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Privacy policy

This notice explains how personal information concerning our Intermediary Partners and their Advisors may be held and used by Virgin Money plc in connection with the administration of our panel of Intermediary Partners and their Advisors (“our Panel”). It should be read in conjunction with our “Terms of Business for Intermediary Partners” (“our Terms”) which define some of the terms used in this notice.

What information we’ll hold about you

By “information” we mean all of the personal information about you that we collect, use, share and store. It can include but isn’t limited to:

  • Information about you and your contact details (e.g. your name, date of birth, address, phone number and email address).
  • Unique identifiers and reference numbers that we or others have allocated to you (e.g. your P Number or any FCA reference number).
  • How you access and use our intermediary website or other digital services (e.g. your IP address, your location and the device and software being used.
Where we collect information from

We collect information directly from you and from others. You may give us information in the following ways:

  • When you register for appointment to our Panel.
  • When you submit business to us on behalf of your clients through any means.
  • Applications, emails, letters, phone calls (including information provided on your behalf by someone else, e.g. an employer, network, club, partner or others in your organisation who are authorised to deal with us).
  • Entries into our competitions, surveys, promotions, and conversations with us on social media.
  • Using our websites, systems or applications, including through cookies that collect information on your internet use.

We also get information from:

  • Public registers and records (e.g. the FCA Register, Companies House).
  • Credit reference agencies (e.g. Experian) and fraud prevention agencies (e.g. CIFAS).
  • Advertisers, Social media networks and companies that do market research, statistical and behavioral analysis (e.g. Google and Facebook).
  • The Government and their agencies (e.g. HM Revenue & Customs).
  • Other companies that provide a service to us (e.g. surveyors and lawyers).
Why we need the information and what we use it for

Data Protection law requires us to have one or more of the following reasons for using your information:

  1. ‘Contract' – where the information needed to administer our panel and process business in accordance with our Terms.
  2. 'Legitimate interest' – 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.
  3. ‘Legal obligation’ – where the law requires us to process your information, for example to prevent and detect money laundering.
  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.

These are the main ways we’ll use your personal information (and the reasons for doing so):

To assess your appointment to our Panel. When you first register for the Panel we will assess the application and your eligibility based upon the information available to us. (Legal obligation; Legitimate Interest)

To administer our Panel and your relationship with us. This incorporates all communication and administration we perform or is necessary for the management of our relationship in accordance with or anticipated by our Terms. This includes the allocation and administration of any relevant passwords, user names or other unique identifiers that are necessary to enable Advisors to submit business to us through any means, payment of procuration fees and communication of changes to our range of products and service availability. (Contract; Legitimate Interest)

To prevent financial crime and the funding of terrorism. The law requires us to help combat the threats posed to our society by terrorism and money-laundering and other financial crime. We also have a legitimate interest in avoiding losses caused by financial crime such as fraud. We may check and share relevant information held by us with fraud prevention agencies, law enforcement and other government agencies for the purpose of preventing, detecting and prosecuting financial crime and the funding of terrorism. (Legal obligation; Legitimate interest)

To improve our services and systems. We have a legitimate interest in making improvements to how we provide our services and to improve the security and resilience of the computer systems we use. We must also respond to any changes in law or regulation that relates to the protection of the information we hold. We may use the information we hold 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. (Legal obligation; Legitimate interest)

Manage and organise our business. We have a legitimate interest in organising and running our business in a correct and commercially sensible way and to comply with our legal and regulatory responsibilities to the UK financial system. We may use the information we hold to analyse how well our marketing is working, train our team members, analyse trends or behaviors we can see, assess the profitability (or other indicators) of a particular product, service, sector or element of it when compared to others to inform our future commercial strategy and to report to and communicate with our regulators, auditors and governmental agencies. (Legal obligation; Legitimate interest)

Administration of marketing, offers and other promotional activity.The range of products and services we offer for distribution through our Intermediary Partners is constantly evolving. We have a legitimate interest in telling you about our products, services and any new developments that we think may interest you, but only where we are permitted to do so. We will also invite participation in promotions, prize draws and competitions from time to time. For some marketing activity we will need to ask for your consent to use your information. You have a legal right to tell us at any time that you don’t want us to use the information we hold in this way or to withdraw any consent that you have given to us. We’ll only get in touch in the ways you’ve told us are acceptable to you. If you’ve said you don’t want to see marketing information, you’ll not receive it. You can opt in to, or out of, receiving marketing information at any time by contacting us in the usual way. (Legitimate interest; Consent)

We may also use the information we hold for any other purposes that you have specifically consented to at any time or, in some limited circumstances, when the law requires or permits us to.

Who we share information with

When using the information we hold we may share it with other people or organisations. We’ll treat the information we hold as confidential and may share information with the following who are also required to keep the information confidential, safe and secure:

  • The companies within the Virgin Money group.
  • Other companies, commercial partners, agents and professionals who provide products, services and administrative support to the Virgin Money group.
  • The companies, organisations and individuals with whom you have a professional or regulatory association or who provide other services to you.
  • Anyone we may transfer our rights and duties under any arrangement to.
  • Anyone else with your permission.

We may also share information we hold with the following types of organisation:

  • Credit reference agencies.
  • Fraud prevention agencies.
  • UK and overseas regulators, authorities and their service providers (e.g. the Financial Conduct Authority).
  • UK and overseas tax authorities (e.g. HM Revenue & Customs).
  • UK and overseas law enforcement agencies (e.g. the National Crime Agency).
How long we hold information

We will hold 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.

Your legal rights in relation to your information

The law guarantees you rights in relation to your personal information. We have set out details of your rights below under individual headings.

Access to information

You always have the right to ask whether or not we hold information about you. And if we do, what the information is, why we’re holding it and the ways it’s being used. You’re also entitled to a copy of the information.

Rectification of information

We always want the information we hold to be up to date and accurate. If any of the information we hold is either incorrect or out of date then please tell us and we’ll fix it.

Erasure of information

You have the right to ask us to erase or delete information where you consider there is no longer any justification for us holding it, either because:

  • The information is no longer needed for the reason we collected it.
  • We held and used the information based only on your consent, which you have now withdrawn.
  • You have previously objected to a way in which we use information.
  • We have been using the information unlawfully.
  • There is a legal obligation on us to erase the information.

When you make a request for information to be erased we’ll have up to one month to respond. If we reject your request we will tell you and set out the reasons why we’ll not erase or delete the information.

Objecting to us using your information

We have told you about the ways in which we use the information we hold. Where we have told you that any use of information is based on ‘legitimate interest’, you can raise an objection to that use. When you make an objection we’ll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

Remember, you can always simply opt out of receiving marketing communications at any time. You can do this by contacting us in the usual way.

Restricting some uses of information

In certain circumstances you have a right to block or limit the use of information by us. This may arise where:

  • You have challenged the accuracy of the information we hold and we are verifying this.
  • You have objected to a use of information (see above) and we are considering whether your objection is valid.
  • We have been using your information unlawfully but you want us to continue to hold the information rather than erase it.
  • We no longer need to keep the information but you have asked us to hold it because of legal claims you’re involved in.
How we use cookies

By accessing the Virgin Money Website you agree to us storing cookies on your system.

Cookies are small files placed on your computer's hard drive, or in your browser memory, when you visit the Site. They help us speed things up for you when you come back. They tell us what parts of the Site you visit, what you like and what's most relevant to you. What cookies don't do is store any personal or confidential information about you.

We use site tracking and monitoring to collect information about how our websites and applications are being used, such as the number of page views that occur on the Site, the number of visitors and common ways of arriving on or leaving the Site and our applications. This in turn helps us identify issues and to improve our services and provide you with a better customer experience.

We also use a third party to provide adverts about our products and services on our behalf across the Internet. The third party may also collect anonymous information about your visits to the Site and applications. This is done through the use of technology that tracks the user's cookie ID which is a numerical identifier. The third party does not collect any personally identifiable information, such as names, e-mail addresses, or phone numbers.

Contacting us for further Information about your rights

You can contact us at any time and in the normal way to discuss how Virgin Money holds and uses your information and your rights.

You can also contact our Data Protection Officer for further information and to request to use these rights. A Data Protection Officer is a person who is formally appointed to ensure that an organisation is aware of and complies with its responsibilities for data protection.

You can write to our Data Protection Officer at Virgin Money, Jubilee House, Gosforth, Newcastle upon Tyne, NE3 4PL.

If for whatever reason you are unhappy with any way we are using your personal information 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

If you have any further questions please contact us:

Phone or email: Please call your dedicated Business Development Manager. You can find your BDM here: https://intermediaries.virginmoney.com/bdm-finder/

Address: Intermediary Sales, Virgin Money, Jubilee House, Gosforth, Newcastle upon Tyne, NE3 4PL

Making changes to this information

We’ll keep this information up to date and it will always be available on the Virgin Money Website or on request at any time.