Privacy Policy

Privacy Statement
Last updated: 31/08/2018

PLEASE READ THIS PRIVACY STATEMENT/PRIVACY POLICY CAREFULLY. “YOU”

AND “YOUR” SHALL REFER TO THE CUSTOMER OR SUBSCRIBER OR VISITOR OF
THE VODAFONE IDEA LIMITED WEBSITE [www.ideacellular.com]. “WE,” “OUR” OR
“US” SHALL REFER TO VODAFONE IDEA LIMITED, PROVIDING OR OFFERING
SERVICES TO YOU OR CUSTOMER OR SUBSCRIBER OF THE VODAFONE IDEA
LIMITED.

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.

This Privacy Statement/Policy explains the collection, use, protection, disclosure, sharing and
transfer, if any, of “personal information” by Vodafone Idea Limited. The Company reserves its
right to amend this Privacy Policy from time to time based on changes as per the business, legal
and regulatory requirements and applicable laws and the same shall be updated on this website.
You are encouraged to periodically visit this page to review the policy and any changes. By
using our website or our products/services or otherwise providing information to us through this
website, you consent that your personal information may be used and handled as described in
this Privacy Statement.

This Privacy Policy is subject to changes as per applicable laws and regulations and shall stand
amended from time to time.

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.

· We may use cookies and other techniques, such as web beacons, to collect information about
how you use our websites, and web-related products and services. This allows us to customize
our website for you so that it is relevant to your interests and needs.

· 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;

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 nikhil.sugnani@vodafoneidea.com .

4. Use of Cookies and similar technologies

We may use cookies and other interactive techniques to collect personal and non-personal
information about you. The cookies mean that our website platforms may remember you to
personalize the content and how you've used the site every time you come back; 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, customized service and experience, and help us develop and
deliver better products and services tailored to our customers’ interests and needs.

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 Limitedmay 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

Vodafone Idea Limited reserves the right to amend / alter / modify and /or change this Privacy
Statement at its sole discretion as needed based on change in technology, laws, rules and
regulations both national and international as may be applicable, orders and instructions from
judicial, quasi-judicial , administrative authorities and Licensor viz DOT apart from business
exigencies and consumer interest at large . If there is such change to our Privacy Statement, the
same shall be updated on the Company website and from such date of updation the Privacy
policy will be displayed on the website and shall be applicable.

Contact Us

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 nikhil.sugnani@vodafoneidea.com