This Privacy Statement explains how we process the information:
- of Administrators whose data may be collected through the Vodafone Smart app (‘App’); and
- of rider’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: 20th January 2021
Last updated: November 2020
Who we are
We are Vodafone Limited, a member of the Vodafone Group.
- “we/us” means Vodafone 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.
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 email@example.com.
How to contact us
Vodafone Privacy Team
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);
- 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.
- Your bike product details in relation to the product that you would like to track, this can include make, manufacturer, serial number.
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.
2. Marketing and 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 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 via v.vodafone.com;
- All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;
- Tell the adviser you no longer want to be marketed to, if you receive an outbound marketing call;
- Email firstname.lastname@example.org 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.
1. 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.
International data transfers
Our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India and Romania.
Our processor ConnectLab (and their data hosting partner SmartComm), who provide the platform and will access the data incase 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.
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 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 3rd party, please contact the Customer Services team via v.vodafone.com.
Right to data portability
You have the right to port your data. You can request this by contacting our Customer Services 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 our Customer Services team via v.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 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 data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our Customer Services 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 our Customer Services team via v.vodafone.com. 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 our www.vodafone.co.uk/privacy.