Introduction

We are West Coast Trains Ltd, also known as Virgin Trains West Coast or more simply, Virgin Trains. This privacy notice is to let you know how we promise to look after your personal data. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Virgin Trains is the trading name for Virgin Rail Group Holdings Limited and its subsidiaries as follows: Virgin Rail Group Holdings Limited, Registered in England and Wales No. 4196341. Virgin Rail Group Limited, Registered in England & Wales No. 328548. West Coast Trains Limited, Registered in England and Wales No. 3007940. Registered Office: The Battleship Building, 179 Harrow Road, London, W2 6NB, VAT no. 672859095.

You can find out more about us at www.virgintrains.co.uk.

If you have any questions or want more details about how we use your personal data, please let us know. See the 'how to contact us' section below for all the different ways you can get in touch.


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What personal information do we collect?

Technical:

  • Details on the devices and technology you use

Communications:

  • What we learn about you from letters, email, and conversations between us

Usage of data:

  • Other data about how you use our products and services

Documentary data:

  • Details about you that are stored in documents in different formats, or copies of them

Special types of data:

The law and other regulations treat some types of personal data as special. We will only collect and use these types of data if the law allows us to do so:

  • Health data and gender - for safety related incidents and refund purposes.
  • Criminal convictions and offences - for fraud prevention and criminal proceedings.

Consents:

  • Any permissions, consents or preferences that you give us

Reward Scheme Indentifiers:

  • Details about reward schemes you are part of e.g. Nectar, Virgin Atlantic Flying Club

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What types of personal data do we use?

We use many kinds of personal data, and group them together like this.


Data we collect when you use our products, services and facilities:

  • Payment and transaction
  • Journey
  • Profile and usage data 
  • Communication
  • Customer Satisfaction
  • Competition & Promotion
  • Loyalty Scheme
  • Recruitment
  • CCTV and Bodycam Footage
  • Wifi & Beam

Data from other data controllers we work with:

  • Card associations
  • Retailers
  • Social networks
  • Fraud prevention agencies
  • Loyalty scheme operators (e.g. Nectar, Virgin Atlantic Flying Club)
  • Market researchers
  • Government and law enforcement agencies

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Who do we share your data with?

We may share your personal data with these organisations:

  • Regulators and other competent authorities
  • Fraud prevention agencies
  • Companies you ask us to share your data with

We may need to share your personal data with other organisations to provide you with the product or service you have chosen:

  • If you provide us with details of a loyalty scheme we are a member of, like Nectar, we will share your data with that scheme
  • If you raise a Delay Repay claim, complaint or a query that is more suited with another Train Operating Company (TOC), the Rail Ombudsman or for Transport Focus

We may also share your personal data in the event a new franchise takes over the operation of Virgin Trains routes with the replacement franchise. We will only do this with your consent.


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How do we use your data?

Data Protection law says that we can use personal data only if we have a proper reason to do so. This includes sharing it outside Virgin Trains. The law says we must have one or more of these reasons:

  • To fulfil a contract we have with you
  • When it's our legal duty
  • When it's in our legitimate interest
  • When you consent to it.

A legitimate interest is when we have a legitimate business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

Below is a list of all the ways that we may use your personal data, and which of the reasons we rely on to do so. Our legitimate interests are also below.



Serving our customers

What we use your personal data for:

  • To deliver our products and services
  • To manage our relationship with you or your business
  • To develop new ways to meet our customers’ needs and to grow our business
  • To develop and carry out marketing activities
  • To study how our customers use our products and services
  • To market our products and services

Our reasons:

  • Your consent
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Keeping our records up to date
  • Working out which of our products and services may interest you and telling you about them
  • Developing products and services, and what we charge for them
  • Defining types of customers for new products and services
  • Seeking your consent when we need it to contact you
  • To provide you with information relating to how you can travel with us
  • As an active customer to keep you informed about our latest offers, deals and competitions
  • Being efficient about how we fulfil our legal and contractual duties


Reducing crime and operating in a safe and lawful manner

What we use your personal data for:

  • To detect, investigate, report, and seek to prevent fraud
  • To manage risk for us and our customers
  • To obey laws and regulations that apply to us
  • To respond to complaints and seek to resolve them

Our reasons:

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Developing and improving how we deal with fraud, as well as doing our legal duties in this respect
  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal and contractual duties


Operating our business effectively

What we use your personal data for:

  • To run our business in an efficient and proper way. This includes managing our business capability, financial position, communications, corporate governance, planning, and audit.

Our reasons:

  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal and contractual duties


Developing our products and services

What we use your personal data for:

  • To develop and manage our brand, products, and services
  • To manage how we work with other companies that provide products and services to us and our customers
  • To find people who might benefit from using our products and services

Our reasons:

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Developing products and services, and what we charge for them
  • Defining types of customers for new products and services
  • Being efficient about how we fulfil our legal and contractual duties
  • Complying with regulations that apply to us


What happens if we send your data outside of the EEA?

We will only send your data outside of the European Economic Area (‘EEA’) to:

  • Comply with a legal duty
  • Provide our products and services

If we do transfer information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. To do this, we will use one or more of these safeguards:

  • Only transfer it to a non-EEA country with privacy laws that give the same protection as the EEA, as deemed by the European Commission
  • Ensure that a contract with the recipient is in place that means they must protect it to the same standards as the EEA
  • Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries.

You can find out more about these safeguards on the European Commission Justice and Information Commissioner’s Office (ICO) websites.


Here is a list of the services we currently use which are located outside of the EEA:

Service Provider

The Trainline

Purpose

Contact Centre
Telephone Bookings

Safeguards

Binding Corporate Rules
EU Model Clauses

Location

India



What happens if you choose not to give us your personal data?

We may need to collect personal data by law, or under the terms of a contract we have with you.

If you choose not to give us this personal data, it may delay or prevent us providing our products or services to you. For example, not providing an email address would prevent us from providing you with an e-ticket to travel.

Sometimes we might ask for information that is useful for us to know but is not required by law or a contract. When this is the case, we will make this clear by marking it as optional. You do not have to provide these extra bits of information, and your choice will not prevent us providing you with our products or services.


How do we use your data for marketing?

We may use your personal data to tell you about our relevant products, competitions and offers. This is what we mean when we talk about ‘marketing’. We may also use your data to help create a profile to find potential customers like you.

We will only send you marketing messages if we have either your consent or a legitimate interest. Using legitimate interests is when we have a legitimate business or commercial reason to use your information in a way that does not unfairly go against what is right and best for you.

If we use our legitimate interest to market you, it would only be when you have purchased, or made an action to purchase a train ticket. We always give you the opportunity to object at the point of collection.

We may use what you tell us about yourself, the data we collect when you use our services, and information from third parties we work with to get a better understanding on what we think would interest you the most. This will also include linking information you have given us to create a full picture of your relationship with us.

You can ask us to stop sending you marketing messages by contacting us at any time by clicking unsubscribe at the bottom of any marketing email or updating your preferences in your online account.

Whatever you choose for marketing, you'll still receive service messages, such as booking confirmations, service updates and timetable changes.


How will we treat children’s privacy?

Our products and services do not specifically address anyone under the age of 13. It is possible for someone of any age to register and purchase some of our products or services. Where we can, we do request date of birth to help identify those persons. In the case we discover that a child under 13 has provided us with consent for marketing, we will immediately remove this consent. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us using one of the methods in the 'how to contact us' section so that we will be able to take the necessary actions.


How do we use your data if you request Assisted Travel on Alexa?

The information you provide to us with your consent, is passed on to the Rail Delivery Group in order that train operators can provide you with the assistance you require. This is because you may be travelling on a train or visit a station that is not run by Virgin Trains. The Rail Delivery Group have a privacy policy for this service located at: https://passenger-assist.org/assisttravel/PrivacyPolicy.html

We will store and process this data to make sure your request is completed, but only for those reasons. If you ask us to, we can save your preferences to save you asking us again. If you do this, we will only keep a record for up to 18 months after your journey.


If you share your information with us using Amazon Alexa

We will process your data in line with our Privacy Policy. We will only collect your name, email, address, and information relating to assisted travel (if provided) in order to provide the service to you. We will not use your information for marketing communication purposes and it won’t get shared with third parties.


If you visit our website and checkout as a 'Guest'.

You may want to buy a ticket from us and checkout as a 'Guest'. When you do this, we will maintain a record of your transaction and any preferences you have set. This is important for us to provide you with the services offered and to comply with our legal obligations.


How long will we keep your personal data?

We will keep your personal data for as long as you are a customer of Virgin Trains. The points below shows how long we keep which information, and our reasons why.


Personal data including transaction history and complaints

For how long:

  • Up to six years after last contact

Our reasons:

  • Keeping our records up to date, working out which of our products and services may interest you and telling you about them
  • To respond to any questions, claims or complaints
  • To comply with regulations that apply to us
  • To be efficient about how we fulfil our legal and contractual duties

CCTV, Bodycam and Call Recordings

For how long:

  • Train CCTV - 7 days after recording
  • Station CCTV - 4 Weeks after recording
  • Bodycam - 4 Weeks after recording
  • Call Recordings - 12 Weeks after recording

Our reasons:

  • To develop and improve how we deal with fraud, as well as fulfilling our legal duties in this respect
  • To comply with regulations that apply to us
  • To be efficient about how we fulfil our legal and contractual duties

For very good reasons, we may keep your data for longer than the periods provided, such as if you were unfortunately involved in a safety incident. If we cannot delete it for legal, regulatory, or technical reasons, we will make sure that your privacy is protected and only use it for those purposes.


Do you want us to share what personal data we have about you, with you?

If you want us to share what information we have about you, please let us know. See the 'how to contact us' section below for all the different ways you can get in touch.

If you do want to contact us, it would be helpful for us to complete your query if you provide us with your address, contact details and what you would like to have a copy of.

Sometimes you may be asked to provide proof of identity before we show you your personal data – this helps us prevent unauthorised access.


Is the personal data we have about you incorrect?

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us using one of the methods in the 'how to contact us' section or you can update details via your online account.

If you do, we will take reasonable steps to check its accuracy and correct it.


Do you want us to stop using your personal data?

You have the right to object to certain ways that we use your personal data, or to ask us to delete, remove, or stop using your personal data if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’. Please note such requests may not always be possible due to legal obligations we may have to keep such records. For example, ensuring you still have your rights under the Consumer Rights Act.

In some cases, there will be legitimate, legal, or other official reasons for us to keep your data. But please tell us if you think that we should not be using it.

It may be possible for us to restrict the use of your data. This means that it would only be used for certain activities, such as legal claims or to exercise legal rights. If this was to happen, we would not use or share your information in other ways while it is restricted.

You can ask us to restrict the use of your personal data if:

  • It is not accurate
  • It has been used unlawfully but you don’t want us to delete it
  • It’s not relevant any more, but you want us to keep it for use in legal claims
  • You have already asked us to stop using your data but you are waiting for us to tell you if we can keep on using it

If you want to object to how we use your data, ask us to delete it or restrict how we use it, please contact us using one of the methods in the 'how to contact us' section .


Do you want to withdraw your consent or object to when we use our legitimate interest for marketing?

You can withdraw your consent or object to marketing at any time. If this is the case, you can do this by:

  • Unsubscribing from an email you receive from us that contains the ‘unsubscribe’ link
  • Updating your preferences via your online account
  • Contacting us and informing us by using the 'how to contact us' section

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.


What is a service message?

Services messages are messages we need to send to let you know about your booking, or the service we provide for you. These are different to marketing emails we send as they contain information we need to tell you to ensure we can provide you with our services effectively. Examples of these include:

  • Booking confirmation and ticket details
  • Changes to terms and conditions and our privacy notice
  • Information about service interruptions

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How to contact us

If you have any questions or want more details about how we use your personal data, please let us know. We’ve provided a few different ways for you to do this, so please pick the one you would prefer to use:

Email:

Privacy Matters

Online Form:

Complaint Enquiry

Telephone:

Customer Resolutions:
03331 031 031

Address:

Customer Resolutions,
FREEPOST RRAE-UJZZ-ESUR,
PO Box 713, Birmingham,
B5 4HH


You also have the right to complain to the Information Commissioner’s Office. You can use the relevant section of the Information Commissioner's Office website to do this.


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Cookies

So, what are Cookies exactly? Simply put, they're tiny files automatically downloaded to any device you use when you visit our website (could be on your computer, tablet, mobile phone or more). They're designed to make your visit quicker, easier, and better. They can also let us know how well our site is working, and tailor your experience on our website.

To find out more about how we use Cookies please see our Cookie Policy.


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