The Smart Tracker is provided to you by Vodacom (Pty) Ltd (Vodacom)

This Privacy Supplement, explains the information that is collected by Smart Tracker and how it will be used. For further information about the Smart Tracker please visit https://www.vodacom.co.za/vodacom/services/v-by-vodacom/curve

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 make, model and year of the vehicle you have;
• Your photos or camera settings, if you want to add photos for profile setup, including the User of the device, to their respective profiles (you can revoke these permissions in your phone’s Settings);
• Your credential information such as passwords, hints and similar security information used for authentication and access to accounts and services;
• 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 mobile handset each time you use the App. For example, we may collect information on the type of mobile 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);
• Information about your usage of the App, such as how often you use it or when you dismiss alerts;
• Your mobile handset or 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. The device will always process location data in order for you to locate the device however, you can turn of location tracking of your mobile handset at any time; and
• Information about your interaction with the App and its features, such as voice related activity if you choose to connect your device with another third party device (for example Alexa). If you do, the other device provider will share with us your “voice intents” which includes the content of your requests to enable us to provide your experience and our services. You can stop the sharing of this information with us by unlinking the device/removing our access to the device.

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 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 device and app in order to improve your experience and troubleshoot.

When we collect your personal information

We collect personal information when:

• You first set up your device in the App and set up your profile;
• You use the App and any of its features (for example, setting a geographical zone or changing tracking mode);
• You subscribe to marketing; or
• You contact our customer care teams.

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 subscriber’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 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.

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 data, which control the scope of legal assistance to be provided; or

4. Consent you provide where Vodacom does not rely on another legal basis. 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 and features for your 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 personal information to tailor these communications, we’ll use your interactions with this App and the data from your 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 have.

To opt out of Marketing messages or profiling:

If you no longer want to receive marketing messages from Vodacom, you can elect to opt out of all marketing communications or only selected methods (email, messaging, phone or post).

There are various ways to opt out:

• Contact our customer care team at [email protected] or call 082 135.
• All our email marketing messages come with an “unsubscribe” link which you can click to unsubscribe;
• Tell the adviser you no longer want to be marketed to, if you receive an outbound marketing call;
• Opting out does not mean that you will no 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 aggregated information in order to improve the service we offer to everyone.

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.

We also process call recordings or chat transcripts when you interact with our customer care, for training and quality purpose.

Where applicable, we share your personal information about you with:

• Companies in the Vodafone Group;
• Partners, suppliers or agents involved in delivering the products and services you’ve ordered or used (for example our supplier Trackimo who help to build the product);
• Companies who are engaged to perform services for, or on behalf of, Vodacom (Pty) Ltd, Vodacom Limited, or Vodafone 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 Smart Tech customer care centres are run by Vodafone Shared Services which is based in Egypt and India.

The personal information accessed will only include support ticket data needed to resolve your issues. For example, your phone number or fall detection data is not transferred.

If you are a non-Vodacom 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 Vodacom (Pty) Ltd sends your personal information to another country, 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 recipient country is not considered to have laws that are equivalent to South African data protection standards then we will ask the third party recipient to enter into a legal agreement that reflects those standard

We’ll store and process your information for as long as we have to by law or as long as we need to be able to deliver you the services you have requested. 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 Vodacom services during this time if you haven’t opted out of receiving marketing communications from us. Once these bases have expired, we’ll delete that information.

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

Below we set out details on how you can exercise your rights. If you have a question regarding Privacy Rights or cannot find the answer, please contact our Customer Services team via [email protected] or call 082 135.

Right to access personal information

You have the right to make a request for a copy of the personal information that Vodafone holds about you. To make this request as an individual or an authorised 3rd party, please contact the customer care team via https://v.vodafone.com/za/help-and-support.

If this does not satisfy your requirement you can complete and submit the form ANNEXURE B available here. We will confirm receipt of your request and ensure that you receive this information within one month of the date of your request.

Right to correct personal information

If you become aware that any of the information we keep about you is incorrect or outdated, you can log into your Vodafone Smart App to edit your personal details. Alternatively, please contact customer care at https://v.vodafone.com/za/help-and-support.

To formalise your request please complete and submit the form ANNEXURE F available here, email [email protected] or call 082 135

Right to object to use of personal information

In certain circumstances, you have the right to object to the use of your personal data.

Complete and submit form ANNEXURE E available here or contact our customer care team via email at [email protected] or call 082 135.

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

If you would like us to remove your personal information from our records, you can request this by completing form F available here. If you do not have an active account, please email [email protected] to let us know what information you would like to have deleted.

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.

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 must undertake to first attempt to resolve any concerns with Vodacom directly. Kindly contact our customer care team at [email protected] or 082 135.

If you need to escalate your query please 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]