In this policy, we explain how we collect, use, share and protect your personal information when you use our products and services, visit our website or interact with us.
Last updated: 1 December 2020
We are Vodafone Roaming Services S.à r.l. (VRS). We use other Vodafone entities and members of the Vodafone Group to deliver global business products and services.
We will act as the Data Controller or Processor for a range of your personal data and will be supported by other organisations within the Vodafone Group.
“Vodafone”, “we”, “us”, “our” means VRS; “third party” means someone who is not you, us or a Business Customer; “Business Customer” means the business customer which has entered into a Services Agreement with Vodafone or another member of the Vodafone Group for Vodafone Business products and Services; 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 15, rue Edward Steichen, L-2540 Luxembourg, Grand Duchy of Luxembourg. We are registered in Luxembourg under company number B125883.
Because we are always looking to help Business Customers with new innovative products and services, this notice may change over time, so we would encourage you to check it regularly. If we make a major change, we will post this on our website.
Vodafone is committed to respecting your privacy. We take privacy, security and complying with data protection and privacy laws seriously.
We have set out our core Privacy Commitments in our Privacy Centre. We aim to put these commitments at the heart of everything we do.
Personal information we collect about you
The information we collect about you and how we collect it can vary depending on (a) the VRS products and services that you use; (b) how you use the products and services; (c) how you have interacted with Vodafone even if you aren’t a customer, and (d) the information that we have obtained from a Business Customer or third party with permission to share such information with us.
Vodafone will process your personal data based on:
The performance of a Service Agreement with a Business Customer, when a Business Customer contracts with Vodafone for services, the Business Customer provides information about itself as a legal entity and also information about you as an individual if you are an employee of the Business Customer or a user of the services for the purpose of for example order fulfilment/delivery, customer service, sending bills, account set up, account relationship management; or
Vodafone’s legitimate business interests, including for example, maintaining the security of our network and services, marketing and improvement of our products and 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; or
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 in certain circumstances to restrict usage of your data, which control the scope of legal assistance to be provided; or
Consent you provide where Vodafone does not rely on another legal basis for such processing, for example to send you marketing communications based on products and services you have expressed an interest in. You may withdraw your consent to Vodafone sending you marketing communications at any time. Visit the Your Rights section of this policy for information on how to withdraw your consent.
We can collect your personal information when you:
Use any of our products and services;
Use our networks or the networks of a Vodafone Group company;
Subscribe to newsletters, alerts or other services from us;
Contact us in any way, or ask for information about a product or service;
Take part in a competition, prize draw or survey;
Visit or browse our website or other Vodafone Group websites;
Have given permission to other companies, such as our business or joint-venture partners as well as our third-party suppliers or contractors, to share information about you or the company you represent;
Where your information is publically available; or
Are the user of the products and services of a business that we acquire.
We may collect information from certain organisations, where appropriate and to the extent we have legal grounds to do so. These include business directories.
For more details on this and how to opt out of these, please see Cookies for more information.
The types of information we may collect or process are, for example:
Identification information: Your name, title, address, employee number, phone and/or mobile number, and email address;
Billing information: Data necessary to calculate charges and process a payment for your use of our products and services;
Your contact with us: Such as a note or recording of a call you make to one of our contact centres, a Live Chat, an email or letter sent, or other records of any contact with us, including complaints and complaint history or your requests to access your personal data;
Your account information: Such as subscriptions you use, account numbers or other information related to the business account you use;
Credential information: Such as passwords, hints and similar security information used for authentication and access to accounts and services; and/or
Cookies: See Cookies for details on what we collect using cookies, web beacons and other technologies, including ad data; and
How you use our products and services: Information detailing things like 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.
How we use your personal information
We will use your personal information for the following purposes:
Processing orders and to provide you with products and services
Process the products and services ordered by you as the person authorised by our Business Customer to place orders when you are the employee, agent, affiliated or customer of our Business Customer, and to deliver those orders and keep you updated with the progress of the order where required.
Billing and Customer Care
Calculating charges and process payment for the products and services you use;
Respond to any questions or concerns that you may have about our network, products or services for example when you contact our customer care.
Improving and innovating our products and services
We collect anonymous, aggregate information in order to improve the service we offer to everyone. None of these analytics are linked back to you in any way.
Managing our networks and understanding network and services usage
To protect our networks and manage the volumes of traffic coming through 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;
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 customizing our products and services.
We may use your personal information for identity verification purposes, for example for access control to our services via logins and for general account management and/or administration.
Marketing communications include things like updates on new products and services, newsletters, event invites, thought leadership articles and blog updates.
Examples of the ways we might use your information for marketing purposes include:
Sending you email marketing communications after you subscribe on our website. The type of content we send you will be specific to the preference(s) you have signed up to.
When you are the contact for one of our existing Business Customers or a customer of one of Vodafone Group’s partner organisations, we may send you email marketing communications for similar products/services.
Sending you email marketing communications based on permission you provided to a third party organisation to share your details with us.
A member of our sales team calling you back after submitting a “contact me” enquiry on our website, or expressing an interest in one of our products or services
Sending you an invite to complete a survey when you are the contact of one of our existing Business Customers, or after a recent interaction with our sales team.
Performing internal analysis on the billing/usage data related to your use of our services to determine whether the Vodafone Business Customer package you use when for example you are the employee of our Business Customer is right for our Business Customer.
Contacting you as the contact of a Business Customer close to, or after, the expiry of the Business
Customer contract to discuss renewal options
Some of these marketing activities will be undertaken by third parties (other organisations), acting on Vodafone’s behalf. A data processing agreement will be in place to ensure your information is only used for the specified purpose.
Remember that opting out of interest-based advertising won’t stop advertisements from being displayed – but they won’t be tailored to your interests.
How we share your personal information
Companies in the Vodafone Group;
Partners, agents or suppliers involved in delivering the products and services to our Business Customer; and
Companies who are engaged to perform services for, or on behalf of, Vodafone.
We may also share personal information about you with our Business Customer only where required for example to allow the Business Customer to verify the payment to us of the products and services you use when you are an employee, agent or customer of our Business Customer, or the person authorised by our Business Customer to access and use those products and services.
Law enforcement and disclosures related to regulatory requirements
We may need to release your information to comply with our legal obligation to respond to the authorities’ lawful demands, for example law enforcement agencies, government bodies, courts or other public authorities. Your personal data shall only be provided when we in good faith believe we are obliged to do so in accordance with the law and pursuant to an exhaustive evaluation of all legal requirements.
We may also share your information with a third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.
Mergers and Acquisitions
If we’re re-organised or sold to another organisation we will provide your information to that organisation.
Third parties that we work with
International data transfer
We may need to transfer your information internationally to other Vodafone Group companies or service providers. 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 country where we offer our services, or if you use our services and products while visiting other countries.
If Vodafone transfers your information internationally, we will make sure that it is done in compliance with the legislation in force, and your information is properly protected.
How long we keep your personal information for
We will retain your personal information for no longer than is necessary to fulfil the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.
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. Please ensure that you read that third party 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.
For more information on how we keep your data secure visit our Privacy Centre.
For more information about your rights, contact us at [email protected]. If our policy does not answer your concern/s you may wish to make an individual rights request to Vodafone.
Please put your request in writing and submit to the postal address or email address below.
Note that as we provide business solutions it may not be possible for us to verify your identity without the help of our Business Customer who might be your employer or the organisation that has authorised your access to, and use of, our products and services. In this case if you want to continue with your request you understand that we would need to ask our Business Customer to verify your identity.
How to contact us
General privacy enquiries and complaints
Vodafone Roaming Services S.à r.l.
Legal Team – Data Privacy Officer
15, rue Edward Steichen
Grand Duchy of Luxembourg