Privacy Portal
This Privacy Policy gets updated from time to time; whenever we make a change, we’ll post this on our website and let you know.
We have revised our privacy policy as we are introducing some new features/some new products/ some new ways of working. The main changes are listed below.
Last updated: 23/08/2024
In this policy, we explain how we collect, use, share and protect your personal information when you use our products and services and our website.
You can find the privacy supplements for all our products and services please go to Privacy Portal | Vodacom Lesotho.
Who we are
We are Vodacom (Pty) Ltd (referred to as a "Vodacom") Our registered office is Vodacom Park NO:585 Mabile Road, Maseru Lesotho. We are registered in Lesotho under company number I95/236.
In some circumstances, Vodafone Group Services Limited (VGSL) controls the processing of your personal information jointly with us. The registered office of VGSL is Vodafone House, The Connection Newbury, Berkshire RG14 2FN. We are 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:
Our registered office is Vodacom Park 585, Mabile Road, Old Europa, Maseru 100, Lesotho . We are registered in Lesotho under company number I95/236. Vodacom Lesotho is registered with the Lesotho Company registry.
Your opinion matters to us – if you have any questions about our privacy policy, you can reach us by post at:
Legal & Compliance - Privacy Office
Postal Address:
P.O. Box 7387,
Maseru 100
VODACOM PARK, 585 MABILE ROAD
MASERU 100, LESOTHO or you can contact the contact centre on 114.
You can contact our Data Protection Officer at privacy@vodacom.co.ls
Vodacom 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 portal. We aim to put these commitments at the heart of everything we do.
The information we collect about you and how we collect it can vary depending on the products and services that you use and subscribe to, how you have used the products and services, and how you have interacted with Vodafone even if you aren’t a customer, or what we have obtained from a third party.
We will collect your personal information when you, for example:
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:
Please see the table below for more information.
Below you can find an overview of the categories of personal information 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.
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.
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.
You may connect your sim with a number of third-party devices, either manually with a sim card or electronically through Vodacom products. 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 a product offering. Those third-party device manufacturers will process your personal data in accordance with their privacy policies and we recommend that you read their privacy policies before choosing to connect your sim to their devices.
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 and privacy and cookies policies will apply to how it uses your personal information – please read them carefully.
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
| Contact details Account information Financial details | Performance of your contract |
Billing and Customer Care
| Account information Financial details Your contact with us | Legitimate interest Performance of your contract | Service messages
| Contact details Account information | Soft opt-in legitimate interests. Performance of your contract |
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 through third parties
| Anonymised/ aggregated: Financial details Traffic data | Consent |
Improving and innovating our products and services through third parties
| Anonymised// aggregated: Account information: | Legitimate Interest |
Manage our networks and understand network usage
| Traffic data Location data | Consent |
Improving roaming services
| Anonymised/ aggregated:: Contact details Credential information Traffic data | Legitimate interest |
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 nearest Vodacom shop.
How is your information used? | What data is used? | Lawful basis |
Marketing
| Contact details Your preferences Browsing history Account information Location data | Consent |
Marketing
| Contact details Account information Questionnaire answers | legitimate interest |
Personalised/targeted advertising online
| Cookie data Browsing history Account information | Consent |
Research and analyticsWe 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 Vodafone 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:
| Account information | Legitimate interest |
Profiling consists of the use of personal data in an automated form 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.
How is your information used? | What data is used? | Lawful basis |
Credit checks and ID
| Financial details Account information Credential information | Performance of your contract |
Fraud Prevention, Security and Debt Collection
Fraud management and law enforcement
| Traffic data Account information Financial details | Legitimate interest |
Network Security
| Anonymous and aggregated contact details or credential related information Traffic data | Legitimate interest |
Physical Security
| Images Video footage | Legitimate interest |
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.
How is your information used? | What data is used? | Lawful basis | Legislation applicable |
Accounting and tax requirements | Compliance with mandatory legal obligation | Companies Act No. 18 of, 2011 Income tax Order, 1993 Value added tax act, 2001 | |
Law enforcement purposes
| Compliance with mandatory legal obligation | Criminal procedure and evidence act, 1981 Penal Code Act, 2012 Prevention of corruption and economic offences act, 1999 | |
Complaint handling purposes | Compliance with mandatory legal obligation | Consumer protection guideline and procedure, 2022 Vodacom Lesotho consumer protection code | |
Voice recording of Customer Centre calls | Compliance with mandatory legal obligation | Consumer protection guideline and procedure, 2022 Vodacom Lesotho consumer protection code | |
Sharing caller ID and location data with emergency services | Compliance with mandatory legal obligation | Criminal procedure and evidence act, 1981 Penal Code Act, 2012 Prevention of corruption and economic offences act, 1999 | |
Sharing account data to national registers | Compliance with mandatory legal obligation | Not applicable |
We may need to transfer your information to other Vodafone Group companies (for instance our Vodafone Intelligence Solutions centres located in Egypt, Hungary, Albania and India, who provide customer support) or service providers in countries outside Lesotho and the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This kind of data transfer will happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.
If Vodafone sends your information to a country that is not in the EEA, we will make sure that your information is properly protected. We will always ensure to conduct a transfer impact assessment and 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 EU data protection standards or deemed adequate by the European Commission (a list of adequacy decisions can be found here ), then we will implement additional technical security and organisational safeguards such as asking the third party to enter into a legal agreement containing standard contractual clauses approved by the European Commission that reflects those standards.
We’ll store your information for as long as we must by law. If there’s no legal requirement, we’ll only store it for as long as we need to.
We’re required by law to keep certain personal information about how you use our services for 12 months. Some account information will be held for 1 year from the end of your contract with us.
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 Vodafone services during this time if you haven’t opted out of receiving marketing communications from us.
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.
Right to correct personal data
You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, or you think it may be inaccurate, you can visit any Vodacom Lesotho shop to rectify such information.
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, you can visit any Vodacom Lesotho shop and we will take reasonable steps to confirm your identity before issuing any copy of your personal information.
Right to data portability
You have the right to be able to take with your data you provided to us in certain circumstances. For example, Vodacom ensures that you can take your data with you by allowing you to access your call data records, or any records that have been prompted by you. To do this, visit the nearest Vodacom Shop.
Right to object to processing where we rely on our legitimate interests:
Please visit the nearest Vodacom shop.
Right to withdraw consent
You can withdraw your consent any time after giving it. Depending on how you provided your consent you should be able to withdraw your consent in the same way. You can also contact our customer care team or visit the nearest Vodacom shop.
Right to restrict use of your data
If you feel the data we hold on you is inaccurate or believe we shouldn’t be processing your data, please contact our customer care team or visit the nearest Vodacom Shop 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 114/115 or visit the nearest Vodacom Lesotho Shop. If your contract with Vodacom has been terminated, we may still have lawful grounds to process your personal data.
To opt out of Marketing messages:
If you no longer want to receive marketing messages from Vodafone, you can elect to opt out of all marketing communications or only selected methods (SMS, phone or post).
There are various ways to opt out:
Opting out does not mean that you won’t any longer receive service-related messages. You will continue to receive those (unless we have indicated otherwise).
To opt out of receiving marketing communications from other Vodafone Group companies, just contact them directly.
In some cases, you may receive marketing from Vodacom, even if you’re not a customer or never had contact with Vodacom. This is a result of third-party marketing lists which Vodacom may acquire from time to time. If you’ve registered to opt out of such marketing, you shouldn’t receive such communications. If you do, we ask that you let us know immediately.
To manage Cookies and understand more about what they are:
Want to disable a cookie, or understand more about what these are? Check the Cookies Policy section of this policy for full details on how to do this.
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, or visit the nearest Vodacom shop. We’ll do our best to help but if you’re still unhappy, you can contact Lesotho communications authority (LCA).
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