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 Smart SIM 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 Vodacom 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.

Vodacom 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. Vodacom’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 Vodacom 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 Vodacom, 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 Vodacom consumer mobile customer, you can log in to your MyVodacom account to manage your marketing permissions and to opt out or into receiving personalised marketing. For customers without a Vodacom mobile number, you can manage your permissions in the Vodafone Smart App (previously known as the V by Vodacom App) (the “App”).

Contact our customer services team via Vodacom.co.za;
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 [email protected] 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 Vodacom 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, Vodacom Limited, or Vodacom 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 Designed & Connected by Vodacom partners to understand how products and the Designed & Connected by Vodacom 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-Vodacom 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 Vodacom Shared Services which is based in Hungary, Egypt, India and Romania.

When Vodacom SA sends your information to another country, 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 South African 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 Vodacom 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.Vodacom.co.za.

Right to correct personal data
You have the right to have your personal data corrected if it is incorrect. You can request this by contacting our customer care via v.vodacom.co.za.

Right to access personal data
You have the right to make a request for a copy of the personal data that Vodacom holds about you. To make this request as an individual or an authorised 3rd party, please contact the customer care team via. v.vodacom.co.za.

Right to object to use of personal data
In certain circumstances, You have the right to object to the use of your personal data. Contact the customer care team via vodacom.co.za.

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 care team via vodacom.com. We’ll do our best to help but if you’re still unhappy, you can contact the Information regulator – their details are at http://www.justice.gov.za/inforeg/.

Right to restrict use of your data
If you feel data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our customer care team via v.vodacom.co.za to discuss your rights. In certain circumstances you will have the right to ask us to restrict processing.

Right to erasure

Vodacom 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 Vodacom has been terminated which you can do with Customer Services. If your contract with Vodacom has been terminated, we may still have lawful grounds to process your personal data. For more information on retention periods please see our www.vodacom.co.za/privacy.