VEON Privacy Policy

Last updated: 25 May 2018

VEON Digital Amsterdam BV (“VEON Digital”, “we”, “us”, “our”) provides the VEON platform (“VEON”). VEON Digital controls the information we collect for the purposes of the General Data Protection Regulation (“GDPR”).

We’re committed to protecting and respecting your privacy. Please read this policy carefully - it explains how we process your information. By downloading and using VEON, you agree to us collecting, processing, using and storing your information as described here.

From time to time, we link to and from the feeds, websites or apps of our partner networks, advertisers and affiliates that we think you’d be interested in. If you follow a link to any of these websites or apps, it’s important to remember that they have their own privacy policies. Please check these policies before you submit any information to these websites or apps – we can’t accept any responsibility or liability for the privacy practices of other websites or apps.

The types of information we collect & how we use it.

We collect information about you when you use VEON, such as information about sign-ups, chats (including who you called or chatted with, and for how long), your device and its technical specs, information about your usage of VEON and associated server logs, your transaction history and – in certain situations – your location. This is set out below:

VEON Marketplace and Marketing, Personalised Content

We will also use your information for marketing as described below. You have the right to change your consents at any time in the Legal and Consents section of Settings within VEON if you do not want us to use your information for marketing purposes.

Tracking Technologies

We and our third party service providers use tracking technologies such as mobile SDKs (which collect information such as mobile identifiers like IDs for Advertising on iOS and Android Advertising IDs) and other similar tracking technologies to enhance your experience using VEON.

These technologies enable us to provide certain features and functionality, improve VEON and your experiences on VEON, remember your choices such as your language preferences, limit the number of times you see an advert or promotion as well as help measure the effectiveness of an advertising campaign, understand how you interact with and use our services to improve our services and market our services to you via VEON or other platforms.

We also use analytics software to monitor, on an anonymised basis, user actions on VEON such as screens opened, buttons clicked, sign in events and downloads for the purposes of performance monitoring of VEON.

You can disable collection of advertising identifiers (such as IDs for Advertising and Google Advertising IDs) for targeted advertising. For iOS mobile devices, go to “Settings” from your mobile device’s home screen, scroll down to “Privacy”, select “Advertising” and then turn on “Limit Ad Tracking”. For Android mobile devices, go to “Google Settings” on your mobile device, select “Ads” and then check the box labelled “Opt Out of Interest-Based Ads”.

How we share your information

We share your information – including your enriched information – with selected third parties, as follows:

If legally required to do so, or if we have a good faith belief that such use is reasonably necessary, we share your information with law enforcement agencies, public authorities or other organisations to:

We will also disclose your information to third parties:

Where we store your information

We provide a global service so, while most of your information is processed on servers in the Germany, Ireland and other countries in the EU, some of the information that we collect from you will be transferred to, and stored at, a destination outside of your country and for users in the European Economic Area ("EEA"), outside of the EEA and in particular in the United States of America, Ukraine, Russia, Georgia and Pakistan. To comply with European data protection law, we make sure that all such transfers of EEA personal information are made subject to the European Commission’s model contracts for the transfer of personal information to third countries, pursuant to appropriate European Union law. These contracts contain obligations to help protect your personal data – if you would like to see a copy, please email contact@veon.com. The European Union Standard Contractual Clauses for transfer of personal information outside of the EU can be found here.

The security of your information

Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your information, but we cannot guarantee the security of your information transmitted through VEON; any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access to your information within our control and possession.

Data retention

We will retain your information for the purposes of providing VEON to you and for providing Marketplace offers and promotions to you if you have chosen to receive these. If your account is inactive for more than one year, we will delete your information unless we are required to retain it to comply with applicable law or meet our legal obligations.

After you have terminated your use of VEON’s services, we will store your information in an aggregated and anonymised format.

How you can manage or delete information

You can delete your VEON account at any time. If you delete your account, we will delete information that you have posted (such as status updates). Please note that the chats sent to, or received from, other users and other information shared with those users (such as contact details, photos and other media) will be retained on those users’ accounts.

Your rights

Children

VEON is not directed at children under the age of 16. We do not knowingly collect personal information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should email us at contact@veon.com. We will delete such accounts and information relating to those accounts from our systems within a reasonable time.

Changes

Any changes we make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.

Contact

Questions, comments and requests regarding this policy are welcomed and should be addressed to the VEON Digital Data Protection Officer at DPO@veon.com.

Appendix 1: Legal Basis of Processing

Last updated: 25 May 2018

Category of Personal Information Processing Purpose

Legal Basis for Processing

Sign-up information: We collect information you provide when you sign up for a VEON account. This includes information such as your name, phone number, email address, profile picture, data collected from a social network (if you log in using your social login ID) and other information you choose to provide. When signing up, you can choose to sync VEON with other services, such as your contacts or social media accounts.

We process sign-up information to operate and provide VEON to you.

If you choose to sync VEON with other social media, we store this information so that you can share your VEON activity with your friends and family.

Necessary for our contract with you.
Chat information: We collect, process and store information such as your online status, your last updated status, your last usage of chat and details of who you chatted with (including who you called or chatted with, and for how long) (“Chat Logs”).

We process chat information in order to run our chat service. We also store your chats so you can search your history and don’t have to worry about losing messages.

We will only use Chat Logs to provide you with value added services such as marketing if you consent.

We process chat information (excluding Chat Logs) because it is necessary for our contract with you.

We process Chat Logs based on your consent. You can withdraw consent at any time - see here for more information.

Device and technical usage information: We collect information you provide when you use VEON, such as your customer profile, unique identification code, mobile carrier and time zone setting. We also collect device information such as operating systems, battery and signal strength, device identifiers and settings and software names. We process device and technical usage information to let you know about your usage statistics and traffic information, to assist us in enforcing our terms, conditions and policies, to improve VEON and our marketing, to administer internal operations (such as for troubleshooting, data analysis, testing, research, statistical and survey purposes), to keep VEON safe and secure (including verifying accounts and activity) and to comply with legal obligations.

We process device and technical usage information because it is necessary for our contract with you.

Necessary for our legitimate interests (to offer a successful product).

Usage information: We collect your usage data – such as stats about how you use our in-app content, services, offers and promotions – and Chat Logs.

We process your usage information to make sure that VEON is easy and fun to use. We do this to provide you with a personal experience (for example, based on your “likes”). We will also measure the popularity and effectiveness of our content, services, offers and promotions, to make these more relevant for you.

Necessary for our contract with you.

Necessary for our legitimate interests (to offer a successful product).

Transaction information: We can’t do everything ourselves, so we use third parties to process payments, and all payment information will be subject to their privacy policies. We won’t collect or use your payment, account or card details, but we will collect information about what services you purchase via VEON.

We collect transaction information so we can better tailor VEON to you.

We use this type of transaction related data for value added services including marketing if you consent.

Necessary for our legitimate interests (to offer a successful product).

Necessary for our contract with you.

For value added services, including marketing, if you consent. You can withdraw consent at any time - see here for more information.

Log Information: When you use VEON, we collect server logs, which includes information like device IP address, access dates and times, app features, app crashes and other system activity, and the third-party services you were using before you started using VEON. We process sign-up information to operate and provide VEON to you. Necessary for our contract with you.

Location information: VEON collects information about your location based on:

  • derivations made from the IP address from which you connect; and/or

  • if you consent (by accepting on your mobile operating system), the Global Positioning System (GPS) of your device when VEON is running in the foreground or background.

(together, “Location Information”).

We (and our service providers) use your Location Information to provide you with location based tools and functions (“Location Functions”).

With your consent, we also provide customised nearby services or value added services (including marketing) (“Location Value Added Services”) on VEON that we think you’d like. We also use Location Information to enhance or localise content and services that you use on VEON.

We process Location Information based on your consent.

If you do not wish to share your GPS location with us or use any Location Functions, you can either switch off the GPS functionality on your mobile device or turn off the relevant Location Functions within VEON.

If you otherwise wish to withdraw your consent to us using Location Information for providing Location Value Added Services, You can withdraw consent at any time - see here for more information.

Appendix 2: Country specific items

California Residents

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2017 will receive information regarding 2016 sharing activities). To request a notice, please submit your request by email to DPO@veon.com. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Russia

For users of our app downloaded from the Russia Appstore and Playstore, we collect and process your information in the first instance using databases and servers located in Russia but such information may subsequently be transferred to servers outside of Russia.