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Privacy Policy - Vodafone Egypt

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<strong>Privacy</strong> <strong>Policy</strong><br />

INTRODUCTION<br />

<strong>Vodafone</strong> is entrusted with the confidentiality of millions of peoples‟ communications and for managing<br />

an immense volume of personal information. We must continue to foster the trust and confidence of<br />

customers and employees in the way we handle their personal information and provide services.<br />

As an organization, <strong>Vodafone</strong> has undergone, and is continuing to undergo, important changes in the<br />

way it operates. <strong>Privacy</strong> comprises a number of separate, but related, concepts, each of which is<br />

important to <strong>Vodafone</strong> to establish its business. These include “information privacy”, often referred to as<br />

data protection, which concerns the protection of information about individuals, “communications<br />

privacy”, which concerns the confidentiality and privacy of peoples‟ communications, and “territorial<br />

privacy”, which concerns issues such as unsolicited communications and spam. This <strong>Policy</strong> provides<br />

clear lines of accountability and oversight within the business.<br />

1. What is the objective of this policy?<br />

1. To pro-actively address customers‟ expectations concerning their privacy and security in order to<br />

create and ensure trust and confidence in <strong>Vodafone</strong> and the products and services it provides;<br />

2. To facilitate business integration and consolidation by ensuring that privacy practices are consistent,<br />

aligned and meet the Group‟s business objectives;<br />

3. Minimizing legal liability, regulatory risk and brand and reputational exposure;<br />

4. To align security requirements for the protection of personal information with Group Security<br />

Policies.<br />

2. Who and what is covered?<br />

This <strong>Policy</strong> concerns the handling of customer personal information, which includes the collection,<br />

storage, access, use, updating, disclosure, disposal, destruction or any other processing of such<br />

information. It is intended to provide a comprehensive set of rules for the management of customer<br />

personal information throughout the customer lifecycle, including:<br />

2.1 Requirements concerning the collection of customer personal information;<br />

Collection methods<br />

2.1.1 The collection of Customer Personal Information where the Customer provides information about<br />

themselves to <strong>Vodafone</strong>, such as on subscription or registration forms (whether online or offline)<br />

2.1.2 The capture of Customer Personal Information where <strong>Vodafone</strong> records or logs information about<br />

the Customer while the Customer interacts with <strong>Vodafone</strong> in some way (e.g. by visiting a<br />

<strong>Vodafone</strong> web site or calling Customer care) or by using a <strong>Vodafone</strong> service (e.g. call logs, text<br />

messages sent, WAP pages visited, content purchased)<br />

2.1.3 The receipt of Customer Personal Information from third parties, such as information about<br />

Customers received from credit vetting or fraud agencies, from loyalty programme partners, or<br />

from marketing agencies providing information to enhance our understanding of, and knowledge<br />

about, our Customers<br />

2.1.4 VFE shall not collect Sensitive Personal Information unless the Customer has given their explicit<br />

consent or there is a legal obligation to collect such information where VFE believes there are<br />

substantial and legitimate reasons for collecting Sensitive Personal Information. Consultancy with<br />

2 <strong>Vodafone</strong> <strong>Egypt</strong> Telecommunications S.A.E<br />

Legal Department

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