Your privacy rights: Call+ and Message+

The types of information we process about you as part of the Call+ or Message+ apps Rich Communications Services are:

• Connectivity information such as the numbers you call or send messages to and the duration of the call;

• Your location via your IP address (or you can choose to share your GPS location with your friends via the share location feature);

• Credential information such as username and password;

• Your device details such as your IMEI number, phone number and device type;

• The app will ask for permission to access your contact book so you can message or call your contacts;

• The app will also ask for permission to access your camera and your device storage for the purposes of file transfers;

• Message and file transfer traffic data such as the numbers of the sender and recipient, the file type, name and length;

• Content of your messages (such as any files or texts) are stored for up to 7 days in the event that the recipient is unavailable when you first send the message;

• We will also filter any malicious communications that you may receive such as spam and viruses. In order to do this, we inspect the content of your communications and stop the harmful activity from reaching your 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 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 apps in order to improve your experience and troubleshoot. 

When we collect your personal information
We collect your personal information when:

• You interact with the apps;

• You send messages or files; or

• You make calls using the apps.

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 in order for you to send messages and files and make calls using the app.
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, see the Your Rights section.
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.

Provide you with your service
We use your data in order to provide you with the Call+ or Message+ services. For example, we use your data in order for you to share your location with your contacts if you choose, or to send files and messages.

Marketing and profiling
Vodafone does not use Call+ or Message+ to send you marketing messages, however, given that they're a communications platform, third parties to whom you have given your permission may send you such communications. If you wish to opt-out of those, you should contact the third party in question.

Other profiling
We also conduct real-time traffic analysis for the purposes of routing and detecting any illegitimate Application To Person (A2P) – that’s companies sending you messages. We do not conduct this analysis on a personal level; all your data is aggregated and the analysis is conducted on that aggregate data.

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 do not transfer data outside of the EEA; all data is stored in our data centres in Germany.

Cessation of service
We retain data for only as long as is necessary for you to receive your service. If you choose to stop using Call+ or Message+, we will delete your data after 30 days.

Message and File Transfers
Message and File Transfers (FT) are stored for up to 7 days in the Store & Forward database if the recipient of your message was not available. This is subsequently deleted after the 7 days are up.

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's 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.

Here, we set out details on how you can exercise your rights.  If you have a question or cannot find the answer, please complete and submit our online form and we’ll help to resolve your query, 

Right to correct personal data 
You have the right to have information held 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 log in to My Vodafone to update it or contact our Customer Services team.

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, visit our Subject Access Request (SAR) page, which gives details on how to do this. Alternatively, you can contact our Customer Services team.

Right to data portability
You have the right to be able to take with you the personal data you provided to us in certain circumstances. 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 order to do this, log in to My Vodafone and go to your billing area.

Right to object to use of personal data
You have the right, in certain circumstances, to object to Vodafone processing your personal information.  For more information or to exercise this right, please contact our Customer Services team or complete and submit our online form and we’ll help to resolve your query, 

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 representative’s Customer Services team. We’ll do our best to help but, if you’re still unhappy, you can contact the ICO – their details are at ico.org.uk 

Right to restrict use of your data
If you feel data we hold on you is inaccurate, or you believe we shouldn’t be processing your data, please contact our Customer Services team to discuss your rights. In certain circumstances, you 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, see the part of this Privacy Policy called How long we keep your personal information for.