Smart Childrens Watch

We are Vodacom (Pty) Ltd (hereinafter referred to as “Vodacom”).  Our registered office is 082 Vodacom Boulevard, Vodavalley, Midrand, 1685. We are registered in the Republic of South Africa under company number 1993/003367/07.

In some circumstances, other Vodacom Group and Vodafone Group Companies including Vodafone Group Services Limited (VGSL) controls the processing of your personal information jointly with us or as our operator. The registered office of VGSL is Vodafone House, The Connection Newbury, Berkshire RG14 2FN. Registered in England under company number 03802001. Unless otherwise specified in a separate privacy statement, the way your personal information is processed will remain compatible with the wording of this privacy statement.

In this privacy policy:

“we/us” means Vodacom (Pty) Ltd;
“you/your” means the user of the account, or the user of the Connected Device
“third party” means someone who is not you or us; and
“Vodacom Group” means Vodacom Group Limited and any company or organisation in which Vodacom Group Limited owns more than 30% of the share capital

“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 main switchboard is [+27 (0)11 653 5000] or you can email us at customercare @vodaocom.co.za

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
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.

Vodacom will process your personal information 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. 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 personal information, 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 personal information, which control the scope of legal assistance to be provided; or
4. Consent you provide where Vodacom does not rely on another legal basis (referred to above). 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 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.

2. Marketing and 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 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.

If you no longer want to receive marketing messages from Vodacom, you can choose to opt out at any time. If you’ve previously opted in to receive personalised content based on how and where you use our network, you can also opt out at any time.
The easiest way to opt out is by using our marketing preferences page, found under your My Vodacom account settings.
There are also various other ways to opt out:
• Contact our customer services team at 082 135 or [email protected].
• Click the link at the end of a marketing email, text or picture message to unsubscribe from that channel
• Change your communication preferences by dialling *135*181#
• Tell the customer care agent if you receive a marketing call
• 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
• Contact our customer care team 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 device settings




3. 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 and/or 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, Vodacom (Pty) Ltd, 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.

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, will store your data in the EEA, who will access the data incase there are any troubleshooting queries.

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 South African data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.

We may not retain your personal information any longer than is necessary for achieving the purpose for which your personal information was collected or subsequently processed, unless:

- The retention of your personal information is required or authorised by law;
- We reasonably require your personal information for lawful purpose related to our function or activities;
- The retention of your personal information is required by a contract that we enter into with you; or
You or competent person consent to the retention of personal information relating to a child.

We have specialised security teams who constantly review, improve, and ensure the implementation of appropriate, reasonable technical and organisational measures to protect your personal information from unauthorised access, accidental loss, disclosure, or destruction. We are required in terms of PoPIA to notify you and the Information Regulator, if any of your personal information has been compromised.

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. You are therefore required to 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 https://v.vodafone.com/za/contact


Right to correct personal information

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 access personal information

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 object to use of personal information

You have the right, in certain circumstances, to object to Vodacom processing your personal information. In order for Vodacom to provide you with products and services, Vodacom is required to process your personal information and as such the provision of your personal information is mandatory and you may not object to same in order to continue using our products or services. For more information or to exercise this right, please contact our Customer Services team at 082 135 or [email protected]. If this relates to an automated decision performed on you (this means with no human involvement), please let us know and we will review your request..
How to lodge a complaint

If you want to contact us about any of your rights or 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 contact our customer care teamon 082 135 or [email protected]. 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]
Right to restrict use of your personal information

If you feel that the personal information we hold on you is inaccurate, or you believe we shouldn’t be processing your personal information, please contact our Customer Services team on 082 135 or [email protected]. to discuss your rights. In certain circumstances, for example where you contest the accuracy of your information, or where Vodacom no longer requires your information for achieving its purpose but must maintain it for purposes of proof, you have the right to ask us to restrict processing.
Right to deletion

Vodacom strives to only process and retain your personal information for as long as we need to. In certain circumstances, for example, where you indicate that your personal information is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, you have the right to request that we erase your personal information that we hold. If you feel that we are retaining your personal information longer than we need, it is worth first checking that your contract with Vodacom has been terminated, which you can do with Customer Services on 082 135 or [email protected]. If your contract with Vodacom has been terminated, we may still have lawful grounds to process your personal information.
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 the service or support to you.