Make £5 Grow Privacy and Cookie Policy

Privacy Notice – How Make £5 Grow holds and uses your information

This notice explains how your information may be held and used by Clydesdale Bank PLC (trading as Virgin Money) to provide the Make £5 Grow programme ("the Programme"):

What information we'll hold about you
Where we collect information from
Why we need the information and what we use it for
Who we share information with
How long we hold information
Your legal rights in relation to your information
How we use cookies
Contacting us for further Information on your rights
Making changes to this information

1. What information we'll hold about you

We only collect information that we know we will need in order to provide the Programme.

By "information" we mean all of the personal information about you that we collect, use, share and store. It can include but isn't limited to:

Where a school is participating in the Programme, the teacher's name, school name, school address, school contact and fax number, teacher's work email, teacher's contact number at school, number of children taking part, if they require funds or not;
Where a home educator is participating in the Programme on behalf of children who are educated outside of a school, the home educator's name, address, contact number and email, number of children taking part and whether the home educator is the parent, guardian or employed tutor of the children taking part.

2. Where we collect information from

We collect information directly from you. You may give us information:

By filling in forms, for example when you sign up to the Programme.
By providing us with ongoing information in relation to the Programme.
By interacting with us on social media platforms such as Facebook or Twitter. This information can include posts and comments, pictures and video footage on sites such as YouTube, Facebook and Twitter. You should always review the terms and conditions and privacy policies of the social media that you use to make sure you understand what kind of information relating to you may be out there in the public domain and how you can stop or limit it from happening.
Via Third Party directory services that contains points of contact for schools that you may have subscribed to.

Important: If you submit details to us of any other person (e.g. a pupil) you must ensure you have their permission or that of their parent/guardian first.

3. Why we need the information and what we use it for

Data Protection law requires us to have one or more of the following reasons for using your information:

"Service performance" – the information needed to deliver participation in the Make £5 Grow programme in accordance with our terms.
"Legitimate interest" – we're allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights.
"Consent" – in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained.

Using your information

These are the main ways we'll use your personal information (and the reasons for doing so):

To provide the Programme, incorporating administration, receiving feedback and responding to any suggestions, issues or complaints you have contacted us about (Service Performance; Legitimate Interest)

To validate your Programme registration when you first register for the Programme and validate your profile and to respond to any social media posts or other public comments you might make, whether they are directly to us or about us, our products, websites, mobile apps, services or other activities (Legitimate Interest)

To enable us (and our third-party service providers) to plan and manage our day-to-day business as effectively as possible (Legitimate Interest)

To administer marketing & promotion from us (Legitimate Interest; Consent)

Manage the programme and your relationship with us, analyse performance of the scheme, and make improvements (Legitimate Interest)

4. Who we share information with

When using the information we hold we may share it with other people or organisations.

We'll treat the information we hold as confidential and will only share information from time to time. The following organisations are required to keep the information confidential, safe and secure:

Other people who help us provide the Programme and related services to you. Examples include market research companies, marketing, design as well as general service companies such as printers, mailing houses, form-scanning service providers and any new business partner.

5. How long we hold information

We'll retain information for no longer than is necessary to manage your relationship with us. In any event we will not continue to hold your personal data for longer than three years from the end of our relationship.

6. Your legal rights in relation to your information

The law guarantees you rights in relation to your personal information. We have set out details of your rights below under individual headings.

Access to information

You always have the right to ask whether or not we hold information about you. And if we do, what the information is, why we're holding it and the ways it's being used. You're also entitled to a copy of the information.

Portability of information

You have the right to get some of your information that you provided from us in a machine readable format.

Rectification of information

We always want the information we hold to be up to date and accurate. If any of the information we hold is either incorrect or out of date then please tell us and we'll fix it.

Erasure of information

You have the right to ask us to erase or delete information where you consider there is no longer any justification for us holding it, either because:

The information is no longer needed for the reason we collected it.
We held and used the information based only on your consent, which you have now withdrawn.
You have previously objected to a way in which we use information.
We have been using the information unlawfully.
There is a legal obligation on us to erase the information.

When you make a request for information to be erased we'll have up to one month to respond. If we reject your request we will tell you and set out the reasons why we'll not erase or delete the information.

Objecting to us using your information

We have told you about the ways in which we use the information we hold.

Where we have told you that any use of information is based on 'legitimate interest’, you can raise an objection to that use. When you make an objection we'll have up to one month to respond to you. We will stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We'll always tell you what the justification is.

Remember, you can always simply opt out of receiving marketing communications at any time. You can do this by contacting us in the usual way.

Restricting some uses of information

In certain circumstances you have a right to block or limit the use of information by us. This may arise where:

You have challenged the accuracy of the information we hold and we are verifying this.
You have objected to a use of information (see above) and we are considering whether your objection is valid.
We have been using your information unlawfully but you want us to continue to hold the information rather than erase it.
We no longer need to keep the information but you have asked us to hold it because of legal claims you're involved in.

7. How we use cookies

By accessing the Site you agree to us storing cookies on your system.

Cookies are small files placed on your computer's hard drive, or in your browser memory, when you visit the Site. They help us speed things up for you when you come back. They tell us what parts of the Site you visit, what you like and what's most relevant to you. What cookies don't do is store any personal or confidential information about you.

We use site tracking and monitoring to collect information about how our websites and applications are being used, such as the number of page views that occur on the Site, the number of visitors and common ways of arriving on or leaving the Site and our applications. This in turn helps us identify issues and to improve our services and provide you with a better customer experience.

We also use a third party to provide adverts about our products and services on our behalf across the Internet. The third party may also collect anonymous information about your visits to the Site and applications. This is done through the use of technology that tracks the user's cookie ID which is a numerical identifier. The third party does not collect any personally identifiable information, such as names, e-mail addresses, or phone numbers.

8. Contacting us for further Information on your rights

You can contact us at any time and in the normal way to discuss how Virgin Money holds and uses your information and your rights.

You can also contact our Data Protection Officer for further information and to request to use these rights. A Data Protection Officer is a person who is formally appointed to ensure that an organisation is aware of and complies with its responsibilities for data protection.

You can write to our Data Protection Officer at Virgin Money, Jubilee House, Gosforth, Newcastle upon Tyne, NE3 4PL.

If for whatever reason you are unhappy with any way we are using your personal information you should contact us in the first instance so that we can understand your issue and try and resolve it. We may ask our Data Protection Officer to look at your situation. If we can't resolve the issue you have the right to complain to the Information Commissioners Office (ICO). The ICO is the UK's independent body set up to uphold information rights. For further information visit ico.org.ukLink opens in a new window

If you have any further questions please contact us at:

Phone: 0191 279 8001

Address: Virgin Money, Jubilee House, Gosforth, Newcastle upon Tyne, NE3 4PL

Email: Make5Grow@virginmoney.com Email opens in a new window

9. Making changes to this information

We'll keep this information up to date and it will always be available at make-5-grow/privacy or on request at any time.