Privacy notice

Our Privacy Notice

Changes to our privacy notice

This Privacy Notice gets updated from time to time; whenever we make a material change, we’ll post this on our website and let you know.

We have revised our privacy notice as we are introducing some new features and ways of working. The main changes are outlined below.

Last updated: 14 October 2024

How to use this privacy notice

In this notice, we explain how we collect, use, share and protect your personal information when you use our products and services and our website.

You can find the privacy supplements for all our products and services at Privacy & Our Products & Services.

Who we are

We are Vodafone Ireland and we are a member of the Vodafone Group.  If you go to http://www.vodafone.com/content/index/about/where.html you can find links to all of the Vodafone operating companies that are part of the Vodafone Group.

In this privacy notice:

• “Vodafone/we/us/our” means Vodafone Ireland;
•  “third party” means someone who is not you or us;
• “partner organisation” means external third party business entity that provides value-added services; and
• “Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns more than 15% of the share capital.

Our registered office is Mountainview, Leopardstown, Dublin 18, Ireland.  We are registered in Ireland under company number 326967. Our main switchboard is (01) 2037000 or you can email us at dataprotection.ie@vodafone.com.

How to contact us

Your opinion matters to us – if you have any questions about our privacy notice, you can email us at: dataprotection.ie@vodafone.com or you can contact our Customer Care team on 1907.

You may contact our Data Protection Officer by email at dataprotection.ie@vodafone.com or in writing to Mountainview, Leopardstown, Dublin 18.

Our principles

Vodafone is committed to respecting your privacy. We take privacy, security, and complying with data protection and privacy laws seriously.

We have set out our core Privacy Commitments in our Privacy Centre. We aim to put these commitments at the heart of everything we do.

Directly from you

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

We will collect your personal information when you, for example:

• sign up to any of our products or services;
• use our network or other Vodafone products or services;
• contact us through various channels for support or ask for information about products or services;
• visit or browse our website; and
• if you are a non-Vodafone customer and contact a Vodafone customer or a Vodafone customer care team.

From third parties

Information collected not directly from you:

• Information we obtain from other sources, such as credit agencies, fraud-prevention agencies, and from other data providers. This includes demographic data, interest-based data, and internet browsing behaviour.

The types of information we may have, where applicable:

1. Contact details Such as your name, address, phone and/or mobile number and email address;
2. Financial details Such as 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 data necessary to process a payment whenever you make a purchase;
3. Your traffic data Every time you use your mobile phone, a record is kept. This includes the number you called or sent an SMS or MMS to, the length, date and time of that call, SMS or MMS, the amount of data you are using and your approximate location at the time that the communication takes place (based on the location of the nearest cell that you sent that call or message from). The same is also recorded every time you receive an incoming call or message. This is data we see as part of providing you with connectivity; we don’t, however, keep a record of the content of your calls or messages.
4. Information about your device or connectivity such as IP address, IMEI and MSISDN.
5. 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;
6. 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;
7. Your account information Such as your date of birth, gender, dates of payment owed or received, subscriptions you use, account numbers or other information related to your account or included in My Vodafone;
8. Credential information We’ll collect passwords, hints, and similar security information used for authentication and access to accounts and services;
9. Your preferences for 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;
10. Cookies See the Cookie Policy for details on what we collect using cookies, web beacons and other technologies, including advertising data;
11. Your browsing history If you have given your permission, Vodafone collects the categories of website you have browsed on your mobile, device or PC, for example Sports, Music or News. However, we don’t have a history of the sites you browse, as this is limited for a short period of time to enable the connection to be made. We use these interests to send you personalised marketing or show you personalised advertising. You can opt out of advertising and manage how we use cookies through the Cookie Settings which can be accessed via our Cookies Policy or, in the case of marketing, your Privacy Settings.
12. 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; or your viewing history if you use our VTV product for example.
13. Details of your use of the specific services or products for example CIOT devices or VTV. You can refer to the specific privacy supplement for each product/service for more information on the data processed.

We will use your personal information for a number of purposes, ranging from enabling us to provide you with the products or services you have requested to ensuring we are keeping these secure from fraud.

We may use Artificial Intelligence (A.I.) to help us provide you with a requested product or service. If we use A.I. we will do so responsibly, and where necessary we will disclose that the content is generated by A.I.

Whenever we use your personal information, we do so based on a specific lawful basis under data protection law listed below:

1. The performance of your contract or to enter into the contract and to take action on your requests for example, so you can make calls and texts, and browse the internet on your phone, we process things like the numbers you dial, how much data you’re using and when you’re doing it so we can provide connectivity. This also enables us to generate your bill, based on your usage. We also may conduct credit checks when you apply for a product or service, which is operated on a bill pay basis to verify your suitability for entry into such a contract.
2. Legitimate interests of Vodafone for example, fraud prevention, maintaining the security of our network and services, direct marketing, and improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our legitimate interests to make sure they do not override your rights. Additionally, in some cases you have the right to object to this processing. For more information, visit the Your Rights section of this notice.
3. Compliance with a mandatory legal obligation including for example accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures.
4. Consent where you have provided it by your own free will. Consent may be withdrawn at any time. See below ‘Your Rights’ for more information on how to do this.

Please see the table below for more information.

Below you can find an overview of the categories of personal information we process about you, the purposes for which we process that personal information and the lawful basis upon which we rely to conduct that processing.

Third parties that we work with

We are not in the business of selling your data, we only share your data with suppliers who help us to provide services.

When you’ve purchased Vodafone products and services using a third party or partner organisation, we often 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, they may have access to your personal information. We don’t authorise them to use or disclose your personal information received from us except in connection with providing their services.

We 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 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.

Mergers and Acquisitions

If we reorganised or merged with or divested part of our business to another organisation, we may need to provide your information to that other organisation or their advisers or receive personal information from that other organisation.

Third party devices that you connect your SIM with

You may connect your SIM with a number of third-party devices, either manually with a SIM card or electronically through our One Number product. These may include mobile phone devices or connected devices such as smart speakers or smartwatches. When you connect your SIM with these devices, those third parties may record your SIM details or your interaction with the network and provide that information to Vodafone for purposes of validating your eligibility for the OneNumber product offering. Those third-party device manufacturers will process your personal data in accordance with their requirements and we recommend that you read their privacy notices / policies before choosing to connect your sim to their devices.

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, privacy and cookies policies will apply to how it uses your personal information – please read them carefully.

It is necessary for us to process your personal information to enable us to provide you with your service. By service we mean any services or products that you buy or use such as broadband, mobiles, use of our apps or smart tech products.

We collect information about your use of our products and services on an aggregated or anonymous basis in order to help us manage and improve the services we offer to everyone.

We process your personal information for marketing and advertising purposes, such as to let you know about new products or services and send you special offers, as well as to help us tailor our service to you.

You can manage your marketing permissions, and your preferences for the data we use to tailor these communications at any time by visiting Your Privacy Settings.

Profiling consists of the use of personal data in an automated form in order to evaluate certain personal aspects relating to an individual. We will process your personal information in this way for credit, fraud, and security purposes.

Under certain circumstances, it is necessary for us to process your personal information in order to comply with the law, for example, when responding to law enforcement requests for data or to comply with tax requirements.

Where applicable, we 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 Ireland 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;
• 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). We’ll ask for your consent before sharing this information;
• Other third parties when you are signing up to their service and it is used by them for authentication and fraud-prevention purposes;
• Third parties that we advertise with, such as Facebook, in order to serve you advertisements online;
• Third parties that we use to serve you marketing.

We may need to transfer your information to other Vodafone Group companies (for instance our Vodafone Intelligence Solutions centres located in Egypt, Hungary, Romania, Albania and India, who provide customer support) 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 will 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 to conduct a transfer impact assessment and 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 or deemed adequate by the European Commission (see list of adequacy decisions), then we will implement additional technical security and organisational safeguards such as asking the third party to enter into a legal agreement containing standard contractual clauses approved by the European Commission that reflects those standards.

We’ll store your information for as long as we must by law. If there’s no legal requirement, we’ll only store it for as long as we need to.

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; to allow us to answer any questions you might have after you cease your services, or for our own business and reporting requirements. 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.

Communications over the internet (such as emails) are not secure unless they have 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.
 

Right to correct personal data

You have the right to have information held about you corrected if it is not accurate. If any of the information that we have on file relating to your account needs to be updated, or you think it may be inaccurate, you can log in to My Vodafone to update it (Login > My account) or contact our Customer Services team.
 

Right to access personal data

You have the right to make a request for a copy of the personal data that Vodafone holds about you. To make this request as an individual or an authorised 3rd party, please fill out the online form or post it to the address on the form. Alternatively, you can contact the Customer Services team. We will take reasonable steps to confirm your identity before issuing any copy of your personal information.
 

Right to data portability

You have the right to be able to take with you data you provided to us in certain circumstances. For example, Vodafone ensures that you can take your data with you by allowing you to download your monthly bills, at the click of a button, in a format of your choice. To do this, log in to My Vodafone and go to your billing area. Some specific apps and services allow you to take out the informed stored by the user into Vodafone’s cloud and hosting services, for example Backup+.
 

Right to restrict use of your data

If you feel the data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our Customer Care team on 1907 to discuss your rights. In certain circumstances you will have the right to ask us to restrict processing.
 

Right to erasure

Vodafone strives to only process and retain your data for as long as we need to. In certain circumstances you have the right to request that we erase personal data of yours that we hold.  If you feel that we are retaining your data longer than we need, it is worth first checking that your contract with Vodafone has been terminated which you can do by contacting our Customer Care team on 1907. If your contract with Vodafone has been terminated, we may still have lawful grounds to process your personal data (for more information on retention periods see How Long We Keep Your Personal Information For).
 

Right to object to processing where we rely on our legitimate interests:

Please contact our Customer Care team on 1907 or email us at dataprotection.ie@vodafone.com.
 

Right to withdraw consent

You can withdraw your consent anytime after giving it. Depending on how you provided your consent you should be able to withdraw your consent in the same way. You can also contact our Customer Care team on 1907 or email us at dataprotection.ie@vodafone.com.
 

To opt out of Marketing messages

If you no longer want to receive marketing messages from Vodafone, you can elect to opt out of all marketing communications or only selected methods (email, SMS MMS, phone or post).

There are various ways to opt out:

• Log in to your Privacy Settings to manage your permissions; your Privacy Settings will also provide you with the ability to opt out or into receiving personalised marketing.
• Contact our customer services team – see the contact us page;
• Click the link at the end of a marketing email or text to unsubscribe;
• Tell the adviser if you receive a marketing call;
• Disable push notification messages, including marketing messages, at any time in our apps by changing the notification settings on your device or by uninstalling the app;

Email dataprotection.ie@vodafone.com for guidance.

Opting out does not mean that you won’t any longer receive service-related messages. You will continue to receive those (unless we have indicated otherwise).

To opt out of receiving marketing communications from other Vodafone Group companies, just contact them directly.

In some cases, you may receive marketing from Vodafone, even if you’re not a customer or never had contact with Vodafone. This is a result of third-party marketing lists which Vodafone may acquire from time to time. If you’ve registered to opt out of such marketing, you shouldn’t receive such communications. If you do, we ask that you let us know immediately.
 

To manage Cookies and understand more about what they are

Want to disable a cookie, or understand more about what these are? Check the Cookies section of this notice for full details on how to do this.
 

How to lodge a complaint

If you want to contact us about any of your rights or to complain about how we use your information, contact our Customer Services team or email us at dataprotection.ie@vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact the Data Protection Commission. Contact details for the Data Protection Commissioner are:

• Email: info@dataprotection.ie
• Phone: +353 (1) 765 01 00 or 1800 437 737
• In writing: Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.