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This notice explains how Virgin Money Giving holds and uses your personal information.
Data Protection law requires us to have one or more of the following reasons for using your information:
1. "Service" – where the information is needed to provide the fundraising and donation services we provide.
2. "Legal obligation" – where we are required by law to process your information, e.g. to verify your identity.
3. "Legitimate interest" – in some cases we're allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights e.g. for our own management analysis and reporting purposes.
4. "Consent" – in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained e.g. if you agree to identify yourself as a donor on a fundraising page.
These are the main ways we'll use your personal information (and the reasons for doing so):
We use your information to provide you with and administer the relevant services described in our "General terms and condition of use for fundraisers and donors". This includes administering secure access to personal fundraising pages and other online services, processing and acknowledging receipt of donations and accounting for them to the relevant charity. We may also send you emails to help you administer your account or to tell you about changes to our service. (Service)
Whilst you are fundraising, we use your information to send you emails and reach you with content on social networking sites. This is designed with the sole purpose of helping you with your fundraising but you can opt out of these at any time. However, if you do, you will miss out on important fundraising tips, alerts, reminders and any rewards we provide from time to time for hitting certain fundraising milestones - although you will remain eligible for any rewards. If you donate through our website regularly, we may get in touch to help you manage that donation. (Service)
If you agree, we will also use your information to send you marketing – see more on marketing below. (Consent)
To combat the threats posed to our society by terrorism and money-laundering and to avoid losses caused by financial crime such as fraud. We may use information about you for the purpose of preventing, detecting and prosecuting financial crime and the funding of terrorism. (Legal obligation)
To run our business in a correct and commercially sensible way and to comply with our legal and regulatory responsibilities, we may use the information about you to help us do this, e.g. to analyse the performance of our marketing, products and any trends or behaviours. (Legitimate interest)
We may also use the information about you to help us develop and test our systems (including new technologies and services) to ensure that they are safe and will work in the ways in which we expect them to. When we do this we'll use processes and technologies that are designed to keep this information secure. (Legitimate interest)
We do not use your information to make automated decisions or undertake profiling about you to determine if we will provide you with our products or services.
With your permission we would like to keep you updated with our news, tell you about fundraising challenges and give you updates on Virgin Money Giving and Virgin Money products and services we think may be of interest to you. You have a legal right to tell us at any time that you don't want to receive this information and you want to withdraw your consent. You can do this by contacting us or unsubscribing from any marketing emails you may receive.
Charities you fundraise for or donate to would also like to send you information about their news, appeals and promotions they think may be of interest to you. If you have consented to receive marketing from a charity through us (see "Who do we share information with?" below), you may opt out at a later date. You have a right at any time to stop that charity contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you will need to contact the charity directly to tell them to stop.
We make the information we have about you and your fundraising available to charities that you are fundraising for. Charities may use this information to administer your fundraising. If you agree, charities may also use your information to send you marketing emails - see more on marketing above.
In some cases we will pass your personal information to the charity to allow them to administer your donations, for example;
a) For fulfilment purposes, such as if you’ve donated to them to buy an event ticket, a place in an event, or if you have requested a refund for your donation, or;
b) When you have donated to the charity directly, such as a one-off donation, a regular gift, or through their campaign (but excluding donations made to fundraising pages) (Service).
In these cases, we will share your name, email address and donation details. This is regardless of whether you have opted in or out of marketing from them.
If your only interaction with us is to make a donation, your information will never be shared with the charity for marketing purposes unless you have expressly agreed to this. Charities you support may or may not decide to use the information we make available to them about you.
We also share your information with carefully selected partners, agents and professionals who provide products, services and administrative support to Virgin Money Giving (such as World Pay who process card payments for us). This includes Virgin Money PLC, who also use anonymised data about you for business analysis. We will pass your information to HMRC if you agree to us processing a Gift Aid Reclaim for you. We may also share relevant information about you with fraud prevention agencies, as well as law enforcement and other government agencies if required to do so by law. If you agree, we will also share your email address with a fundraiser if you are making a donation. All of the information you make publically available on our website, will also be made available for website developers to access to build useful tools, e.g. fundraising leader boards.
All countries within the EEA, which includes the UK, have similar standards of legal protection for your personal information. To provide some products and services we transfer and process information in countries outside the EEA where there aren't similar standards. In these cases we'll take all reasonable steps necessary to make sure your information is protected to UK standards. This may be through only allowing transfers to countries which have been officially recognised as having an adequate legal framework for the protection of information (an 'adequacy decision'). It may be through having recognised safeguards in place with our commercial partners, such as using standard terms in the contracts we have with them that are recognised and approved by our regulators as imposing high standards for the protection of information or where our commercial partner is a signatory to a recognised and binding code of conduct.
To find out more about any particular uses of information in countries outside the EEA, the existence of an "adequacy decision" for that country or the safeguards we have put in place, please send an email to email@example.com or write to us at Virgin Money Giving, Discovery House, 4 Norwich Business Park, Whiting Road, Norwich, NR4 6EJ.
You have the right to access the information we hold about you, ask us to rectify any of that information, erase it, restrict or object in whole or part to the processing of it and ask us to make the information we hold about you portable. If you want to exercise any of these rights, please send an email to firstname.lastname@example.org or write to us at Virgin Money Giving, Discovery House, 4 Norwich Business Park, Whiting Road, Norwich, NR4 6EJ.
We'll retain information for no longer than is necessary and this will mean that we'll continue to hold some information for a period of time after our relationship has ended. This is to comply with our legal and regulatory obligations to keep records of our relationship, to resolve disputes or where it may be needed for future legal proceedings.
If for whatever reason you are unhappy with any way we are using your personal data you should contact us in the first instance so that we can understand your issue and try and resolve it. We may ask our Data Protection Officer to look at your situation. If we can't resolve the issue you have the right to complain to the Information Commissioners Office (ICO). The ICO is the UK's independent body set up to uphold information rights. For further information visit ico.org.uk