Privacy and You | Privacy | Vodafone Ireland

All personal information will be obtained fairly. We obtain personal information about you in various ways. This can happen automatically, when we’ve asked you to provide it (e.g. for the purposes of entering into a contract) or sometimes from third parties.  We will make you aware of all purposes that we intend to use your personal information at the time of collection or the purposes will be advised to you prior to use.

For example, we can collect personal information when you:

• Buy or use any of our products and services;
• Use our network or other Vodafone products and services;
• Register for a specific product or service;
• Subscribe to newsletters, alerts or other services from us;
• Contact us in any way, or ask for information about a product or service;
• Take part in a competition, prize draw or survey;
• Visit or browse our website or other Vodafone Group websites;
• Have given permission to other companies to share information about you; or
• Are the customer of a business that we acquire.

We may collect information from certain organisations, where appropriate. These include fraud-prevention agencies, business directories and credit reference agencies.

We may also collect information about you from other companies, our business or joint-venture partners as well as our third-party suppliers or contractors.

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our website). For more details on this and how to opt out of these, check our cookies policy

All personal information will be accurate and complete and where necessary, kept up to date. 

All methods of acquiring personal information from you (e.g. customer application forms, competition entries) will have a clear information piece explaining any intended purposes including any secondary uses that may not be obvious to you (e.g. if competition entries are intended to be used for marketing purposes this will be clearly advised to you, and you will have the opportunity to express if your choice is to opt in for such processing of your personal information).

Information we collect about you can vary depending on the products and services that you use and subscribe to, how you have used the products and services, and how you have interacted with Vodafone even if you aren’t a customer, or what we have obtained from a third party with permission to share it with us.

The types of information we may have are, for example:

• Your name, address, phone and/or mobile number, your date of birth, gender and email address;
• Your credit or debit card information, information about your bank account and other banking information – for example, you’ll have to give us this information when you open an account with us. We’ll collect the information necessary to process a payment whenever you make a purchase;
• Your contact with us, such as a note or recording of a call you make to one of our contact centres, a Live Chat, an email or letter sent, or other records of any contact with us;
•  Your account information, such as dates of payment owed or received, subscriptions you use, account numbers or other information related to your account or included in My Vodafone;
• Credential information – we’ll collect passwords, hints and similar security information used for authentication and access to accounts and services;
• Your preferences for particular products, services and lifestyle activities when you tell us what they are, or we assume what they are, based on how you use the products and services;
• See our Cookies policy for details on what we collect using cookies, web beacons and other technologies, including ad data;
• Call traffic details (including the time and date of calls for billing purposes) and data usage (to enable us to charge you the right amount and to alert you if you’re close to your usage limit).
• Your location data. This can be precise where it uses Global Positioning System (GPS) data or by identifying nearby mobile phone masts and Wi-Fi hotspots and you enable location-based services or features. Or less precise where, for example, a location is derived from your IP address or data such as a post code or name of a town or city; or
• Information we obtain from other sources, such as credit agencies, fraud-prevention agencies, and from other data providers and could include demographic data, interest based data, and internet browsing behaviour.

We’ll also get information about how you use our products and services, such as:

• The level of service that you receive – for example, network or service faults and other events that may affect our network services or other services;
• Details of your use of the specific services – you will find more information on Phone, Mobile, Apps, and Home Broadband also within the relevant sections on each of these here.

Vodafone collects:

• Your website browsing information, this includes details about the websites you visit on your mobile, device or PC.  However, we don’t have a history of your web-browsing as this is limited for a short real-time period to enable the connection to be made; and
• Date, time and length of your internet browsing, and your approximate location at the time you are browsing.

Vodafone does not keep records of your web browsing.

We do not keep records of what content you look at online. The only exception to this is when we are required to do so by law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities.

For more information on your browsing history and our use of cookies, see the cookies policy here.

Personal information will be kept only for clear and legal purposes. All personal information will be processed fairly and in keeping with the purposes for which it was obtained.

We will only process your personal information where we have a lawful purpose to do so, for example:

• Where you have provided your consent. You can withdraw your consent at any time and we will provide you with details on how to withdraw your consent at the time we capture same;
• For the preparation or performance of a contract with you; or
• Based on our legitimate interests to provide services and products to you. We set out below some of the legitimate business reasons why we process your personal information. Please also refer to our supplemental policies which set out product/service specific information. You can find more details here.

Personal information will not be used, disclosed or processed in any manner incompatible with the purposes for which it was obtained. We will not use your personal information for other compatible secondary purposes without advising you.

We may use and analyse your information to, for example:

Credit checks and ID

• Carry out a credit check when you apply for a contract for any products or services with us.
• We may also use your personal information for identity verification purposes, for access to your account and for general account management.

Processing your order and provide you with your products and service(s)

• Process the products and services you’ve bought from us, and keep you updated with the progress of your order.
• Provide the relevant product or service to you. This includes other services not included in your agreement with us, services that use information about where you are, and to contact with you messages about changes to the products or services.

Billing and Customer Care

• Bill you for using our products and services, or to take the appropriate amount of credit from you.
• Respond to any questions or concerns you may have about our network, products or services.

Keep you updated about products and services

• Keep you updated with current information about products and services you’ve taken.
• Keep you informed generally about new products and services, send you newsletters or white papers, to invite you to participate in a survey or to let you know about offers, promotions, prize draws or competitions (unless you choose not to receive our marketing messages. These messages can be based on how you use our products and services which could include, for example, your calling and messaging activities, location information and browsing information.
• We’ll also let you know about other companies’ products and services we think may be of interest to you (unless you prefer not to).

Manage our networks and understand network usage

• Protect our networks and manage the volumes of calls, texts and other uses of our networks. For example, we identify peak periods of use so we can try and ensure the networks can handle the volume at those times;
• Understand how you use our networks, products and services. That way we can seek to review, develop and improve these, develop more interesting and relevant products and services, as well as personalising our products and services;

Provide Roaming Services

• To improve your roaming experiences, to ensure that we’re meeting our commitments around fair use, to detect and resolve fraudulent use of our networks (and our partner roaming networks) and to solve any technical issues that you may experience.
• To understand how Vodafone is performing in providing roaming services, whether Roaming Services and related products are working as intended, or whether improvements are needed to make roaming better.  

Vodafone uses personal information such as your name, email address, password, mobile phone number and call records in order to do this. Vodafone creates aggregated and statistical management reports from this information that do not identify you individually. Vodafone may also take this personal information and anonymise it so that more in-depth analysis of our roaming services can be undertaken. This helps Vodafone to develop its roaming services for customers. When we anonymise your personal information this means that we can no longer identify you.

Fraud Prevention

• Protect and detect fraud or other crimes, to protect and detect misuse or damage to our networks, to recover debts or trace those who owe us money.

Research and analytics

We use a variety of analytics methods including what is commonly referred to as “Big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets (that is why it is “big” data) to uncover hidden patterns and hitherto unrevealed trends. At Vodafone we take governance of big data analytics seriously. Our data scientists are required to sign up to a Code of Ethics. We have a strict use case process that requires that privacy and data protection law checks are carried out before any use case commences. We have strict rules ensuring that personal information is anonymised or de-identified at the appropriate stage in the process.

We use our analytics to:

• Conduct market research and to carry out research and statistical analysis including to monitor how customers use our networks, products and services
• Build your customer profile to frame our marketing campaigns and determine how we might personalise those;
• Provide anonymised and aggregated reports to third parties (such reports don’t contain information which may identify you as an individual). These can be to third parties such as content providers, advertisers, and other business or public entities.

Meeting our business needs

We may use and analyse your personal information, such as your account information and details of your contract for products or services with us, to pursue our legitimate interests and those of third parties with whom we do business. The legitimate interests we pursue by such processing are to operate our business in a responsible and commercially prudent manner. This may also involve sharing some of your personal information with potential lenders to us and potential acquirers of us or any of our assets and their respective advisors and service providers.

Disclosure of personal information will only be made to third parties who are our agents or servants acting on our directions. Save as required by law (e.g. criminal investigations) no disclosure of personal information will be made to third parties for those third parties' own purposes or use.

Personal information may be legitimately given to Vodafone's servants or agents for legitimate purposes as described above. This may include the transfer of this personal information to other jurisdictions for processing (for example our Customer care call centres based in Egypt). In these circumstances Vodafone will ensure that adequate contractual and technical safeguards are in place to protect your personal information.

Where you have agreed to be in included in our directory enquiry list your information will automatically be included in the National Directory Database (NDD) currently hosted by Eir (as nominated by the Commission for Communications Regulation (ComReg)).

• For fixed services your NDD Opt Out preference will transfer automatically from your previous provider, unless otherwise specified.
• For mobile services we will automatically list you as preferring not to receive direct telemarketing from third parties.

You may wish to contact Customer Care on 1907 if you are a consumer or on 1800 800 020 for Enterprise care if you would like to amend these preferences.

We may share information about you with:

• Companies in the Vodafone Group;
• Partners or agents involved in delivering the products and services you’ve ordered or used;
• Companies who are engaged to perform services for, or on behalf of, Vodafone Limited, or Vodafone Group;
• Credit reference, fraud-prevention or business-scoring agencies, or other credit scoring agencies;
• Debt collection agencies or other debt-recovery organisations;
• Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law;
• A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement;
• Emergency services (if you make an emergency call), including your approximate location;
• Third parties for joint promotions with that third party. They’ll be responsible for their own compliance with applicable privacy laws;
• Partner organisations we’ve carefully chosen so they can contact you about their products and services (which may or may not include Vodafone products and services);
• Other third parties when you have given us your consent to the disclosure for authentication and fraud-prevention purposes.

Fraud management and law enforcement

We’ll also release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.

Mergers, Acquisitions and other Corporate Transactions

If we’re reorganised or we or any of our assets are sold to another organisation or we seek to borrow from another organisation we will provide your information to that organisation and its advisors and service providers to the extent that this is relevant to the proposed transaction.

Third parties that we work with

Where you’ve purchased Vodafone products and services using a third party or partner organisation, we may need to exchange information with them as part of managing that relationship and your account – for example, to be able to identify your order and be able to pay them.

If we have a contract with a service provider or contractor to provide us with services or provide a service on our behalf, and they may have access to your personal information, we don’t authorise them to use or disclose your personal information except in connection with providing their services.

We may collect and combine information in order to monitor your use of products and services, and that of our other customers, as well as to help us to improve the quality of our products and services. We may provide this information to third parties (for example, to content providers and advertisers) but any such third party reporting shall not include information which may identify an individual customer.

Third party products that you buy through your Vodafone account

Where you buy a third-party product or service through your Vodafone account (such as Charge to Bill for mobile), the contract for it is with the party selling that product or service. Vodafone is only charging the amount directly to your bill as part of its arrangements with the seller. As part of this, you’re agreeing that Vodafone may pass certain personal information to the seller to complete your purchase with them.

The seller’s terms and conditions and privacy and cookies policies will apply to how it uses your personal information – please read them carefully.

We may need to transfer your information to other Vodafone Group companies or service providers in countries outside the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy.  This kind of data transfer may happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.

If Vodafone sends your information to a country that is not in the EEA, we will make sure that your information is properly protected.  We will always ensure that there is a proper legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.

We’ll store your information for as long as we have to by law. If there’s no legal requirement, we’ll only store it for as long as we need to in order to provide products or services to you.

Subject to the above, the following specific retention periods will be followed:

We’ll keep some personal information for a reasonable period after your contract with us has finished in case you decide to use our services again. We, or one of our partners, may contact you about Vodafone services during this time if you haven’t opted out of receiving marketing communications from us.

We have specialised security teams who constantly review and improve our measures to protect your personal information from unauthorised access, accidental loss, disclosure or destruction. We use transport layer security (TLS) technology, for example to encrypt sensitive information such as your financial information.

Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered, as this is the nature of the Internet.

We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

We’ll never ask for your secure personal or account information by an unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.

Our website may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. So make sure you read that company’s privacy and cookies policies before using or putting your personal information on their site.

The same applies to any third-party websites or content you connect to using our products and services.

You may choose to disclose your information in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter and Pinterest) or using third-party services that allow you to post reviews or other information publicly, and a third party could use that information.

Social plug-ins and social applications are operated by the social network themselves and are subject to their own terms of use and privacy and cookies policies. You should make sure you’re familiar with these.