Last updated: 17/01/2021
How to use this privacy and cookies policy
In this policy, we explain how we collect, use, share and protect your personal information when you use our products and services and our website.
- • “we” or ”us” means Clear Mobile. Clear Mobile is a trading name of, and operated by, Vodafone Ireland Limited which is a private company limited by shares registered in Ireland at Mountainview, Leopardstown, Dublin 18. Reg no. 326967; and
- • “third party” means someone who is not you or us.
How to contact us
Personal information we collect about you
We collect personal information about you based on how you have used our products and services, how you have interacted with Clear Mobile (even if you aren’t a customer), or what we have obtained from a third party with permission to share it with us.
We 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, based on your usage. We also need to conduct credit checks when you apply for a product or service.
- Our legitimate business interests for example, fraud prevention, maintaining the security of our network and services, direct marketing, research and analytics, and 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, which are subject to strict internal policies (such as retention periods), procedures, and your right to restrict usage of your data, which control the scope of legal assistance to be provided; or,
- Consent you provide, for example, processing of certain types of personal data for research and analytics where we do not rely on another legal basis. Consent may be with drawn at any time by changing your data preferences. Sign into your online account to view your data preferences.
We will collect your personal information when you, for example:
- Buy or use our products and services;
- Use our network;
- 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 or survey;
- Visit or browse our website;
- Have given permission to other companies, such as our business or joint-venture partners as well as our third-party suppliers or contractors, to share information about you;
- Where your information is publicly available; or,
- Are the customer of a business that we acquire.
We also collect information from certain organisations, where appropriate and to the extent we have legal grounds to do so. These include fraud-prevention agencies, business directories, credit check reference/vetting agencies, billing calculating agencies and connected network providers.
The types of information we may have are:
- Your name, address, mobile number, date of birth and email address;
- Your credit or debit card information or bank details– for example, you’ll have to give us this information when you open an account with us. We’ll collect the data necessary to process a payment whenever you make a purchase;
- Your traffic data. This is data we see as part of providing you with connectivity like the numbers you call, the time and duration of the call or the amount of data you are using;
- Your location data. This can be precise where you use Global Positioning System (GPS) data or by identifying nearby mobile phone masts and Wi-Fi hotspots when you enable location-based services or features. Or less precise where, for example, a location is derived from your IP address or data such as a eircode or name of a town or 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, 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 online account;
- Credential information – we’ll collect passwords, hints and similar security information used for authentication and access to accounts and services;
- Your preferences for particular products, services and lifestyle activities when you tell us what they are, or we assume what they are, based on how you use the products and services;
- See Cookies for details on what we collect using cookies, web beacons and other technologies, including ad data;
- Information we obtain from other sources, such as credit agencies, fraud-prevention agencies, and from other data providers. This includes demographic data, interest based data, and internet browsing behaviour.
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: every time you use your mobile phone, a record is kept. This includes the number you called or sent an SMS or MMS to, the length, date and time of that call, SMS or MMS and your approximate location at the time that the communication takes place (based on the location of the nearest cell that you sent that call or message from). The same is also recorded every time you receive an incoming call or message. We don’t, however, keep a record of the content of your calls or messages.
How we use your personal information
We will use your personal information for the following purposes:
1. To provide you with your service
Processing your order and provide you with your products and service
- To process the products and services you’ve bought from us, and keep you updated with the progress of your order;
Processing your order and provide you with your products and service
- To process the products and services you’ve bought from us, and keep you updated with the progress of your order;
Billing and Customer Care
- To bill you for using our products and services;
- Contact you if the billing information you provided us with is about to expire or we’re not able to take payment;
- 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 purchased. For example, changes to our terms and conditions, price plan and data use, roaming or service interruptions.
Provide 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 partner roaming networks) and to solve technical issues if you are experiencing.
- To understand how we are performing in providing roaming services, whether Roaming Services and related products are working as intended, or whether improvements are needed to make roaming better.
We use personal data such as your name, email address, password, mobile phone number, and call records in order to do this. We may create aggregated and statistical management reports from this information that do not identify you individually. We may also take this personal data and anonymise it so that more in-depth analysis of our roaming services can be undertaken. This helps us to develop its roaming services for customers without identifying users in an individual way.
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 are linked back to you in any way.
Manage our networks and understand 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 to 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, develop and improve these, develop more interesting and relevant products and services, as well as personalising our products and services.
3. Marketing & tailoring our service to you
- As our customer, we will keep you informed generally about new products and services, send you newsletters or white papers, and invite you to participate in a survey or let you know about offers, promotions, prize draws or competitions.
- We’ll contact you by post, online, phone, SMS, or push notifications through apps where available.
- We can further tailor these messages using your calling and messaging activities, location information and browsing information, if you have authorised that we process this information for this purpose;
You can control your Marketing permissions and the data we use to tailor these communications at any time using your online account.
- Remember that opting out of interest-based advertising won’t stop advertisements from being displayed – but they won’t be tailored to your interests.
Research and analytics
We use a variety of analytics methods including what is commonly referred to as “Big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets (that is why it is “big” data) to uncover hidden patterns and hitherto unrevealed trends. We take governance of big data analytics seriously. Our data scientists are required to sign up to a Code of Ethics. We have a strict use case process that requires that privacy and data protection law checks are carried out before any use case commences. We have strict rules ensuring that personal information is anonymised or de-identified at the appropriate stage in the process.
We use our analytics to:
- Conduct market research and to carry out research and statistical analysis including to monitor how customers use our networks, products and services
- Frame our marketing campaigns and determine how we might personalise those;
- Provide anonymised and aggregated reports to third parties (such reports don’t contain information which may identify you as an individual). These can be to third parties such as content providers, advertisers, and other business or public entities.
We will sometimes need to profile you, for credit, fraud and security purposes.
Credit checks and ID
- We may carry out a credit check when you apply for a contract for any products or services with us.
- We will also use your personal information for identity verification purposes, for access to your account and for general account management. We sometimes supplement the information we collect about you with information from other sources to assess the accuracy of the information that we hold.
Fraud Prevention & Security
- We will process your traffic data in order to protect against and detect fraud, to protect and detect misuse or damage to our networks, to recover debts or trace those who owe us money resulting from the use of our services.
How we share your personal information
Where applicable, we share information about you with:
- Companies within our group of companies;
- Partners or agents involved in delivering the products and services you’ve ordered or used;
- Companies who are engaged to perform services for us on our behalf or on behalf of any company within our group of companies;
- Credit reference, fraud-prevention or business-scoring agencies, or other credit scoring agencies;
- Debt collection agencies or other debt-recovery organisations;
- Law enforcement agencies, government bodies, regulatory organisations, courts or other public authorities if we have to, or are authorised 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 for joint promotions with that third party;
- Partner organisations we’ve carefully chosen so they can contact you about their products and services. We’ll ask for your consent before sharing this information;
- Other third parties when you are signing up to their service and it is used by them forauthentication and fraud-prevention purposes;
- Third parties that we advertise with, such as Facebook, in order to serve you advertisements online;
- Third parties that we use to serve you marketing.
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
Where you’ve purchased our products and services using a third party or partner organisation, we often need to exchange information with them as part of managing that relationship and your account– for example, to be able to identify your order and be able to pay them.
If we have a contract with a service provider or contractor to provide us with services or provide a service on our behalf, and they may have access to your personal information, we don’t authorise them to use or disclose your personal information except in connection with providing their services.
We collect and combine information in order to monitor your use of products and services, and that of our other customers, as well as to help us to improve the quality of our products and services. We provide this information to third parties (for example, to content providers and advertisers) but any such third party reporting shall not include information which may identify an individual customer.
Third party products that you buy through your account
Where you buy a third-party product or service through your account (such as Charge to Bill services, the contract for it is with the party selling that product or service. We are only charging the amount directly to your bill as part of our arrangements with the seller. As part of this, you’re agreeing that we may pass certain personal information to the seller 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.
International Data Transfers
We may need to transfer your information to other companies within our group of companies or service providers in countries outside the European Economic Area (EEA). The EEA consists of countries in the European Union, Switzerland, Iceland, Liechtenstein and Norway: they are considered to have equivalent laws when it comes to data protection and privacy. This kind of data transfer may happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the EEA, or if you use our services and products while visiting countries outside this area.
If we send your information to a country that is not in the EEA, we will make sure that your information is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer. In addition, if the country is not considered to have laws that are equivalent to EU data protection standards then we will ask the third party to enter into a legal agreement that reflects those standards.
Some of our customer care services are based in our Service Centres in Egypt and India. Companieswithin our group of companies operate under a shared agreement based on the standard contractual clauses set out by the European Commission for the transfer of personal data to data processors established in third countries.
How long we keep your personal information for
We’ll store your information for as long as we have to by law. If there’s no legal requirement, we’ll only store it for as long as we need to.
We’ll keep some personal information for a reasonable period after your contract with us has finished in case you have any questions following the closure of your account, or decide to use our services again. We, or one of our partners, may contact you about our services during this time if you haven’t opted out of receiving marketing communications from us.
Keeping your personal information secure
We have specialised security teams who constantly review and improve our measures to protect your personal information from unauthorised access, accidental loss, disclosure or destruction.
Communications over the internet (such as emails) aren’t secure unless they’ve been encrypted. Your communications may go through a number of countries before being delivered, as this is the nature of the internet.
We cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
We’ll never ask for your secure personal or account information by an unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.
Our website may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. So make sure you read that company’s privacy and cookies policies before using or putting your personal information on their site.
The same applies to any third-party websites or content you connect to using our products and services.
You may choose to disclose your information in certain ways such as social plug-ins (including those offered by Google, Facebook, Twitter and Pinterest) or using third-party services that allow you to post reviews or other information publicly, and a third party could use that information.
Right to correct personal data
You have the right to have information held about you corrected if it is not accurate. If your personal information needs updating, or you think it may be inaccurate, or contact our customer services team.
Right to access personal data
You have the right to make a request for a copy of the personal data that Clear Mobile holds about you. To make this request as an individual or an authorised 3rd party, please email us firstname.lastname@example.org. When submitting any request by email, please ensure to provide enough information to allow us to identify and verify your account (name, mobile number, postal address and date of birth).
Right to data portability
You have the right to be able to take with you data you provided to us in certain circumstances. In order to do this, please email email@example.com and we will provide you with a file containing any information you provided to us when signing up to Clear Mobile. When submitting any request, please ensure to provide enough information to allow us to identify and verify your account (name, mobile number, postal address and date of birth).
Right to object to use of personal data
You have the right, in certain circumstances, to object to Clear Mobile processing your personal information. Please contact us at firstname.lastname@example.org for any queries.
To opt out of marketing messages:
If you no longer want to receive marketing messages from Clear Mobile, you can opt out of marketing communications. You can also chose only to receive marketing messages through your preferred medium (email, SMS, phone, or post) or you can opt out of all marketing.
There are various ways to opt out:
- Sign into your online account to manage your permissions;
- Contact our customer services team
- Tell the adviser if you receive a marketing call;
- Email email@example.com for guidance.
Opting out of direct marketing messages does not mean that you will not receive service-related messages. You will continue to receive those (unless we have indicated otherwise).To manage Cookies and understand more about what they are: Want to disable a cookie, or understand more about what these are? Check the Cookies section of this policy for full details on how to do this.
How to lodge a complaint
If you want to contact us about any of your rights or complain about how we use your information, contact our Customer Services team or email us at firstname.lastname@example.org We’ll do our best to help but if you’re still unhappy, you can contact the Data Protection Commission, who may be contacted by email email@example.com or by post to Data Protection Commission, Canal House,Station Road, Portarlington, R32 AP23 Co Laois.
Right to restrict use of your data
If you feel data we hold on you is inaccurate or believe we shouldn’t be processing your data, pleasecontact us to discuss your rights. In certain circumstances you will have the right to ask us to restrictprocessing.
Right to erasure
We strive to only process and retain your data for as long as we need to. In certain circumstances youhave the right to request that we erase personal data of yours that we hold. If you feel that we areretaining your data longer than we need, please contact us at firstname.lastname@example.org.