Secure Net Home Privacy Policy

Information we collect about you

The types of information we process about you and any devices you register with the service when you use Secure Net Home and the accompanying App are:

• Your browsing activity on the network, including IP addresses; Secure Net Home is a service that uses a Domain Name System (DNS) Filtering process on websites you are navigating to in order to protect you from malicious sites and malware. This means for example, that if we know a certain website or app traffic has been blacklisted because it contains harmful content, we'll warn you that you shouldn't proceed to that site before you land on it or block access directly in case of malicious sites based on threat intelligence. We do not use this information for other purposes;
• Your email and phone number;
• Information about devices and associated policies or filtering rules that are set up to be protected by Secure Net Home or to be subject to parental controls. For example, we collect information on the type of connected device that you are using (such as whether it's a mobile device, a laptop, a gaming console or smart home devices, and their manufacturers) and its unique device identifier (for example, the MAC address of the device's wireless network interface);
• If you activate the Secure Net Home cleaning tool, we will access data from your device to help remove security threats from your device;
• The names or nicknames of users or devices you add when creating family profiles;
• Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services. This could be your Vodafone ID credentials if you set up your login via this method.

We'll also get information about how you use our products and services, such as:

• Details of your use of our services - for example, we can see whether or not a site has been blocked and keep a limited record of this information for service and customer care (see How long we keep your personal information for), or how often you interact with our online portal or App dashboard to see summaries of your threat protection or parental controls, or the sorts of parental controls you are setting; and
• We also collect anonymous analytics information on how our customers use the Secure Net App or the online portal in order to improve your experience and troubleshoot (for example, we can see whether certain functionalities are not working as intended and fix them or how much our customers use the parental control functionalities).

When we collect your personal information

We collect your personal information when:

• You browse the internet on a fixed connection with any of your devices when you have an active Secure Net Home subscription;
• You activate and use the cleaning tool feature of the App;
• You interact with the App or online Portal (where you can see what threats have been blocked or set any parental controls);
• When content is blocked as a result of the security protections or when a parental control limits access to certain content.

Vodafone will process your personal data based on:

Vodafone's legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, 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.

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

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. For example, we need your consent to process the content of your communications in order to detect and block any security threats. Furthermore, we will require your consent in order to process your traffic and location data for value added services. If you allow people to use your connectivity services we may not be able to identify them (for example guest WIFI users or people using your 'mobile hotspot'). Therefore, we will rely on the consent of the account holder who will then be responsible for informing users on how their traffic data will be processed when using services supplied to you.

Secure Net Home is an optional service, which you can deactivate at any time. To do so, you can navigate to the Secure Net Home portal, Secure Net App or via the link sent to you in your welcome SMS or alternatively, you can contact our Customer Services team.

To provide you with your service

In order for us to protect you from security threats and to apply any parental control rules you may have set, we view your browsing activity in order to do so. We do not use this information for marketing or personalised profiling and it is retained for a limited period of time.

Profiling and automated decision making

Our threat monitoring is based on profiling and automated decisions; for example, websites we block are based on the intelligence we have gathered. You can, at any time, go into your portal or App and view why something has been blocked (for example, if it was malicious or contained malware). You can also customise which websites are limited when parental controls are on outside of the default list provided.

To improve our service

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.

Service messages

From time to time we'll send you monthly summaries of the threats that have been blocked. You can turn these off in your account settings if you no longer wish to receive them via the app notification settings or by contacting Vodafone customer services.

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.

All data is stored in our data centres in Germany. Our third-party service provider (Allot Ltd.) stores your personal data in the United Kingdom (UK) and the European Economic Area (EEA).

We'll store your information for as long as we have to by law. If there's no legal requirement, we'll only store it for as long as we need to (13 months from when your contract with Vodafone terminates).

Browsing history

We keep a limited record of your browsing history for service and customer care purposes only. Your browsing history will only be kept for 3 months. Vodafone does not repurpose your browsing for the purposes of marketing or personalised profiling. For example, if you believe that we should not have blocked a site, we can check that for you.

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.

Here's how you can exercise your rights. If you have any questions, please contact our Customer Service.

Right to correct personal data

You have the right to have information held about you corrected if it is not accurate. If what we hold on 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 3rd party, please fill out the online form or post it to the address on the form. Alternatively, you can contact the Customer Services team.

Right to data portability

You have the right to be able to take with your data you provided to us in certain circumstances. For example, 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 a format of your choice. In order to do this, log in to My Vodafone and go to your billing area. Some specific apps and services allow you to take out the informed stored by the user into Vodafone's cloud and hosting services, for example Backup+.

Right to object to use of personal data

In some cases you will have the right to object to use of personal data. Contact our Customer Services team or email us at data.protection@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 or email us at data.protection@vodafone.com. We'll do our best to help but if you're still unhappy, you can contact the ICO. Their website has details on how to contact the ICO.

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 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 section in this privacy policy called "How long do we keep your personal information for?").

Cookies are tiny text files that are stored on your computer, tablet or mobile phone when you visit a website. The cookies mean that the website will remember you and how you've used the site every time you come back.

Cookies themselves don't hold personal information such as your name or bank details. And in many cases, we won't be able to link the information we collect by using a cookie back to you. They can, however, help us to find information once you're logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service, white paper or newsletter.

First party cookies

First party cookies originate from the same domain as the website you're currently visiting.

Controlling your cookies

You can control how you use cookies in your browser. If you wish to restrict or block the cookies which are set by any website - including a Vodafone website, you should do this through the web browser settings for each web browser you use, on each device you use to access the internet.

Information on controlling and deleting cookies, including on a wide variety of browsers, is also available at allaboutcookies.org