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.


This privacy policy relates to how we use your data as a stakeholder of Virgin Trains. If you also are a Virgin Trains customer, please also see our main Privacy Policy for how we use your data.


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 types of personal data do we use?

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


Contact

  • Where you work, who you are and how to contact you

Consents

  • Any permissions, consents, or preferences that you give us

Open data and public records

  • Details about you that are in public records, and information about you that is openly available on the internet

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Where will we collect personal data from?

We may collect personal data about you from these sources:


Data you give to us

  • Information you provide to us by filling in forms on our site or by contacting us
  • Information collected through face-to-face interactions

Data from open sources

  • Search engines
  • Corporate and/or Government sites
  • Companies House Register

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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, such as the Department For Transport
  • Companies you ask us to share data with
  • Business associates, including other train companies and agencies we employ

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.


Informing our Stakeholders

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 market our products and services

Our reasons:

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Keeping our records up to date
  • Developing products and services, and what we charge for them
  • informing you of relevant information relating to our business and our products and services, as required by our franchise agreement
  • To provide you with information relating to how we are operating as a business
  • 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
  • Being efficient about how we fulfil our legal and contractual duties
  • Complying with regulations that apply to us

From time to time, MPs or councillors may contact us on behalf of constituents who raise an issue with them regarding Virgin Trains. We only use data in this way to determine whether the constituent has previously contacted Virgin Trains and to respond to the MP or councillor’s request.


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.


We currently, will not be sending your data outside of the EEA. We will let you know if this changes.


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

If you choose not to give us this personal data, it will prevent us in providing you with the newsletter that we dispatch. This would be the same as if you unsubscribed.


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.


What data:

  • Personal data

For how long:

  • Until unsubscribed or no longer relevant

Our reasons:

  • To keep you informed
  • To respond to any questions, claims or complaints
  • Being 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. 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 as a stakeholder, 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.

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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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