Privacy Policy

Your Personal Information

The only personal information that is collected at this web site is the personal information that you choose to provide to us. For example when

  • you make a purchase
  • you register your mobile phone number with us
  • you request, register for or purchase a specific product or service such as topping up mobile phone, or setting up an email account with us
  • you request further information about a product or service
  • you contact us with an enquiry or complaint
  • you submit a job application
  • you respond to a competition or survey

Your personal information will only be used for the purpose for which you have provided it. Where we would also like to use that information to contact you about new products and services, we let you know and ask your permission.

Back to Top

Online Purchases

The information that you provide should you choose to purchase a product or service online, will be used for the following purposes:

  • To carry out credit vetting where you are applying for bill payment facility.
  • To confirm your use of a valid credit card for your purchase.
  • To send you the goods and services that you have purchased.
  • To keep you informed about new products and services unless you object to receiving our marketing messages
Back to Top

Credit Vetting

The personal information that you provide when you apply for a postpaid subscription with Vodafone ie your name, address and date of birth will be used to carry out a credit check with licensed credit vetting agencies, and to verify your identity. This is to protect you from identity theft and Vodafone from fraudulent credit applications.

Information held about you by the credit vetting agencies may already be linked to or associated with records relating to one or more of your partners where you have associated or joint financial arrangements. When you apply for a postpaid contract, Vodafone will assess your application with reference to any such linked or "associated" records. You may only decline a linked or associated search, but only if you declare that such a financial link does not have any adverse effect on your application. We will check the validity of your declaration with the credit reference agencies and if we discover any associated records, which would affect the accuracy of this declaration we may decide not to proceed with the application on this basis. If you wish to proceed on that basis please contact our Credit Control department who will carry out a manual review instead.

We will use credit scoring and/or automated decision making systems when assessing your application. If you are turned down for a postpaid contract, please contact our Data Protection Officer with information about the date and time of your application, where you applied, and any other information that you think may assist your application to be reviewed.

During the lifetime of your postpaid contract with us, we will disclose details account and billing information to the credit vetting agencies such as change of address, the payments you made, account balances, any payment default, dispute, queries and debts. This information will be retained by the credit vetting agencies, and may be used by us and other organisations to help make decisions about other credit applications made by you or other members of your household with whom you are linked financially.

We will also share your details with fraud and theft prevention agencies to protect you and us from fraud and theft. Information supplied to these fraud prevention agencies may result in a warning marker being placed against the address or addresses used in any applications and this will be accessible to other members of those fraud prevention agencies. A warning marker means that Vodafone and other members of these fraud prevention agencies should take extra precautions to ensure that personal and address information is genuine − this helps to protect an address from any further misuse.

Information held by fraud prevention agencies may also be shared with other organisations to help them make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household.

Any information we hold about your account will also be used for debt tracing and claims assessments. In the event that you do not repay in full and on time, we may tell credit reference agencies who will record the outstanding debt.

If your application is declined following a credit check and because of information held by the below credit vetting agencies used by Vodafone Malta Limited, you can request a copy of your credit reference file by writing to:

  • Credit Info
  • [insert address]
  • Tel: [insert]
  • Email: [insert]
  • Web Address: [insert]

Please note that these credit vetting agencies will charge a fee to provide you with a copy of your credit reference record. The fee will depend on the level of detail that you request. More information is given on the websites referred to above.

Back to Top

Marketing

We use the following methods to inform our customers about new products, services, pricing tariffs and promotions − post, telephone, email, text and other forms of electronic communication that your mobile phone may be capable of receiving such as mms, video etc.

However, because we understand that you do not wish to receive marketing by all these channels all the time, we allow you to tailor how we might communicate with you. When we collect contact information from you that we think we might use to send you marketing messages, we notify you of your marketing choices and offer you the opportunity to indicate your objections.

So that you might change your mind about your choices at any time in the future, we offer a range of ways in which you can inform us about your marketing preferences:

  • All email messages and email newsletters will contain information on how you can stop us sending you email marketing.
  • At any time, you can send a text message from Vodafone mobile phone to XXXX changing your marketing preferences e.g. "stop SMS", "stop Email". In order to stop marketing messages by all channels from Vodafone, please text STOP All to XXX.
  • At any time you can call our call centre and advise them that you would like to change your marketing preferences.
  • You can contact the Vodafone Data Protection Officer on data−protection.mt@vodafone.com
  • explaining which marketing messages you would like to receive and/or which you object to. Don´t forget to provide our Data Protection Officer with your mobile phone number so that they can find your details and log your marketing preferences quickly.

We do not − generally − rent, sell or disclose your contact details to third parties so that they can carry out their own marketing campaigns. However, in highly rare and exceptional circumstances, where we are providing specific service or specific content with another company, we may share your contact information with that company in order that they might contact you about their products and services. In these highly rare and exceptional circumstances, we will ensure that you are given clear notice about this and we will provide you with information on how you can object to that happening.

From time to time, we may run joint advertising campaigns with carefully selected partners with whom we may have specially negotiated offers and discounts for our customers. Because we understand the concerns that you might have about your information being shared with others, when this happens, we remain in control of your customer information and will not allow those third parties to use those details for their own purposes in future.

Back to Top

Cookies

We may use cookies and other interactive techniques such as web beacons to collect non−personal information about how you interact with our website, and web−related products and services, to:

  • understand what you like and use about our website
  • understand what you do not like and do not use on our website
  • provide a more enjoyable, customised service and experience, and
  • help us develop and deliver better products and services tailored to our customers´ interests and needs.

We may use a persistent cookie to record details such as a unique user identity and general registration details on your PC. This helps us recognise 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.

Most browser technology (such as Internet Explorer, Netscape etc) allows 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.

More information about cookies

Please note that if you refuse our cookie or delete it at a later date, you will have to enter your registration security details each time you visit this site or wish to use one of our web−related services or products.

We use the services of Atlas Solutions to manage the advertisements that you see on this website, and on other websites were Vodafone has bought advertising space − for example banner ads. If you have visited this website as a result of clicking on a Vodafone advertisement that you have seen on another site, Atlas Solutions will have placed a cookie on your browser, and this may interact with web beacons (also known as 1x1 pixels or gifs) so that we can understand whether our advertising is effective and which pages of our website are used or visited as a result of that advertising. No personal information is contained in or collected as a result of using these cookies or web beacons.

Back to Top

Security

Vodafone recognises that its customers are increasingly concerned about how companies protect personal information from misuse and abuse. Vodafone has a specialised fraud, risk and security team which is constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction.

Where we have contracted with a third party to provide some part of a service that you have requested, we will ensure that those agents, by written agreement, are required to implement similar security measures and will process your information only as authorised by Vodafone to fulfil the service that they have been contracted to provide on our behalf. Those third parties will not be entitled to use your personal data for their own purposes. Where necessary, our fraud risk and security team will audit a third party to ensure that they are meeting the security promises that they have made to Vodafone Malta Limited.

Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered − this is the nature of the World Wide Web/Internet. Vodafone cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.

Back to Top

Mobile Internet

Vodafone´s aim is to provide a mobile Internet service that is similar to the Internet experience that you get when you access the Internet via your PC. Features that we offer include:

  1. Re−formatting non−Vodafone Live! websites into content that can be delivered to and viewed on your mobile handset. In order to do this, we have partnered with a specialised third party. Your request for a website will be re−directed to our partner, who will retrieve the website that you have requested, re−format it and deliver it to your mobile phone. Our partner is contractually prohibited from using any information about your requests for their own purposes and from disclosing that information to any third party without prior permission from Vodafone. Our specialist security teams will be undertaking regular audits of their systems to ensure that you can expect the same privacy protection from them as you get from Vodafone Limited.
  2. When you use an Internet service via your mobile handset, we may have to pass through your mobile phone number to the website or service in question. This will only done where it is an essential part of the web service that you are selecting or using − for example where your mobile phone is used as part of their validation process for their mobile Internet services or where you are requesting something to be delivered to your handset such as an application or download. Please note that when you are accessing a non−Vodafone site via the mobile Internet, you should always read their privacy policy or terms and conditions − particularly if you are considering providing them with your personal information.
Back to Top

Advertising

  1. Vodafone has partnered with Yahoo! to provide targeted advertising on third party sites as well as on Vodafone Live! sites. Exactly the same technology as described here is used. From time to time, you may find that you can access certain services or content for free or at a discounted rate in return for receiving the targeted advertising that is delivered with that content or service. The only way that you will be able to object to the targeted advertising is not to access the content or service.
  2. The ability to bookmark your favourite sites. You can do this via your PC or your mobile handset. You will then be able to access your favourite websites or mobile Internet sites from your Vodafone handset. Your personal information is not shared with any site that you might choose to bookmark in this way.
  3. Downloads and applications that you can use to improve your mobile Internet experience. Many of those are provided by companies other than Vodafone so it is important that when you download an application or anything else to your mobile handset, you make sure that you read any terms and conditions in case your personal information is used in anyway that is not covered by this privacy statement.
Back to Top

Mobile Telephone Information

Each time you use your mobile phone to make a telephone call, to send a text or sms message, or use any of the services that are available to you via your mobile phone, our network will record certain information such as:

  • The date and time of that you made the call or sent the text message,
  • The number that you called or sent the text to, and
  • Your approximate location. This information does not pinpoint where you were exactly, but provides an indication of the nearest mobile phone mast or cell site. This obviously changes as you move around with your mobile phone.
  • The type of activity that was carried e.g. voice call, text or mms message, WAP session etc.

This information is stored and used by us for the following purposes:

  • To connect the call that you are making or to deliver the message that you wish to send.
  • To bill you for use of our product, service or network or − where you are a pay as you talk customer − to deduct the appropriate credit from your mobile phone.
  • To respond to any queries or concerns that you may have about your use of our network or services − for example when you call our customer care agents with a question about charges to your prepaid credit or on your monthly bill.
  • To maintain the integrity of, and to manage traffic flow over, our network. For example we identify peak periods of use so that we can try and ensure that the network can handle the volume of traffic at those times.
  • To understand how our different customers use our network, products and services − this in turn enables us to develop more interesting and relevant products and services for our customers as well as better price tariffs.

We understand that your communications are private and confidential − for that reason we do not record the content of the calls you make over our network. From time to time when you call our customer service numbers, your calls may be recorded for quality assurance and training purposes, but these recordings are retained just long enough so that any training issues can be taken up with the customer service agent in question.

Text messages are deleted from our systems once they have been delivered to the intended receiving phone number. If a text message cannot be delivered immediately, the network will keep trying for a short period. After that time the text message will be purged from the network and will no longer be available.

Back to Top

Spam

We know just how annoying unwanted marketing messages or "spam" can be and it is for that reason that we do not provide third parties with your contact details so that they can send marketing messages to you.

Unwanted messages to your phone or email can be a real nuisance and on occasion can be very distressing, we therefore take strong and robust measures to try and ensure that these types of messages are kept out of our network.

To do this, we use technologies that monitor traffic flow and filter messages to try and identify offensive content before it reaches your email inbox or mobile phone. We are continuously working on improving our anti−spam protection, but it may be that, from time to time, a message that you do want will be blocked. We apologise if this happens, but hope that you will agree that this is better than being flooded with unwanted and offensive material.

Despite these initiatives, it may be that sometimes an unwanted SMS or text message will get through to your mobile phone. When it does, please forward the offending message to 87726 − an easy way to remember this number is VSPAM (V is on the number 8 on your key pad, S is on the number 7 on your keypad etc). Our team who work on our anti−spam initiatives will try and identify the senders of those unwanted messages take the necessary action to try and prevent that person or company sending such messages to our customers again. This may involve reporting the sender, or referring complaints, to the relevant regulatory authority such as Data Protection Commissioner´s Office (the body responsible for overseeing compliance with Maltese data protection legislation) and the Malta Communications Authority (the regulatory body for the telecommunications industry).

Back to Top

Disclosure Policy

Other than as explained in this section, we do not rent, sell or disclose your personal information or contact details to third parties for their own use:

  • We may share information about you, your account and your mobile phone with companies within the Vodafone Group* for the purposes set out in, and subject to the terms of, this Privacy Policy Statement and the conditions in the terms and conditions that accompany your contract or prepaid service. For example we may use another Vodafone Group company to provide a service to our customers on our behalf.
  • In the event that we undergo re−organisation or are sold to a third party, any personal information we hold about you may be transferred to that re−organised entity or third party for the purposes and subject to the terms of this Privacy Policy Statement and the conditions in the terms and conditions that accompany your contract or prepay service.
  • It may be necessary to share your personal information with third parties who are involved in the delivery of the products and services ordered or used by you. For example, we may disclose your personal information to a credit card company to validate your credit card details and obtain payment when you buy a phone or other product or service.
  • It may also be necessary to pass your personal information to an organisation from whom you have ordered any mobile−related products or services.
  • From time to time Vodafone may be obliged by law or order of the court to disclose your personal information to meet any legal or regulatory requirements or obligations − for example the law enforcement agencies are able to require phone related information from us where it is relevant to their investigations into criminal activity. In such circumstances we will take all reasonable efforts to ensure that those requirements or obligations are in accordance with applicable law.

*For the purposes of this Privacy Policy Statement, "Vodafone Group" means Vodafone Group Plc and any company or other entity in which Vodafone Group Plc owns (directly or indirectly) more than 15% of the issued share capital. Companies in the Vodafone Group shall include, without limitation, Vodafone Business Solutions Limited, Vodafone Content Services Limited, Vodafone Global Services Limited.

Back to Top

Location Based Services

In order to provide mobile communications, the Vodafone network needs to know approximately where you are so that it can deliver calls and messages to you.

This information will be shared with the emergency services in the event that you make an emergency call. This is done to ensure that the requested emergency service has the best chance of getting to you in the shortest possible time.

Vodafone Malta Limited does not currently provide any other location based services.

Back to Top

Directory and Directory Enquiry Services

Vodafone Malta Limited does not include our customers´ personal contact details in any directory or directory enquiry (118X) service whether run by us or a third party.

If you call your customer care and ask for a Directory Listing, they will query the directory listings on the databases of the other operators and provide you with a response.

You have a couple of choices − you can choose to have your information in all forms of directory such as all 118 services, web and reverse look−up facility or you can simply have your information made available through all 118 services.

It is obviously very useful to be in such services for example if a friend or family member has lost your mobile phone number, but it also means that anyone who knows or has obtained your name and address would also be able to obtain your mobile phone number.

If you ask for a listing, your information will be available on the Go website who act as a collection point for all web directory information from all network and fixed line providers. Third party companies who provide directory or directory assistance services then obtain that information from Go in order to provide their own services or products. This is because we are obliged to share this information with other directory service and directory enquiry service providers to ensure that you have a choice of such service.

Instead of contacting customer care, you can write to the Vodafone Data Protection Officer, setting out your choices, to:

  • Vodafone Malta Limited
  • Vodafone House
  • Msida Road
  • Birkirkara BKR 9024

Please include a photocopy of ID Card, driving licence or passport, to confirm your identity, and a copy of a utility bill or something similar to confirm your address. This is to stop people signing you up maliciously for inclusion in these products and services.

Back to Top

Overseas Transfer

Transferring your information outside of the European Economic Area*

It may be necessary to transfer your personal information to other group companies or service providers located in countries outside of the EEA. This may happen where our servers or suppliers and service providers are based outside of the EEA or where you use our services and products while visiting countries outside of the EEA.

Where the data protection and other laws of these countries may not be as comprehensive as those in Malta or the EU, we will take steps to ensure that your privacy rights are respected. To do this we take the following steps:

  • Define the specific security measures that we require from them to protect our personal information.
  • Require them to sign a contract guaranteeing to comply with those security requirements and agreeing that we can audit them to ensure that they do comply with those security requirements.
  • Where they are based outside of the EEA, our fraud, risk and security team may require a security audit to be carried out before they are provided with personal information.
  • During the lifetime of the contract we will monitor for ongoing compliance with the defined security measures.
  • *The European Economic Area (EEA) currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein

Back to Top

How can you obtain a copy of your personal information?

You can write to us at any time to obtain details of the personal information we may hold about you. It would be helpful if you could provide a brief description of the information that you would like from us

  • Please write to:
  • Data Protection Officer
  • Vodafone Malta Limited
  • Vodafone House
  • Msida Road
  • Birkirkara BKR 9024

Your request should include:

  • Your mobile phone number.
  • Proof of identity (e.g. a copy of your ID card, passport or driving licence).
  • Confirmation of registered or account address (e.g. a copy of a utility bill).
  • If you have a prepaid line, you should provide confirmation of the security password that you have set up on your account. If you have registered your use of your prepaid number with us, we will only provide information from the date of registration because we can only verify that you are the user of the relevant number from that date.
  • If you have not registered your use of your mobile phone number, we will not provide you with any information because we cannot verify that you are the user of the number in question.

Please note that the following information cannot be provided even if requested:

  • The content of any calls or voicemails because this is not logged or retained by Vodafone Malta Limited.
  • The content of any text messages sent or received because this is not logged or retained by Vodafone Malta Limited once the message has been sent to the intended recipient. Any message not delivered within 48 hours or so, is overwritten by subsequent text message traffic.
  • Information about incoming calls to your mobile phone from any calling party because, in the case of a Vodafone customer, such data is held as billing or charging data in relation to the calling customer and not you, the receiving customer. Such data is also not provided because an incoming call could have the number identity withheld by the caller and such data would still be present on the Vodafone systems and hence we could be disclosing information of the caller to the called party against the caller´s consent. This data would only be provided with the consent of the calling Vodafone customer, police request or a court order.
  • Information about charges relating to use of the prepaid service. The prepaid service does not require billing information because the cost of use is deducted from your credit.
Back to Top

Enquiries or Complaints

Here is how you can exercise your data protection rights:

  • To object to receiving marketing messages from Vodafone Malta Limited.
  • To be provided with a copy of your personal information.
  • To ask for a review of any decision that Vodafone might make about you using a wholly automated process. This is particularly relevant when you are applying for a contract with Vodafone Malta Limited and we carry out a credit check. If you are turned down, you may wish to ask for that decision to be reviewed. If you wish to do so, please put your request in writing to the Data Protection Officer at the address below − setting out all the circumstances of your case such as the date of your application, how you applied e.g. in which store, or through a representive, and any other information that you think may support your application.
  • To have your personal information amended. If you have requested a copy of your personal information (see second bullet point above) and believe that there is something inaccurate in your information, you should write to the Data Protection Officer at the address below setting out what information you believe to be inaccurate, why you believe it to be inaccurate and provide what evidence you can to support your argument.
  • To have your personal information deleted where that personal information is no longer required for our legitimate business purposes. Where this right applies, you should put your request in writing to the Data Protection Officer at the address below.

If you believe that Vodafone Malta Limited is in breach of Maltese data protection law, you should put your complaint in writing to the Data Protection Officer at the address below, setting out your case.

If you have any enquiries about Vodafone Malta Limited´s data protection or privacy practices, you should put your enquiry in writing to the Data Protection Officer at the address below or to

data-protection.mt@vodafone.com

  • Data Protection Officer
  • Vodafone Malta Limited
  • Vodafone House
  • Msida Road
  • Birkirkara BKR 9024
Back to Top

My Vodafone website

Vodafone Malta uses data provided by My Vodafone registered members to:

  • Subscribe to the My Vodafone mailing list: Vodafone Malta sends direct communications via email (known as "enewsletter") from time to time to registered My Vodafone members regarding latest news and useful information about the company's products/services and/or activities. Members may unsubscribe from this mailing list, at any time, by logging into My Vodafone, clicking into 'My Account' and unticking the box next to the statement 'I would like to receive Vodafone news'.
  • Fulfill applications of services and requests on the Web Portal: Vodafone Malta will collect and use personal member data for fulfilling services and other requests that a member would have requested through the Vodafone Malta Web Portal. My Vodafone members may also access their stored personal information as originally submitted in the 'My Vodafone' registration form and update/amend such information whenever they like. Should a member want to terminate membership and therefore, no longer avail himself/herself of any of the 'My Vodafone' services, he/she may formally request Vodafone Malta, in writing, to remove his/her personal details from all Vodafone Malta systems and no longer be recognized as a 'My Vodafone' member. Vodafone Malta is further committed to abide to that member's request .
  • Carry out marketing analysis and measure site activity: Vodafone Malta collects the personal information of My Vodafone members given by the same members in the membership registration form. Vodafone Malta may also collect general information, which does not personally identify members. This information is collected through "traffic data" and may entail the use of "IP addresses" and other numeric codes used to identify a computer. This information may be helpful for statistical purposes and data analysis with an aim at improving and better meeting members' needs.
  • Act within legal norms and as means of security: It may be necessary, if required by law or if pertinent to judicial authorities or criminal investigations, to release members' personal information. Vodafone Malta may also use members' details to investigate and help prevent potentially unlawful activity or any activity that threatens the network or otherwise violates the user agreement for that service.

Vodafone Malta reserves the right to modify its Privacy Policy from time to time should statutory obligations so mandate, or should the interest of its customers' security so require.

Back to Top