;
- Update your account or personal data;
- Provide information in connection with the post-funding support services 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 or in the marketing materials we make available to you which we think will interest you based upon the information we collect from your cookies. We will keep your contact details for marketing purposes and may pass your contact details to third parties (for example, SULC’s corporate partners or SULC’s other delivery 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 and our services 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 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;
- for our legitimate interests (for example to provide the Site, its features and our services, including in order to give you the best user experience)
- 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.
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 are required to do so to provide post-funding support services to you;
- 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.
Array Data Hosting/CRM
Everwise Post-funding support programme including mentor scheme management / hosting
(trading as GC Business Finance) Finance Partner
Hopin Events Platform
MailChimp Email marketing
Salesforce Data hosting / CRM
Start Up Loans Company Finance Partner
TEDCO Business Support Delivery Partner
Yorkshire In Business Delivery Partner
Street UK Finance partner
Virgin Red Competitions and rewards
Virgin Unite Entrepreneurial charity
Virgin Management Group Company
Zoom Webinar Platform
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.
In addition, there may be opportunities for your business to be featured by another Virgin entity. Where such opportunities arise, we may share your website and high level details of your business with the relevant Virgin entity but we will always notify you if you are selected for any of these opportunities.
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?
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.
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 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
66 Porchester Road, London, United Kingdom, W2 6ET
Alternatively, you can contact our data protection officer at firstname.lastname@example.org
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