Virgin Atlantic Airways and Virgin Atlantic Holidays Privacy Notice

1.1 Scope of this privacy notice

This privacy notice describes the nature of all personal information that we collect, use and otherwise process about you in connection with your relationship with us as a customer, potential customer or just an enquirer (whether as a direct booker, agent booker, Flying Club member, lounge visitor, Cargo booker (direct, agent or B2B bookings), site visitor, app user, enquirer to one of our retail stores or call centres, job applicants or otherwise).

We are happy to provide any additional information or explanation needed and/or answer any questions you may have (please refer to the “About us” section below for details on how to contact us below).

1.2 Privacy notice updates

This privacy notice may change from time to time and is available on our website. You can tell when this privacy notice was last updated by looking at the date at the bottom of the privacy notice. If we make changes to this privacy notice, we will post the updated version on our website.

2.1 Who are we?

We are:

• Virgin Atlantic Airways Limited, a company incorporated in England and Wales under company number 01600117, with our registered address as set out below; and

• Virgin Holidays Limited trading as Virgin Atlantic Holidays, a company incorporated in England and Wales under company number 01873815, with our registered address as set out below.

2.2  Who's the Data Controller?

Virgin Atlantic Airways and Virgin Atlantic Holidays are each the data controller of all personal information that we collect, use and/or otherwise process about you under this privacy notice.

Virgin Atlantic Airways and Virgin Atlantic Holidays will act as joint controllers in relation to certain activities such as where we are conducting campaigns or undertaking analytics / customer insights jointly or across the customer base of both companies or where we are operating combined customer services operations. To keep things simple, whatever our position under data protection law, you can use the same contact details (as set out in this privacy notice) for any questions or requests you have in relation to data protection and your personal information. We will make sure these requests get to the right place. 

Unless otherwise stated, all sections of this privacy notice apply equally to both Virgin Atlantic Airways and Virgin Atlantic Holidays.

If you have made a booking for a hotel, car hire, standalone ancillary product or package holiday, then the Virgin Atlantic Holidays Booking Conditions identify that your contract is with Virgin Atlantic Holidays and Virgin Atlantic Holidays is the data controller in relation to personal information collected in connection with that booking.

If you have made a flight only booking then the Virgin Atlantic Airways Booking Conditions identify that your contract is with Virgin Atlantic Airways and Virgin Atlantic Airways is the data controller in relation to personal information collected in connection with that booking.

If you are a member of the Virgin Atlantic Flying Club,  Virgin Red Limited, who own and manage Virgin Points supporting the Flying Club will also separately be a data controller of your personal information relating to earning, redeeming and management of Virgin Points, details of which you can find in their privacy policy.

If you join Flying Club and fulfil the criteria set out in the Virgin Atlantic Flying Club terms and conditions, then you also agree that your data will be shared with Virgin Red for the purposes of the Virgin Red Loyalty Programme.  Virgin Red Limited’s address is Whitfield Studios, 50A Charlotte Street, London, W1T 2NS and you can contact their data protection officer at dpo@red.virgin.com.

In relation to Cargo, Virgin Atlantic Cargo is a division of Virgin Atlantic Airways and therefore Virgin Atlantic Airways is the data controller in relation to personal information collected, used and / or otherwise processed in relation to Cargo.

2.3 How to contact us

If you have any questions about this privacy notice or the ways in which we handle your personal information you may contact us as follows:

FAO: The Data Protection Officer

Address: General Counsel’s Office, The VHQ, Fleming Way, Crawley, West Sussex, United Kingdom, RH10 9DF

Email: data.protection@fly.virgin.com

2.4  To comply with the General Data protection Regulation (2016/679) we have appointed a European representative. If you wish to contact them, their details are as follows:

MCF Legal Technology Solutions Limited

Riverside One

Sir John Rogerson’s Quay

Dublin 2

Email: VirginatlanticEUrepresentative@mcf.ie

3.1 What types of information do we collect about you?

The types of personal information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we might collect any of the following types of information:

• Details about you. Your name, email address, address, telephone number, date of birth, loyalty membership details, your Flying Club and frequent flyer Membership Details, your Flying Club  tier status,  your payment details, meal preferences, language needs, your reason for travel (such as for a wedding, birthday or anniversary), special dietary requirements and other flying or lounge preferences and, if necessary, information about your health to the extent relevant to your fitness to fly, to provide you with special assistance and facial recognition data where we are required to do so in relation to security requirements imposed by a country through which you are travelling. If you are a B2B customer booking our Cargo services, this information may also include your job role and employer details. If you are booking a hotel or package holiday, your hotel room preferences and holiday itinerary;

• Identification documents/information. If you are flying on a route requiring Advance Passenger Information or other Passenger Name Records (PNR) to be collected and shared, your passport, identity card details and other required identity and contact information, including your passport number, the country in which your passport was issued and the expiry date of your passport or identity card. We will take a copy of your identification, national insurance number and proof of address if you attend a job interview;

• Details about the services you arrange with us. Your travel details, including details of your travel itinerary, where you’re flying from and to, other booking information, any onward travel details if relevant (for example if you need our assistance for a connecting flight, if you’ve booked airport transportation with us, or booked a tour and details of experiences or excursions booked), your baggage requirements, any upgrade information, your check in date and time, your lounge visits, seat preferences, meal preferences including special dietary requirements, details of any special assistance you might need from us and any other information relevant to enable us to provide you with the travel or other services that you’ve arranged with us. We will also collect details of your hotel, holiday and package;

• Financial information. If you’re using the website to book flights, hotels or other products or purchase products from our Retail Therapy online store or by phone with us or at one of our retail stores, your payment details, which may include billing addresses, credit/debit card details and bank account details;

• Transaction data. Your transactions on the website, including the date and time, the amounts charged and other related details;

• Your interactions with us or our partners. Your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or our website, over the phone or simply verbally to our people), when you get in touch via social media, when you attend any events we host or details of your preferences or attributes based on your interactions with our website or our goods or services.  In addition, we receive details of your preferences or behaviours based on your use of, or interactions with, our partners and their business offerings;

• Job applications. If you apply for a job with us, your CV, work history, educational details, qualifications, skills, projects, references, proof of entitlement to work in the relevant country, national security number, your passport or other identity document details, your current level of remuneration (including benefits), the role you’re applying for and any other similar information that you provide to us;

• Your use of our systems and services. Details of the way in which you use our site, app, call centres, retail stores, Wi-Fi, lounges, aircrafts and/or social media pages (please see the “OUR SITE, APP AND COOKIES” section below for further details);

• Emergency contact details. If you have made a booking we will request emergency contact details (name, telephone number, email, address);

• Pet details. If you request a pets booking through our Cargo services (including for accompanied pets), your contact details (including name, address, telephone and email), passenger details (including lead passenger name, booking reference, flight number, flight date or proposed flight dates and route, nationality), cargo pet booking details (including air waybill, number and type of pet, pets name), details of your pet (such as breed, name, weight) and pet crate; and

• Deceased details. If we are transporting human remains through our Cargo services, information contained on the deceased's death certificate including name, date and place of birth, age, gender, date and place of death, cause of death, occupation and signature, description and residence of informant.

How we collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we will collect information in any of the following ways:

4.1 Information that you provide to us:

• When you browse our site or mobile application;

• When you manage your booking on our site;

• When you book or search for a flight, holiday or other service (such as flight, cruise, hotel, lounge access, airport transportation or special assistance, Cargo booking) via our site app, retail store, our call centre or Virgin Atlantic Flight+Hotel, or via our Customer Centre;

• When you fill in part of the booking information on our site but do not complete the booking;

• When you manage your booking or check in online;

• When you provide information at a kiosk at an airport in relation to your check-in, bag drop or boarding or cargo booking;

• When you book or search for a flight, hotel, holiday or other service via a third party (such as a travel agent);

• When you register to enrol in Flying Club via the site, app, call centre or via a third party (such as your corporate employer);

• When you apply for a job with us by email, via the site;

• When you attend a job interview or assessment;

• When you communicate with us by any means, which could include (but is not limited to) via our retail stores, call centres, press office, social media post, website, email or Live Chat;

• When you request a brochure or sign up to receive email updates.

• When you ‘follow’, ‘like’, post to, or interact with our social media accounts (including Facebook, LinkedIn, Twitter, Pinterest, Instagram and YouTube);

• When you provide us with information about an accident, illness or incident that occurred in connection with your holiday or flight;

• When you participate in any of our competitions, promotions (for example via any social media channels or email) surveys or market research;

• When you make a complaint;

• When you travel with us (or with our codeshare partners on a code sharing arrangement);

• When you use our airport lounges (and any services we make available in our lounges);

• When you attend any events we might host;

• When you use our inflight entertainment; and

• When you make a Cargo consignment booking for you or for another person for whom you are legally authorised to act (including all types of cargo such as pets).

4.2 Information that we get from third parties, including:

• A person / company making a booking on your behalf. We will receive personal information in the form of booking details where, for instance, a family member or friend, travel agent,  employer, Cargo booking agent who may be based inside or outside the EU makes or updates a booking on your behalf;

• When you make a complaint via a third party. If you make a complaint (e.g. about a hotel or flight) via a third party (such as your travel agent or hotel) they will provide us with details of your complaint.

• Employers, recruitment agencies and referees. If you are a job applicant we may contact (or be contacted by) your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application;

• Partner airlines.  We will receive booking and flight information from partner airlines, together with (where relevant) information relating to your Flying Club earning or redemption activity;

• Service providers. We may collect or receive personal information from travel agents, airport kiosk, ground handling agencies and gate providers, our website developer, IT support provider loyalty partners and service providers, analytics service providers and payment services provider (who may be based inside or outside the UK / EU);

• Website security. We will collect information from our website security service partners who are based inside OR outside the UK / EU, about any misuse to the website, for instance, the introduction of viruses, Trojans, worms, logic bombs, website attacks or any other material or action that is malicious or harmful;

• Social media plugins. We may use social media plugins from the various service providers who are based both inside and outside the UK / EU including but not limited to Facebook, Twitter, LinkedIn, Instagram and YouTube. By providing your social media account details you are authorising that third-party provider to share with us certain information about you

• Government bodies. At some US airports, Customs and Border Protection use facial recognition technology during the check-in and boarding process in accordance with US law. The use of this technology is voluntary. Where your photograph is taken, Customs and Border Protection will confirm to us whether or not you have met its security requirements;

• Regulatory authorities. We may obtain personal information about you in connection with Cargo consignment bookings from regulatory authorities.

In certain circumstances, we will collect information which is referred to as special categories of personal information. This is most likely to include information about:

• Your health (for example if you ask us to provide you with special assistance arrangements during your flight or at one of the airports or during your holiday, to determine your fitness to fly with us, or if you specify a particular meal preference indicative of a medical condition or sensitivity to certain foods);

• Your religion (for example if you specify a particular meal preference indicative of a particular religion such as a kosher or halal meal);

• Your race, ethnicity, religious or philosophical beliefs and sexual orientation for the purpose of our diversity and equal opportunities records;

• Your health as necessary for the purpose of arranging your interview or supporting your needs and access to our workplace if you are an employee; and

• Biometric data in the form of photographs for the purpose of testing new technology at our check-in kiosks and boarding gates.

• Your criminal record for the purposes of completing background checks necessary for you to be able to work with us.

We need to have further justification for collecting, storing and using this type of personal information. We process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit consent;

• Where we need to carry out our legal obligations or exercise rights in connection with employment;

• Where it is needed in the public interest, such as for equal opportunities monitoring;

• Where it is needed in relation to legal claims, or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent; and

• Where you have already made the information public.

6.1 For what purposes do we use your information?

We will use your information for a variety of different purposes some of which will be dependent on the services that you engage us for. This includes:

• To facilitate your travel and manage your booking with us. We will use your information to provide you with any services that you request or purchase from us. This includes providing your flight, cruise or hotel, arranging a tour, transportation or car hire, checking you in to your airport, administering your Flying Club membership, (including earning and redeeming points and other benefits),providing your lounge access, managing the transit of your luggage, providing you with any special assistance, providing you with airport transportation, issuing you with your tickets (on the basis of performing our contract with you or where you have provided your consent);

• To send you service communications and provide support services. We will use your information to send you any communications relevant to the services or products you’ve requested or purchased from us. This includes sending you an email to notify you of changes to your flight time or itinerary, or providing you with a voucher, ticket or e-ticket. We will also provide you with customer service and support, deal with your enquiries, scheduling changes, complaints, comments or observations shared with us and monitor your progress through airport check in to ensure that you make your flight (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with customer service);

• To manage our relationship with you. This includes notifying you of changes to our terms of use or privacy notice, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);

• To send you marketing communications.  We will use your personal information to keep you up to date with our latest news, offers, partnerships, sales, promotions and competitions that we think might be of interest / relevant to you (or those of our Flying Club) if you have indicated that you are happy to receive marketing communications from us. Marketing will include details of products and services provided by both Virgin Atlantic and Virgin Atlantic Holidays. We (or our partners or service providers on our behalf) may do this using analysis compiled from information we have collected from you or which we have generated about you or which we have lawfully received about you from our partners. Please see the “MARKETING” section below for more information;

• To provide assistance with online bookings. We collect your information when you fill in the required fields of our online booking forms but do not complete your booking or transaction in order to save your booking form and send you reminders in relation to making your booking (where this is compliant with data protection law);

• To provide you with suggestions and recommendations. To share your information with selected third parties such as suppliers and partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so);

• To enable you to join Flying Club and the Virgin Red Loyalty Programme, to update your details and for points reconciliation purposes. We will use and share (with Virgin Red) the details provided on your account registration form and any amendments to your online profile (on the basis of performing our contract with you) as well as using / sharing (with Virgin Red) details of your loyalty points (including earning and redeeming points) (on the basis of performing our contract with you and our legitimate interests);

• To process and facilitate transactions with us. We will use your information to process transactions and payments, e.g. for flight bookings or purchases on our Retail Therapy store or for Cargo bookings, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);

• To personalise and improve your customer experience. We will use your information to provide you with a more personalised service. For example, tailoring the communications we send to you with your preferred routes and destinations, serving you only with advertising that we think you might like and/or enhancing your holiday experience, acknowledging your tier status with us and/or any inflight preferences (on the basis of our legitimate interests to present you with the right kinds of products and services);

• To manage our business and improve customer service. We record calls for the purposes of improving our customer service, quality assurance, training, security and for general business purposes (on the basis of our legitimate interest);

• To enable us to interact with you on social media platforms. These include Facebook, LinkedIn, Twitter, Instagram and YouTube, for example, posting status updates, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);

• To process your job applications. We will use your information to process any job applications you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);

• To optimise our site and app. If you use our sites or apps, we will use your information to ensure that the content from our websites are presented in an effective manner for you and your device, to provide you with access to our site and application in a manner that is effective, convenient and optimal, and to provide you with personalised content relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users);

• To ensure security and protect our business interests. In certain circumstances, we will use your personal information  to ensure the security of our services, buildings, and people, including to protect against and investigate and deter against fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business, where we have a legal obligation to do so, for establishing exercising or defending legal claims or for reasons of substantial public interest);

• To process and facilitate your transactions with us. We will use your personal information to process transactions and payments for bookings or purchases, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);

• To determine your fitness to fly. In certain circumstances, we will use your personal information to determine whether it is safe for you and/or other passengers to fly with us (on the basis of your consent);

• Cargo tracking and Air Waybills. We will use your personal information to process requests through the Virgin Atlantic Cargo website including cargo tracking, AWB requests and bookings;

• To develop and improve our services. Will we use your information to review, develop and improve the services we provide;

• To conduct research. We will use your information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you chose to participate in customer surveys, consumer focus groups and research (on the basis of our legitimate interests to improve our products, services and customer service);

• To detect fraud, terrorism and unlawful activities. To protect against, investigate, and deter fraudulent, unauthorised, or illegal activity, including identity fraud, terrorism and other types of unlawful conduct (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);

• To comply with our legal obligations, policies and procedures. In certain circumstances, we will use your information to enable us to:

  • Comply with our policies and procedures, and our legal obligations (for example adhering to court orders and subpoenas);
  • To enforce our legal rights;
  • To protect the rights, property and safety of staff, passengers and others;
  • This includes sharing your information with our lawyers, technical advisors, law enforcement and other regulatory bodies where necessary (on the basis of our legitimate interests or to comply with a legal obligation).
  • Occasionally we will use your information to make decisions about what communications you would like to receive from us in order to improve your customer experience.

6.2 On what grounds will we process your information?

We will use your information for the purposes listed above, either:

• For the performance of your contract with us and the provision of our contract with you;

• To comply with a legal obligation;

• For our legitimate interests (we explain what we mean by this below);

• To protect your vital interests;

• With your consent;

• For establishing, exercising or defending legal claims; or

• For reasons of substantial public interest.

6.3 What do we mean by “legitimate interests"?

As outlined above, in certain circumstances we (or partners on our behalf) may use your personal information to pursue legitimate interests of our own or that of third parties, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you, our customers. This involves:

• Providing you with and improving our customer service (including sharing data with our service providers and partners for the purposes of providing you with our goods and services, including to help us provide and administer your Flying Club membership and benefits);

• Determining the effectiveness of our site/tools/services and improving the security and optimisation of our network, sites and services;

• Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;

• Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing in certain circumstances, and serving you with advertising that is relevant and likely to be of interest to you;

• Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business; and

• Reviewing, improving and developing the services we provide.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don't automatically override yours and we won’t use your personal information if we believe your interests should override ours, unless we have other lawful grounds to do so (such as your consent or if we have a legal obligation. If you have any concerns about our processing please refer to details of “YOUR RIGHTS” section below.

As we outline in “YOUR RIGHTS” section below, you have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.

7.1 Who do we share your information with?

In connection with the purposes and on the lawful grounds described above, we share your personal information with the following third parties:

• Virgin Holidays Limited sharing with Virgin Atlantic Airways Limited. Virgin Holidays Limited will share your personal information with Virgin Atlantic Airways Limited where this is: (a) required for your booking, for example, where you book a flight and hotel details of your booking will be shared with Virgin Atlantic Airlines Limited to provide your flight; (b) necessary to provide customer service functions; (c) required for business analytics purposes; (d) required for the purposes of trend analysis and developing our products and services; and (e) processed in relation to ensuring an enhanced and tailored customer experience. They will also share information where you have consented to Virgin Atlantic sending you marketing.

• Virgin Atlantic Airways Limited sharing with Virgin Holidays Limited t/a Virgin Atlantic Holidays. In operating this website, Virgin Atlantic Airways will share personal information it collects through cookies or similar tracking technologies on this website with Virgin Atlantic Holidays to enable Virgin Atlantic Holidays to: (a) understand and analyse user experience, track and understand visitor movements and analyse trends; (b) send reminders if you fill in our online booking forms but do not complete the booking / transaction (where this is compliant with data protection law); and (c) identify you or your device for the purposes of online marketing and retargeting of promotional materials to you online. Further details and how to reject cookies can be found in our cookie policy. They will also share information where you have consented to Virgin Holidays sending you marketing.

• Third party providers, subcontractors and suppliers that we work with to provide your booking and other services you. We share your information with third party suppliers that provide us with services in connection with our business and the provision of our services to you. This includes: marketing agencies and/or companies that run our marketing or research campaigns, IT developers, service providers and hosting providers, loyalty partners and service providers, analytics service providers, third parties that manage promotions or competitions that we may run, third party software companies that provide us with applications on a white label basis, advertising providers and networks, ground agents, logistical services related to the transportation of goods and cargo, site analytics providers, medical service providers, fraud detection agencies and credit card screening companies based in both inside and outside of the EU;       

• Sky Team Alliance. Virgin Atlantic are a member of the SkyTeam Alliance, a global network of airlines that process personal information to provide passengers with a more seamless travel experience. For more information, please read the SkyTeam Alliance Joint Privacy Notice https://www.skyteam.com/en/joint-privacy-notice.

• Travel agents, tour operators, cargo booking agents or other third parties. These include: airlines, hotels, transport companies, excursion providers, airport authorities, insurance companies, car hire companies, ground handling agencies, cruise companies, your corporate employer who may book your flight (whether as part of a package or otherwise) or any other person who has booked a flight, hotel or package on your behalf, who may be based both inside and outside the UK / EU or your Cargo booking agent who is making a Cargo booking on your behalf;

• Third party suppliers that we work with to provide your booking and other services and that are delivering a portion of your itinerary. We share your information with third party suppliers that are providing us with services in the provision of services to you and as part of your travel itinerary. This includes for example: airlines, tour operators, transport companies, excursion providers, airport authorities, insurance companies, car hire companies, ground handling agencies, cruise agents, codeshare partners and travel agents based inside and outside the EU;

• Companies within the Virgin Group, our Partner Airlines, Virgin Red Limited and Loyalty Partners. We share your information with our Flying Club partners based inside and outside the UK / EU if you have agreed that you are happy to hear from them about products, services and offers that may be of interest.  We also share your Flying Club information including, for example, flights taken, to administer the relevant services to you, carry out statistical analysis, do market research and enable you to take advantage of the loyalty benefits available through our Flying Club and/or Flying Co programme, e.g. to credit your Flying Club account with Virgin Points.

• Virgin Red. To enable you to join Flying Club and the Virgin Red Loyalty Programme, to update your details and for points reconciliation purposes, we will share the details provided on your account registration form and any amendments to your online profile as well as details of your loyalty points (including earning and redeeming points) with Virgin Red.

• Airports, customs, immigration/border control and/or other regulatory / government authorities.  The majority of destinations require us to provide ‘Advance Passenger Information’ about you to the border/immigration authorities of your travel destination. Advance Passenger Information comprises the basic information contained in your passport that you would be required to present on your arrival (see here for more details). In addition, laws in certain countries in your itinerary such as the USA and countries your flight may fly over require us to provide certain additional advance information about you and your travel arrangements. We will provide this information where we are required to do so. In addition, we may disclose personal information relating to cargo consignments to customs or other governmental / regulatory authorities in the country of departure and/or destination in order to comply with the law in those countries;

• Third parties for marketing. We share your information with any selected third party that you consent to our sharing your information with for marketing purposes;

• Regulators and governmental bodies. Where necessary, we share your information with regulators and governmental bodies including HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers based inside and outside the EU, who require reporting of processing activities in certain circumstances;

• Prospective sellers and buyers of our business. We may share your information with prospective sellers or buyers of such business or assets, only in the event that we decide to sell or buy any business or assets;

• Third parties which are successors of the business. Your information may be disclosed to any successors of our business, in the event of re-organisation, merger or sale, for them to use for the purposes as set out in this privacy notice;

• Transfer of agreement. To anyone to whom we transfer or may transfer our rights and duties under any agreement we have with you or your business; and

• Courts or advisors. Any other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

8. 1 When you’ll hear from us

We will use your personal information to keep you up to date with our latest news, offers, partnerships, sales, promotions and competitions that we think might be of interest / relevant to you (or those of our Flying Club) if you have indicated that you are happy to receive marketing communications from us. Marketing will include details of products and services provided by both Virgin Atlantic Airways and Virgin Atlantic Holidays .

8. 2 Opting out of marketing

If you no longer want to hear from us, you can opt-out or unsubscribe by:

• Following the ‘unsubscribe’ link contained in any email marketing communications that you receive from us;

• If you have a Flying Club Account with us, updating your marketing preferences within your account;

• By contacting us using the details in the ‘ABOUT US’ section above.

• If you receive direct marketing in relation to Cargo you can opt-out by email by contacting Cargo.Marketing@fly.virgin.com

Third parties and marketing

We might rely on third parties under contract to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.

9.1 What we collect when you interact with our sites and apps

As you may already know, most sites and apps collect certain information automatically in log files about the way in which you interact with them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to the site or app, number of page views, the search queries you make, and similar information.

This information will be collected by us or by a third party site analytics service provider and will be collected using cookies.

As we’ve described above, we use this information to save your settings, such as the last holiday you searched for so you can find it easily the second time, give you access to greater features on our website, help improve our functionality and services, run diagnostics, analyse trends, track visitor movements, gather broad demographic information and personalise our services.

Virgin Atlantic Airways Limited will share certain information collected through cookies and similar technologies with Virgin Holidays Limited. Please see section 7 for further details.

9.2 What do we mean by ‘cookies’?

Cookies are small amounts of information in the form of text files, which we store on the device you use to access our site or our marketing communications. Cookies allow us to monitor your use of our services and improve them. For example, a temporary cookie is also used to keep track of your ‘session’. Without that temporary cookie, you would not be able to purchase flights via our site.

We also use cookies for site analytics purposes and to monitor how customers interact with and receive our marketing communications (for example if you open the marketing communication and/or click through any of our offers). We use this information to try to improve the relevance and tone of our future communications to ensure we’re servicing you as best as we can.

We give you options in relation to cookies when you first visit our site. If you choose ‘Accept all’, you consent to us using all cookie types. Choosing ‘Reject all’ means we’ll only use the cookies essential for the website to function properly. Click on ‘Settings’ if you’d prefer to consent to specific cookie categories.

If you don’t want cookies to be installed on your device, you can also change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the ‘Help’ section of your internet browser (or visit http://www.aboutcookies.org). Please note that, if you do set your internet browser to reject cookies, you will not be able to access all of the functions of our site.

• For details of all the cookies that we use, and what we use them for, please visit our cookie policy page.

10.1 Overview of your rights

You have certain rights in respect of the personal information that we hold about you, including:

• The right to be informed of the ways in which we use your information as we seek to do in this privacy notice;

• The right to ask us not to process your information for marketing purposes;

• The right to request access to the information that we hold about you;

• The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;

• In certain circumstances, the right to ask us to stop using informationabout you:

• The right to withdraw your consent for our use of your information in reliance of your consent;

• The right to object to our using your information on the basis of our legitimate interests (see paragraph 6.3 above for information about legitimate interests) or the legitimate interests of a third party and there is something about your particular situation which makes you want to object to us using it on this ground;

• The right to receive a copy of any information we hold about you in connection (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;

• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances; and

• The right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence;

• Please note that, notwithstanding these rights, we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and research purposes, and to defend ourselves against any legal claims. We may also need to send you service-related communications relating to your site user account even when you have requested not to receive marketing communications.

10.2 How to exercise your rights.

• Contacting us. You can exercise your rights by contacting us using the details in the “ABOUT US” section above – please specify whether your request relates to Virgin Atlantic Airways and / or Virgin Atlantic Holidays. Or, if you wish to stop receiving marketing communications, by checking the applicable boxes on forms that we use to collect your information to tell us that you don’t want to participate in marketing, clicking on the ‘unsubscribe’ link in marketing emails or by updating your marketing preferences on your Flying Club account or If you receive direct marketing in relation to Cargo you can opt-out by email by contacting Cargo.Marketing@fly.virgin.com. Please note that if you unsubscribe from marketing from one Virgin entity you will still receive marketing from other Virgin entities. For example, if you have signed up to receive marketing from both Virgin Atlantic Airways and Virgin Atlantic Holidays, you will need to unsubscribe to marketing from both.

• Updating your own details. Depending on the nature of your request, you may also be able to do update your details yourself. For example:

• You may update some of the details we hold about you by logging into your booking and following the instructions to edit your details, or contact us to change details of your booking;

• If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the 'unsubscribe' link.

• You can update some of the details we hold about you by logging into your Flying Club account via the Flying Club section of our site and following the instructions to edit your details;

• Requesting information we hold about you. You are entitled to receive information we hold about you. You can submit a Subject Access Request by contacting us using the details in the ‘ABOUT US‘ section above – please specify whether your request relates to Virgin Atlantic Airways  or Virgin Atlantic Holidays. To help us confirm your identity and to ensure your personal information is not disclosed to anyone who does not have a right to receive it, please send us a photocopy of your passport, or any other official identity document. Without this documentation, we may not be able to process your request.

• Requesting Proof of Travel. We are happy to provide Proof of Travel letters as requested.  Simply submit a signed written request including the following information:

  • Your full name - including any former names by which you may have been known;
  • Your full address - including any former address or addresses, at which you may have been resident at the time the booking was made;
  • Booking reference or flight number, route and date of travel;
  • A photocopy of any official document on which your name, address and usual signature appear - i.e. your Driving Licence or Passport
  • Please send your request to us at the following address:
  • Customer Relations - Virgin Atlantic Airways, The VHQ, Fleming Way, Crawley, West Sussex, RH10 9DF

We will comply with your requests unless we have a lawful reason not to do so.

• You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.3 What we need from you to process your requests

Please be aware that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request.

11.1 Our service providers and suppliers

We are based within the United Kingdom (“UK”), however, in certain circumstances, information that we collect about you will, during our relationship, be sent to and held by us in countries based outside of the UK where we work with suppliers and service providers that are either based outside of the UK, or have servers based outside of the UK. Countries based outside of the UK may protect information differently, and so where we do transfer your information to suppliers based outside of the UK and countries that the European Commission deems to provide adequate levels of protection for personal information, we will take all steps necessary to ensure that it is adequately protected and used in accordance with this privacy notice, including but not limited to relying on any appropriate cross-border transfer solutions such as the European Commission's Standard Contractual Clauses with the UK Addendum or the UK International Data Transfer Agreement.

11.2 Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.

11.3 Destination territories

As we outline above, in certain circumstances, we are required to share certain information about you in advance of your travel with immigration or other government authorities before we can deliver you to your destination

12.1 Our security measures

We strive to constantly keep our security practices under review to ensure that we are keeping your information as safe as possible. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. By way of example we:

• Ensure the physical security of our offices, lounges, airports, warehouses and other sites;

• Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions;

• Are a company compliant with the Payment Card Industry Data Security Standard ‘PCI DSS’, which means high standards of security in respect of your payment information;

• Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work;

• Carry out regular penetration testing of our systems and third party reviews of our software; and

• Maintain internal policies and deliver data protection and confidentiality training to ensure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.

12.2 How you can help ensure the security of your information?

You too can play a part in helping to keep your information safe, including:

• Choosing strong passwords;

• Keeping your booking references and passwords confidential, avoid sharing them with anyone else or using your password for multiple accounts;

• Limiting the information you share on social media and be conscious of using public Wi-Fi;

• Ensuring that you log out of your booking management page on your Flying Club account or profile with us after each session if you are using a shared computer;

• Informing us immediately if you know or suspect that your password or booking reference has been compromised, or if someone may have accessed your account;

• Keeping your devices protected by ensuring that you’re using the most up to date version of your operating system and have suitable anti-virus software if applicable; and

• Keeping alert to any fraudulent emails that might appear to be from us. Any emails that we send will come from the following email addresses: flyingclub@emails.virginatlantic.com; flyingclub@service.virginatlantic.com; virginatlantic@emails.virginatlantic.com; virginatlantic@service.virginatlantic.com; virginatlanticholidays@emails.virginatlantic.com; virginatlanticholidays@service.virginatlantic.com; cargomarketing@emails.virginatlantic.com.

12.3 Links to other sites and resources

Our site contains content and links to other sites that are operated by third parties (including our partner airlines and/or any other third parties whom we believe you may be interested in). Please note that we do not control these third party sites or the cookies that such third parties operate and this privacy notice will not apply to them. Be sure to consult the Terms of Use and privacy notice of the relevant third party site to understand how that site collects and uses your information and to establish whether and for what purposes they use cookies.

We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims. We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example:

• We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis unless we are required to retain it for evidential or legal purposes;

• We retain a suppression lists of individuals who no longer wish to be contacted by us indefinitely. We need to keep this information to comply with their wishes not to contact them; and

• We retain any unsuccessful CV's or job applications that we receive for a period of up to 2 years in case we think you might be suited to another opportunity that becomes available in the near future.

14.1 Not happy?

If you have any comments, questions or concerns about the contents of this privacy notice or the way in which we use your information, we encourage you to contact us using the details in the “ABOUT US” section above to see if we can help resolve the issue in the first instance.

However, if you wish to make a formal complaint or have concerns regarding the ways in which we use your information, you may do so by contacting the Information Commissioner’s Office (also known as the “ICO”). The ICO is an independent authority and the UK’s supervisory authority for information rights.

You can register your concerns on the ICO site here https://ico.org.uk/concerns/handling/.