Vodafone Smart SIM - Privacy Statement

Vodafone Smart SIM – Privacy Statement

This privacy statement explains the information that is collected by Vodafone through the connectivity services we provide to your Connected Internet of Things Devices (‘Connected Devices’) and how this data will be processed. Connected Devices are those that are compatible with a Vodafone Smart SIM (also known as the V-Sim by Vodafone) (the “SIM”). You can view this statement, and the statement for our Connected Devices in the Settings Menu of the App or online at any time.

Some of our products are developed in partnership with specific third party partners, who will process your personal data collected from the device hardware, as a data controller in their own right. For more information on how those third parties use your personal data you will need to visit their privacy policy. Listed below are links to the privacy policies for Vodafone smart products, developed in partnership with third parties.

There may be other third party products advertised by Vodafone which are not part of the Vodafone range and it is advised that their privacy policies are reviewed before purchasing.

·        V-Pet Tracker, in partnership with Kippy (Android, iOS)

·        V-Bag Tracker, in partnership with Alcatel (iOS)

·        V-Camera, in partnership with Arlo (Android, iOS)

·        V-Kids Watch, in partnership with TCL (iOS)

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
Reformatted privacy notice	We have updated the structure and format of the privacy notice to meet new legal requirements.
Introduction	Amendments to partners privacy policies and expanded to include other products not just Vodafone Products
Privacy notice	Name change from V-Sim to Smart SIM

 

Last updated: 8^th July 2020

 

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.

 

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 Devices are:

·        Your Connected Device-generated data where it’s been provided by our partners (see Third party sources of data);

·        Your account information, such as the number of products 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 Marketing & profiling);

·        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 the SIM connectivity we provide for Connected Devices, such as the data connections performed and the amount of data consumed;

·        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. 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.

 

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 Connected Devices;

·        Device or app-generated data has been provided by our partners (see Third party sources of data);

·        You subscribe to marketing; or

·        You contact our customer care teams with a question or complaint.

 

Third party sources of data

Given that our customer care teams act of your one-stop-shop for queries and issues around your Connected Devices, we share limited personal data between Vodafone and the partners whose products you have purchased in order for us to achieve this. 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.

 

If you have given us your permission, we also receive your Connected Device’s Service Data from our partners in order to profile you and tailor our communications to you. For example, if we can see that you regularly use a product we might think you want to hear about our others. You can adjust your privacy preferences at any time; see Marketing and profiling for more details.

 

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 network traffic data as part of making your devices “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 the connectivity you have requested for your Connected Devices;

·        billing and customer care; 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 purchasing preferences and data from your Connected Devices 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 elect to opt out of all marketing communications or only selected methods (email, messaging, phone or post).

 

There are various ways to opt out:

·        If you are a Vodafone consumer mobile customer, you can log in to your My Vodafone account to manage your marketing permissions and to opt out or into receiving personalised marketing.

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

·        All our marketing messages come with an “unsubscribe” link which you can click to unsubscribe;

·        Tell the adviser if you receive an outbound marketing call;

·        Email data.protection@vodafone.com 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 & Conditions change. You will still continue to receive those (unless we have indicated otherwise).

 

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 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 third party Vodafone partners to understand how products and the Vodafone offering is performing commercially. For example, if we know that certain products are selling well, we can focus on partnering with more partners that cater to the market. This information does not identify you personally.

 

International data transfers

 

Our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India 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’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 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 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 3rd 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 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 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 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 see our www.vodafone.co.uk/privacy.