Privacy Policy - Vodafone Egypt

Privacy Policy
2.4 Requirements concerning disclosures and transfers of customer personal information;
2.4.1. Subject to any legal requirements to disclose Customer Personal Information, VFE shall only
disclose or transfer Customer Personal Information to the extent that it is necessary for the
Permitted Business Purpose(s) for which that Customer Personal Information was collected.
2.4.2. As a general principle, VFE should not transfer Control of Customer Personal Information. In
particular, VFE shall not trade in Customer Personal Information, including selling, hiring, or
renting it to third parties. However, in certain limited circumstances the transfer of Control may be
justified for a specific purpose, such as in connection with the operation of a loyalty programme
operated in combination with a loyalty programme partner or partners to which the Customer
concerned has subscribed. Any transfer of Control must be approved by the Privacy Officer.
2.4.3. Disclosure of Customer Personal Information may take place where VFE provides or transfers
Customer Personal Information to a third party, but also includes where a third party is given
access to the systems (for example, for purposes of system maintenance). VFE shall ensure that
any disclosures of Customer Personal Information are kept to a minimum, for example, by using
use „dummy data‟, instead of „live‟ Customer Personal Information. Where it is not possible to
anonymise Customer Personal Information or use „dummy data‟, VFE shall ensure that the third
party is appointed as a third party processor and the requirements of this policy with regard to third
party processors shall be observed in all respects. The Privacy Officer should be consulted on any
proposed techniques to anonymise Customer Personal Information or use „dummy data‟.
2.5 Requirements concerning the destruction, retention and anonymity of customer personal
information;
2.5.1. Certain Customer Personal Information may be required to be retained for legal reasons. Where
this is the case, VFE shall maintain a register of the categories of Customer Personal Information
and the time period and purposes for which it must legally be retained (“Mandatory Retention
Requirements”). VFE shall retain the categories of Customer Personal Information set out in the
Mandatory Retention Requirements for the periods and purposes specified.
2.5.2. Subject to the Mandatory Retention Requirements, VFE shall ensure that Customer Personal
Information identifies a Customer for no longer than is necessary for the relevant Permitted
Business Purposes or is otherwise deleted. Therefore, upon the expiration of the Permitted
Business Purpose(s), Customer Personal Information shall be either permanently deleted or
anonymised.
2.6 How to manage customer requests about their personal information;
VFE shall establish appropriate points of contact to respond to questions, requests and complaints from
Customers. In particular, VFE shall establish procedures for dealing with the following requests from
Customers regarding their Customer Personal Information:
2.6.1. Requests by Customers for copies or extracts of their Customer Personal Information:
VFE Customer Complaints department shall establish a procedure to enable Customers to have
copies or extracts of their Customer Personal Information
2.6.2. Objections or requests regarding direct marketing by VFE:
VFE Marketing department shall establish a procedure to enable Customers to object to receiving
direct marketing material and shall ensure that any such objections are respected across all
business units and communications channels;
4 Vodafone Egypt Telecommunications S.A.E
Legal Department