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This privacy supplement describes the type of personal information we process and explains how we collect, use, share and protect your personal information. This privacy supplement is not intended to replace Vodacom’s privacy policy but is designed to provide additional contextual information relating to SwitchONBenefits. For more information on the Vodacom privacy statement please click here or go to the Vodacom Privacy Portal: https://www.vodacom.co.za/vodacom/privacy-policy/switch-on-benefits

Last updated: [14 March 2022, Alegra Dijkstra]

What is SwitchONBenefits

SwitchONBenefits (also referred to as “the Service”) is a rewards benefits service that offers 2 variants; 1) a free service and 2) a Premium subscription service that is available exclusively to Vodacom subscribers (“the Users”). The Service gives the Users the opportunity to participate in a subscription based service that will offer premium reward benefits. SwitchONBenefits will provide Users with weekly premium benefit offers from South Africa’s premium retailers. The Service is based on a weekly subscription charge based on '7 day’s eligibility. SwitchONBenefits can be accessed via an App (Android and iOS), a web portal that is mobile friendly, as well as a dedicated USSD platform. The Service may also grant users the benefit of discounted promotions, with Users being charged a discounted price for a special subscription available in a premium service at Vodacom’s discretion.

How to contact us

Your opinion matters to us – if you have any questions about this service, you can email us at: info@switchonbenefits.com.

Your opinion matters to us – if you have any questions about this privacy supplement, you can email us at: Askpopi@vodacom.co.za or you can write to our privacy team at:

The Privacy Office – Legal Affairs
Vodacom (Pty) Ltd
Corporate Park
082 Vodacom Boulevard
Midrand
1685

Personal information we collect about you

Personal information we collect about you

To enable you to make use of the Service, and provide the service, through the application, SwitchONBenefits collects the below information about you:

• MSISDN (Mobile Number), name and email address – This is used to manage and provide the service, to authenticate the user via OTPs (one-time PINs)/password, and to subscribe and bill the user as it relates to the service provision
• Information on how you use the service, such as the date, time and length of your usage (tracked by cookies)
• Subscription and billing for the service

We may use your information to contact you about our own goods and services that may be of interest to you. If you have agreed to receive 3rd party marketing, we may also use your information to contact you about 3rd parties’ goods and services.

We will share your personal identifiable information with Upstream Systems (Pty) Ltd (acquisition and subscription management partner) and Firefly Investments 190 (Pty) Ltd t/a Berelo Innovations (Customer interface (Web & USSD) content platform partner), who are our appointed service providers who enables the Services. Our Service Providers may need to transfer your information cross border to Greece which is where Upstream’s head office is located, in order to be able to provide the Service.

We might also use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your movements on our website). These collect information that tells us how you use our website, web-related products and services.

This, in turn, helps us make our website relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit our website again. See the next section for more details.

You can choose to refuse cookies or set your browser to let you know each time a website tries to set a cookie.

We collect your personal information when

• You subscribe to the service
• You use the service
• Vodacom will process your personal information based on:
  • Vodacom’s obligation – to provide you with the service you have asked for.
  • Vodacom’s legitimate business interests – when it comes to developing and improving the service to gain insights through app analytics.
  • Your communication preferences.

How we use your personal information

We may use your personal information for the following purposes:

• Provide, personalize, and improve our Products.
• To deliver our Products, including to personalize features, make suggestions for you (such as creative messaging and targeting) on and off our Products.
• Product research and development: We use the information we have, to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
• Provide measurement, analytics, and other business services.
• Help advertisers and other partners measure the effectiveness and distribution of ads and services and understand the types of people who use their services and how people interact with their websites, apps, and services.
• Promote safety, integrity, and security i.e.:
  • Verify accounts and activity,
  • Combat harmful conduct, detect, and prevent spam and other bad experiences,
  • Maintain the integrity of our Products,
  • Promote safety and security on and off SwitchONBenefits. For example, we use available data to investigate suspicious activity or violations of our terms or policies, or to detect when someone needs help.
• Send you marketing communications, communicate with you about our Products and Services, and let you know about our policies and terms.
• We also use your information to respond to you when you contact us.
• Conduct and support research and innovation on topics of general welfare, technological advancement, public interest, health, and well-being.

SwitchONBenefits Companies and Partners

• SwitchONBenefits share infrastructure, systems, and technology with other Partners, which includes but is not limited to:
  • Upstream Systems SA (Pty) Ltd
  • Firefly Investments 190 (Pty) Ltd t/a Berelo Innovations
• The sharing of infrastructure systems and technology is intended to provide an innovative, relevant, consistent, and safe experience across all Vodacom SA (Pty) Company Products you use.
• We also process information about you across the Companies for these purposes, as permitted by applicable law and in accordance with their terms and policies.
• We also work to understand how people use and interact with Company Products, such as understanding the number of unique users on different Company Products.

Information Sharing or Transfer

Information is shared with others in the following ways:

• If the ownership or control of all or part of our Product or their assets changes, we may transfer your personal information to the new owner, subject to a data processing agreement.
• Sharing with Third-Party Partners:
  • The SwitchONBenefits Service may contain links to third party websites or programs that are not controlled by or affiliated to Vodacom and/or its appointed service providers for this Service. Vodacom is not responsible for the content, offers or privacy policies of such sites and programs. Your dealings with third party sites e.g. acceptance of their cookies, are solely between you and the applicable third party.
  • We do not sell any of your information to anyone, and we never will.
  • We also impose strict restrictions on how our partners can use and disclose the data we provide.
  • Here are the types of third parties we share information with:
    • Partners who use our analytics services.
    • We provide aggregated statistics and insights that help people and businesses understand how people are engaging with adverts, listings, Pages, videos, and other content. For example, admin users receive information about the number of people or accounts who viewed, reacted to, as well as aggregate demographic and other information that helps us and them understand interactions.
• Sharing with Advertisers
  • We provide advertisers with reports about who is seeing their ads and how their ads are performing, but we do not share information that personally identifies anyone (information such as your name or email address that by itself can be used to contact you or identify who you are) unless you give us permission which will be applicable to lead generation campaigns.
  • Other information we share with advertisers include general demographic and interest information (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Midrand and likes software engineering) to help them better understand their audience. We also confirm which ads led someone to make a purchase or take an action with an advertiser.

International Data Transfer

• If you are visiting our websites from a country other than South Africa, the various communications will necessarily result in the transfer of information across international boundaries.
  • We may also need to transfer your information to our partners and service providers in countries outside South Africa, in which case we will fully comply with applicable data protection legislation. These partners include but are not limited to Upstream Systems (Pty) Ltd and Firefly Investments 190 (Pty) Ltd t/a Berelo Innovations.
• This may happen if our servers or suppliers and service providers are based outside South Africa, or if our services are hosted in systems or servers in Vodafone Operating Companies outside South Africa including the European Economic Area (EEA) or India and/or if you use our services and products while visiting countries outside South Africa.

How long we keep your personal information for

The personal information processed in connection with your account or activity will be de-identified or deleted five (5) years after agreement/subscription termination. This is in line with the Vodacom Pty (Ltd) personal data retention standards.

Vodacom Pty (Ltd) may retain aggregated and statistical reports about use of our Products and services, but these reports will not identify you as a user.

Keeping your personal information secure

• We are committed to implementing leading data security safeguards.
• 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.
• If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we will ensure that your information is protected and that they only process your information in the way we have authorised them to do so. These organisations will not be entitled to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we have set.
• Communications over the internet (such as emails) are not secure unless they have been encrypted. Your communications may go through several 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’s beyond our control.
• We’ll never ask for your secure personal or account information by unsolicited means of communication. You’re responsible for keeping your personal and account information secure and not sharing it with others.
• 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.
• Social plug-ins and social applications are operated by the social networks themselves and are subject to their own terms of use, privacy and cookies policies. You should make sure you’re familiar with these.

Your rights

At Vodacom, we are committed to processing personal information honestly, ethically, with integrity, and always consistent with applicable laws and our values. Below we set out details on how you can exercise your rights. Please note, under certain circumstances these rights may be limited if we still have lawful grounds to process your personal information. If you have a question or cannot find the answer, please contact our Customer Care team at Customer Care or call 082 135.

Right to correct personal information

You have the right to correct information held about you if it’s not accurate. The only personal information we will process will be if you decide to access SwitchONBenefits. To request a correction or updating your profile, you may contact our customer service team.

Right to access personal information

You have the right to make a request for a copy of the personal information that we hold about you. Having provided adequate proof of identity, you have the right to request to confirm, free of charge, whether we hold personal information about you and request from us the record or a description of the personal information about you held by us.

Right to object to use of personal information

In certain circumstances, you have the right, to object to us processing your personal information.

Right to unsubscribe and opt-out of the service

• Users can cancel their participation to the SwitchONBenefits Service at any time, by sending a free SMS with the cancellation keyword STOP or CANCEL to the respective dedicated SMS long code (0820099664) or by dialing *139*1# USSD string , or within the Service app (iOS or Android) or website (https://www.switchonbenefits.com/) by selecting the “Downgrade Membership” option in the “My Profile” page.
• Subscribers who join the SwitchONBenefits service are considered users of the Service until they cancel their subscription.
• A Subscription can also be cancelled at the sole discretion of Vodacom, in the event of a clear expression of non-interest in participating in the Service is demonstrated by a user (after subscription), via SMS communication (e.g. the User sending an SMS message reporting “I do not want to participate”).
• Users who cancel their subscription can re-register at any given time by sending the defined registration keyword(s) to the dedicated long code.

Right to deletion

In certain circumstances, for example, where you indicate that your personal information is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, you have the right to request that we erase your personal information that we hold.

How to lodge a complaint

Should you believe that Vodacom has used your personal information contrary to applicable law, you undertake to first attempt to resolve any concerns with Vodacom directly. Kindly click our customer care team. We will do our best to help but if you are still unhappy, you can contact the Privacy Office at askprivacy@vodacom.co.za.

If you are not satisfied with such process, you have the right to lodge a complaint with the Information Regulator at:

The Information Regulator (South Africa)
JD House, 27 Stiemens Street,
Braamfontein,
Johannesburg, 2001.

P.O Box 31533
Braamfontein, Johannesburg, 2017
Email: inforeg@justice.gov.za

Complaint’s email: POPIAComplaints@inforegulator.org.za