Privacy Supplement

Vodacom Fantasy League is a service that offers the ability for a fan i.e Vodacom subscriber, to play a Vodacom Fantasy League soccer game, where Vodacom subscribers can assemble an imaginary team of real life players and score points based on those players’ actual statistical performance in real matches. It is a premium service, and can only be accessed by paying for access.

Vodacom Fantasy League covers the South African Premier Soccer League and the English Premier League.

Vodacom subscribers will be asked to play Vodacom Fantasy League by purchasing a recurring daily R3 subscription giving them access for 24 hours on each successful day of billing. Subscribed users will also receive ongoing content updates sent to their device via SMS as part of the convenience of playing.

Due to the method of billing from the subscriber’s airtime, the Vodacom Fantasy League service is currently only available to Vodacom subscribers

Your opinion matters to us – if you have any questions about this privacy supplement, you can email us at: [email protected] or you can write to our privacy team at:

The Privacy Office – Legal Affairs
Vodacom (Pty) Ltd
Corporate Park
082 Vodacom Boulevard
Midrand
1685

Information we collect about you

In order to enable you to make use of the App and provide the service through the application, Vodacom Fantasy League collects the below information about users:

• MSISDN (Mobile Number) – This is used to manage and provide the service, to authenticate the user via OTPs (one time PINs), and to subscribe and bill the user as it relates to the service provision;
• User Name (Not the actual customer name)- this is used to communicate to the user by a name specified by the user, where appropriate or required to do so, as well as to identify the user on leaderboards in the service;
• Information on how you use the service, such as the date, time and length of your usage
• Consent management – this is used to obtain permission for:

- Subscription and billing for the service
- Sending related messages to you

We might also use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our website). These collect information that tells us how you use our websites, web-related products and services.

This, in turn, helps us make our website relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our website again. See the next section for more details.

You can choose to refuse cookies, or set your browser to let you know each time a website tries to set a cookie.

Personal information we collect about you

We collect your personal information when:

• You subscribe to the service;
• You use the service.

Vodacom will process your personal information based on:

• Vodacom’s obligation – to provide you with the service you have asked for;
• Vodacom’s legitimate business interests – when it comes to developing and improving the service to gain insights through app analytics;
• Your communication preferences.

Your personal information is collected for the purpose of being used and processed in:

• providing the Service, enabling your subscription, and billing your account;
• personalising the Service to your respective preferences,
• for the serving of appropriate, tailored advertising to you via the Service,
• for the purpose of tracking the Service’s performance,
• troubleshooting, data analysis, testing, research and service improvement and/or to identify any technical issues that may occur from time to time,
• for use in devising additional enhancements or improvements to the Service, ;
• statistical, tracking, redundancy and audit purposes; and
• Contacting you with offers or promotions for similar, related services (you will be afforded the opportunity to opt out of those messages specifically should they be sent to you).

We may share information about you with:

• companies in the Vodacom and Vodafone Group (Vodafone Group Plc and any company or other organisation in which Vodacom owns more than 15% of the share capital);
• partners or agents involved in delivering the Services;
• companies who are engaged to perform Service for, on behalf of Vodacom (Pty) Ltd including Vodafone Limited, or the Vodafone Group, being Fanclash SA (Pty) Ltd, Upstream Systems South Africa (Pty) Ltd and Altron TMT (Pty) Ltd;
• law enforcement agencies, regulatory organisations, courts or other public authorities if we have to, or are authorised to by law.

We will release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.

If we are reorganised or sold to another organisation, we may transfer any personal information we hold about you to that organisation.

We may need to transfer your information to other group companies or service providers in countries outside South Africa. This may happen if our servers or suppliers and service providers are based outside South Africa, or if you use our services and products while visiting countries outside this area.

The personal information processed in connection with Vodacom Fantasy League will be retained for a period of 5 years for audit purposes should you choose to cancel your account.

Vodacom may retain aggregated and statistical reports about use of the Vodacom Fantasy League Application but these reports will not identify you as a user.

In case you need more information on how Vodacom uses your personal information and/or maintains the security of your information, and your rights to access and/or delete the information Vodacom holds, please contact the Privacy Officer at [email protected]

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.

If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we will make sure they have appropriate security measures and only process your information in the way we’ve authorised them to. These organisations will not be entitled to use your personal information for their own purposes. On a regular basis, our security teams will check them to make sure they meet the security requirements we have set.

At Vodacom, we are committed to processing personal information honestly, ethically, with integrity, and always consistent with applicable laws and our values. Below we set out details on how you can exercise your rights. Please note, under certain circumstances these rights may be limited if we still have lawful grounds to process your personal information. If you have a question or cannot find the answer, please contact our Customer Care.

Right to correct personal information

You have the right to make a request for a copy of the personal information that Vodacom holds about you. The only personal information we will hold is your leader board activity which you will be able to see within the app.

Right to object to use of personal information

You have the right, in certain circumstances, to object to Vodacom processing your personal information.

If you want to opt out of the Vodacom Soccer Fantasy League service and content messages;

• dial *117*177#, and go to “Fantasy”, “Settings”, “Cancel messages” and cancel the messages as you prefer; or
• send an email with your request to [email protected].

Please note you may not opt out of system messages.

Right to deletion

You have the right to make a request for deletion of the information that Vodacom Fantasy League holds about you. You will need to have cancelled your subscription to do this, and send a request to [email protected].

How to lodge a complaint

Should you believe that Vodacom has used your personal information contrary to applicable law, you undertake to first attempt to resolve any concerns with Vodacom directly. Kindly click our customer care team. We will do our best to help but if you are still unhappy, you can contact the Privacy Office at [email protected]. If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator at

The Information Regulator (South Africa)
JD House
27 Stiemens Street
Braamfontein
Johannesburg
2001

Email: [email protected]

Complaints email: [email protected]