V-Home by Vodafone – Privacy Statement
Section: reformatted privacy notice
Changes: we have updated the structure of the privacy notice to meet new legal requirements
Last updated: [12 March 2019]
Who we are
We are Vodafone Limited, a member of the Vodafone Group.
• “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: +44(0)1635 33251 or you can email us at email@example.com
How to contact us
Vodafone Privacy Team
V-Home is powered by Samsung SmartThings. Their registered office is Samsung Electronics (UK) Limited, Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16.
If you are a Trusted Contact
If you are a Trusted Contact of one of our customers, we collect your information when they register you in the V by Vodafone app. You will receive an alert through text message when this happens.
We will receive the following information about you:
• Your mobile phone number;
• Your full name; and
• (If provided) your relationship to our customer (for example, mother or spouse)
One of our Assisted Alarm Service agents will contact you when our customer is unresponsive to an alert from one of the connected devices in their V-Home. We will not use your data in any other way.
You can remove yourself as a Trusted Contact at any time by either:
• Asking our customer to remove you from their list;
• Asking an agent when you are contacted (please quote the HubID provided in your text message alert); or
• Request removal via our online chat
V-Home Privacy Supplement
Personal information we collect about you
Information we collect about you
The types of information we process about you when you use your V-Home Connected Devices are:
• Your Connected Device-generated data where it’s been provided by our partner (see the Third party sources of data section below) such as alerts from your SmartThings devices and your interactions with them (for example, the type of alert, when it was triggered and whether you have taken an action to dismiss the alert);
• When you receive a call from us when we follow up an alert as part of the Assisted Alarm Service, your interactions with the Service;
• Your account information, such as the number of connected SIMs 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 the Marketing & profiling section below); and
• 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.
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 V-Home Connected Devices, where device-generated data has been provided by our partner (see Third party sources of data);
• You subscribe to marketing; or
• You contact our customer care teams with a question or complaint or interact with our Vodafone Assisted Alarm Service.
Third party sources of data
Given that our customer care teams act as your one-stop-shop for queries and issues around your Connected Devices, we share limited personal data between Vodafone and Samsung. 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.
We also receive your Connected Device-generated data from Samsung in order to provide the services you’ve requested (for example, for the Vodafone Assisted Alarm Service, we need to see the device-generated information to be able to respond to any home alerts and take any follow-up actions).
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 devices’ data to provide the Vodafone Assisted Alarm Service 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 V-Home and Vodafone Assisted Alarm Service;
• for billing and customer care; and
• for identity verification.
2. Marketing & profiling
If you’re 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 identify 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 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 V by Vodafone app.
There are also various other ways to opt out:
- Contact our customer services team on our website
- 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
If you’re opted out of marketing, you may still receive service-related messages.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. For more details, you can visit out credit checks page on our privacy portal
• 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 Samsung to understand how products and the V-Home offering is performing commercially. For example, if we know that certain features are well received, we can focus on developing more of the same. 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, based in Hungary, Egypt, 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 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 will 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. Therefore, 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 and cannot find the answer, please contact our Customer Services team via the V by Vodafone App or online
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 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-home. You can request this by contacting our customer care 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 Services team via the V by Vodafone App or online. 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