Visitor privacy statement
1 Who we are
Vodafone Limited are the controller of your personal information that is collected and processed subject to your visit at Vodafone.
Our registered office is Vodafone House, The Connection Newbury, Berkshire RG14 2FN. We are registered in England under company number 1471587 and registered with the Information Commissioner’s Office (ICO), registration number Z1933885.
We provide details of how to contact us in the ‘How to contact us’ section of this privacy statement.
2 Definitions
In this privacy statement:
“we/us” means Vodafone Limited;
“third party” means someone who is not you or us or a part of Vodafone Group; and
“Vodafone” or “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.
3 The Basics
3.1 Personal information we collect about you
3.1.1 Vodafone will process your personal information based on
Vodafone’s legitimate business interest, including for example, fraud prevention, maintaining the security of sites and internal systems. 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, see the 'Your rights' section of this privacy statement;
Compliance with a mandatory legal obligation, including for example where certain information is necessary to satisfy a legal or regulatory requirement or to manage the health, safety and welfare of our employees and contractors, 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;
Consent you provide, where Vodafone does not rely on another legal basis or reliance on our legitimate business interests, you choose to provide us with your personal information and the processing of that information is voluntary. Your consent can be withdrawn at any time. When you give your consent, you will be given details on how to change your mind or visit the 'Your rights' section of this privacy statement for more information.
3.1.2 How we collect information about you
We collect personal information about you from our employees or from you directly when you visit a Vodafone site, for example, your name and contact details including your email address in addition to your photo when you physically check into one of our locations. Personal data may be received by employees who are checking you in for a visit.
We may also collect information about you from your access to Vodafone sites and surveillance on those sites as part of our security and crime prevention measures.
3.1.3 Information we collect about you
The types of personal data we will process include but is not limited to;
Name
Address
Email
Telephone number
Vehicle details including vehicle registration
Photographs of you including CCTV footage
Access card records
Work contact details
3.2 How we use information about you
We may process the personal information that we collect about you for the following purposes:
Access management, such as to give you physical access to Vodafone sites including carparks;
Maintaining health, safety and wellbeing, such as recording accidents for insurance and safety regulations
Meeting our contractual obligations with our site suppliers,
Compliance with security and company policies, for example we will record your car details to ensure your parking complies with our parking policy.
To contact you to obtain your feedback regarding your visit to Vodafone.
3.3 Who we share information about you with
We may share personal information about you with:
Companies in the Vodafone Group;
Companies who are engaged to perform services for, or on behalf of Vodafone Limited or a company in the Vodafone Group, including for example, our insurers and legal advisors and those who manage our sites;
Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, when we are obliged by law to do so;
A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.
3.4 Where we process information about you
In doing the above, we may need to transfer personal information about you to other companies in the Vodafone Group or third parties located (or whose servers may be located) in countries outside of where you are engaged, including countries outside of the United Kingdom and the European Economic Area (EEA). If we send personal information about you to a country that is not in the United Kingdom and the EEA, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organizational measures to protect your personal information.
3.5 How long we keep information about you
We’ll store your information for as long as we have to by law. If there is no legal requirement, we will only store it for as long as we need to. Generally, this means that we will retain your information for no longer, than 30 days after your visit to a Vodafone site (unless you tell us otherwise, for example, to remember your details for future visits).
3.6 How we protect your personal information
Vodafone is committed to protecting your personal information. We apply strong security and privacy measures to protect your personal information from unauthorised access, use, loss, disclosure or destruction. For example, we encrypt your personal information when it is transmitted, and we store it in a controlled environment with limited access. Our dedicated security and privacy teams conduct assessments on our products, services and operations to ensure our privacy and security policies are implemented. Our suppliers and others who process personal information on our behalf are expected to comply with our high standards. Vodafone employees and approved third parties who need access to personal information are subject to internal policies, strict confidentiality obligations and training. We monitor the implementation of these internal policies. Failure to comply with our policies may lead to investigation and possible disciplinary action up to and including summary dismissal Vodafone complies with applicable data protection laws, including applicable data breach notification laws.
4 Your rights
Right to correct or update information: you have the right to have the information we hold about you corrected if it is not accurate. If the information we hold about you needs updating, or you think it may be inaccurate, you can contact data.protection@vodafone.com;
Right to access: want a copy of the personal information we hold on you? You can apply for a copy of your personal information by contacting data.protection@vodafone.com;
Right to object: you have the right to object to the processing of your personal information where we rely on our legitimate ground to do so. You can request to object to processing by contacting data.protection@vodafone.com;
Right to deletion: in certain circumstances you have the right to request that we erase the personal information we hold about you. You can request for your information to be deleted by contacting data.protection@vodafone.com;
Right to restrict use of your information: if you feel the personal information we hold about you is inaccurate or believe we shouldn’t be processing your personal information, you may have the right to ask us to restrict processing that information. You can request to restrict processing by contacting data.protection@vodafone.com;
Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you. You can raise a request for data portability by contacting data.protection@vodafone.com.
If we don’t take action based on any of the above requests, we will inform you of the reasons why.
5 Changes to this Privacy Statement
This privacy statement gets updated from time to time, so we’d encourage you to check it regularly.
6 How to contact us
If you have any further questions about this privacy statement or how we process your information, please contact data.protection@vodafone.com