LAST UPDATED: MAY 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 information 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 information that we hold and process about you. We are registered on the public register of data controllers maintained by the Information Commissioner in the UK. See the "Talk to us" section 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 policy explains how we collect, use and store the personal information you provide to us. 'Personal information' 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 policy may change from time to time and, if it does, the most up-to-date version will be available on the Site. Please make sure that you are aware of the latest version of this Privacy Policy.

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.

We are proud to give you access to the Site and related services. In return, we may collect, use and share your personal information as is necessary for us to make the Site available in accordance with the Terms and Conditions, to improve your user experience, and as is necessary to progress any application you make. We will only use personal information for our purposes in a manner permitted by relevant data protection legislation, including for the provision of our services and, where you have consented, for marketing purposes.

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

  • From you;
  • From the Start Up Loans Company (SULC); or
  • From 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 mainly when you sign up, 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 receive personal information 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 information;
  • 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 at any time by contacting us at the address 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 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 information 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 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 information.

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 fraud prevention agencies 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. 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. We also have to take into account our legal obligations in respect of that data. For example, we may need to keep some non-personal information for financial reporting or other legal obligations.

You can request that we delete your personal information 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 the law 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 other Virgin companies 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 information safe and secure. These trusted third parties would only be permitted to use your personal information for the purposes we specify.

As at the date this 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 companies – 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 information 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 information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information 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 information, 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 information which you’ve registered on this website 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.

WILL WE BE TRANSFERRING ANY PERSONAL INFORMATION 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 information 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 information than that required by EU data protection laws. If we transfer your data to a company based outside the EEA, we will take all steps reasonably necessary to ensure that your 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.

If you would like to see the terms of any of our supplier agreements, please get in touch with us at the address below and we will share these with you provided that we are not prevented from doing so by obligations of confidentiality.

WHAT ABOUT PERSONAL INFORMATION 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 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 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.
  • Right of rectification – you have the right to request that we rectify inaccurate personal data about you.
  • Right of erasure – you have the right to request that we erase all personal data about you.
  • 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 of your personal data (unless we have overriding compelling grounds to continue processing) and the right to object to direct marketing.
  • 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.

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.

HOW YOU CAN ACCESS YOUR INFORMATION

You can request, at any time, access to the personal information we hold about you. You can email or write to us to request access to your personal information, using the details on our Contact Us page.

You are entitled to be told by us whether we, or someone else on our behalf, is processing your personal information, what personal information we hold, details of the purposes for the processing of your personal information and details of any third party with whom your personal information has been shared. You can also request that we correct any personal information which we hold about you where it is inaccurate.

Sometimes you may be asked to provide proof of identity before we show you your personal information so we can prevent unauthorised access.

TALK TO US

If you have any queries, comments or complaints regarding this privacy policy, just get in touch.