Last updated: 31/08/2018
The merged entity arising out of the merger of erstwhile Vodafone India Limited & Vodafone Mobile Services Limited with and into Idea Cellular Limited to form “Vodafone Idea Limited” (hereinafter ‘Company’) is committed to protecting the privacy of personal information of our customers which has been provided to us or collected by us when you use our products and services which are operated under different brands. Our Privacy Statement is designed and developed to understand the privacy and security of customers’ personal information.
Definition of Personal Information
Personal Information includes:
Personally Identifiable Information (hereinafter referred to as PII): “Personally Identifiable Information” is information that is about, or can be related to, an identifiable individual. It includes any information that can be linked to an already identified individual or used to directly or indirectly identify an individual. Personal information does not include information that is anonymous, aggregated, or is no longer identifiable to a specific person.
Sensitive Personal Data or Information (hereinafter referred to as SPDI): “Sensitive Personal data or Information” means personal information which is more sensitive in nature viz. financial information such as Bank account or credit card or debit card or other payment instrument details, Biometric details, passwords or authentication information for any of our products or services etc.
For the purposes of this Privacy Statement, sensitive personal data or information has been considered as a part of Personal Information.
This Privacy Statement describes the Personal Information which we may collect and our approach towards handling or dealing with the same. This Privacy Statement is designed to enable you understand:
· Personal information that we collect and methods of collection
· Purposes of collection and usage of personal information
· Measures taken by us to protect your personal information
· Usage of Cookies, Device Identifiers and other similar technologies
· Location Based Services (LBS)
· Disclosure, Sharing and Transfer of your Personal Information
· Ways by which you can access and update your Personal Information
This Privacy Statement is provided for your information and is not intended to limit or exclude your rights under laws and regulations applicable in India.
1. Collection of Personal Information
Vodafone Idea Limited and its authorized Third Parties will collect information pertaining to your identity, demographics, and related evidentiary documentation. For the purposes of this document, a ‘Third Party(ies)’ is a service provider which is associated with Vodafone Idea Limited and is involved in handling, managing, storing, processing, protecting and transmitting information on behalf of Vodafone Idea Limited. This definition also includes all sub-contractors, consultants and/or representatives of the Third party.
The information we collect about you will depend on our products and services you use and/or subscribe to. We may hold information relating to you that you have provided to us on Customer Acquisition/Application form (CAF) or that we may have obtained from another source such as our suppliers or from marketing organizations and credit agencies. We may also collect your personal information when you use our services, websites, and applications or otherwise interact with us during the course of our relationship.
The information we may collect includes, but is not limited to, the following:
· Your name, father’s name, mother’s name, spouse’s name, date of birth, current and previous addresses, telephone number, mobile phone number, email address, occupation and any such information contained in the documents used as proof of identity and proof of address.
· Your sensitive personal information such as Bank account or credit card or debit card or other payment instrument details, Biometric details, physiological information, passwords or authentication information for use of our products or services etc
· Information that gets generated during your use of our network, products and services such as your Call data records, your traffic data such as the phone numbers that you call and send messages to (and the phone numbers that you receive calls and messages from) and the date, time, duration and cost of your communications including your phone location at the time these communications are made. We collect your spend, your device details, your phone usage (including voice, messaging, web/ WAP use, application use), your purchasing habits, your location, your browsing history (including the date, time and duration of your internet session), application and feature usage, and your preferences (i.e. tracking our website and application usage information) and other information that you may provide to us from time to time for the services that you receive from the Company.
· Your preferences for particular products, services or lifestyle activities when you tell us what they are or when we assume what they are based on how you use our products and services.
· Your contact with us, such as: a note or recording of a call you make to one of our contact centers, an email or letter you send to us and other records of any contact you have with us.
· Device Identifiers which are used to identify your mobile device for interest-based targeted advertising.
· As per India IT Rules, 2011, we shall seek explicit consent from you while we collect your Sensitive Personal Data or Information (SPDI).
2. Use of Personal Information:
The information that we collect from you is held in accordance with applicable laws and regulations in India. It may be used by us for a number of purposes connected with our business operations and functions. We may use this information to contact you regarding matters relevant to the underlying service provided. Further we may use and analyze your personal information for various lawful purposes and enrichment of service experience. If required for business and to provide better services to you, we may acquire your information from our business partners and third parties (during our business association with them), while you are availing their service through us.
The purposes for which your personal information may be used includes, but is not limited to:
· Provide, maintain and improve our products and services;
· Verify your identity as mandated by laws and regulations;
· Carry out a credit check if you are applying for a contract for airtime services and to assess your application;
· Process your orders and applications;
· Keep you informed about new products and services unless you do not want to receive our marketing messages;
· Data Analytics that help us get valuable insights to enhance customer experience as well as improve upon service delivery.
· Provide the relevant service or product to you, which includes other services not included in your agreement with us and services that use information about location tracker, and to contact you with service-related messages about changes to the service or product;
· Contact you with offers or promotions based on how you use our products and services, including your calling and messaging activities, location information and browsing information (unless you have asked us not to contact you);
· Administer your account and bill you for using our products or services or to take appropriate amounts for the products or services rendered to you;
· Respond to any questions or concerns that you may have about using our network, products or services;
· Contact you (including by post, email, fax, short text message (SMS), pager or telephone) with offers and promotions about the products and services of carefully selected third parties which we think may be of interest to you (unless you ask us in writing not to) and who have been contracted with us to keep the information confidential, or who are subject to obligations to protect your personal information. For completeness we note that where such contact is via electronic means, our terms and conditions record our agreement with you that the electronic marketing messages we and our selected third parties send need not include an unsubscribe facility;
· Registering your details and allocating or offering you rewards, discounts or other benefits and fulfilling any requests as a part of our loyalty or reward programs and other similar schemes
· Inclusion in any telephone or similar directory or directory enquiry service provided or operated by us or by a third party (subject to your preference you may have indicated to us in writing)
· Understand how our different customers use our network, products and services so we can develop more interesting and relevant products and services for our customers, as well as personalize the products and services we offer you;
· Carry out research and statistical analysis and monitor customer use of our network, products and services on an anonymous or personalized basis;
· Settling accounts with those who provide related services to us;
· Carry out any activity in connection with a legal, governmental or regulatory requirement on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;
· Carry out activities connected with the running of our business such as personnel training, quality control, network monitoring, testing and maintenance of computer and other systems and in connection with the transfer of any part of our business in respect of which you are a customer or a potential customer;
· Other usages that you may consent to;
· Vodafone Idea Limited will retain your information for as long as we have to by law and as per directions of the regulatory & law enforcement authorities. If there is no legal requirement, we will only store your information for as long as we have the justified business requirement and we need it for providing services to you. After that, the Company will destroy it by making it unreadable or undecipherable.
3. How We Protect Your Personal Information
We adopt reasonable security practices and procedures, in line with international standard IS/ISO/IEC 27001, to include, technical, operational, managerial and physical security controls in order to protect your personal information from unauthorized access, or disclosure while it is under our control.
· To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system.
· We have specialized security teams who constantly review and improve our measures to protect your personal information from unauthorized access, accidental loss, disclosure or destruction.
· Our security practices and procedures limit access to personal information on a need to know basis. Further, our employees, to the extent they may have limited access to your personal information on a need to know basis, are bound by Vodafone Idea Limited Code of Conduct and confidentiality policies which obligate them to protect the confidentiality of your personal information.
· We take steps to ensure that our contracted third parties adopt reasonable level of security practices and procedures to ensure security of personal information. We cannot protect any information that you make available to the general public in any publicly accessible area of our website or any other media.
· When we dispose of your personal information, we use reasonable procedures to erase it or render it unreadable
· No data transmission over the Internet is completely secure and for reasons outside of our control, security risks may still arise. Any personal information transmitted to us or from our online products or services will therefore be at your own risk. However, we will strive to ensure the security of your information. We observe reasonable security measures to protect your personal information against hacking and virus dissemination.
In case of any concerns the privacy officer can be contacted at email@example.com .
We may sometimes use a persistent cookie to record details such as a unique user identity and general registration details on your PC. This helps us recognize you on subsequent visits to this website so that you don't have to re-enter your registration details each time you visit us and allows us to carry out the activities mentioned above.
During the usage of our mobile apps platforms, we may collect and use Device Identifiers (unique random number) called Advertising/Device ID typically assigned by the mobile operating system software. Device Identifiers are typically used to track your device uniquely by the mobile advertisement networks for sending you marketing communications or advertisements.
Using cookies and device identifiers, we may compile information about where you, or others who are using your computer or mobile devices, saw the advertisements and determine which advertisements are clicked. This information allows our advertising partners to deliver targeted advertisements that they believe will be of most interest to you.
Vodafone Idea Limited does not have access to or control of the cookies /device identifiers that may be placed and used by third party applications, websites or platforms. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these third party sites. Nonetheless, we seek to protect the integrity of our website/applications.
Most browser technologies (such as Internet Explorer, Chrome, etc.) allow you to choose whether to accept cookies or not – you can either refuse all cookies or you can set your browser to alert you each time that a website tries to set a cookie. Most of the mobile operating systems allow users to reset the Advertising/Device ID by visiting the Ads setting on their mobile devices to ‘limit tracking’ for the purpose of opting out of behaviorally targeted advertisements.
Location Based Services (LBS)
Location Based Services (LBS) refer to a broad range of services that utilize the knowledge of the geographical position of a mobile device, in order to provide services based on the location information. It allows our customers to receive services and advertising based on their geographic location. Such services can be provided in response to a customer’s manual input of his or her location information into the mobile device or by using a technology (such as mobile apps leveraging location tracking technology, Cell-site location, etc.) to track the location of the customer automatically. In addition, LBS can also help in law enforcement and emergency services.
We may use location information in all kinds of ways that enhance our customer’s experience. For any specific location based services that may be of use to you and where we may require to share the location details with one of our carefully selected 3rd parties to provide you such services, a specific opt-in will be taken before any such information is shared.
5. Disclosure, Sharing and Transfer of Personal Information
Authorized Third Parties:
Vodafone Idea Limited may at its discretion employ, contract or include third parties external to itself for strategic, tactical and operational purposes. We may disclose and/or transfer your personal information or other information collected (as defined in section 1: Collection of personal information), stored and processed by us to such third parties. Such third parties though external to the Company, will always be entities which are covered by contractual agreements. These agreements in turn include Vodafone Idea Limited’s guidelines to the management, treatment and secrecy of personal information. This may also include:
· Sharing your Sensitive Personal Data or Information (SPDI). However, as per India IT Rules, 2011, we shall seek explicit consent from you at the time of collection if we intend to share your Sensitive Personal Data or Information (SPDI) with third parties.
· Sharing aggregated & anonymized information about the subscriber with authorized third parties in order to provide better product & services (now or in future).
Authorized third-parties include our subsidiaries, divisions, and third-party business affiliates but not limited to:
· Partners or agents who are involved in delivering the products and services you have ordered or used;
· Customer Verification agencies
· Credit-reference agencies, fraud-prevention agencies, business-scoring agencies or other credit-scoring agencies;
· Debt-collection agencies or other debt-recovery organizations;
· Emergency services (if you make an emergency call), including your approximate location.
· Our Business partners involved in delivering and improving our services
· Our IT vendors hosting our websites and applications; operating various features available on the website and applications; sending emails; analyzing data; providing search results and links and assisting in fulfilling your orders.
Government Agencies: Vodafone Idea Limited may also share your personal information with Government agencies or other authorized law enforcement agencies (LEAs) mandated under law to obtain such information for the purpose of verification of identity or for prevention, detection, investigation including but not limited to cyber incidents, prosecution, and punishment of offences. This may also include sharing your Sensitive Personal Data or Information (SPDI).
Marketing Agencies: If you have opted to receive marketing material from us, we may also provide your personal or anonymized information to carefully selected third parties who we reasonably believe provide products or services that may be of interest to you and who have been contracted with Vodafone Idea Limited to keep the information confidential, or who are subject to obligations to protect your personal information.
We will never share your Sensitive Personal Data or Information (SPDI) with any Marketing agencies.
For completeness we note that where such contact is via electronic means, our terms and conditions record our agreement with you that the SMS marketing messages we and our selected third parties send need not include an unsubscribe facility.
If you would like to opt-out of receiving marketing materials, please SMS ‘Start on 1909 (toll free) for preference based communication. The options are ‘0’ – Full blocked category. ‘1’ – For banking/financial products / credit cards. ‘2’ – For real estate, ‘3’ – For education, ‘4’ – For health care, ‘5’ – For consumer goods and automobiles, ‘6’ – For communication/Entertainment/ Broadcasting, ‘7’ – For tourism and leisure. Please note that registration or change of preference shall be effective after 7 days from the date of request. Please note that Vodafone Idea Limited will still need to send you essential information about your account or changes to your service which will not be restricted by opting for DND. If you want to opt-out of sharing anonymized information with authorized third-party companies, sms “OPTOUT DS” to 12345 from your mobile
Data Analytics: We may permit certain authorized third parties to track your usage, and analyze your personal data. Data Analytics is performed in order to better understand our products and services usage, and enhance them by helping us make better decisions. These include, but not limited to:
· Website Analytics vendors and agencies
· Mobile App Analytics vendors and agencies
Other Scenarios: We may transfer personally identifiable information as an asset in connection with a merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. Vodafone Idea Limited may disclose Contact Information in special cases where we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our terms and conditions of use or may be causing injury or interference with our rights, property, our customers or anyone who could be harmed by such activities.
6. Update of Personal Information
We strive to keep our records updated with your latest information. To this end, if you see any discrepancy in your personal information or if a part of your personal information changes, we request you to reach out to our customer service at198 and communicate the change(s) for updating our records. You may however need to walk in to any of our stores and follow prescribed procedures to request or update your personal information.
7. Notification of Changes
We are committed to safeguarding your personal information collected and handled by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your personal information, you may reach us by contacting firstname.lastname@example.org