We will use your Personal Information for a number of purposes ranging from enabling us to provide you with the products or services you have requested to ensuring we are keeping these secure from fraud.
We may use Artificial Intelligence (A.I.) to help us provide you with a requested product or service. If we use A.I. we will do so responsibly, and where necessary we will disclose that the content is generated by A.I.
Whenever we use your Personal Information, we do so based on a specific lawful bases under data protection law listed below:
- The performance of your contract or to enter into the contract and to take action on your requests. For example, so you can make calls and texts, and browse the internet on your phone, we process things like the numbers you dial, how much data you’re using and when you’re doing it so we can provide connectivity. This also enables us to generate your bill, based on your usage. We also need to conduct credit checks when you apply for a product or service to verify your suitability for entry into such a contract.
- Vodacom’s legitimate business interests for example, fraud prevention, prevention of tax evasion and financial crime, maintaining the security of our network and services, direct marketing, and the improvement of our services. Whenever we rely on this lawful basis to process your Personal Information, we assess our legitimate interest 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.
- Protecting your legitimate interests – for example, providing notifications regarding network availability and performance in your area, notification of emergency services, and fraud prevention. For more information, visit the 'Your rights' section of this policy.
- Compliance with a mandatory legal obligation, including for example, where a particular law requires Vodacom to process Personal Information for a defined purpose.
- Consent you providewhere Vodacom does not rely on another legal basis (referred to above). Consent may be withdrawn at any time. When you give your consent, you will be given details on how to change your mind or visit the “Your rights” section of this policy for more information.
Third parties that we work with
We are not in the business of selling your data, we only share with suppliers who help us to provide services.
When you’ve purchased Vodacom products and services using a third party or partner organisation, we often need to exchange information with them as part of managing that relationship and your account – for example, to be able to identify your order and be able to pay them.
If we have a contract with a service provider or contractor to provide us with services or provide a service on our behalf, they may have access to your Personal Information. We don’t authorise them to use or disclose your Personal Information received from us except in connection with providing their services.
We collect and combine information in order to monitor your use of products and services, and that of our other customers, as well as to help us to improve the quality of our products and services. We provide this information to third parties (for example, to content providers and advertisers), but any such third-party reporting shall not include information which may identify an individual customer.
Mergers and Acquisitions
If we reorganised or merged with or divested part of our business to another organisation we may need to provide your information to that other organisation or their advisers or receive Personal Information from that other organisation.
Third party devices that you connect your sim with
You may connect your sim with a number of third-party devices, either manually with a sim card or electronically through our One Number product. These may include mobile phone devices or connected devices such as smart speakers or smart watches. When you connect your sim with these devices those third parties may record your sim details or your interaction with the network and provide that information to Vodacom for purposes of validating your eligibility for the OneNumber product offering. Those third-party device manufacturers will process your Personal Information in accordance with their privacy policies and we recommend that you read their privacy policies before choosing to connect your sim to their devices.
Third party products that you buy through your Vodacom account
Where you buy a third-party product or service through your Vodacom account (such as Charge to Bill for mobile), the contract for it is with the party selling that product or service. Vodacom is only charging the amount directly to your bill as part of its arrangements with the seller. As part of this, you’re agreeing that Vodacom may pass certain Personal Information to the seller to complete your purchase with them.
The seller’s terms and conditions, privacy and cookies policies will apply to how it uses your Personal Information – please read them carefully.
Below you can find an overview of the categories of Personal Information (not an exhaustive list) we process about you, the purposes for which we process that Personal Information and the lawful basis upon which we rely to conduct that processing.
a. To provide you with your service
It is necessary for us to process your Personal Information to enable us to provide you with your service. By service we mean any services or products that you buy or use such as broadband, mobiles, use of our apps or smart tech products.
| How is your information used? | What data is used? | Lawful basis |
To process your order and provide you with your products and services · To process the products and services you’ve bought from us, install equipment at your property or deliver equipment to you and keep you updated with the progress of your order. · To provide the relevant products or services to you. This includes other services not included in your agreement with us, (e.g. PayPal), services that use information about where you are, and to contact with you messages about changes to the products or services. · Where you’ve purchased Vodacom products and services using a third party or partner organisation, we often need to exchange information with them as part of managing that relationship and your account – for example, to be able to identify your order and be able to pay them. | Basic Personal Information Contact details Account information Financial details | Performance of your contract |
Billing and Customer Care · 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. | Basic Personal Information Account information Financial details Your contact with us | Performance of your contract |
Service messages · 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, price plan and data use, upgrade you might be entitled to, roaming or service interruptions. | Basic Personal Information Contact details Account information | Performance of your contract |
b. To improve our service
We collect information such as on your use of our products and services on an aggregated or anonymous basis in order to help us manage and improve the services we offer to everyone.
| How is your information used? | What data is used? | Lawful basis |
Improving and innovating our products and services · We anonymise, de-identify 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. · We conduct surveys to understand various aspects of our interaction with you, the use of our services and products and the network. | Anonymised/ aggregated: Financial details Traffic data | Legitimate interest |
Improving and innovating our products and services through third parties · We collect and combine information in order to monitor your use of products and services, and that of our other customers, as well as to help us to improve the quality of our products and services. We provide this information to third parties (for example, to content providers and advertisers) but any such third-party reporting shall not include information which may identify an individual customer. | Anonymised/ aggregated: Account information | Legitimate Interest |
Manage our networks and understand network usage · 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. | Traffic data Location data | Performance of a contract |
| · 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. | Legitimate interest |
Improving roaming services · To improve your roaming experiences and understand how Vodacom is performing in providing roaming services, whether Roaming Services and related products are working as intended, or whether improvements are needed to make roaming better. Vodacom uses Personal Information such as your name, email address, password, mobile phone number and call records in order to do this. | Anonymised/ aggregated: Basic Personal Information Contact details Credential information Traffic data | Performance of contract |
| Vodacom creates aggregated and statistical management reports from this information that do not identify you individually. Vodacom may also take this Personal Information and anonymise it so that more in-depth analysis of our roaming services can be undertaken. This helps Vodacom to develop its roaming services for customers without identifying users in an individual way. | Legitimate interest |
c. Marketing and tailoring our service to you
We process your Personal Information for marketing and advertising purposes, such as to let you know about new products or services and send you special offers, as well as to help us tailor our service to you.
You can control your marketing permissions and the data we use to tailor these communications at any time by visiting the section “Your Rights” in this policy.
| How is your information used? | What data is used? | Lawful basis |
Marketing · We process this data for the purpose of sending you marketing communications in the manner outlined in the row below. We can further tailor these messages using your calling and messaging activities, location information and browsing information, if you have authorised that we process this information for this purpose. · If you have given your permission, we will also contact you to let you know about products and services of other Vodacom Group companies that are not same/similar to the products and services that you have bought including Vodacom Financial Services and Vodacom Insurance; Vodacom Payment Services and those of other companies which we think may interest you depending on your marketing preferences. | Basic Personal Information Contact details Your preferences Browsing history Account information Location data | Consent |
Marketing · As our customer, we will keep you informed generally about new products and services, send you newsletters or white papers, invite you to participate in a survey or let you know about offers, promotions, prize draws or competitions. We tailor these messages based on the sorts of products and services you’ve bought from us (for example, we know not to market to you if you’re in the middle of your phone contract). · We’ll contact you by post, online, phone or push notifications through our apps. | Basic Personal Information Contact details Account information Questionnaire answers | Legitimate interest |
Personalised/targeted advertising online · 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. It can be on websites belonging to Vodacom, those of other organisations as well as other online media channels such as social media sites. We may also combine data collected via the cookies with other data we have collected. If you don't want any information processed through the use of cookies, check our cookies section. It explains how to control and opt out of cookies. · Remember that not providing consent for interest-based advertising won’t stop advertisements from being displayed – but they won’t be tailored to your interests. | Cookie data Browsing history Account information | Consent |
Research and analytics We use a variety of analytics methods including what is commonly referred to as “Big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets (that is why it is “big” data) to uncover hidden patterns and hitherto unrevealed trends. At Vodacom we take governance of big data 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 for anonymisation and de-identified techniques where appropriate. We use our analytics to: · Market research and to carry out research and statistical analysis including to monitor how customers use our networks, products and services on an anonymous or personal basis; · Frame our marketing campaigns and determine how we might personalise those; · Provide reports to third parties (such reports don’t contain information which may identify you as an individual). These can be to third parties such as content providers and advertisers or as part of Vodacom Analytics. | Account information Basic Personal Information | Legitimate interest |
d. Profiling, Fraud Management and Security
Profiling consists of the use of Personal Information in an automated form (automated decision) in order to evaluate certain personal aspects relating to an individual. We will process your Personal Information in this way for credit, fraud and security purposes. When we conduct such profiling or automated decision-making activities, we will do so in accordance with the provisions of the relevant legislation or lawful requirement.
| How is your information used? | What data is used? | Lawful basis |
Credit checks and ID · We will carry out a credit check when you apply for a contract for any products or services with us. · We will also use your Personal Information for identity verification purposes, for access to your account and for general account management. We sometimes supplement the information we collect about you with information from other sources (e.g. Home Affairs, Credit reference agencies) to assess the accuracy of the information that we hold. | Basic Personal Information Financial details Account information Credential information | Consent |
Fraud Prevention, Security and Debt Collection · We will process your traffic data to protect against and detect fraud, to protect and detect misuse or damage to our networks, to recover debts or trace those who owe us money resulting from the use of our services. | Basic Personal Information Traffic data Account information Financial details | Legitimate interest |
Fraud management and law enforcement · We may be obligated to release information to law enforcement for purposes of fraud prevention. | Obligation in law |
| · Processing for the purpose of protecting us against fraud, defending our rights or property, or to protect our legitimate interests or the interests of our customers. | Performance of a contract/Legitimate interest |
Network Security · We will process your traffic data in order to protect and detect misuse or damage to our networks or to detect and resolve fraudulent use of our networks (and our partner roaming networks) and to solve technical issues you are experiencing. | Anonymous and aggregated contact details or credential related information Traffic data | Legitimate interest |
Physical Security · We may use CCTV footage to safeguard our stores and sites. | Images Video footage | Legitimate interest |
e. To comply with mandatory legal obligation
Under certain circumstances, it is necessary for us to process your Personal Information in order to comply with the law, for example, when responding to law enforcement requests for data or to comply with tax requirements. which are subject to strict internal policies, procedures, and your right to restrict usage of your Personal Information, which control the scope of legal assistance to be provided. We are also required to also process your Personal Information pursuant to legislation including but not limited to the Financial Intelligence Centre Act, 38 of 2001 (FICA), the Regulation of Interception of Communications and Provisions of Communication-related Information Act 70 of 2002 (RICA), the Electronic Communications and Transactions Act, 2002 (ECTA), the Electronic Communications Act, 2005 (ECA), the Consumer Protection Act, 2008 (CPA), the Promotion of Access to Information Act, 2000 (PAIA), and the Cybercrimes Act, 2020.
