There are a range of Vodafone apps. This Privacy Statement also applies to those apps, but there will also be an additional Privacy Supplement provided with the app itself with more specific information. In those cases, both will apply. 

When you download or use a Vodafone app, information may be accessed from or stored on your device. This will let it operate and function as well as remember you.

To provide you with the service, communicate with you and to work to improve our services, we’ll need to collect information about your device (for example, type, unique identifiers, its operating system, if you’re using 3G or 4G, etc.), app ID and information about your use of the app. Additional information also may be collected to provide you with the requested service.

Each app will set out the preferences it requires to operate, some of which you may be able to opt out of in some cases.

Opting out of certain preferences may, however, affect the functionality of certain services and apps. For example, if you opt out of the location-based feature on your device, you may find that an app doesn’t operate.

It’s important to flag that, where you choose to download or use an app not operated by Vodafone, those apps are subject to their own terms of use and privacy and cookies policies. Make sure you’re familiar with those before downloading or using that app. We can’t be responsible for the security and content of such third-party apps.

This application collects information about the way your phone interacts with our network and services as described below. We hold this data securely and anonymously for 14 months, which lets us view and plan for seasonal variations of network use.

Network coverage

This application will capture statistics about your connectivity for phone calls. This allows us to diagnose connectivity or connection quality problems and make improvements to our network in your area. We log:

• the percentage of time your phone is on the network.
• the cell ID and location of the phone masts used and how you move between them, when your phone is active.
• signal strength areas of limited or no service.
• quality of the coverage (2G, 3G, 4G).

Internet connectivity

This application will capture statistics about your connectivity for internet or data coverage. This allows us to diagnose connectivity or connection quality problems. We log:

• every hour, a test of whether you can connect to the internet.
• your upload and download speed.
  
• the cell ID and location of the phone masts used and how you move between them, when your phone is active.
  
• areas of limited or no service.
  
• quality of the coverage.
  
• how long it takes to set up a connection to the internet.
  
• Wi-Fi quality.
• MAC addresses of the Wi-Fi hot spots your device can see

Call quality and usage

The success or failure of your calling experience can be diagnosed using technical details about the network, your coverage, or your phone’s signal quality during a call. This helps us improve all aspects of your calling experience. We log:

• the cell ID and location of phone masts serving your incoming and outgoing calls and other masts used if you change location during the call.
• signal strength.
• call duration.
• how the call ends.
• quality of the coverage.

Data usage

So that we can diagnose the overall usage of the internet data use on different phone models we capture information about how much your device use internet services and consume data. This helps us improve device and network data efficiency for you and other customers based on real world data usage. We log:

• hourly data use.
• how much data your phone uses when in standby mode.
• how much data goes over Wi-Fi connections vs. the cellular network.

Applications

So that we can identify trends in data usage that help us allocate capacity for data heavy applications in your area, we assess the data use of the applications on your phone. We log:

• what apps are installed on your phone.
• how long they are used.
• how much data and how fast each app receives and transmits.

Location

When we measure the items above related to coverage and usage, we know your rough location from the phone mast Wi-Fi hot spot your phone is using. When your phone or one of your apps is using GPS location data, we use that to assess location more precisely and sometimes speed if available with GPS information. This enables us to identify areas of weak coverage and This information will be used to improve poor performance for you and fellow customers.

Anonymisation of Information

The network and device improvements that this application is designed for do not require personal information. This means we do not log personal information, all network data is anonymised by the application before it is sent to Vodafone.

• This app does not log your phone number.
• This app does not log numbers you dial or that dial you.
• This app does not log any content of your communications.
• This app does not log content, sender or receiver information of text messages on your device.
• This app does not log the names of the Wi-Fi hot spots
  

Secure Net – Privacy Statement

This privacy supplement gives some additional information specific to Secure Net and the accompanying App.

Secure Net is a security product that provides additional protection when browsing on our mobile or fixed networks with any of your devices capable of connecting to the internet via these networks. It also allows you to manage your child’s access to the internet with a variety of parental controls.

For general information about how we process your data as part of providing mobile connectivity, you can view our main privacy policy here

Last updated: 20.09.2021

Who we are

We are Vodafone Ireland Limited and we are a member of the Vodafone Group.    

In this privacy statement: 

“Vodafone/we/us/our” means Vodafone Ireland Limited;  

“third party” means someone who is not you or us; 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.  

How to contact us

Your opinion matters to us. If you have any queries about our Privacy Statement or practices, please contact us.   

Our main switchboard is (01) 2037000 or you can email us at dataprotection.ie@vodafone.com     

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

Personal information we collect about you

Information we collect about you

The types of information we process about you and any devices you register with the service when you use Secure Net and the accompanying App are:

·       Your browsing activity on the network; Secure Net is a service that uses a process Domain Name System (DNS) Filtering on websites you are navigating to you in order to protect you from malicious sites and malware. This means for example, that if we know a certain website or app traffic has been blacklisted because it contains harmful content, we’ll warn you that you shouldn’t proceed to that site before you land on it. We do not use this information for other purposes;

·       Your phone number, tariff information and price plan;

·       Information about devices that are set up to be protected by Secure Net or to be subject to parental controls. For example, we collect information on the type of connected device that you are using (such as whether it’s a mobile device, a laptop, a gaming console or smart home devices, and their manufacturers) and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

·       If you activate the Secure Net cleaning tool, we will access data from your device to help remove security threats from your device;

·       The names or nicknames you add when creating family profiles;

·       If you are adding children’s profiles, we’ll ask for their age range – this is so we can restrict age-inappropriate content; and

·       Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services. This could be your Vodafone ID credentials if you set up your login via this method.

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

·       Details of your use of our services – for example, we can see whether or not a site has been blocked and keep a limited record of this information for service and customer care (see How long we keep your personal information for), or how often you interact with our online portal or App dashboard to see summaries of your threat protection or parental controls, or the sorts of parental controls you are setting; and

·       We also collect anonymous analytics information on how our customers use the Secure Net App or the online portal in order to improve your experience and troubleshoot (for example, we can see whether certain functionalities are not working as intended and fix them or how much our customers use the parental control functionalities).

When we collect your personal information

We collect your personal information when:

·       You browse the internet on a mobile or fixed connection with any of your devices when you have an active Secure Net subscription;

·       You activate and use the cleaning tool feature of the App.

·       You interact with the App or online Portal (where you can see what threats have been blocked or set any parental controls); and

·       When content is blocked as a result of the security protections or when a parental control limits access to certain content.

Vodafone will process your personal data based on:

1.           Vodafone’s legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, and improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business 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 policy.

2.           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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

3.           Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time. For example, we need your consent to process the content of your communications in order to detect and block any security threats.

We will require your consent in order to process your traffic and location data for value added services. If you allow people to use your connectivity services we may not be able to identify them (for example guest WIFI users or people using your ‘mobile hotspot’). Therefore, we will rely on the consent of the account holder who will then be responsible for informing users on how their traffic data will be processed when using services supplied to you.

Secure Net is an optional service, which you can deactivate at any time. To do so, you can navigate to the Secure Net portal at https://securenet.vodafone.ie or via the link sent to you in your welcome SMS or alternatively, you can contact our Customer Services team at 1907.

How we use your personal information

To provide you with your service
In order for us to protect you from security threats and to apply any parental control rules you may have set, we view your browsing activity in order to do so. We do not use this information for marketing or personalised profiling and it is retained for a limited period of time.

Profiling & automated decision making
Our threat monitoring is based on profiling and automated decisions; for example, websites we block are based on the intelligence we have gathered. You can, at any time, go into your portal or App and view why something has been blocked (for example, if it was malicious or contained malware). You can also customise which websites are limited when parental controls are on outside of the default list provided.

To improve our service
We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone.  None of these analytics are linked back to you in any way.

Service messages
From time to time we’ll send you monthly summaries of the threats that have been blocked. You can turn these off in your account settings if you no longer wish to receive them via the app notification settings or by contacting Vodafone customer services.

How we share your personal information

Where applicable, we share information about you with:

·       Companies in the Vodafone Group;

·       Partners, suppliers 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; or

·       A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

International data transfers

All data is stored in our data centres in Germany and in whichever local market of whom you are a customer.

How long we keep your personal information for

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.

Browsing history

We keep a limited record of your browsing history for service and customer care purposes only for 30 days. Vodafone does not repurpose your browsing for the purposes of marketing or personalised profiling.

·       For example, if you believe that we should not have blocked a site, we can check that for you; or

·       In order for you to be able to view a history of the protection provided (such as number of security threats blocked by the service) with the App or the Secure Net portal.

Keeping your personal information secure

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) 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.

Your rights

Here's how you can exercise your rights. If you have any questions, please contact our Customer Service.

Right to correct personal data
You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, or you think it may be inaccurate, you can log in to My Vodafone to update it (Login > My account) or contact our Customer Care.

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 download this form  and email or post it to the address on the form. Alternatively, you can contact the Customer Care on 1907.

Right to data portability
You have the right to be able to take with your 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. In order 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 information stored by the user into Vodafone’s cloud and hosting services, for example Backup+. For any queries send an email to dataprotection.ie@vodafone.com.

Right to object to use of personal data

In some cases you will have the right to object to use of personal data. Contact our Customer Care team on 1907 or email us at dataprotection.ie@vodafone.com

How to lodge a complaint
If you want to contact us about any of your rights or if complain about how we use your information, contact our Customer Care team at 1907 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  who may be contacted by email info@dataprotection.ie or by post to Data Protection Commission, Canal House, Station Road, Portarlington, or 32 AP23 Co Laois. 

Right to restrict use of your data
If you feel 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 with 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).  

If you believe that Vodafone is processing personal data that is not required, or no longer required for our business purposes, please complete the online form here to submit an erasure request.

Our cookie policy

Cookies are tiny text files that are stored on your computer, tablet or mobile phone when you visit a website. The cookies mean that the website will remember you and how you've used the site every time you come back.

Cookies themselves don't hold personal information such as your name or bank details. And in many cases, we won’t be able to link the information we collect by using a cookie back to you.  They can, however, help us to find information once you're logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service, white paper or newsletter. 

First party cookies

First party cookies originate from the same domain as the website you’re currently visiting. 

Controlling your cookies

You can control how you use cookies in your browser.  If you wish to restrict or block the cookies which are set by any website - including a Vodafone website, you should do this through the web browser settings for each web browser you use, on each device you use to access the internet.

Information on controlling and deleting cookies, including on a wide variety of browsers, is also available at allaboutcookies.org

Vodafone Secure Net is a service that offers protection against security threats including viruses, trojans, spyware, adware and unwanted programs. 

This supplement defines how your information is used by by Secure Net. Please go to privacy section to read Vodafone’s full privacy policy.

What information we collect

Please also refer to the full Vodafone Ireland privacy policy on this page.

Vodafone will collect and use your data, including usage statistics, to:

• Improve the service;
• Improve the security of the Vodafone Network; and
• Provide you with a higher level of security and protection whilst you are on the Vodafone Network.

For how long do you keep my personal data? 

Vodafone may retain aggregated and statistical reports that have been generated using your personal data and anonymised data for a longer period, but as these reports cannot identify you as a user, they cannot be used in a way that impacts your privacy.

Information security

Vodafone takes technical and organizational security measures as required by law and by industry standards to protect your personal data from unauthorized access, use or disclosure.  We take steps to ensure that we only use your personal information as described in this privacy notice and to honour the permission choices that you have made. We only partner with service providers who contract to provide the same level of information security that you can expect from Vodafone.

Who provides the service?

Vodafone Secure Net are provided solely by Vodafone Ireland Limited, registered in Ireland at Mountainview, Leopardstown, Dublin 18 under registered number 326967.

Vodafone Secure Net is a service that offers protection against security threats including viruses, trojans, spyware, adware and unwanted programs. Vodafone SecureNet Find & Ring operates as a complimentary service that helps locate your device. It requires access to your device’s location data.

This supplement defines how your information is used by by Secure Net and the complimentary Find & Ring feature. Please go to privacy section to read Vodafone’s full privacy policy.

What information we collect

In addition to your device location data, we will also ask you to enter your email address when first setting it up. This is for product registration so that we can activate Find and Ring.

Please also refer to the full Vodafone Ireland privacy policy on this page.

This is the email address we will use for account recovery. Make sure you keep your account details secure - this is essential for your privacy and security.

Vodafone will collect and use your data, including usage statistics, to:

• Improve the service;
• Improve the security of the Vodafone Network; and
• Provide you with a higher level of security and protection whilst you are on the Vodafone Network.

Location information - Secure Net Find & Ring only

Secure Net Find & Ring will only share location data with your separate permission if you choose to use the app. Secure Net Find & Ring locates your device by making use of the location data assessing the GPS location data, Wifi location data and the network location data that your device uses. This data is broadcast to Vodafone every 3 hours and when the battery is low on your device. 

Vodafone only uses the location data from Secure Net Find and Ring to locate your device on your request. We do not sell it or rent it out to third parties.

For how long do you keep my personal data? - (Secure Net Find & Ring only) 

Vodafone will retain your email address for as long as you continue to use Secure Net Find & Ring. Vodafone will retain the location data from your device for a maximum of 24 hours. After that time the data will be deleted and no location history is maintained.

Vodafone may retain aggregated and statistical reports that have been generated using your personal data and anonymised data for a longer period, but as these reports cannot identify you as a user, they cannot be used in a way that impacts your privacy.

Information security

Vodafone takes technical and organisational security measures as required by law and by industry standards to protect your personal data from unauthorised access, use or disclosure.  We take steps to ensure that we only use your personal information as described in this privacy notice and to honour the permission choices that you have made. We only partner with service providers who contract to provide the same level of information security that you can expect from Vodafone.

Who provides the service?

Vodafone Secure Net and Secure Net Find and Ring are provided solely by Vodafone Ireland Limited, registered in Ireland at Mountainview, Leopardstown, Dublin 18 under registered number 326967.

Every time you use your mobile phone, a record is kept. This includes the number you called or sent a text or picture message to, the length, date and time of a call, text or picture message 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. We don’t, however, keep a record of the content of your calls or messages.

We’ll also keep a record of the data you use. This will record things like how much you spend in or out of bundle, or in an app, to enable us to charge you the right amount on your next bill as well as other things such as alerting you if you are close to your usage limit, fix faults and send you service messages. We don’t keep a record of the content of any messages you send using your data.

As part of providing the service, we need to understand and manage traffic flows on the network. So this also means we require information about your data usage. This includes capturing IP addresses and traffic data such as the websites you’ve visited.  We’ll also have information about the Vodafone apps you use including location data. Having this information also means that we’re able to provide you with services that you request and work to improve them.

Capturing the websites you’ve visited doesn’t mean that we will have a history of your web-browsing as this is limited for a short real time period to enable the connection to be made. Details about websites visited may be stored for analytical purposes, such as counting the amount of times a specific web URL is visited, but this is only captured in a generic format and cannot be linked back to individual customers.  For more information on your browsing history, see our Cookies Policy.

To help us provide you with services and work to improve them, we need to understand how you use your mobile. This means that we’ll have certain information about your device such as its make and model, the device ID, which operating system it uses, and if you’re using 3G or 4G.

It’s important to flag to you that third-party content providers like Spotify, and Sky Sports will have their own terms of use, and privacy and cookies policies that apply to you when you access their content on your mobile. Make sure you’re familiar with these and understand how they use your information before downloading or using their services.

As part of providing this service, we need to understand and manage traffic flows on the network.

To do this, we need information about your broadband usage. This includes capturing IP addresses and traffic data such as the websites you’ve visited. We’ll also have information about the Vodafone apps that you use. Having this information means we’re able to provide you with services that you request and work to improve them.

Capturing the websites you’ve visited doesn’t mean that we will have a history of your web-browsing as this is limited for a short real time period to enable the connection to be made. Details about websites visited may be stored for analytical purposes, such as counting the amount of times a specific web URL is visited, but this is only captured in a generic format and cannot be linked back to individual customers.  For more information on your browsing history, see the cookies policy.

For more information on using apps, see the app section above.

It’s important to flag that third-party content providers such as Spotify and Sky Sports will have their own terms of use and privacy and cookies policies that apply when you access their content using broadband. Make sure you’re informed on these and understand how your information is used before downloading or using their services.

If you watch TV through the Vodafone TV app, please also read the Apps section on this page.

It’s important to flag that certain content providers may have their own terms of use and privacy and cookies policies that may apply to you when you access their content. Content providers include, for example, Netflix, iPlayer. You should check these on their websites to be sure you’re informed on and understand how your information is used.

Vodafone wants you to receive the most benefit from your TV service with us.

In order to be able to provide you with our TV service, and to continually improve it, we need to collect information about how you watch TV. We can do this using the Vodafone TV Box or the Vodafone TV app on your devices. For example, we’ll collect information about what you watch (which may include adverts), how long you watched it for and what you did such as pausing, recording, fast-forwarding, etc.

We’ll collect information about what you used to watch it (such as which Vodafone TV Box or which device) and where you watched it (location data, time zones, etc.). We’ll know what you downloaded or purchased. We’ll also know, for example, the IP addresses for any devices, device IDs and/or unique identifiers, your user IDs and passwords, any device parental control or purchase PIN codes. Your devices such as your Vodafone TV Box will tell us about your use of the services and third-party content, products and services.

We also use the information we collect to be able to charge you the right amount on your next bill (for example, where you have rented a film or have elected to charge Netflix to your Vodafone bill) as well as other things such as fix faults and send you service messages.

We’ll use the information to be able to provide you with localised content, to send you viewing recommendations and analyse what you watched so that we can enhance our services further.

We’ll also use the information to provide reports to third parties such as content providers and advertisers. These reports won’t contain information that may identify you.

We may use the information you provide us to contact you about offers and promotions including competitions, prize draws and surveys based on how you use our products and services.

We may also contact you to let you know about products and services of Vodafone, Vodafone Group companies and those of other companies which we think may interest you.

We may tailor or personalise the marketing message and its content based on the information you’ve provided to us and your use of Vodafone’s website, products and services.

We’ll assume that you’re comfortable to receive these messages unless you tell us otherwise. We’ll contact you by post, online, phone or push notifications through our apps.

For more information on online advertising, see the Advertising Online section below.

We use a variety of analytics methods, which involve mathematically driven analysis techniques where large and varied data sets uncover hidden patterns and previously unrevealed trends. At Vodafone we take governance of 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 at the appropriate stage in the process so that it is no longer possible to identify an individual.

How to opt out

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, text, phone or post).

There are various ways to opt out:

• Contact our customer services team – see the contact us page;
• Click the link at the end of a marketing email or text to unsubscribe;
• 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 receive service-related messages anymore. You will still 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 by contacting us on 1800200234 or (01)2527218.

To deliver advertising that is relevant to you, you’ll also see targeted advertising online based on the use of cookies. This is known as interest-based advertising.  We may also combine data collected via the cookies with other data we have collected.

You’ll also receive direct marketing based on use of cookies. If you don't want any information processed through the use of cookies, check our cookies policy. It explains how to control and opt out of cookies.

Remember that opting out of interest-based advertising won’t stop advertisements from being displayed – but they won’t be tailored to your interests. 

This privacy supplement gives some additional information specific to the OneNumber service and explains how Vodafone process your data to provide you with such service.

For general information about how we process your data as part of providing mobile connectivity, you can view our main privacy policy here

What is OneNumber?

OneNumber Connectivity Plans provide the ability to share Vodafone airtime and data allowances across multiple devices, you can stay connected to Vodafone’s network on other connected eligible devices, including smartwatches, tablets or Alexa device without WiFi or your phone nearby. To be eligible for OneNumber, you must have a pay monthly plan with us.

Last updated: 26th June 2023

Who we are

We are Vodafone Ireland. We are a member of the Vodafone Group.
In this privacy policy:

• “we/us” means Vodafone Ireland;
• “third party” means someone who is not you or us; 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 lead supervisory authority is the Data Protection Commissioner.

• Email: info@dataprotection.ie
• Phone: +353 (0)57 868 4757 or +353 (0)761 104 800
• In writing: Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.
  
• How to contact us
  Your opinion matters to us – if you have any queries about our Privacy Statement or practices, please contact us.
  Our main switchboard is (01) 2037000.
  You may contact our Data Protection Officer by email at dataprotection.ie@vodafone.com or writing to:
  
  Data Protection Officer
  Vodafone Ireland
  Mountain View
  Leopardstown
  Dublin 18
  Ireland
   

Information we collect about you:

• Your contact details, such as your phone number,
  
• Cookies: functional, performance and strictly necessary cookies, please see more details in the Cookies Policy section.
• Data about the Device and SIM: IMSI (International Mobile Subscriber Identity), MSISDN from the device (phone number), make and model from the device.  

When we collect your personal information:

We collect your personal information when:

• We collect your mobile phone number that you use to authenticate yourself. We don’t collect names, addresses or email addresses from your device but we do need access to certain browser attributes (see our Cookie Policy).
• We collect some information about your device and your use of Vodafone OneNumber (for example, language, equipment and usage statistics).
• We’ll share some information with your Vodafone carriers and partners, and get some information back from them: your mobile number and other information about your tariff and the eligible services available to you.
  

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

• Details of your use of our services – for example, we can see whether our customers are actively using the service.
• We also collect aggregated analytics information on how our customers use OneNumber in order to improve your experience and troubleshoot.  

Vodafone will process your personal data based on:

1. Vodafone’s legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, and improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business 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 policy.
2. Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time. For example, we need your consent to process your data for marketing purposes.
   
3. Performance of your contract or to enter into the contract and to take action on your requests. For example, we process your account information and payment details for monthly billing of the service associated with the airtime plan.
    

To provide you with your service
In order for us to provide you with the OneNumber service we are required to process your data to manage such subscription and additional service to the primary airtime plan.

To improve our service
We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone. None of these analytics are linked back to you in any way.

Marketing & profiling

If you are eligible for the OneNumber service with an eligible plan, but are yet to complete the user journey, based on your marketing consent, we may contact you to provide value added service for OneNumber.
To opt out of Marketing messages or profiling:
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, messaging, phone or post).

To opt out of Marketing messages or profiling: 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, messaging, phone or post).

There are various ways to opt out:

·       If you are a Vodafone consumer mobile customer, you can log in to your My Vodafone account, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

·       All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·       Tell the adviser if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

Where applicable, we share information about you with:

• Companies in the Vodafone Group;
• Partners, suppliers 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; or
• A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

Personal data will be stored on the OneNumber platform for 60 days to facilitate subscription and managing of additional services on a primary mobile contract after which we will store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested.

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. Once these periods have expired, we’ll delete that information.

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) 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.
 

Here's how you can exercise your rights. If you have any questions, please contact our Customer Service.

Right to correct personal data
You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, 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 on 1907.

Right to access personal data
Want a copy of the personal information we hold on you? You can do this by contacting Customer Care on 1907 or on our website. We will take all reasonable steps to confirm your identity before issuing any copy of your personal information.

Right to data portability
You have a right to receive a copy of all personal information that you consented to provide to us, or have provided to us as part of your contract with us. Please contact our Customer Services team on 1907.

Right to object to use of personal data
In some cases you will have the right to object to use of personal data. If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234.

Right to erasure
You have a right to request the erasure of your personal information which we hold about you where the personal information is no longer necessary, where you have withdrawn your consent or where you feel that there is no lawful reason for us to process your personal information.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.
 

Right to restrict use of your data
If you wish to restrict the use of your data by Vodafone, please contact our Customer Services team on 1907. It is helpful to let us know the reason for your restriction request.

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

 ·                Email: info@dataprotection.ie

·                Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

·                In writing: Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Our cookie and tracking technologies policy

This section is about what cookies and other tracking technologies are, how we use them and how you can manage them.

What are cookies?
Cookies are small files that are stored on your device when you visit a website. The cookies mean that the website will remember you and how you've used the site every time you come back.
If you want to know more about cookies, head to aboutcookies.org or allaboutcookies.org (please note: these links open a new window or browser tab).

What are other similar tracking technologies?
This refers to any other method used to store information, gain access to information, or track activities on your device, such as Local Shared Objects (“flash cookies”), scripts, tracking pixels and plugins, app trackers (including SDKs) on smartphones, tablets, smart TVs or other devices.

How we use cookies/tracking technologies
We use cookies and other similar tracking technologies to do a number of things. For example, remembering your preferences, recording what you've put in your shopping basket, or counting the number of people looking at a website. We also use them to keep track of what you've bought from us, what you've done on the site, and to make online advertising more relevant to you.

Cookies usually comprise of unique alphanumeric identifier that sits on your browser. In some cases, we won’t be able to link the information we collect by using a cookie back to you. They can, however, enable us to link that information back to you and your personal information, for example, when you log in, or choose to register for a service, or newsletter. We may also use cookies in order to provide you with personalised adverts based on your browsing behaviour.
We've put our cookies into the following categories, to make it easier for you to understand why we need them:

1. Strictly necessary – these are used to help make our website work efficiently
2. Performance – these are used to analyse the way our website works and how we can improve it
3. Functionality – these help to enhance your experience by doing things like remembering products you've added to your basket.
4. Targeting/advertising – these are used to share some information with third parties who we advertise with, so we know how you've reached our website. We can also use cookies to identify the parts of the website you’re interested in. We then use this information to show you adverts and pages we think may also be of interest to you, to tailor how we communicate with you, or to tailor the contents of the communications we send to you. If you prefer, you can opt out of these. Tailoring of content means it includes information reflecting the interest you’ve shown in the content of our web pages, or offers or promotions that we think may interest you, and to improve how we respond to your needs.
   

In addition to the cookies we use on our websites, we also use cookies and similar technologies in some emails and push notifications we send to mobile devices from our apps. These help us to understand whether you have opened the email and how you have interacted with it. If you have enabled images, cookies may be set on your computer or mobile device. Cookies will also be set if you click on any link within the email.

We sometimes use persistent cookies as well as 'session-based' cookies. A 'persistent' cookie will remain for a period of time set for that cookie. A 'session-based' cookie is allocated only for the duration of your visit to our website and automatically expires when you close down your browser.

First-party cookies

First-party cookies originate from the same domain as the website you’re currently visiting (in this case, vodafone.co.uk).
See our list of first-party cookies (shown later on in this cookies policy).

Third-party cookies are not used in association with the OneNumber website.

Controlling your cookies
You can manage your cookie preferences by accessing the preference centre below;

Consent Preferences
You can also control how you use cookies in your browser or your device settings. Information on controlling and deleting cookies is also available at http://allaboutcookies.org

V by Vodafone – Privacy Statement

This privacy statement explains the information that is collected by Vodafone through the connectivity services we provide to your Connected Devices (‘Connected Devices’) and how this data will be processed. Connected Devices are those that are compatible with a V-Sim. You can view this statement, and the statement for our Connected Devices in the Settings Menu of the App at any time.

Some of our products are developed in partnership with specific third party partners, who will process your personal data as a data controller in their own right.

·       V-Pet, in partnership with Kippy or POD

·       V-Bag and V-Kids Watch in partnership with Alcatel

·       V-Camera, in partnership with Arlo.

·       V-Luggage and V-Mini, in partnership with Trackimo.

We take the privacy of our users very seriously. We ask that you read this privacy statement carefully as it contains important information about how we will use your personal data.

Changes to our privacy policy

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and let you know.

We have recently revised our Privacy Statement for this App and Service; the main changes are listed below.

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

·       “we/us” means Vodafone Ireland Ltd.;

·       “third party” means someone who is not you or us; 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 Vodafone Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us – if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer
Vodafone Ireland
Mountain View
Leopardstown
Dublin 18
Ireland

Information we collect about you

The types of information we process about you when you use your Connected Devices are:

·       Your Connected Device-generated data where it’s been provided by our partners (see Third party sources of data);

·       Your account information, such as the number of products you have with us and dates of payment owed or received;

·       Your preferences for particular products or services when you tell us what they are, or we assume what they are, based on how you use the products and services (see Marketing & profiling);

·       Customer care information through your contact with us, such as a note or recording of a call you make to one of our contact centres;

·       Information about the V-Sim connectivity we provide for Connected Devices, such as the data connections performed and the amount of data consumed;

·       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. 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.

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; and

·       Details of your use of our services – for example, we can see the amount of data your devices are using which we can use to assess what sorts of data allowances we need to provide for different Connected Devices.

When we collect your personal information

We collect your personal information when:

·       You use any of your Connected Devices;

·       Device or app-generated data has been provided by our partners (see Third party sources of data);

·       You subscribe to marketing; or

·       You contact our customer care teams with a question or complaint.

Third party sources of data

Given that our customer care teams act of your one-stop-shop for queries and issues around your Connected Devices, we share limited personal data between Vodafone and the partners whose products you have purchased in order for us to achieve this. For example, we may need to share the fact that your device isn’t working or that we needed to reset it with the partner in question.

If you have given us your permission, we also receive your Connected Device’s Service Data from our partners in order to profile you and tailor our communications to you. For example, if we can see that you regularly use a product we might think you want to hear about our others. You can adjust your privacy preferences at any time; see Marketing and profiling for more details.

Where necessary, we collect information from certain organisations. These include fraud-prevention agencies, business directories and credit reference agencies.

Vodafone will process your personal data based on:

1.           The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your network traffic data as part of making your devices “connected” and we’ll need to process your payment details for your monthly billing.

2.           Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.           Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

1. To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       to help us identify you and any accounts you hold with us;

·       to provide you with the connectivity you have requested for your Connected Devices;

·       billing and customer care; and

·       identity verification.

2. Marketing & profiling

If you are opted into marketing and have given us permission to use your data to tailor these communications, we’ll use your purchasing preferences and data from your Connected Devices to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, if we can see that you have purchased V-Pet, we can make sure we don’t market that product to you.

To opt out of Marketing messages or profiling:

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, messaging, phone or post). 

There are various ways to opt out:

·       If you are a Vodafone consumer mobile customer, you can log in to your My Vodafone account, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

·       For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

·       Contact our customer services team via v.vodafone.com;

·       All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·       Tell the adviser if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

3. Other profiling and automated processing

Outside of the profiling we conduct for marketing purposes to tailor and personalise the communications we send, we also profile you for credit, fraud and security purposes.

This can sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others. The goal is to make the decisions as quick, efficient, fair and correct as possible, based on what we know.  It can affect the products or services we may offer you now or in the future.

We will process your personal data in order to protect against and detect fraud, and to recover debts or trace those who owe us money resulting from the use of our services.

4. Service improvement

·       We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone.  None of these analytics are linked back to you in any way.

·       To 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; and

·       To 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.

Where applicable, we share information about you with:

·       Companies in the Vodafone Group;

·       Partners, suppliers 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; or

·       A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

We also share aggregate performance information with third party V by Vodafone partners to understand how products and the V by Vodafone offering is performing commercially. For example, if we know that certain products are selling well, we can focus on partnering with more partners that cater to the market. This information does not identify you personally.

If you are a non-Vodafone consumer mobile customer and we need to verify your identity, we will need to transfer your data to our service provider, which is based in India. Additionally our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India and Romania.

When Vodafone sends your information to a country that is not in the EEA, we 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 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) 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.

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our Customer Services team via v.vodafone.com.

Right to correct personal data
If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data
If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability
You can submit a portability request by this by logging into your My Vodafone account.
You will receive your information in a digital, machine-readable format.

Right to object to use of personal data
·       If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

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

·                Email: info@dataprotection.ie

·                Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

·                In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data
If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

This privacy statement (‘Statement’) explains the information that is collected by Vodafone when you use this website and purchase products and services through our online store. You can view the privacy statements for our connected products within their respective apps.

Our website contains links to other websites. This privacy statement applies only to this website so when you access links to other websites you should read their own privacy policies.

We take the privacy of our users very seriously. We ask that you read this privacy statement carefully as it contains important information about how we will use your personal data.

Changes to our privacy policy

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and we’ll communicate any material changes.

We have recently revised our Privacy Statement for this website; the main changes are listed below.

 Who we are
We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

• “we/us” means Vodafone Ireland Ltd.;
• “third party” means someone who is not you or us; 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 Vodafone Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us – if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer
Vodafone Ireland
Mountain View
Leopardstown
Dublin 18
Ireland

Personal information we collect about you

Information we collect about you

The types of information we process about you when you use this site are:

·       Your contact details, such as name, address, phone number, and email address;

·       Your payment details, such as credit or debit card information and banking information;

·       The types of products you have purchased;

·       Any contact you have with us such as calls to us or if you email us; and

·       Your website browsing information, such as how you are using our website or your IP address.

When we collect your personal information

We can collect your personal data when you:

·       Visit or browse this website;

·       Purchase products and services from us;

·       Register your interest for future products and services; or

·       Contact us with a complaint or query.

Third party sources of data

Where necessary, we collect information from certain organisations. These include fraud-prevention agencies, business directories and credit reference agencies.

Vodafone will process your personal data based on:

1.           The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your payment details and billing address to be able to fulfil your purchase and send you your hardware.

2.           Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.           Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

How we use your personal information

1. To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       To process the products and services you’ve bought from us, and keep you updated with the progress of your order;

·       To bill you for using our products and services, or to take the appropriate amount of credit from you;

·       Contact you if the billing information you provided us with is about to expire or we’re not able to take payment;

·       To respond to any questions or concerns you may have about our network, products or services; and

·       We will contact you with customer service messages to keep you updated with current information about products and services you’ve purchased. For example, changes to our terms and conditions, or letting you know about the status of your order.

2. Marketing and profiling

If you are opted into marketing and given us permission to use your data to tailor these communications, we’ll use your interactions with this site to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, if we can see that you have purchased V-Pet, we can make sure we don’t market that product to you.

To opt out of Marketing messages or profiling:

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, messaging, phone or post). 

There are various ways to opt out:

·       If you are a Vodafone consumer mobile customer, you can log in to your My Vodafone account, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

·       For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

·       Contact our customer services team via v.vodafone.com;

·       All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·       Tell the adviser if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

3. Other profiling

Outside of the profiling we conduct for marketing purposes to tailor and personalise the communications we send, we also profile you for credit, fraud and security purposes.

This can sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others. The goal is to make the decisions as quick, efficient, fair and correct as possible, based on what we know.  It can affect the products or services we may offer you now or in the future.

·       We will carry out a credit check when you apply for a contract for your products and services with us. Information on credit checks is included in our Privacy Policy.

·       If you are not already a Vodafone customer, we will use your personal information for identity verification purposes. We sometimes supplement the information we collect about you with information from other sources (such as the electoral roll) This will be prompted to you on first registration of a connected device within the V by Vodafone or V Auto apps. We also use this verification for access to your account and for general account management. However, this identity verification process is supported by human agents that will verify the output of the automated decision.

·       We will process your personal data in order to protect against and detect fraud, and to recover debts or trace those who owe us money resulting from the use of our services.

How we share your personal information

Where applicable, we share information about you with:

·       Companies in the Vodafone Group;

·       Partners, suppliers 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; or

·       A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

We also share aggregate performance information with third party V by Vodafone partners to understand how products and the V by Vodafone offering is performing commercially. For example, if we know that certain products are selling well, we can focus on delivering more of the same. This information does not identify you personally.

International data transfers

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.

How long we keep your personal information for

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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. Once these bases have expired, we’ll delete that information.

Keeping your personal information secure

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) 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.

Your rights

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our Customer Services team via v.vodafone.com.

Right to correct personal data
If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data
If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability
You can submit a portability request by this by logging into your My Vodafone account.

You will receive your information in a digital, machine-readable format.

Right to object to use of personal data

·       If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

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

·                Email: info@dataprotection.ie

·                Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

·                In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data

If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

Our cookie policy

A cookie is a small text file which is placed onto your mobile (or other electronic device) when you access our website. More information also available at https://www.vodafone.ie/content?id=BAU026375&v=2

The table below is designed to provide more information about the cookies we use and why:

 This privacy statement explains the information that is collected by Vodafone through the connectivity services we provide to your Connected Devices (‘Connected Devices’) and how this data will be processed. Connected Devices are those that are compatible with a V-Sim. You can view this statement, and the statement for our Connected Devices in the Settings Menu of the App at any time.

Some of our products are developed in partnership with specific third party partners, who will process your personal data as a data controller in their own right.

·      V-Pet, in partnership with Kippyor POD

·      V-Bag and V-Kids Watch in partnership with  Alcatel.

·      V-Camera, in partnership with Arlo.

·      V-Luggage and V-Multi Tracker in partnership with Trackimo.

We take the privacy of our users very seriously. We ask that you read this privacy statement carefully as it contains important information about how we will use your personal data.

Changes to our privacy policy

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and let you know.

We have recently revised our Privacy Statement for this App and Service; the main changes are listed below. 

Last updated: [05/11/2018]

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

·      “we/us”means Vodafone Ireland Ltd.;

·      “third party”means someone who is not you or us; 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 Vodafone Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us –if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer
Vodafone Ireland
Mountain View
Leopardstown
Dublin 18
Ireland

Personal information we collect about you

Information we collect about you

The types of information we process about you when you use your Connected Devices are:

·      Your Connected Device-generated data where it’s been provided by our partners (see Third party sources of data);

·      Your account information, such as the number of products you have with us and dates of payment owed or received; 

·      Your preferences for particular products or services when you tell us what they are, or we assume what they are, based on how you use the products and services (see Marketing & profiling);

·      Customer care information through your contact with us, such as a note or recording of a call you make to one of our contact centres;

·      Information about the V-Sim connectivity we provide for Connected Devices, such as the data connections performed and the amount of data consumed;

·      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. 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.

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; and

·      Details of your use of our services – for example, we can see the amount of data your devices are using which we can use to assess what sorts of data allowances we need to provide for different Connected Devices.

When we collect your personal information

We collect your personal information when:

·      You use any of your Connected Devices;

·      Device or app-generated data has been provided by our partners (see Third party sources of data);

·      You subscribe to marketing; or

·      You contact our customer care teams with a question or complaint.

Third party sources of data

Given that our customer care teams act of your one-stop-shop for queries and issues around your Connected Devices, we share limited personal data between Vodafone and the partners whose products you have purchased in order for us to achieve this. For example, we may need to share the fact that your device isn’t working or that we needed to reset it with the partner in question.

If you have given us your permission, we also receive your Connected Device’s Service Data from our partners in order to profile you and tailor our communications to you. For example, if we can see that you regularly use a product we might think you want to hear about our others. You can adjust your privacy preferences at any time; see Marketing and profiling for more details.

Where necessary, we collect information from certain organisations. These include fraud-prevention agencies, business directories and credit reference agencies.

Vodafone will process your personal data based on:

1.          The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your network traffic data as part of making your devices “connected” and we’ll need to process your payment details for your monthly billing.

2.          Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.          Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

How we use your personal information

1. To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       to help us identify you and any accounts you hold with us;

·       to provide you with the connectivity you have requested for your Connected Devices;

·       billing and customer care; and

·       identity verification.

2. Marketing & profiling

If you are opted into marketing and have given us permission to use your data to tailor these communications, we’ll use your purchasing preferences and data from your Connected Devices to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, if we can see that you have purchased V-Pet, we can make sure we don’t market that product to you.

To opt out of Marketing messages or profiling:

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, messaging, phone or post).  

There are various ways to opt out:

·       If you are a Vodafone consumer mobile customer, you can log in to your My Vodafone account, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

·       For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

·       Contact our customer services team via v.vodafone.com;

·       All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·       Tell the adviser if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

3. Other profiling and automated processing

Outside of the profiling we conduct for marketing purposes to tailor and personalise the communications we send, we also profile you for credit, fraud and security purposes. 

This can sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others. The goal is to make the decisions as quick, efficient, fair and correct as possible, based on what we know.  It can affect the products or services we may offer you now or in the future.

We will process your personal data in order to protect against and detect fraud, and to recover debts or trace those who owe us money resulting from the use of our services.

4. Service improvement

·      We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone.  None of these analytics are linked back to you in any way.

·      To 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; and

·      To 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.

How we share your personal information

Where applicable, we share information about you with:

·      Companies in the Vodafone Group;

·      Partners, suppliers 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; or

·      A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

We also share aggregate performance information with third party V by Vodafone partners to understand how products and the V by Vodafone offering is performing commercially. For example, if we know that certain products are selling well, we can focus on partnering with more partners that cater to the market. This information does not identify you personally.

[ACCORDION] International data transfers

If you are a non-Vodafone consumer mobile customer and we need to verify your identity, we will need to transfer your data to our service provider, which is based in India. Additionally our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India and Romania.

When Vodafone sends your information to a country that is not in the EEA, we 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.

How long we keep your personal information for

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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. Once these bases have expired, we’ll delete that information.

Keeping your personal information secure

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) 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.

Your rights

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our Customer Services team via v.vodafone.com.

Right to correct personal data
If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data
If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability
You can submit a portability request by this by logging into your My Vodafone account.
You will receive your information in a digital, machine-readable format.

Right to object to use of personal data
·       If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

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

·                Email: info@dataprotection.ie

·                Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

·                In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data
If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

This privacy statement explains the information that is collected by Vodafone through the V by Vodafone application (‘App’). We have privacy statements for our respective Connected Devices that we will present to you as you add a new device to your account. You can view this statement, and the statement for our Connected Devices in the Settings Menu of the App at any time.

Changes to our privacy policy

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and let you know.

We have recently revised our Privacy Statement for this App and Service; the main changes are listed below.

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

• “we/us” means Vodafone Ireland Ltd.;
• “third party” means someone who is not you or us; 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 Vodafone Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us – if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer

Vodafone Ireland

Mountain View

Leopardstown

Dublin 18

Ireland

Personal information we collect about you

Information we collect about you

The types of information we process about you when you use your V by Vodafone App are:

·       Your name, address, mobile number, date of birth and email address;

·       If we need to verify your identity, documentation such as a passport or other identification;

·       Your account information, such as the number of connected SIMs you have with us and dates of payment owed or received;

·       Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;

·       Any photos you upload to personalise your Connected Devices’ accounts;

·       Your preferences for particular products or services when you tell us what they are, or we assume what they are, based on how you use the products and services (see Marketing & profiling);

·       Customer care information through your contact with us, such as a note or recording of a call you make to one of our contact centres;

·       Information about your mobile device each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

·       Information about your usage of the App, such as how often you use it; and

·       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. 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.

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 our services – for example, we can see the amount of data your devices are using which we can use to assess what sorts of data allowances we need to provide for different Connected Devices; and

·       We also collect anonymous analytics information on how our customers use the V by Vodafone App in order to improve your experience and troubleshoot.

When we collect your personal information

We collect your personal information when:

·       You buy a connected product from us (online, or in store);

·       You first register your Connected Device product in the V by Vodafone App;

·       If you’re a non-Vodafone customer, when we verify your identity and you add your payment details;

·       You grant the App access to your camera (for taking pictures for ID verification) or your device’s photo album (if you want to add personalised pictures to your Connected Devices’ accounts);

·       You use the V by Vodafone Application; or

·       You subscribe to marketing.

Third party sources of data

Where necessary, we collect information from certain organisations. These include fraud-prevention agencies, business directories and credit reference agencies.

Vodafone will process your personal data based on:

1.           The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your payment details for your monthly billing.

2.           Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.           Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

How we use your personal information

1. To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       to help us identify you and any accounts you hold with us;

·       billing and customer care;

·       to notify you of any changes to the App or to our services that may affect you; and

·       identity verification.

2. Marketing & profiling

If you are opted into marketing and given us permission to use your data to tailor these communications, we’ll use your interactions with this App and data from your Connected Devices to inform the sorts of marketing we should be sending you so that it’s the most relevant for you.

To opt out of Marketing messages or profiling:

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, messaging, phone or post). 

There are various ways to opt out:

·       If you are a Vodafone consumer mobile customer, you can log in to your My Vodafone account, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

·       For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

·       Contact our customer services team via v.vodafone.com;

·       All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·       Tell the adviser if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

3. Other profiling and automated processing

Outside of the profiling we conduct for marketing purposes to tailor and personalise the communications we send, we also profile you for credit, fraud and security purposes.

This can sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others. The goal is to make the decisions as quick, efficient, fair and correct as possible, based on what we know.  It can affect the products or services we may offer you now or in the future.

·       We will carry out a credit check when you apply for a contract for your products and services with us. Information on credit checks is included in our Privacy Policy.

·       If you are not already a Vodafone customer, we will use your personal information for identity verification purposes. We sometimes supplement the information we collect about you with information from other sources (such as the electoral roll). This will be prompted to you on first registration of a connected device within the V by Vodafone or V Auto apps. We also use this verification for access to your account and for general account management. However, this identity verification process is supported by human agents that will verify the output of the automated decision.

·       We will process your personal data in order to protect against and detect fraud, and to recover debts or trace those who owe us money resulting from the use of our services.

4. Service improvement

·       We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone. None of these analytics are linked back to you in any way.

·       To 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; and

·       To 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.

How we share your personal information

Where applicable, we share information about you with:

·       Companies in the Vodafone Group;

·       Partners, suppliers 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; or

·       A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

We also share aggregate performance information with third party V by Vodafone partners to understand how products and the V by Vodafone offering is performing commercially. For example, if we know that certain products are selling well, we can focus on partnering with more partners that cater to the market. This information does not identify you personally.

 International data transfers

If you are a non-Vodafone customer and we need to verify your identity, we will need to transfer your data to our service provider, which is based in India. Additionally our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India and Romania.

When Vodafone sends your information to a country that is not in the EEA, we 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.

How long we keep your personal information for

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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. Once these bases have expired, we’ll delete that information.

Keeping your personal information secure

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) 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.

Your rights

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our Customer Services team via v.vodafone.com.

Right to correct personal data
If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data
If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability

You can submit a portability request by this by logging into your My Vodafone account.

You will receive your information in a digital, machine-readable format.

Right to object to use of personal data

·       If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

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

·                Email: info@dataprotection.ie

·                Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

·                In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data

If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

Our cookie policy

A cookie is a small text file which is placed onto your mobile (or other electronic device) when you access our App. We use cookies on our App to recognise you whenever you visit the App (this speeds up your access to the App as you do not have to log on each time).

Description of cookies

The table below is designed to provide more information about the cookies we use and why:

This privacy statement explains the information that is collected by Vodafone through the V Auto application (‘App’) and as part of delivering connectivity and services via your V-Auto device (‘Connected Device’) and how this data will be processed. 

We take the privacy of our users very seriously. We ask that you read this privacy statement carefully as it contains important information about how we will use your personal data.

Changes to our privacy policy

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and let you know.

We have recently revised our Privacy Statement for this App and Service; the main changes are listed below. 

Last updated:17/07/2019

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

·      “we/us”means [Vodafone Ireland Ltd.;

·       “third party”means someone who is not you or us; 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 Vodafone Ireland, Mountain View, Leopardstown, Dublin 18. 

We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

V-Auto is powered by our processor, Vodafone Automotive Italia SpA.

How to contact us

Your opinion matters to us –if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer

Vodafone Ireland
Mountain View
Leopardstown
Dublin 18
Ireland

Personal information we collect about you

Information we collect about you

The types of information we process about you when you use your Connected Device and the V-Auto App are:

·       Your name, address, mobile number, date of birth and email address;

·       If we need to verify your identity, documentation such as a passport or other identification;

·       Your account information, such as the number of products you have with us, dates of payment owed or received and the make, model and year of the vehicle you have; 

·       Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;

·       Your preferences for particular products or services when you tell us what they are, or we assume what they are, based on how you use the products and services;

·       Customer care information through your contact with us, such as a note or recording of a call you make to one of our contact centres;

·       Information about your mobile device each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

·       Information about the V-Sim connectivity, such as the data connections performed and the amount of data consumed, as well as information about the V-Auto device the V-Sim is in;

·       Information about your usage of the App, such as how often you use it;

·       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; and

·       Your driving information such as:

o  your trips, so that we can show them to you in the app; and

o  your acceleration, braking, driving speed and other driving indicators, so that we can give you feedback on how to make your driving safer and calculate your driving score.

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 our services – for example, we can see the amount of data your device is using which we can use to assess whether our data allowances are sufficient; and

·       We also collect anonymous analytics information on how our customers use the V-Auto App in order to improve your experience and troubleshoot. 

When we collect your personal information

We collect your personal information when:

• You buy a connected product from us (online, or in store);
• You first register your Connected Device product in the V-Auto App;
• If you’re a non-Vodafone customer, when we verify your identity and you add your payment details;
• You use the V-Auto Application and any of its features (such as Find my Car, Auto SOS, My Trips, and Driver Safety Score);
• You activate and drive with the V-Auto device installed in your vehicle;
• Where a user has nominated you as an additional user to the V-auto product;
• You subscribe to marketing; or
• You contact our customer care teams with a question or complaint.

Third party sources of data

Where necessary, we collect information from certain organisations. These include fraud-prevention agencies, business directories and credit reference agencies.

Where we have partnered with any third parties for promotions or offers you have participated in, we will share aggregate information between us and these parties to measure the success of the initiative.

Vodafone will process your personal data based on:

1.          The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your network traffic data as part of making your V-Auto device “connected” and we’ll need to process your payment details for your monthly billing.

2.          Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.          Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

How we use your personal information

1. To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       to help us identify you and any accounts you hold with us;

·       to provide you with connectivity for your V-Auto device and its functionalities such as Find my Car, Auto SOS, My Trips, and Driver Safety Score;

·       billing and customer care;

·       to notify you of any changes to the App or to our services that may affect you; and

·       identity verification.

2. Marketing & profiling

If you are opted into marketing and have given us permission to use your data to tailor these communications, we’ll use your interactions with this App and the data from your V-Auto device to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, if we can see that you have purchased V-Pet, we can make sure we don’t market that product to you.

To opt out of Marketing messages or profiling:

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, messaging, phone or post).  

There are various ways to opt out:

·      If you are a Vodafone consumer mobile customer, you can log in to your MyVodafone account to manage your marketing permissions and to opt out or into receiving personalised marketing. For customers without a Vodafone mobile number, you can manage your permissions in the V-Auto App.

·      Contact our customer care team via v.vodafone.com; 

·      All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·      Tell the adviser if you receive an outbound marketing call;

·      Email [data.protection.ie@vodafone.com] for guidance.

Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

3. Other profiling and automated processing

Outside of the profiling we conduct for marketing purposes to tailor and personalise the communications we send, we use automated processing to generate the insights behind the key functionalities of the App. For example, we:

·      create a driving score for you. This is based on a number of data inputs such as your acceleration, speed and deceleration; and

·      provide you contextual information. For example, in the status screen you’ll get offered to set a parking alert if we detect that your car is moving or you’ll get offered directions to your car if we detect from your phone location that you are nearby it.

We also profile you for credit, fraud and security purposes. This can sometimes use systems to make automated decisions based on personal information we have or are allowed to collect from others. The goal is to make the decisions as quick, efficient, fair and correct as possible, based on what we know.  It can affect the products or services we may offer you now or in the future.

·      We will carry out a credit check when you apply for a contract for your products and services with us, as described in our privacy policy. 

·      If you are not already a Vodafone customer, we will use your personal information for identity verification purposes. We sometimes supplement the information we collect about you with information from other sources (such as the electoral roll) This will be prompted to you on first registration of a connected device within the V by Vodafone or V Auto apps. We also use this verification for access to your account and for general account management. However, this identity verification process is supported by human agents that will verify the output of the automated decision.

·      We will process your personal data in order to protect against and detect fraud, and to recover debts or trace those who owe us money resulting from the use of our services.

4. Service improvement

·      We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone.  None of these analytics are linked back to you in any way.

·      To 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; and

·      To 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.

How we share your personal information

Some features of your V-Auto device require us to share information with third parties, but we’ll ask you before we do, as these are optional. For example, when our agents ring you when Auto SOS has detected a collision, we ask you whether you need us to send help to the car’s location. Additionally, when we partner with third parties that can offer you services based on data such as your location, your driving score, or whether you’ve been in an accident we make sure no data is shared unless you actively request us to do so.

Where applicable, we share information about you with:

·      Companies in the Vodafone Group;

·      Partners, suppliers 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;

·      Third parties who you have nominated to view your driver information via the app;

·      Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law; or

·      A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

International data transfers

If you are a non-Vodafone customer and we need to verify your identity, we will need to transfer your data to our service provider, which is based in India.

When Vodafone sends your information to a country that is not in the EEA, we 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.

How long we keep your personal information for

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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. Once these bases have expired, we’ll delete that information.

Keeping your personal information secure

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) 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.

Your rights

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our customer care team via. v.vodafone.com/ie

Right to correct personal data

If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data
If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability
You can submit a portability request by this by logging into your My Vodafone account.
You will receive your information in a digital, machine-readable format.

 Right to object to use of personal data
·       If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account, by selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

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

·                Email: info@dataprotection.ie

·                Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

·                In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data

If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Our cookie policy

How we use cookies 

A cookie is a small text file which is placed onto your mobile (or other electronic device) when you access our App. We use cookies on our App to recognise you whenever you visit the App (this speeds up your access to the App as you do not have to log on each time).

Our cookies don't hold personal information such as your name or bank details. They simply let us find information about your browsing experience that we can associate to you if you are logged in. 

To do this we sometimes use persistent cookies. We take looking after your personal information seriously – we're always monitoring and improving how we protect it.

We've put our cookies into the following categories, to make it easier for you to understand why we need them:

1.          Strictly necessary – these are used to help make our website work efficiently

2.          Performance – these are used to analyse the way our website works and how we can improve it

3.          Functionality – these help to enhance your experience by doing things like remembering products you've added to your basket

4.          Targeting/advertising – these are used to share some information with third parties who we advertise with, so we know how you've reached our website. We can also use cookies to identify the parts of the website you’re interested in. We then use this information to show you adverts and pages we think may also be of interest to you, to tailor how we communicate with you, or to tailor the contents of the communications we send to you. If you prefer, you can opt out of these. Tailoring of content means it includes information reflecting the interest you’ve shown in the content of our web pages, or offers or promotions that we think may interest you, and to improve how we respond to your needs.

Controlling your cookies

You can control how you use cookies in your browser or your device settings. 

If you change your cookie settings in your browser, your experience with us won't be tracked.

Information on controlling and deleting cookies is also available at http://allaboutcookies.org

Curve - Smart Tracker – VST001– Privacy Statement

This Privacy Statement explains how we process the information of:

• subscribers whose data may be collected through the V by Vodafone app (‘App’); and
• users whose data may be collected via the Smart Tracker with model ID VST001 (‘Device’).

We take the privacy of our subscribers and users very seriously. We ask that you read this Privacy Statement carefully as it contains important information about how we will use your personal data.

If you are sharing your device with others, as the main account owner you are responsible for ensuring that such users have been made aware of the personal data processing, including location data, as outlined in this statement.

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and let you know.

We have recently revised our Privacy Statement for this App and Service; the main changes are listed below. 

Last updated: 19/07/2021

Who we are

We are Vodafone Ireland Limited, a member of the Vodafone Group. 

In this privacy policy:

• “we/us” means Vodafone Ireland Limited; 
• “third party” means someone who is not you or us; 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. 

Vodafone Ireland limited is a private Company Limited by Shares, registered in Ireland with registered office at MountainView, Leopardstown, Dublin18. We are registered in Ireland under company number 326967. 

Our main switchboard is 1907 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 policy, you can email us at: dataprotection.ie@vodafone.com com or you can write to our privacy team at:

Vodafone Privacy Team

Vodafone Ireland Limited
MountainView

Leopardstown, 

Dublin 18 

D18 XN97 

Ireland 

Personal information we collect about you

Information we collect about you

The types of information we process includes;

·       Your name, address, mobile number or landline number, date of birth and email address;

·       Your account information, such as the number of products you have with us, dates of payment owed or received and the make, model and year of the vehicle you have;

·       Your photos or camera settings, if you want to add photos for profile setup, including the user of the device, to their respective profiles (you can revoke these permissions in your phone’s Settings);

·       Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;

·       Your preferences for particular products or services when you tell us what they are, or we assume what they are, based on how you use the products and services;

·       Customer care information through your contact with us, such as a note or recording of a call you make to one of our contact centres;

·       Information about your mobile handset each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

·       Information about your usage of the App, such as how often you use it or when you dismiss alerts; and

·       Your mobile handset or device 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. The device will always process location data in order for you to locate the device however, you can turn of location tracking of your mobile handset at any time. 

·       Information about your interaction with the App and its features, such as voice related activity if you choose to connect your device with another third party device (for example Alexa). If you do, the other device provider will share with us your “voice intents” which includes the content of your requests to enable us to provide and improve your experience and our services (you can stop the sharing of this information with us by unlinking the devices/removing our access to the other device). 

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 our services – for example, we can see the amount of data the device is using which we can use to assess whether our data allowances are sufficient; and

·       We also collect anonymous analytics information on how users use the device and app in order to improve your experience and troubleshoot.

When we collect your personal information

We collect personal information when:

·       You first set up your device in the App and set up your profile;

·       You use the App and any of its features (for example, setting a geographical zone or changing tracking mode);

·       You subscribe to marketing; or

·       You contact our customer care teams.

Vodafone will process your personal data based on:

1.           The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your network traffic data as part of making your device “connected” and we’ll need to process subscriber’s payment details for your monthly billing.

2.           Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.           Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

How we use your personal information

1.           To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       to help us identify you and any accounts you hold with us;

·       to provide you with connectivity and features for your device;

·       billing and customer care;

·       to notify you of any changes to the App or to our services that may affect you; and

·       identity verification.

2.           Marketing and profiling

If your Vodafone account is  opted into marketing and you have given us permission to use your data to tailor these communications, we’ll use your interactions with this App and the data from your Connected Device to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, we can see whether you are getting the most out of your purchase or which Products you already have.

To opt out of Marketing messages or profiling:

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, messaging, phone or post).

There are various ways to opt out:

·       Contact our customer care team on 1907 

·       

·       Log onto My Vodafone though the Vodafone website or via My Vodafone app to review and change your marketing preferences

·       Tell the adviser you no longer want to be marketed to, if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

·       Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms and Conditions change. You will still continue to receive those (unless we have indicated otherwise). You may also receive marketing via push notifications if you have not turned them off via your App settings.

3.           Service improvement

We collect anonymous, de-identified or aggregated information in order to improve the service we offer to everyone. 

To 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; and

To 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.

We also process call recordings or chat transcripts when you interact with our customer care, for training and quality purposes. 

How we share your personal information

Where applicable, we share information about you with:

·       Companies in the Vodafone Group;

·       Partners, suppliers or agents involved in delivering the products and services you’ve ordered or used (for example our supplier Trackimo who help to build the product);

·       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; or

·       A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

International data transfers

Our customer care centres are run by Vodafone Shared Services which is based in Egypt and India. 

The data accessed will only include support ticket data needed to resolve your issues. For example, your phone number or fall detection data is not transferred.

If you are a non-Vodafone customer and we need to verify your identity, we will need to transfer your data to our service provider, which is based in India.

When Vodafone sends your information to a country that is not in the EEA, we 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.

How long we keep your personal information for

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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. Once these bases have expired, we’ll delete that information.

Keeping your personal information secure

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) 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.

Your rights

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our Customer Services team via v.vodafone.com.

Right to correct personal data

You have the right to have your personal data corrected if it is incorrect. You can request this by contacting our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

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 contact the Customer Services online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

Right to data portability

You have the right to port your data. You can request this by contacting our Customer Services Team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

Right to object to use of personal data

In certain circumstances, you have the right to object to the use of your personal data. Contact our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

How to lodge a complaint

If you want to contact us about any of your rights or if complain about how we use your information, contact our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact by post to the Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co Laois.”

Right to restrict use of your data

If you feel data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 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 with our Customer Services team online or by calling 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 please see https://n.vodafone.ie/privacy.html

Smart Childrens Watch (VKW001) – Privacy Statement

This Privacy Statement explains how we process the information:

• of Administrators whose data may be collected through the Vodafone Smart app (‘App’); and
• wearer’s (‘User’s’), collected via the connected device (‘Connected Device’).

We take the privacy of our users very seriously. We ask that you read this Privacy Statement carefully as it contains important information about how we will use your personal data.

Last updated: 14/07/2021

This Privacy Policy gets updated from time to time; whenever we make a change, we’ll update the content and let you know.

We have recently revised our Privacy Statement for this App and Service; the main changes are listed below. 

Last updated: [03 August 2021]

Who we are

We are Vodafone Ireland Limited, a member of the Vodafone Group. 

In this privacy policy:

• “we/us” means Vodafone Ireland Limited; 
• “you/your” means the user of the account owner or the user of the Connected Device
• “third party” means someone who is not you or us; 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. 

Vodafone Ireland limited is a private Company Limited by Shares, registered in Ireland with registered office at MountainView, Leopardstown, Dublin18. We are registered in Ireland under company number 326967. 

Our main switchboard is 1907 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 policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Vodafone Privacy Team

Vodafone Ireland Limited
MountainView

Leopardstown, 

Dublin 18 

D18 XN97 

Ireland 

Personal information we collect about you

Information we collect about you

The types of information we process includes;

·       Your name, address, mobile number or landline number, date of birth and email address;

·       Your account information, such as the number of products you have with us, dates of payment owed or received and the type of Connected Device you have;

·       Your phone’s address book, so that you can add contacts to the group (you can revoke these permissions in your phone’s Settings);

·       Your photos or camera settings, if you want to add photos of Group members, including the User of the device, to their respective profiles (you can revoke these permissions in your phone’s Settings);

·       Your preferences for particular products or services when you tell us what they are, or we assume what they are, based on how you use the products and services;

·       Customer care information through your contact with us, such as a note or recording of a call you make to one of our contact centres;

·       Information about your Connected Device each time you use the App. For example, we may collect information on the type of device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

·       Messages between your phone and the device, this is stored locally on your devices;

·       Information about your usage of the App, such as how often you use it or when you dismiss alerts; and

·       Your Connected Device 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.

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 our services – for example, we can see the amount of data the Connected Device is using which we can use to assess whether our data allowances are sufficient; and

·       We also collect anonymous analytics information on how users use the Connected Device in order to improve your experience and troubleshoot.

When we collect your personal information

We collect personal information when:

·       You first set up your Connected Device product in the App and add your contact details and those of contacts;

·       You use the App and any of its features (for example, dismissing alerts or messaging other contacts);

·       You subscribe to marketing; or

·       You contact our customer care teams with a query.

Vodafone will process your personal data based on:

1.           The performance of your contract or to enter into the contract and to take action on your requests. For example, we’ll need to process your network traffic data as part of making your device “connected” and we’ll need to process Administrator's payment details for your monthly billing.

2.           Vodafone’s legitimate business interests, 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 business 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 policy.

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, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or

4.           Consent you provide where Vodafone does not rely on another legal basis. Consent is always presented to you separately and you can withdraw your consent at any time.

How we use your personal information

1.           To provide you with your service

We use your information for service provision and to fulfil any purchases you have made:

·       to help us identify you and any accounts you hold with us;

·       to provide you with connectivity for your Connected Device;

·       billing and customer care;

·       to notify you of any changes to the App or to our services that may affect you; and

·       identity verification.

1.           Marketing and profiling

If your Vodafone account is  opted into marketing and you have given us permission to use your data to tailor these communications, we’ll use your interactions with this App and the data from your Connected Device to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, we can see whether you are getting the most out of your purchase or which Products you already have.

To opt out of Marketing messages or profiling:

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, messaging, phone or post).

There are various ways to opt out:

·       Contact our customer care team on 1907 

·       

·       Log onto My Vodafone though the Vodafone website or via My Vodafone app to review and change your marketing preferences

·       Tell the adviser you no longer want to be marketed to, if you receive an outbound marketing call;

·       Email dataprotection.ie@vodafone.com for guidance.

·       Opting out does not mean that you won’t any longer receive service-related messages, such as messages telling you about your order status or when our Terms and Conditions change. You will still continue to receive those (unless we have indicated otherwise). You may also receive marketing via push notifications if you have not turned them off via your App settings.

2.           Service improvement

We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone. None of these analytics are linked back to you in any way.

To 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; and

To 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.

How we share your personal information

Where applicable, we share information about you with:

·       Companies in the Vodafone Group;

·       Partners, suppliers 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; or

·       A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.

·       Smartcomm for neo [MHV1]

International data transfers

Our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India and Romania.

Our processor Smartcomm, who provide the platform and will access the data in case there are any troubleshooting queries, will store your data in the EEA

The data accessed will only include support ticket data needed to resolve your issues. For example, your phone number or issues with the device. 

If you are a non-Vodafone customer and we need to verify your identity, we will need to transfer your data to our service provider, which is based in India.

When Vodafone sends your information to a country that is not in the EEA, we 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.

How long we keep your personal information for

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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. Once these bases have expired, we’ll delete that information.

Keeping your personal information secure

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) 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.

Your rights

Below we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please contact our Customer Services team via v.vodafone.com.

Right to correct personal data 

You have the right to have your personal data corrected if it is incorrect. You can request this by contacting our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

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 contact the Customer Services online or by calling 1907 or emailing dataprotection.ie@vodafone.com

Right to data portability

You have the right to port your data. You can request this by contacting our Customer Services Team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

Right to object to use of personal data

In certain circumstances, you have the right to object to the use of your personal data. Contact our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 

How to lodge a complaint

If you want to contact us about any of your rights or if complain about how we use your information, contact our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission  - by post to Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co Laois.

Right to restrict use of your data

If you feel data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our Customer Services team online or by calling 1907 or emailing dataprotection.ie@vodafone.com 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 with our Customer Services team online or by calling 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 please see https://n.vodafone.ie/privacy.html

 [MHV1]This is covered in 2^nd bullet point (our partners, suppliers or agents etc.)