V-Auto Privacy Policy

V-Auto – Privacy Statement

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.
 

Section

Changes Date
Reformatted privacy notice We have updated the structure and format of the privacy notice to meet new legal requirements. 25th   
May 2018
Updated cookie section Updated with information that is collected via Vodafone ID. 2nd February 2019
Updated how we collect information and who we share information with Expanded to include when third party personal data is collected by the user when using the multi-user feature. 6th June 2019


















Last updated: 6 June 2019

 
Who we are

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

In this privacy policy:

  • “we/us” means Vodafone 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 Vodafone House, The Connection Newbury, Berkshire RG14 2FN]. We are registered in [England under company number 1471587. Vodafone Limited is registered with the Information Commissioner’s Office (ICO), registration number Z1933885. 

Our main switchboard is [+44(0)1635 33251] or you can email us at data.protection@vodafone.com.    

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: [data.protection@vodafone.com] or you can write to our privacy team at:

Vodafone Privacy Team

Vodafone House
The Connection
Newbury
RG14 2FN England

   

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

·        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 Device 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 choose to opt out at any time. If you’ve previously opted in to receive personalised content based on how and where you use our network, you can also opt out at any time.

The easiest way to opt out is by using our marketing preferences page, found under your My Vodafone account settings. For customers without a Vodafone mobile number, you can manage your permissions in the Vodafone Smart Tech App.

There are also various other ways to opt out:

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

·        Click the link at the end of a marketing email, text or picture message to unsubscribe from that channel

·        Change your communication preferences by texting the relevant code in this table [PDF: 342KB]

·        Tell the adviser if you receive a marketing call

·        Disable push notification messages, including marketing messages, at any time in our apps by changing the notification settings on your device or by uninstalling the app

·        Contact our customer data team for guidance

·        Email data.protection@vodafone.com

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 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.

 

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 near 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. For more details, you can visit our credit checks page

·        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 Vodafone Smart Tech 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.

 

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 care team via v.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 third party, please contact the customer care team via. v.vodafone.com


Right to data portability

You have the right to port your data; for V-Auto this means that (aside from your monthly billing and account information) you can also ask for a copy of your telematics data (this means the driving history data that has been generated by your V-Auto device), You can request this by contacting our customer care team via v.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 the customer care team via v.vodafone.com.

 

How to lodge a complaint

If you want to contact us about any of your rights or to complain about how we use your information, contact our customer care team via v.vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact the ICO – their details are at www.ico.org.uk

 

Right to restrict use of your data

If you feel the data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our customer care team via v.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 Customer Services.  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 visit  www.vodafone.co.uk/privacy 

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.

 

What’s its called

What it is used for

Type

Duration

VF-UUID

This allows us to track browser actions to understand how Vodafone ID is being used (e.g. button clicks, page load times etc.)

2

Persistent cookie

Session

To track your web session. After successful authentication this cookie is set to keep the authenticated session (and authorisation details) active in the browser. This means if you come back in the same browser within 30 minutes, you do not need to re-authenticate.

1

30 minutes

loadedData

loadedData1

marketChange

When you select what country you are in, these cookies remember your selection.

3

On browser close

Trx

To track time out for current transaction

1

10 minutes

Auth_${AuthorizationId}

To track time out for transaction

1

1 Day

Language

To track language selection

2

30 Days

Recall

To track “remember me” settings

2

On browser close

sessionTimerData

To track transaction time out

2

Session

 

origin_tealium_profile

Functional Cookie used to derive the profile (i.e. UK) used by Tealium and hand this over to the Service (e.g. V Shop)

3

Session

origin_tealium_environment

This is a functional cookie used to identify  the environment (web environment not location i.e. live web page or testing web page) used by the customer and hand this over to the Service (e.g. V Shop) to locate traffic

3

1 year

utag_main

This is a tracking/behavioural cookie that contains different information about the session and presents a unique identifier of the customer in that session.

 

This gathers usage statistics used to analyse customer behaviour/ trends taking place on our site and use it to improve customer experience and performance of our site to give you the best experience possible.

 

All variables listed here:

  • ses_id – A unique identifier for the session.
  • _st – A Unix/Epoch time stamp, in milliseconds.
  • v_id – A unique identifier for each visitor.
  • _ss – A Boolean that indicates if the page viewed is the first in a session. A value of 1 means yes and 0 means no.
  • _pn – The number of pages viewed during the current session.
  • _sn – The number of sessions for this visitor.

 

3

 

openidAccessToken

openidRefreshToken

These cookies remember who you are to keep you logged into your account on the app so you don’t have to log in every time.

1

Session

  
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