Vodacom Lesotho

1. Contact details Such as your name, address, phone and/or mobile number and email address;
2. Financial details Such as your credit or debit card information, information about your bank account and other banking information – for example, you’ll have to give us this information when you open an account with us. We’ll collect the data necessary to process a payment whenever you make a purchase;
3. Your traffic data Every time you use your mobile phone, a record is kept. This includes the number you called or sent an SMS or MMS to, the length, date and time of that call, SMS or MMS, the amount of data you are using and your approximate location at the time that the communication takes place (based on the location of the nearest cell that you sent that call or message from). The same is also recorded every time you receive an incoming call or message. This is data we see as part of providing you with connectivity; we don’t, however, keep a record of the content of your calls or messages.
4. Information about your device or connectivity such as IP address, IMEI and MSISDN.
5. 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 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;
6. 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;
7. Your account information Such as your date of birth, gender, dates of payment owed or received, subscriptions you use, account numbers or other information related to your account or included in My Vodacom app;
8. Credential information We’ll collect passwords, hints and similar security information used for authentication and access to accounts and services;
9. Your preferences for products, services and lifestyle activities when you tell us what they are, or we assume what they are, based on how you use the products and services;
10. Cookies See the Cookies Policy for details on what we collect using cookies, web beacons and other technologies, including advertising data;
11. Your browsing history If you have given your permission, Vodacom collects the categories of website you have browsed on your mobile, device or PC, for example Sports, Music or News. However, we don’t have a history of the sites you browse, as this is limited for a short period of time to enable the connection to be made. We use these interests to send you personalised marketing or show you personalised advertising. You can opt out of advertising through Cookies or, in the case of marketing, your privacy settings ,
12. 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; or your viewing history if you use our V-Live products for example.
13. Details of your use of the specific services or products for example V-Live products . You can refer to the specific privacy supplement for each product/service for more information on the data processed.

How we use your personal information and our lawful basis to do so

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:

1. The performance of your contract or to enter into the contract and to take action on your requests for example, so you can make calls and texts, and browse the internet on your phone, we process things like the numbers you dial, how much data you’re using and when you’re doing it so we can provide connectivity. This also enables us to generate your bill, based on your usage. We also conduct credit checks when you apply for a product or service, which is operated on a bill pay basis to verify your suitability for entry into such a contract.
2. Legitimate interests of Vodacom 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 legitimate 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.
4. Consent where you have provided it by your own free will. Consent may be withdrawn at any time. See below ‘Your Rights’ for more information on how to do this.

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.

To provide you with your service

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.

To improve our service

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.

Marketing and tailoring our service to you

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.

Profiling, Fraud Management and Security

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.

To comply with mandatory legal obligation

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 we share your personal information

1. Companies in the Vodafone Group
2. Partners or agents involved in delivering the products and services you’ve ordered or used.
3. Companies who are engaged to perform services for, or on behalf of, Vodafone Limited, or Vodafone Group.
4. Credit reference, fraud-prevention or business-scoring agencies, or other credit scoring agencies.
5. Debt collection agencies or other debt-recovery organisations.
6. Law enforcement agencies, government bodies, regulatory organisations, courts, or other public authorities if we have to, or are authorised to by law.
7. A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.
8. Emergency services (if you make an emergency call), including your approximate location.
9. Third parties for joint promotions with that third party.
10. Partner organisations we’ve carefully chosen so they can contact you about their products and services (which may or may not include Vodafone products and services). We’ll ask for your consent before sharing this information. Other third parties when you are signing up to their service and it is used by them for authentication and fraudprevention purposes.
11. Third parties that we advertise with, such as Facebook, in order to serve you advertisements online.
12. Third parties that we use to serve you marketing.

International Data Transfers

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.

How long we keep your personal information for

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.

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. 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.

Your rights

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:

1. Dial the relevant products USSD to manage your permissions.
2. Contact our customer care team – see the contact us page.
3. Tell the adviser if you receive a marketing call.
   Contact the customer care team for guidance or visit the nearest Vodacom shop.

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).