ABOUT OUR PRIVACY AND COOKIES POLICY
Our Privacy and Cookies Policy get updated from time to time. All changes we make will be posted on our website.
Last updated: 04/04/2022
Who we are
“Vodafone Albania” SH.A. (hereinafter referred to as ‘Vodafone’ or ‘we/us’) is an Albanian legal entity, part of the group “Vodafone Group” Plc and its registered office is at Autostrada Tiranë-Durrës, Rr. “Pavarësia”, Nr. 61, Kashar, Tiranë, Albania. Vodafone is an entity registered at the National Business Centre (NIPT number K11715005L) and it is also registered as a controlling entity with the Office of the Commissioner for the Right to Information and Personal Data Protection (IDP) in accordance with the requirements of Law No. 9887, dated 10.03.2008, “On the Protection of Personal Data”, as amended. As an operator, Vodafone applies modern technology and strives to provide services and innovations in the field of telecommunications and the internet, in order to meet the current and future needs of its customers.
How to contact us
Your opinion matters to us. If you have any queries, you can mail us at the postal address: Autostrada Tiranë-Durrës, Rr. “Pavarësia”, Nr. 61, Kashar, Tiranë, Albania; or, you can send us an email at: email@example.com.
Vodafone considers the protection of your privacy and personal data as a very important matter and is committed every day to rigorously implementing the entire legal framework in their protection and respect, as defined by the Constitution of the Republic of Albania, Law No. 9887, dated 10.03.2008, “On the Protection of Personal Data” as amended, Law No. 9918, dated 19.05.2008, “On Electronic and Postal Communications” as amended and other bylaws issued for the implementation of the above-mentioned laws.
The protection of personal data is based on: a) processing in a fair and lawful manner; b) the collection of information for clearly defined, legitimate and specific purposes, and in processing in accordance with these purposes; c) the adequacy of the data, which must be related to the purpose of the processing and must not exceed it; d) the accuracy of the data and, when necessary, the data should be updated; every reasonable step must be taken to delete or correct inaccurate or incomplete data in relation to the purpose for which it was collected or further processed; d) keeping the data in such a form as to enable the identification of data subjects for a period of time, but not more than is necessary for the purpose for which they were collected or further processed; dh) processing in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss or damage.
The personal data that Vodafone collects from its customers are always used in accordance with the legislation in force. Personal data is only processed for the exact period of time and in accordance with the specific purposes for which it was collected by Vodafone.
All methods of personal data collection (such as customer application forms or collection through participation in various competitions, or from the use of Vodafone applications) will have attached full explanatory information on the purpose of collection, even if it is secondary and not easily understood by you (such as in the case of various competitions; if the collection of personal data is for marketing purposes, then this will become clear to you and you will be given the opportunity to refuse the provision of data).
PERSONAL INFORMATION WE COLLECT ABOUT YOU
The information we collect about you and how we collect it can vary depending on the products and services that you use and subscribe to, how you have used the products and services, and how you have interacted with Vodafone even if you aren’t a customer, or what we have obtained from a third party with permission to share it with us.
Vodafone will process your personal data based on:
- The performance of your contract or to enter into the contract and to take action on your requests. For example, so you can make calls and texts, and browse the internet on your phone, we process things like the numbers you dial, how much data you’re using and when you’re doing it so we can provide connectivity. This also enables us to generate your bill.
- Vodafone’s legitimate business interests, for example, fraud prevention, maintaining the security of our network and services, direct marketing, and the 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.
- Compliance with a mandatory legal obligation, including for example accounting and tax requirements and regulations in relation to electronic communications and financial services, which are subject to strict internal policies (such as retention periods), procedures, and your right to restrict usage of your data.
- Substantial public interest, for example, to assist with detecting and preventing fraud, tax evasion and financial crime, or to safeguard the economic well-being of certain individuals.
- Consent you provide where Vodafone does not rely on another legal basis. Consent may be withdrawn at any time through our applications (My Vodafone and JUTH) or by visiting one of our stores.
We will collect your personal information when you, for example:
- Buy or use any of our products and services;
- Use our network or other products and services offered by Vodafone;
- Register for a specific product or service;
- Subscribe to newsletters, alerts or other services from us;
- Contact us through various channels, or ask for information about a product or service
- Take part in a competition, prize draw, event or survey;
- Visit or browse our website;
- Have given permission to other companies to share information about you;
- Where your information is publicly available, or
- Are the customer of a business that we acquire.
We may also collect information about you on CCTV when you visit our premises or on other security cameras as part of our security and crime prevention measures.
The types of information we may have are, where applicable:
- Your name, surname, personal identification number, address, mobile number, fix number, date of birth, gender, copy of ID, email address and IP address. Your identification data are mandatory to enable your connection to the network according to the provisions of Law No. 9918/2008 "On Electronic communications in the Republic of Albania", as amended. Other contact details are voluntary data to benefit from customer care services.
- Your credit or debit card information, information about your bank account and other financial information. We’ll collect the data necessary to process a payment whenever you make a purchase.
- Your traffic data. Vodafone processes traffic data which are necessary so as to provide you with connectivity, like call time, duration, number called, charging for the relevant service, etc.
- During the service process, Vodafone can find out when, with whom and respectively how long your phone calls have lasted. Vodafone processes this data to enable the analytical table of monthly telephone calls as well as to enable the management of debtors for unpaid bills.
- Your 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 less precise where, for example, a location is derived from your IP address or data such as a post code or name of a town/city.
- Your contact with us, such as a note or recording of a call you make to one of our contact centres, a Live Chat (TOBI), an email or letter sent, or other records of any contact with us.
- Your account information, such as dates of payment owed or received, subscriptions you use, account numbers or other information related to your account or included in My Vodafone or Juth app.
- Credential information – we’ll collect passwords and similar security information used for authentication and access to accounts and services.
- See the Cookies Policy for details on what we collect using cookies and other technologies, including ad data.
- In accordance with the requirements of the Regulation "On protection of consumers and subscribers of public electronic communications services", approved by Decision of the Steering Council of AKEP no. 2, dated 11.03.2021, Vodafone may collect sensitive personal data related to subscribers with disabilities, such as: type of disability, membership in associations, preferred method of communication, etc. in order to provide and guarantee adequate access to the service for these subscribers.
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 the specific services or products, for example: To ensure we offer our TV service, Vodafone TV, and to continuously improve it, we collect information about list of channels etc.
HOW WE USE YOUR PERSONAL INFORMATION
We will use your personal information for the following purposes:
1. To provide you with your service
Vodafone collects data from telephone traffic in order to provide the highest quality service to customers and to best respond to their requests. This data gives us the opportunity to further develop our services, improve them and provide you with information that has been prepared according to your requirements, such as SMS, MMS, e-mail, telemarketing, etc. In the same way, Vodafone collects and processes your call and internet traffic data. The history of the websites you visited can be saved so that next time you can easily connect to these sites.
Processing your order and providing you with your products and services
- To process the products and services you’ve bought from us, install equipment at your property or deliver equipment to you, and keep you updated with the progress of your order.
- To provide the relevant product or service to you. This includes other services not included in your agreement with us, services that use information about where you are, and to contact with you for messages about changes to the products or services.
Billing and customer care
- To bill you for using our products and services, or to take the appropriate amount of credit from you.
- To respond to any questions or concerns you may have about our network, products or services.
We will contact you with customer service messages to keep you updated with current information about products and services you’ve taken. For example, changes to our terms and conditions or service interruptions.
Providing roaming services
- To improve your roaming experiences, to ensure that we’re meeting our commitments around fair use, to detect and resolve fraudulent use of our networks (and our partners' roaming networks) and to solve technical issues if you are experiencing any.
- To understand how Vodafone is performing in providing roaming services, whether roaming services and related products are working as intended, or whether improvements are needed to make roaming better.
2. To improve our service
Improving and innovating our products and services
- We collect anonymous, de-identified or aggregate information in order to improve the service we offer to everyone. None of these analytics reports are linked back to you in any way.
Managing our networks and understanding network usage
- 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.
- To understand how you use our networks, products and services. That way we can seek to review and improve these, and develop more interesting and relevant products and services, as well as personalizing our products and services.
3. Vodafone market analysis, sales and direct marketing activities
- Vodafone constantly strives to adapt its electronic communication and TV services to the requirements of its customers and to continuously improve them. For this reason, Vodafone does market research where we try to understand the wishes of our customers. Your phone and internet usage information help Vodafone develop new products and services.
- Vodafone may use your personal information for commercial or promotional purposes and make this information available to third parties, but only with your consent. Vodafone may have received your data from other companies that collect and sell data as part of their business. At the same time, Vodafone needs to use your data to advice you on using Vodafone services and products.
- To provide you with the best possible services, Vodafone, only with your consent, will use your personal data for direct marketing purposes. You can choose not to be contacted for the whole field of direct marketing or even for specific categories of it. Thus, you can make a separate complaint about: direct mail; bulk SMS; e-mail; outbound telemarketing; and market research participation.
4. Fraud prevention and security
We will process your personal and traffic data in order to protect against and detect fraud, to protect and detect misuse or damage to our networks or to recover debts.
5. To improve your Vodafone website experience
HOW WE SHARE YOUR PERSONAL INFORMATION
Where applicable, we share 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.
- Companies who are engaged to perform services for, or on behalf of, Vodafone Limited, or Vodafone Group.
- Debt collection agencies or other debt-recovery organizations.
- Law enforcement agencies, government bodies, regulatory organizations, courts or other public authorities if we have to, or are authorized to by law.
- A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement.
- Emergency services (if you make an emergency call), including your approximate location.
- Third parties that we use to serve you marketing of Vodafone products.
Fraud management and law enforcement
- We will release information if it’s reasonable for the purpose of protecting us against fraud, defending our rights or property, or to protect the interests of our customers.
- We also may need to release your information to comply with our legal obligation to respond to the authorities’ lawful demands. Your personal data shall only be provided when we in good faith believe we are obliged to do so in accordance with the law and pursuant to an exhaustive evaluation of all legal requirements.
Mergers and acquisitions
If we’re reorganised or sold to another organisation, we will provide your information to that organisation.
Third parties that we work with
The disclosure of personal data to third parties will only take place if these parties are agents or in the service of Vodafone and act in accordance with our instructions. For example, Vodafone cooperates with third parties, such as with the company "Marketing & Distribution" shpk in order to benefit from its documentation archiving service or with the company "TNT Express Albania" shpk in order to provide to its customers the service of sending invoices by mail. In any case, Vodafone ensures that these third parties meet the confidentiality of information obligations and all necessary conditions of data protection and security. Vodafone does not disclose your personal information to third parties who are not Vodafone’s agents or service providers, unless express consent has been granted.
If you have given your consent to a third party, in order to obtain your personal data from Vodafone, then Vodafone is not responsible for the transfer of this data.
Third party devices that you connect to your SIM
You may connect third party devices to your SIM. These may include mobile devices or connected devices such as smart watches.
When you connect your SIM to these devices, these third parties may record your SIM information or your interaction with the network. These device manufacturers will process your personal data in accordance with their privacy policies and we recommend that you read those policies before choosing to connect your SIM with their devices.
Third party products that you buy through your Vodafone account
When you buy a third-party product or service through your Vodafone account (such as TIDAL, etc.), you enter into a contract with the company selling that product or service. Vodafone is only charging the amount directly to your bill as part of its arrangements with the partner company. In this context, you are agreeing that Vodafone may pass certain personal information to such parties, in order to complete your purchase with them.
The seller’s terms and conditions and privacy and cookies policies will apply to how it uses your personal information – please read them carefully.
Data for telephone directories and service numbers
Pursuant to Law No. 9918, dated 19.05.2008, ‘On Electronic and Postal Communications’ and other bylaws, Vodafone is obliged to cooperate with the relevant entities recognized by law for the establishment of telephone directories. Your personal information may be provided to companies that create these directories only with your consent. When you choose one of Vodafone’s subscription services, you will be asked for consent to participate in the telephone directory and to include the personal data you want to share. This will enable Vodafone to transmit your data for the creation of general telephone directories based on the instructions of the Regulatory Authority and in compliance with the protection of personal data.
INTERNATIONAL DATA TRANSFERS
For the purposes of providing and maintaining its service, Vodafone, as part of “Vodafone Group” Plc, has the right to share databases and service platforms where its subscriber data is kept with other companies of “Vodafone Group” Plc, and these databases and service platforms may be physically located in other countries in the world where “Vodafone Group” Plc operates. Moreover, Vodafone, for the purposes of providing its service, may need to transfer personal data to countries that provide a sufficient level of security and protection of personal data according to the list approved by Decision No. 8, dated 31.10.2016 of the Commissioner for the Right to Information and Protection of Personal Data, or in other countries in accordance with the requirements of Law No. 9887/2008 "On the Protection of Personal Data", as amended. In any case, Vodafone ensures that there is a proper contract that clearly defines the obligations of the parties during the data transfer.
International transfers may be to companies with which Vodafone cooperates to enable the provision of various services in accordance with international standards.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
Personal data will be stored for as long as necessary according to the main purpose of their collection. Data retention deadlines will be in full compliance with the applicable legal framework.
In some cases, some of the data that is not usually stored by Vodafone may be stored due to special circumstances, such as judicial investigations.
Data storage deadlines are as follows:
- Telephone traffic data is stored for as long as is necessary to guarantee the provision of the service. Traffic data is also stored for the needs of the prosecution bodies and criminal case courts, according to the relevant legislation. Telephone traffic data includes call time, duration, number dialed. These data together with the abovementioned data that serve for your identification will be stored for a period of 2 years in accordance with the provisions of Law No. 9918/2008 "On Electronic Communications in the Republic of Albania", as amended.
- For the same reason as above, Prepaid customers data - the data collected through the Subscription contract - shall be stored for a period of 2 years from the termination of your subscription.
- In the case of postpaid customers, we are required by the Civil Code (so that we properly manage any disputes that may arise) to keep your data - the data collected through the Subscription contract – for a period of 10 years from the termination of your contract.
- Monthly invoices (not analytical invoices) are stored for up to 10 years from their date of issue in accordance with the requirements of Law No. 25/2018 “On Accounting and Financial Statements” and the requirements of the Civil Code.
KEEPING YOUR PERSONAL INFORMATION SECURE
Vodafone Albania, aware of the importance and sensitivity of personal data, strictly respects the security measures provided in Law No. 9887, dated 10.03.2008, ‘On the Protection of Personal Data’. This is achieved by using advanced and modern techniques to maintain its databases and computer systems. Vodafone also ensures that the transfer and registration of data follows strict security measures in full compliance with the relevant legislation.
However, our website may provide links to third-party websites. Vodafone is not responsible for the security and content of these websites and advises you to read that company’s privacy and cookies policies before using or putting your personal information on their site. The terms of these sites may differ from those of Vodafone.
Pursuant to Law No. 9887, dated 10.03.2008, ‘On the Protection of Personal Data’ as amended in relation to personal data processed by Vodafone, you have the following rights:
- Right to access personal data – You have the right to request, at any time confirmation if your personal data are being processed by Vodafone and to have access on this data and information the purpose, period, legal grounds for processing, data category that are being processed and category of recipients of the data. To submit your request please use the following form.
- Right to request the blocking, correction or deletion of personal data – If you are informed that the information held about you is not accurate or has been collected and processed in violation of the law, you have the right to request the correction or deletion of your personal data as well as the immediate cessation of processing. To submit your request please use the following form;
- Automatic decision-making – You have the right to request not to be subject to decisions that have legal effects on you or significantly affect you when the decision is based on automatic data processing.;
- Right to data portability – You have the right to request that the data that we process about you to be transferred to another controller, when technically feasible. To submit your request please use the following form;
- Right to object to use of personal data – You have the right, in certain circumstances, to object to Vodafone processing of your personal information for specific reasons as marketing and profiling. If you wish to object the use of personal data for marketing or profiling purposes, you can do so through My Vodafone App and/or the Juth App by following the instructions here. To submit your request please use the following form;
- Right to lodge a complaint – If you feel that your rights, freedoms or legitimate interest have been violated you can contact us by mail.
Your written request and/or complaint should be followed with your signature and a valid identification document.
All requests/complaints must be mailed to the following address:
Rr: ‘Pavarësia’, Nr. 61,
Kashar, Tiranë, Albania
Or you can send us an email at:
Please attach your name, address and mobile number to your application. Also for security reasons please use the email address that you have declared during your registration as Vodafone customer to send your request. Vodafone will take all the necessary steps to identify your identity before releasing a copy of the information.
We will aim to work through your request/complaint as quickly as possible and within 30 days of receiving it, we will send you the requested information or inform you of the reason for not executing your request.
In case you are not satisfied with the handling of requests by Vodafone, you always have the right to contact the Office of the Commissioner for Personal Data Protection at this address: Rr. "Abdi Toptani", nd. 5, Tiranë. For more information visit the Commissioner’s website: www.idp.al.
Vodafone Albania reserves the right to change or modify this Policy at any time in accordance with any possible changes made to the legislation in the field of personal data protection and privacy.