Privacy

We may use the information you provide us to contact you about offers and promotions including competitions, prize draws and surveys based on how you use our products and services.

We may also contact you to let you know about products and services of Vodafone, Vodafone Group companies and those of other companies which we think may interest you.

We may tailor or personalise the marketing message and its content based on the information you’ve provided to us and your use of Vodafone’s website, products and services.

We’ll assume that you’re comfortable to receive these messages unless you tell us otherwise. We’ll contact you by post, online, phone or push notifications through our apps.

For more information on online advertising, see the Advertising Online section below.

We use a variety of analytics methods, which involve mathematically driven analysis techniques where large and varied data sets uncover hidden patterns and previously unrevealed trends. At Vodafone we take governance of analytics seriously. Our data scientists are required to sign up to a Code of Ethics. We have a strict use case process that requires that privacy and data protection law checks are carried out before any use case commences. We have strict rules ensuring that personal information is anonymised at the appropriate stage in the process so that it is no longer possible to identify an individual.

How to opt out

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, text, phone or post).

There are various ways to opt out:

• Contact our customer services team – see the contact us page;

• Click the link at the end of a marketing email or text to unsubscribe;

• 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;

• Email dataprotection.ie@vodafone.com

  for guidance.

Opting out does not mean that you won’t receive service-related messages anymore. You will still continue to receive those (unless we have indicated otherwise).

To opt out of receiving marketing communications from other Vodafone Group companies, just contact them directly.

In some cases, you may receive marketing from Vodafone, even if you’re not a customer or never had contact with Vodafone. This is a result of third-party marketing lists which Vodafone may acquire from time to time. If you’ve registered to opt out of such marketing, you shouldn’t receive such communications. If you do, we ask that you let us know immediately by contacting us on 1800200234 or (01)2527218.

To deliver advertising that is relevant to you, you’ll also see targeted advertising online based on the use of cookies. This is known as interest-based advertising. We may also combine data collected via the cookies with other data we have collected.

You’ll also receive direct marketing based on use of cookies. If you don't want any information processed through the use of cookies, check our cookies policy. It explains how to control and opt out of cookies.

Remember that opting out of interest-based advertising won’t stop advertisements from being displayed – but they won’t be tailored to your interests.

V by Vodafone – Privacy Statement

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

Some of our products are developed in partnership with specific third party partners, who will process your personal data as a data controller in their own right.

· V-Pet, in partnership with Kippy or POD

· V-Bag and V-Kids Watch in partnership with Alcatel

· V-Camera, in partnership with Arlo.

· V-Luggage and V-Mini, in partnership with Trackimo.

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.

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

· “we/us” means Vodafone Ireland Ltd.;

· “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 Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us – if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer
Vodafone Ireland
Mountain View
Leopardstown
Dublin 18
Ireland

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 V-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.

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, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

· For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

· 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 dataprotection.ie@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.

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 V by Vodafone partners to understand how products and the V by 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.

If you are a non-Vodafone consumer mobile 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 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.

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.

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.

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
If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data
If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability
You can submit a portability request by this by logging into your My Vodafone account.
You will receive your information in a digital, machine-readable format.

Right to object to use of personal data
· If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

If you want to contact us about any of your rights, or to enquire or make a complaint about how we use your information, contact our Customer Services team via v.vodafone.com or by email at dataprotection.ie@vodafone.com We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission. Contact details for the Data Protection Commissioner are:

· Email: info@dataprotection.ie

· Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

· In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data
If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

This privacy statement (‘Statement’) explains the information that is collected by Vodafone when you use this website and purchase products and services through our online store. You can view the privacy statements for our connected products within their respective apps.

Our website contains links to other websites. This privacy statement applies only to this website so when you access links to other websites you should read their own privacy policies.

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 we’ll communicate any material changes.

We have recently revised our Privacy Statement for this website; the main changes are listed below.

Who we are We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

• “we/us” means Vodafone Ireland Ltd.;

• “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 Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us – if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer Vodafone Ireland Mountain View Leopardstown Dublin 18 Ireland

Personal information we collect about you

Information we collect about you

The types of information we process about you when you use this site are:

· Your contact details, such as name, address, phone number, and email address;

· Your payment details, such as credit or debit card information and banking information;

· The types of products you have purchased;

· Any contact you have with us such as calls to us or if you email us; and

· Your website browsing information, such as how you are using our website or your IP address.

When we collect your personal information

We can collect your personal data when you:

· Visit or browse this website;

· Purchase products and services from us;

· Register your interest for future products and services; or

· Contact us with a complaint or query.

Third party sources of data

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 payment details and billing address to be able to fulfil your purchase and send you your hardware.

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 process the products and services you’ve bought from us, and keep you updated with the progress of your order;

· To bill you for using our products and services, or to take the appropriate amount of credit from you;

· Contact you if the billing information you provided us with is about to expire or we’re not able to take payment;

· To respond to any questions or concerns you may have about our network, products or services; and

· We will contact you with customer service messages to keep you updated with current information about products and services you’ve purchased. For example, changes to our terms and conditions, or letting you know about the status of your order.

2. Marketing and profiling

If you are opted into marketing and given us permission to use your data to tailor these communications, we’ll use your interactions with this site 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, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

· For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

· 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 dataprotection.ie@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

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. Information on credit checks is included in our Privacy Policy.

· If you are not already a Vodafone customer, we will use your personal information for identity verification purposes. We sometimes supplement the information we collect about you with information from other sources (such as the electoral roll) This will be prompted to you on first registration of a connected device within the V by Vodafone or V Auto apps. We also use this verification for access to your account and for general account management. However, this identity verification process is supported by human agents that will verify the output of the automated decision.

· 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.

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 Ireland 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 V by Vodafone partners to understand how products and the V by Vodafone offering is performing commercially. For example, if we know that certain products are selling well, we can focus on delivering more of the same. This information does not identify you personally.

International data transfers

We may need to transfer your information to other Vodafone Group companies or service providers in countries outside the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This kind of data transfer may happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.

If Vodafone sends your information to a country that is not in the EEA, we will 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 If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability You can submit a portability request by this by logging into your My Vodafone account.

You will receive your information in a digital, machine-readable format.

Right to object to use of personal data

· If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

If you want to contact us about any of your rights, or to enquire or make a complaint about how we use your information, contact our Customer Services team via v.vodafone.com or by email at dataprotection.ie@vodafone.com We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission. Contact details for the Data Protection Commissioner are:

· Email: info@dataprotection.ie

· Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

· In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data

If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

Our cookie policy

A cookie is a small text file which is placed onto your mobile (or other electronic device) when you access our website. More information also available at https://www.vodafone.ie/content?id=BAU026375&v=2

The table below is designed to provide more information about the cookies we use and why:

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

Some of our products are developed in partnership with specific third party partners, who will process your personal data as a data controller in their own right.

· V-Pet, in partnership with Kippyor POD

· V-Bag and V-Kids Watch in partnership with Alcatel.

· V-Camera, in partnership with Arlo.

· V-Luggage and V-Multi Tracker in partnership with Trackimo.

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.

Last updated: [05/11/2018]

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

· “we/us”means Vodafone Ireland Ltd.;

· “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 Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us –if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer Vodafone Ireland Mountain View Leopardstown Dublin 18 Ireland

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 V-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, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

· For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

· 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 dataprotection.ie@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 V by Vodafone partners to understand how products and the V by 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.

[ACCORDION] International data transfers

If you are a non-Vodafone consumer mobile 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 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 If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability You can submit a portability request by this by logging into your My Vodafone account. You will receive your information in a digital, machine-readable format.

Right to object to use of personal data · If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

If you want to contact us about any of your rights, or to enquire or make a complaint about how we use your information, contact our Customer Services team via v.vodafone.com or by email at dataprotection.ie@vodafone.com We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission. Contact details for the Data Protection Commissioner are:

· Email: info@dataprotection.ie

· Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

· In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

This privacy statement explains the information that is collected by Vodafone through the V by Vodafone application (‘App’). We have privacy statements for our respective Connected Devices that we will present to you as you add a new device to your account. You can view this statement, and the statement for our Connected Devices in the Settings Menu of the App at any time.

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.

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

• “we/us” means Vodafone Ireland Ltd.;

• “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 Ireland, Mountain View, Leopardstown, Dublin 18. We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

How to contact us

Your opinion matters to us – if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer

Vodafone Ireland

Mountain View

Leopardstown

Dublin 18

Ireland

Personal information we collect about you

Address Book

When our customers upload their address book to the V by Vodafone App, we collect your information. You will receive an SMS alert if they subsequently add you as a Trusted Contact for one of our V Products.

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)

We will not use your data for purposes other than adding them to services when requested by the account holder.

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 ID provided in your SMS alert); or

· Request removal via customer services via v.vodafone.com.

Information we collect about you

The types of information we process about you when you use your V by Vodafone App are:

· Your name, address, mobile number, date of birth and email address;

· If we need to verify your identity, documentation such as a passport or other identification;

· Your account information, such as the number of connected SIMs you have with us and dates of payment owed or received;

· Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;

· Any photos you upload to personalise your Connected Devices’ accounts;

· 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 your mobile device each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

· Information about your usage of the App, such as how often you use it; and

· 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;

· 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; and

· We also collect anonymous analytics information on how our customers use the V by Vodafone App in order to improve your experience and troubleshoot.

When we collect your personal information

We collect your personal information when:

· You buy a connected product from us (online, or in store);

· You first register your Connected Device product in the V by Vodafone App;

· If you’re a non-Vodafone customer, when we verify your identity and you add your payment details;

· You grant the App access to your camera (for taking pictures for ID verification) or your device’s photo album (if you want to add personalised pictures to your Connected Devices’ accounts);

· You use the V by Vodafone Application; or

· You subscribe to marketing.

Third party sources of data

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 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;

· billing and customer care;

· to notify you of any changes to the App or to our services that may affect you; and

· identity verification.

2. Marketing & profiling

If you are 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 inform 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 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, access ‘settings’ on the My Vodafone App, or call 1800 200 234 to manage your marketing permissions and to opt out or into receiving personalised marketing.

· For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

· 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 dataprotection.ie@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 carry out a credit check when you apply for a contract for your products and services with us. Information on credit checks is included in our Privacy Policy.

· If you are not already a Vodafone customer, we will use your personal information for identity verification purposes. We sometimes supplement the information we collect about you with information from other sources (such as the electoral roll). This will be prompted to you on first registration of a connected device within the V by Vodafone or V Auto apps. We also use this verification for access to your account and for general account management. However, this identity verification process is supported by human agents that will verify the output of the automated decision.

· 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 Ireland 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 V by Vodafone partners to understand how products and the V by 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

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 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 If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability

You can submit a portability request by this by logging into your My Vodafone account.

You will receive your information in a digital, machine-readable format.

Right to object to use of personal data

· If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account. By selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint

If you want to contact us about any of your rights, or to enquire or make a complaint about how we use your information, contact our Customer Services team via v.vodafone.com or by email at dataprotection.ie@vodafone.com We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission. Contact details for the Data Protection Commissioner are:

· Email: info@dataprotection.ie

· Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

· In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data

If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Right to erasure

If you would like us to remove your personal data from our records, you can request this by logging into your My Vodafone account. If you do not have an active account, please email dataprotection.ie@vodafone.com to let us know what information you would like to have deleted.

We will send you confirmation when your request has been completed. Please note that if you have an active service with us, much of the information that we keep about you cannot be deleted as this is required to provide you with the service to you and to provide support to you.

Our cookie policy

A cookie is a small text file which is placed onto your mobile (or other electronic device) when you access our App. We use cookies on our App to recognise you whenever you visit the App (this speeds up your access to the App as you do not have to log on each time).

Description of cookies

The table below is designed to provide more information about the cookies we use and why:

This privacy statement explains the information that is collected by Vodafone through the V Auto application (‘App’) and as part of delivering connectivity and services via your V-Auto device (‘Connected Device’) and how this data will be processed.

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.

Last updated:17/07/2019

Who we are

We are Vodafone Ireland Ltd, a member of the Vodafone Group.

In this privacy policy:

· “we/us”means [Vodafone Ireland Ltd.;

· “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 Ireland, Mountain View, Leopardstown, Dublin 18.

We are registered in Ireland under company number 326967.

Our main switchboard is +353 1 2037000.

V-Auto is powered by our processor, Vodafone Automotive Italia SpA.

How to contact us

Your opinion matters to us –if you have any questions about our privacy policy, you can email us at: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Data Protection Officer

Vodafone Ireland Mountain View Leopardstown Dublin 18 Ireland

Personal information we collect about you

Information we collect about you

The types of information we process about you when you use your Connected Device and the V-Auto App are:

· Your name, address, mobile number, date of birth and email address;

· If we need to verify your identity, documentation such as a passport or other identification;

· Your account information, such as the number of products you have with us, dates of payment owed or received and the make, model and year of the vehicle you have;

· Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;

· 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;

· 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 your mobile device each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

· Information about the V-Sim connectivity, such as the data connections performed and the amount of data consumed, as well as information about the V-Auto device the V-Sim is in;

· Information about your usage of the App, such as how often you use it;

· 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 and you enable location-based services or features. 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; and

· Your driving information such as:

o your trips, so that we can show them to you in the app; and

o your acceleration, braking, driving speed and other driving indicators, so that we can give you feedback on how to make your driving safer and calculate your driving score.

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 V-Auto App in order to improve your experience and troubleshoot.

When we collect your personal information

We collect your personal information when:

• You buy a connected product from us (online, or in store);

• You first register your Connected Device product in the V-Auto App;

• If you’re a non-Vodafone customer, when we verify your identity and you add your payment details;

• You use the V-Auto Application and any of its features (such as Find my Car, Auto SOS, My Trips, and Driver Safety Score);

• You activate and drive with the V-Auto device installed in your vehicle;

• Where a user has nominated you as an additional user to the V-auto product;

• You subscribe to marketing; or

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

Third party sources of data

Where necessary, we collect information from certain organisations. These include fraud-prevention agencies, business directories and credit reference agencies.

Where we have partnered with any third parties for promotions or offers you have participated in, we will share aggregate information between us and these parties to measure the success of the initiative.

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 V-Auto device “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 connectivity for your V-Auto device and its functionalities such as Find my Car, Auto SOS, My Trips, and Driver Safety Score;

· billing and customer care;

· to notify you of any changes to the App or to our services that may affect you; 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 interactions with this App and the data from your V-Auto device 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 MyVodafone account to manage your marketing permissions and to opt out or into receiving personalised marketing. For customers without a Vodafone mobile number, you can manage your permissions in the V-Auto App.

· Contact our customer care 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.ie@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 use automated processing to generate the insights behind the key functionalities of the App. For example, we:

· create a driving score for you. This is based on a number of data inputs such as your acceleration, speed and deceleration; and

· provide you contextual information. For example, in the status screen you’ll get offered to set a parking alert if we detect that your car is moving or you’ll get offered directions to your car if we detect from your phone location that you are nearby it.

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, as described in our privacy policy.

· If you are not already a Vodafone customer, we will use your personal information for identity verification purposes. We sometimes supplement the information we collect about you with information from other sources (such as the electoral roll) This will be prompted to you on first registration of a connected device within the V by Vodafone or V Auto apps. We also use this verification for access to your account and for general account management. However, this identity verification process is supported by human agents that will verify the output of the automated decision.

· 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

Some features of your V-Auto device require us to share information with third parties, but we’ll ask you before we do, as these are optional. For example, when our agents ring you when Auto SOS has detected a collision, we ask you whether you need us to send help to the car’s location. Additionally, when we partner with third parties that can offer you services based on data such as your location, your driving score, or whether you’ve been in an accident we make sure no data is shared unless you actively request us to do so.

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;

· Third parties who you have nominated to view your driver information via the app;

· 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.

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.

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 care team via. v.vodafone.com/ie

Right to correct personal data

If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your My Vodafone account to edit your personal details. Alternatively, please contact customer care on 1907.

Right to access personal data If you are a current customer and would like a copy of your personal data, you can submit your request by logging into your My Vodafone account. If you are not an active customer, please send your request to dataprotection.ie@vodafone.com including details of the account in question or any accounts you have previously had.

We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to data portability You can submit a portability request by this by logging into your My Vodafone account. You will receive your information in a digital, machine-readable format.

Right to object to use of personal data · If you do not want your personal information to be used for any purpose, other than those necessary to provide a service to you, please let us know by selecting your data preferences. You can change your preferences at any time using your My Vodafone account, by selecting ‘settings’ on the My Vodafone App or by calling 1800 200 234. For customers without a Vodafone mobile number, you can manage your permissions in the V by Vodafone App.

How to lodge a complaint If you want to contact us about any of your rights, or to enquire or make a complaint about how we use your information, contact our Customer Services team via v.vodafone.com or by email at dataprotection.ie@vodafone.com We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission. Contact details for the Data Protection Commissioner are:

· Email: info@dataprotection.ie

· Phone: +353 (0)57 868 4757 or +353 (0)761 104 800

· In writing: Data Protection Office, Canal House, Station Road, Portarlington, County Laois, R32 AP23, or Data Protection Office, 21 Fitzwilliam Square, Dublin 2, D02 RD28.

Right to restrict use of your data

If you wish to restrict the use of your data by Vodafone, please email dataprotection.ie@vodafone.com. It is helpful to let us know the reason for your restriction request.

Our cookie policy

How we use cookies

A cookie is a small text file which is placed onto your mobile (or other electronic device) when you access our App. We use cookies on our App to recognise you whenever you visit the App (this speeds up your access to the App as you do not have to log on each time).

Our cookies don't hold personal information such as your name or bank details. They simply let us find information about your browsing experience that we can associate to you if you are logged in.

To do this we sometimes use persistent cookies. We take looking after your personal information seriously – we're always monitoring and improving how we protect it.

We've put our cookies into the following categories, to make it easier for you to understand why we need them:

1. Strictly necessary – these are used to help make our website work efficiently

2. Performance – these are used to analyse the way our website works and how we can improve it

3. Functionality – these help to enhance your experience by doing things like remembering products you've added to your basket

4. Targeting/advertising – these are used to share some information with third parties who we advertise with, so we know how you've reached our website. We can also use cookies to identify the parts of the website you’re interested in. We then use this information to show you adverts and pages we think may also be of interest to you, to tailor how we communicate with you, or to tailor the contents of the communications we send to you. If you prefer, you can opt out of these. Tailoring of content means it includes information reflecting the interest you’ve shown in the content of our web pages, or offers or promotions that we think may interest you, and to improve how we respond to your needs.

Controlling your cookies

You can control how you use cookies in your browser or your device settings.

If you change your cookie settings in your browser, your experience with us won't be tracked.

Information on controlling and deleting cookies is also available at http://allaboutcookies.org

Curve - Smart Tracker – VST001– Privacy Statement

This Privacy Statement explains how we process the information of:

• subscribers whose data may be collected through the V by Vodafone app (‘App’); and

• users whose data may be collected via the Smart Tracker with model ID VST001 (‘Device’).

We take the privacy of our subscribers and 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.

If you are sharing your device with others, as the main account owner you are responsible for ensuring that such users have been made aware of the personal data processing, including location data, as outlined in this statement.

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.

Last updated: 19/07/2021

Who we are

We are Vodafone Ireland Limited, a member of the Vodafone Group.

In this privacy policy:

• “we/us” means Vodafone Ireland 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.

Vodafone Ireland limited is a private Company Limited by Shares, registered in Ireland with registered office at MountainView, Leopardstown, Dublin18. We are registered in Ireland under company number 326967.

Our main switchboard is 1907 or you can email us at dataprotection.ie@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: dataprotection.ie@vodafone.com com or you can write to our privacy team at:

Vodafone Privacy Team

Vodafone Ireland Limited
MountainView

Leopardstown,

Dublin 18

D18 XN97

Ireland

Personal information we collect about you

Information we collect about you

The types of information we process includes;

· Your name, address, mobile number or landline number, date of birth and email address;

· Your account information, such as the number of products you have with us, dates of payment owed or received and the make, model and year of the vehicle you have;

· Your photos or camera settings, if you want to add photos for profile setup, including the user of the device, to their respective profiles (you can revoke these permissions in your phone’s Settings);

· Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;

· 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;

· 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 your mobile handset each time you use the App. For example, we may collect information on the type of mobile device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

· Information about your usage of the App, such as how often you use it or when you dismiss alerts; and

· Your mobile handset or device 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 and you enable location-based services or features. The device will always process location data in order for you to locate the device however, you can turn of location tracking of your mobile handset at any time.

· Information about your interaction with the App and its features, such as voice related activity if you choose to connect your device with another third party device (for example Alexa). If you do, the other device provider will share with us your “voice intents” which includes the content of your requests to enable us to provide and improve your experience and our services (you can stop the sharing of this information with us by unlinking the devices/removing our access to the other 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 the device is using which we can use to assess whether our data allowances are sufficient; and

· We also collect anonymous analytics information on how users use the device and app in order to improve your experience and troubleshoot.

When we collect your personal information

We collect personal information when:

· You first set up your device in the App and set up your profile;

· You use the App and any of its features (for example, setting a geographical zone or changing tracking mode);

· You subscribe to marketing; or

· You contact our customer care teams.

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 device “connected” and we’ll need to process subscriber’s 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 connectivity and features for your device;

· billing and customer care;

· to notify you of any changes to the App or to our services that may affect you; and

· identity verification.

2. Marketing and profiling

If your Vodafone account is opted into marketing and you have given us permission to use your data to tailor these communications, we’ll use your interactions with this App and the data from your Connected Device to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, we can see whether you are getting the most out of your purchase or which Products you already have.

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:

· Contact our customer care team on 1907

·

· Log onto My Vodafone though the Vodafone website or via My Vodafone app to review and change your marketing preferences

· Tell the adviser you no longer want to be marketed to, if you receive an outbound marketing call;

· Email dataprotection.ie@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 and Conditions change. You will still continue to receive those (unless we have indicated otherwise). You may also receive marketing via push notifications if you have not turned them off via your App settings.

3. Service improvement

We collect anonymous, de-identified or aggregated information in order to improve the service we offer to everyone.

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.

We also process call recordings or chat transcripts when you interact with our customer care, for training and quality purposes.

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 (for example our supplier Trackimo who help to build the product);

· 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.

International data transfers

Our customer care centres are run by Vodafone Shared Services which is based in Egypt and India.

The data accessed will only include support ticket data needed to resolve your issues. For example, your phone number or fall detection data is not transferred.

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.

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 Services team online or by calling 1907 or emailing dataprotection.ie@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 Services online or by calling 1907 or emailing dataprotection.ie@vodafone.com

Right to data portability

You have the right to port your data. You can request this by contacting our Customer Services Team online or by calling 1907 or emailing dataprotection.ie@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 our Customer Services team online or by calling 1907 or emailing dataprotection.ie@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 online or by calling 1907 or emailing dataprotection.ie@vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact by post to the Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co Laois.”

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 online or by calling 1907 or emailing dataprotection.ie@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 our Customer Services team online or by calling 1907. 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 https://n.vodafone.ie/privacy.html

Smart Childrens Watch (VKW001) – Privacy Statement

This Privacy Statement explains how we process the information:

• of Administrators whose data may be collected through the Vodafone Smart app (

  ‘App’

  ); and

• wearer’s (

  ‘User’s’

  ), collected via the connected device (

  ‘Connected Device’

  ).

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.

Last updated: 14/07/2021

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.

Last updated: [03 August 2021]

Who we are

We are Vodafone Ireland Limited, a member of the Vodafone Group.

In this privacy policy:

• “we/us” means Vodafone Ireland Limited;

• “you/your” means the user of the account owner or the user of the Connected Device

• “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.

Vodafone Ireland limited is a private Company Limited by Shares, registered in Ireland with registered office at MountainView, Leopardstown, Dublin18. We are registered in Ireland under company number 326967.

Our main switchboard is 1907 or you can email us at dataprotection.ie@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: dataprotection.ie@vodafone.com or you can write to our privacy team at:

Vodafone Privacy Team

Vodafone Ireland Limited MountainView

Leopardstown,

Dublin 18

D18 XN97

Ireland

Personal information we collect about you

Information we collect about you

The types of information we process includes;

· Your name, address, mobile number or landline number, date of birth and email address;

· Your account information, such as the number of products you have with us, dates of payment owed or received and the type of Connected Device you have;

· Your phone’s address book, so that you can add contacts to the group (you can revoke these permissions in your phone’s Settings);

· Your photos or camera settings, if you want to add photos of Group members, including the User of the device, to their respective profiles (you can revoke these permissions in your phone’s Settings);

· 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;

· 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 your Connected Device each time you use the App. For example, we may collect information on the type of device that you are using and its unique device identifier (for example, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface);

· Messages between your phone and the device, this is stored locally on your devices;

· Information about your usage of the App, such as how often you use it or when you dismiss alerts; and

· Your Connected Device 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 and you enable location-based services or features. 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;

· Details of your use of our services – for example, we can see the amount of data the Connected Device is using which we can use to assess whether our data allowances are sufficient; and

· We also collect anonymous analytics information on how users use the Connected Device in order to improve your experience and troubleshoot.

When we collect your personal information

We collect personal information when:

· You first set up your Connected Device product in the App and add your contact details and those of contacts;

· You use the App and any of its features (for example, dismissing alerts or messaging other contacts);

· You subscribe to marketing; or

· You contact our customer care teams with a query.

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 device “connected” and we’ll need to process Administrator's 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 connectivity for your Connected Device;

· billing and customer care;

· to notify you of any changes to the App or to our services that may affect you; and

· identity verification.

1. Marketing and profiling

If your Vodafone account is opted into marketing and you have given us permission to use your data to tailor these communications, we’ll use your interactions with this App and the data from your Connected Device to inform the sorts of marketing we should be sending you so that it’s the most relevant for you. For example, we can see whether you are getting the most out of your purchase or which Products you already have.

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:

· Contact our customer care team on 1907

·

· Log onto My Vodafone though the Vodafone website or via My Vodafone app to review and change your marketing preferences

· Tell the adviser you no longer want to be marketed to, if you receive an outbound marketing call;

· Email dataprotection.ie@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 and Conditions change. You will still continue to receive those (unless we have indicated otherwise). You may also receive marketing via push notifications if you have not turned them off via your App settings.

2. 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.

· Smartcomm for neo [MHV1]

International data transfers

Our customer care centres are run by Vodafone Shared Services which is based in Hungary, Egypt, India and Romania.

Our processor Smartcomm, who provide the platform and will access the data in case there are any troubleshooting queries, will store your data in the EEA

The data accessed will only include support ticket data needed to resolve your issues. For example, your phone number or issues with the device.

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.

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 Services team online or by calling 1907 or emailing dataprotection.ie@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 Services online or by calling 1907 or emailing dataprotection.ie@vodafone.com

Right to data portability

You have the right to port your data. You can request this by contacting our Customer Services Team online or by calling 1907 or emailing dataprotection.ie@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 our Customer Services team online or by calling 1907 or emailing dataprotection.ie@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 online or by calling 1907 or emailing dataprotection.ie@vodafone.com. We’ll do our best to help but if you’re still unhappy, you can contact Data Protection Commission - by post to Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co Laois.

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 online or by calling 1907 or emailing dataprotection.ie@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 our Customer Services team online or by calling 1907. 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 privacy

[MHV1]This is covered in 2^nd bullet point (our partners, suppliers or agents etc.)