Virgin Media Ireland Privacy Policy

Legitimate Interest.

6. 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.

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.

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 fulfil your request to “unsubscribe” from further messages from us. We may retain anonymised 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 rely on trusted third parties to help us run our business and to provide us with specialised services. We may share your information with the following third parties:

Service Providers: 

We work with service delivery partners to deliver our service including for order fulfilment, delivery, service provisioning and support.

Customer care services:

These companies may assist you with support enquiries you have when you contact Virgin Media 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. These companies may also scan and upload letters we receive from our customers and provide general account administration services;

Sales services:

We work with companies to provide sales support to new and existing customers; This may include third party retail partners, online partners, and franchise store operators.

 IT services:

We work with IT service providers to deliver and maintain our service. This includes cloud computing providers, data storage providers and software providers.

 Financial services:

This may include third parties providing billing services for Virgin Media.

Other third parties:

We may also use legal advisors,
accountants and consultants and we may share your information with 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.

I. Transfers outside the European Economic Area (EEA)

Some third parties may be located in countries outside the European Economic Area (EEA). The EEA includes European Union countries, Iceland, Liechtenstein and Norway. If Virgin Media transfer data outside of the EEA, we ensure dedicated safeguards are established, including contractual and technical safeguards to ensure your information is protected in line with data protection laws. For example, transfers may take place using Standard Contractual Clauses.

J. Push Notifications on Virgin Media Apps:

If you download our apps, certain communications may be sent by push notifications to your device. Push notifications are messages that pop up on your mobile device. You can manage your push notification preferences within our apps. You can also change your preferences at any time in your device settings. Please note, disabling push notifications does not change your Virgin Media marketing preferences.

K. Cookies:

Some cookies are required on our website as they enable it to function. These are known as Strictly Necessary Cookies. Strictly Necessary Cookies are always turned on.

All other cookies are switched off unless you choose to accept them on our website.

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 personalised service, and to remember certain choices you’ve made so you don’t have to re-enter them.

For more information on how we use cookies and how to manage your preferences, please read our cookies policy. A copy of this can be found here.

L. 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 one month. 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. Please note, Virgin Media may no longer have a copy of the information you are requesting due to our data retention and deletion protocols.

 Rectify your information:

If the information we hold about you is inaccurate or incomplete you can request rectification.

Erase your information:

You have the right to request that your information is deleted when there's no compelling reason for us to keep it.

Portability:

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.

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 privacy@virginmedia.ie or by post to the address provided above.

For GDPR-specific information and rights, go to www.virginmedia.ie/business/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:

1. Data Protection Commission
2. 21 Fitzwilliam Square South
3. Dublin 2
4. D02 RD28
5. Telephone: 01 7650100

This Privacy Policy was last updated on 8th November 2022