A. We care about your privacy
This Policy applies to all customers and prospective customers of Virgin Media as well as to any visitors to or users of our websites or apps, or any person that engages with us whether or not customers of Virgin Media.
When you use our services, your information will be handled as set out here in this Policy. While we may make changes to this Policy from time to time, we will publish any updated version of this Policy on our website, and we will take steps to inform you in advance of any material change that may affect the services that you have subscribed to.
B. Information we collect
Depending on the services and/ or products you use, we may collect the following information where relevant:
- Contact Details, meaning information that allows us to directly identify or contact you. This information includes name, address, telephone number, e-mail address, user names and passwords, date of birth, gender, language preferences, delivery details.
- Account Details, meaning information you provide to us to set up our services such as customer ID, payment method, bank account, credit card number (if applicable to your subscriptions), billing address, product subscriptions, products purchased through any of our channels, as well as the transaction details, your credit rating information (acquired from credit rating agencies).
- Competition Info, meaning information you provide to us when you enter competitions.
- Customer Care Info, meaning information when you contact us inquiring about our products and services and also information such as your support requests and the details required to resolve them. The time and duration of the customer care call, the communication channel used to contact us (including social media) and the solution applied. We may also record your call to the customer care team.
- Website Data, such as when you use our website, we collect the time and duration of the session, pages visited, campaign attributes, transaction details and technical details (IP/MAC address, operating system and browser type).
- Telephony Data, such as your telephone number, the phone numbers that you call and send messages to, time and duration of the call, device details (hardware model, operating system version, IMEI, IMSI), amount of data used.
- Internet Data, such as the amount of data used, time duration of the session, device, IP/MAC address, the websites you visit.
- Television Data, such as programmes you view, use of our services (e.g. “Replay”), technical data such as time and duration of watched content, the quality of the connection, the model and service number of your set top box, software version used, smartcard ID, and level of the service package.
- Personalised TV Service Data, if you have one of our latest set-top boxes, we use your information to provide a personalised TV service on your set-top box and on our Virgin TV Anywhere App (where you have opted-in to receive TV recommendations from us) that helps you remember your favourite shows, your most watched channels, most used apps and we may also recommend new ones suited to your taste, according to your viewing history.
- Email Data, if you use our e-mail services we collect technical data and the email addresses of the sender and receiver.
- App Data, we keep a record of whether or not and how often you use the apps we present to you in the TV menu.
- Directories Info, we will publish your name, address and telephone number where you have given your consent to be included in the public directories. Where you have not been included in directories and you want to appear in them, you can ask for it by calling 1908.
- Service Data , meaning information necessary for us to provide services to you, such as the model and service number of your set top box, software version used, smartcard ID, IP/MAC address, location data and level of the service package.
We will not request nor should you provide sensitive data (‘special categories’) in your interactions with us (e.g. race, ethnicity, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health or sexual life). If you choose to volunteer any such data, understand that we will process it in accordance with the law.
As further explained below, we may combine this information even where it is collected in different ways.
C. How we use your information
1. To provide our products and services
We use your information so we can provide you with Virgin Media services and products. For example:
- To bring you our products and services.
- To make sure our products and services are working as they should be.
- To tell you about the Virgin Media products and services we think you may love.
- To deliver your orders so you get your Virgin Media goodies as quickly as possible.
- To give you exclusive access to our online services like My Virgin Media.
- To respond quickly to your queries or issues.
- To administer competitions you may enter
- To send you your bill.
Providing our services to you also involves performing the following activities which are necessary to make the service available to you: network and traffic management, capacity planning, technical and commercial support, hardware and software upgrades, account administration, collection of payments and quality controls. We may also use your information when asking for feedback in respect of the performance of our products and services, our customer care service and our maintenance and operations. We may use information related to your use and access to our products and services for purposes of customer enquiries. We may also monitor and record our communications with you, including e-mails and phone conversations, for training purposes, quality assurance and to record details about the products and services you order from us.
We use Contact Details, Account Details and Service Data along with, Competition Info and Website Data. We also use Telephony Data, Internet Data, Television Data, Personalised TV Service Data, Email Data, App Data and Directories Info. We may also check your credit information with credit rating agencies, in order to fulfil the legitimate interest of guaranteeing payment of our services.
Your information may also be used to fulfil the legitimate interest of preventing and detecting fraud.
Legal basis for processing this information:
Performance of the contract, except for Directories Info and content recommendations (based on consent), credit scoring and fraud prevention (based on legitimate interest) and consent in relation to competitions.
2. To build your customer profile and improve and personalise our products and services
We use your information to improve and personalise your customer experience, so you can get the most out of our services.
For instance, high “Video On Demand” usage in a certain genre may lead to a broader film catalogue in this genre. We may also use your information to conduct market research (including surveys) in order to improve our existing services and develop new products according to the needs of our customers. Getting to know you better helps us to better meet your needs.
We build your customer profile with the following information: Contact Details, Account Details and Website Data. We analyse your Account Details, with special attention to your product subscriptions and any feedback that we may have received from you in order to figure out how we can improve and personalise your experience.
We use information collected through cookie type technologies, information you have provided to us, and information from your Virgin Media account, to help us tailor our services to your needs to deliver a better, more personalized service, and to remember certain choices you’ve made so you don’t have to re-enter them. Cookie type technologies also enable us to identify traffic to our website including pages visited, visitor numbers and traffic paths taken. For more information on how we use cookie type technologies and how to manage them, please read our cookies policy. A copy of this can be found https://www.virginmedia.ie/terms/cookie-policy/
Legal basis for processing this information:
Legitimate interest and consent for the use of cookie type technologies.
3. To personalise the ads you see on TV and on websites
We may use your information to personalise the ads you see on your TV where you allow us to do so.
We may use Contact Details, Account Details, Television Data and Website Data to personalise the ads you see on TV and on websites and we build your profile with your interests and preferences combining your Television Data or Website Data.
Legal basis for processing this information:
4. To present new products and services
As a new customer when you purchase products and/or services from us, we will ask you if you would like to receive marketing information from us by way of email, SMS, phone, post, telephone call or other specified means of contacting you.
Provided you agree to receive marketing information from us by the means you have chosen, we will continue to send you information about our products and services until you contact us to opt out of receiving some or all of the marketing or to change the frequency or manner in which you receive the information. You can change your marketing preferences at any time by calling our Customer Service free of charge on 1908 or by contacting us through our online channels.
We are a triple play company that provides telephone (mobile and fixed), broadband and TV services. We may contact you to tell you about our new telephone, broadband or TV products or services, or bundle of services that might be of interest to you where you have opted in to receive marketing from us as described above. In the case of electronic marketing (which includes SMS and email) we will collect your marketing preferences for similar products or services, (once you have provided us with your consent to electronic marketing for the original Virgin Media product or service) on an opt-out basis. You should note that as we are a triple play company the term “similar” means any of or a combination of our telephone, broadband or TV products and/or services. You will be given an opportunity to opt out each time we send a marketing communication to you electronically. We may use your Contact Details, Account Details, Television Data and Website Data in order to offer you such products and services.
We provide both general information about our products and services and also tailored information based on your interests and preferences combining your Television Data, Website Data, with your Contact Details and Account Details.
Legal basis for processing this information:
Legitimate business purposes for purposes of marketing our similar products and services to you. Any other marketing communication we send to you requires your consent.
5. To meet our legal obligations and for safety and security
We need to store some of your information to meet our legal obligations. We may be required by law to retain or disclose your information to competent authorities, including law enforcement agencies, where we have a good faith belief that we are required to do so under applicable law. These disclosures may be made without your knowledge, and without further notice, in compliance with our legal obligations. We reserve the right to challenge the access to information by authorities but we do not promise to challenge every demand.
We are required to store Telephony Data and Internet Data to meet our legal obligations. We may also retain, preserve or share other information if we have a good faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request; (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce our terms and conditions of providing services to you or any other agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public.
Legal basis for processing this information:
Compliance with a legal obligation, or where in our, your or others’ legitimate interests or vital interests, or in the public interest.
6. For Statistics
We may use depersonalised and aggregated information to develop reports and analysis about what types of content and /or advertisements are watched or skipped, for research and for other legitimate business purposes. We combine your information, in aggregated form, with those of other customers to generate summarised reports that help us to optimise our services and programming, and can also help other entities, like broadcasters or advertisers, better plan their activity. This information will allow us, for example, to better plan our network capacity, or to make better decisions about our TV content.
We use your Account Details, Television Data, App Data for these statistical purposes.
Legal basis for processing this information:
D. How do we protect your information?
We work very hard to protect your privacy and have taken key steps in protecting it. We have formally appointed individuals who are responsible for the security of our network, supporting infrastructure and our information systems. We have implemented solutions to protect your information, which consist of a variety of both technical and policy based solutions which vary depending on the applicable service or product offered or provided to you. These solutions may include, but are not limited to, password protection, encryption, firewalls, anti-virus, intrusion detection, anomaly detection and access controls for our employees.
E. Lawful basis for processing:
To use your information lawfully we rely on one or more of the following legal bases:
- Performance of a contract;
- Legal obligation;
- Our legitimate interests;
- Your consent (where you have provided it);
- Protecting the vital interests of you and others; and
- Public Interest.
To help you better understand where these legal bases apply we have set out for you some examples of each lawful bases at various point throughout this policy, for example at Section C “How we use your information” we clarify that your information is used for performance of a contract in some cases, using your consent for TV recommendations and for legitimate interest purposes in the case of credit scoring and fraud prevention. Where we rely on your consent to process your information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
F. Data Retention:
We retain your information in accordance with our record retention policy. This policy operates on the basis that we only retain information for as long as is necessary and in accordance with any legal requirements that we are required to meet.
Where applicable and in order to offer you information on our products and services, we collect and store certain information for so long as you remain a customer of Virgin Media. In relation to receiving information about our similar products and services, your marketing consent to electronic marketing will remain valid for a further 12 months after receipt of an email or SMS from us unless you opt-out of receiving further electronic marketing communications from us. You can of course also contact us at any time by calling our Customer Service free of charge on 1908 or contact us as set out in the ‘Your rights’ section of this Policy. In order to offer you personalised advertising, we collect and store your Television Data for three (3) months after viewing.
We retain your information even after you have stopped receiving services from us if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our terms and conditions of service, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalised information after your account has been closed.
G. Confidentiality of your information
Your communications are confidential. We may process metadata (information processed to deliver the communications), but we never access any of the content of your telephony calls, emails, internet, or App browsing (except our own communications with you as explained above). In the case of the TV service, we do not use information to provide personalised recommendations on adult content.
H. Sharing your information
We share your information with the following third parties:
Service Providers – we rely on trusted third parties to help us run our business and to provide us with specialised services. These can include companies who provide the following:
- Customer care services:
These companies may assist you with any support enquiries you have by phone, email or carry out in-home support calls as well as provide administration services, for example updating your account when you order a new service or cancel a service from Virgin Media. These companies may also contact you for marketing purposes, where we have your consent, and carry out customer satisfaction surveys;
- Sales services:
We work with companies to provide sales support to new and existing customers;
- IT services:
These companies may scan and upload letters we receive from our customers and provide general account administration services;
- Financial services:
This may include third parties providing billing services for Virgin Media; and
- Other third parties:
We may also use legal advisors, accountants and consultants and we may share your information with credit check or debt agencies.
Regulators – in certain circumstances we are required to provide your information to a regulator or other statutory bodies (e.g. in the investigation of complaints).
Group Companies – Virgin Media is part of Liberty Global Group. We may share your information with companies within the Liberty Global Group, with our parent company, subsidiaries, or other companies under common control (collectively "Affiliates"), for the operation of services or platforms or a purchaser of our business. We will require our Affiliates or any purchaser to honour this Policy where we share your information with them.
We require all of the above third parties to keep your information confidential and secure and use it solely for the purpose of providing the specified products and services to us.
Transfers outside the European Economic Area (EEA)
Some third parties may be located in countries outside the EU and Switzerland where different privacy rules apply. We will continue to use the European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the E.U. These clauses are contractual commitments between companies transferring personal data (for example Virgin Media Ireland Limited to its parent company, Liberty Global Inc.), binding them to protect the privacy and security of the data. Virgin Media adopt Standard Contractual Clauses so that the data flows necessary to provide, maintain and develop our services takes place legally.
Further information about the Standard Contractual Clauses adopted by the EU Commission can be found at the end of this Policy.
I. Your rights
You can exercise your rights by submitting a request in the form you'll find here. We will consider your request upon receipt and reply to you within 30 days. While some of these rights apply generally, certain rights apply only in certain limited cases.
Withdraw your consent:
Where you have given your consent to any of the uses of your information mentioned you can withdraw your consent at any time. If you withdraw your consent to the use or sharing of your information for purposes set out in this Policy, you may not have access to all (or any) of our products or services and we might not be able to provide you all (or any) of the products or services under this Policy. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
Access your information:
You can request a copy of the information that we hold about you.
Rectify your information:
If the information we hold about you is inaccurate or incomplete you can request a rectification.
Erase your information:
You can ask us to delete your information.
You can request that the information you provided to us be returned to you in a commonly used machine readable format, or, if you wish, directly transferred to another provider.
Restriction of processing:
You can request restriction of processing for the following cases (please state which case you are in when making your request):
- If you are contesting the accuracy of the your information;
- If you believe that we shouldn’t be processing your information, but you don’t want us to erase it;
- If we no longer need the information but you need it for the instigation or defence of a legal claim;
- If you have objected to the processing and we are in the process of verifying whether we have legitimate grounds to keep processing the information.
You can request to stop being profiled or receiving our latest offers from us:
- You can choose not to be profiled for our marketing activities,
- You can choose not to be notified of our latest offers.
Automated decisions including profiling:
You have the right to ask for any automated decision, including profiling, to be manually assessed by a person in certain circumstances.
J. How can you contact us about this Policy?
The controller of your information is Virgin Media Ireland Limited having its registered office Macken House at 39/40 Mayor Street Upper, Dublin 1, D01 C9W8, Ireland.
Data Protection Officer (DPO): You can address any question, comment or request regarding your information to our Data Protection Officer at firstname.lastname@example.org or by post to the address provided above.
For GDPR-specific information and rights, go to www.virginmedia.ie/gdpr.
Data Supervisory Authority: In case you’re not satisfied with the response we give you, you can also lodge a complaint with a data protection supervisory authority such as the Office of the Data Protection Commission:
Data Protection Commission
21 Fitzwilliam Square South
Telephone: 01 7650100
Additional information about International data transfers using Standard Contractual Clauses
The European Commission can decide that standard contractual clauses offer sufficient safeguards on data protection for the data to be transferred internationally.
It has so far issued two sets of standard contractual clauses for data transfers from data controllers in the EU to data controllers established outside the EU or European Economic Area (EEA).
It has also issued one set of contractual clauses for data transfers from controllers in the EU to processors established outside the EU or EEA
EU controller to non-EU or EEA controller
EU controller to non-EU or EEA processor