Mobile Internet Advertising Charter (the “Charter”)
1.1 The purpose of the Charter is to set out Vodafone’s commitment to customer privacy and compliance with the legal and regulatory framework governing mobile internet advertising in Ireland.
1.2 Please note that it is necessary for Vodafone customers to agree to the use of their personal information. Customers can opt-out at any stage without affecting their access to any Vodafone mobile internet services.
1.3 This Charter is not intended to be nor is it in substitution of any of the provisions of the Data Protection Acts 1988 and 2003 (the “Data Protection Acts”). Vodafone has established procedures which seek to ensure continued compliance with the Data Protection Acts.
1.4 This Charter should be read in conjunction with Vodafone’s general customer and product specific terms and conditions.
2. Commitment to Customer Privacy
2.1 The mobile internet is an emerging and continually evolving medium for advertising. Vodafone is committed to ensuring that its customers’ personal information and privacy rights are protected.
2.2 Vodafone is committed to ensuring its compliance with all applicable legal and regulatory obligations at all times.
3. Mobile Advertising
3.1 Mobile advertising is any advertising offer, promotion or incentive from a third party advertiser provided to Vodafone’s mobile customers via Vodafone’s mobile internet (“Vodafone Live!”). Mobile advertising is intended to enrich the consumer experience by providing tailored advertising and marketing solutions to customers from Vodafone and selected third parties.
3.2 In certain circumstances, it may be possible to make information more relevant to a specific customer by using their personal information, where that customer has expressly consented to this information being used for that purpose. Vodafone strives to use appropriate consent mechanisms in relation to all of its mobile internet advertising activities.
4.1 In addition to Vodafone’s legal and regulatory obligations, this Charter sets out Vodafone’s commitment to our customers to maintain the best in class standards in relation to the use of our customers personal information.
4.2 This charter draws on the guidelines set by the Advertising Standards Association of Ireland, the Internet Advisory Board, Broadcasting Commission of Ireland and the Department of Health and Family Affairs.
5.1 Vodafone offers a wide range of products and services using the most modern technologies including mobile telecommunications and internet related services.
5.2 Vodafone will retain control of all customers’ personal information at all times and will not provide this to third parties for use outside of Vodafone’s control without clear consent from our customers. Data will not be used, disclosed or processed in any manner incompatible with the purposes for which it was obtained.
5.3 Disclosure of customer personal data will only be made available to third parties who are our agents or servants acting on our directions. Save as required by law, no disclosure of data will be made to third parties for those third parties' own purposes or use without the customers express consent.
5.4 Data obtained from customers will be adequate, relevant and not excessive in relation to the purposes for which it was obtained.
6.1 Vodafone shall obtain clear, informed and active customer consent before personal information can be used for tailoring the advertising of third party products and services to a customer.
6.2 If a Vodafone service is necessarily supported by advertising, a customer may receive generic advertising irrespective of whether their consent has been obtained.
6.3 Only customers who have expressly provided their consent by opting in may directly be sent marketing messages from Vodafone and / or third party advertisers.
6.4 Customers are entitled to withdraw their consent to the use by Vodafone of their personal data at any time .
Vodafone is conscious that spam advertising is becoming increasingly common and continues to monitor its network for and seeks to minimise such activity.
8. Customer information that may be used in Mobile Advertising
Subject to customer consent being obtained, Vodafone’s mobile advertising inventory may be tailored using four main types of information as follows:
- network or service context;
- customer demographic information;
- customer behavioural information;