Shareholder privacy statement

We are Vodafone Group Plc. We are the parent company for the Vodafone Group and are the controller responsible for this website.

In this privacy policy:

• “we/us” means the company responsible for processing your data, being either Vodafone Group Plc, Equiniti Limited (“EL”), or both companies collectively;
• “third party” means someone who is not you or us or EL; and
• “Vodafone Group” means Vodafone Group Plc and any company or other organisation in which Vodafone Group Plc owns more than 20% of the share capital.

Our registered office is Vodafone House, The Connection Newbury, Berkshire RG14 2FN. We are registered in England under company number 1833679. Vodafone Group Plc is registered with the Information Commissioner’s Office (“ICO”), registration number Z8088474.

This privacy policy extends to the share registry services which are carried out by EL. We have appointed EL under the rules of the Companies Act 2006 to manage our register of shareholders. EL's role as registrar includes keeping an up-to-date record of shares held by shareholders, administration of shareholder payments, managing share transfers, issuing share certificates and supporting other regulatory functions. In carrying out registry services, EL processes personal information about you as a shareholder on our behalf. You are also recommended to view EL's privacy policy which can be found on https://investors.vodafone.com/individual-shareholders/shareholder-privacy-statement.

If you use any of the apps and online engagement tools we make available to our shareholders  ("Online Services"), you should be aware of any additional privacy notices that are made available for the relevant Online Service. This privacy policy supplements, but does not override, those notices.

If you are also a Vodafone Group customer, you should refer to the separate privacy notices which govern the personal information which we collect from you in relation to the Vodafone products or services which are provided to you as a customer. You can find a copy of these policies here.

Your opinion matters to us – if you have any questions about our shareholder privacy statement, you can email us at: [email protected] or you can write to our privacy team at:

Global Privacy Team – Group Legal
Vodafone Group Services Limited
Vodafone House
The Connection
Newbury
RG14 2FN
England

Information we collect about you when you become a registered shareholder

The types of information we collect about you are:

• Your details such as your name, date of birth, your address and contact details;
• Details of how you have in the past exercised, or intend in the future to exercise, your voting rights;
• Your bank or building society account details into which dividends or other returns on your shares have in the past, or should in the future, be paid; and
• The reference number attributed to you as a Vodafone Group shareholder.

We collect your personal information in a variety of ways, including when you:

• Provide details to us directly or through your agent, stock broker or share plan administrator;
• Provide details to third parties who perform services on our behalf, such as Computershare; or
• Register for or use any of our online services or our website.

 1. Our legitimate business interests, for example, direct communication to you as a shareholder. 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.

2. Consent you provide where Vodafone does not rely on another legal basis. Consent will always be presented separately to you, can be withdrawn at any time and you will be given details on how to change your mind.

We use your information (with the support of Equiniti):

• To manage your shareholding interest in Vodafone Group Plc;
• To allow you to exercise your rights as a shareholder;
• To maintain our shareholder register;
• To contact you with shareholder related information, including important information about shareholder payments, the annual report and accounts and Notice of our Annual General Meeting and any other relevant information that relates to your Vodafone Group Plc shareholding; and
• To address any queries you raise with us.

We encourage you to register for Equiniti’s Shareview Portfolio to manage the information we provide to you as it provides a secure online platform to help you manage your shareholdings and communication preferences for receiving communications from Vodafone.

If you use Equiniti’s Online Services or websites they use cookies and other online tools to collect information about how you use and navigate the sites, including your IP address. Equiniti uses this information to improve the quality and design of their Online Services and websites and create new features and services. Equiniti explain more about these tools in their Cookies Policy.

Visit our FAQs page for information on how to register for a Shareview Portfolio.

Some of the organisations we share information with may be located 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.

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. 

We will only share personal information with a limited number of trusted third parties who work with us to help deliver our services, in order to fulfil our legal obligations or at your request. Such third parties include:

• Equiniti Limited as our Registrar, who manages our share register and ProSearch a subsidiary of Equiniti Group plc who provide a service to help trace our shareholders whose records need to be updated
• other members of Equiniti Group plc including Equiniti Financial Services Limited who provides regulated services such as dealing as well as the Vodafone Share Account and Dividend Reinvestment Plan services.
• payment providers who help us manage payments to our shareholders;
• service providers who help operate our back office systems and provide other services (e.g for the purpose of printing our annual report communications);
• Regulators who regulate how we operate, these include the Financial Conduct Authority (“FCA”), the London Stock Exchange, HMRC, the Takeover Panel and the ICO; and
• solicitors and professional service firms who provide us with legal support in relation to our services or any litigation.

In addition to the above, we will share your personal information:

• if the law requires or permits disclosure, or there is a duty to the public to share or disclose your personal information (e.g. for the purpose of verifying shareholdings or contacting shareholders about matters relating to the company, their shareholding or a related exercise of rights);
• with any third party at your request or with your consent;
• with any individual or company to whom we propose to transfer our obligations and rights in relation to the administration of our share register; and
• with any other person that requires access to or receipt of your personal information in connection with or as a result of any agreement we may have with or concerning you, or our arrangements with you.

We may use your personal information to help us to detect and prevent fraud, fight financial crime and meet our regulatory responsibilities. This may involve checking public registers (e.g. the electoral roll or registers of county court judgments, bankruptcy orders or repossessions), conducting online searches from websites and other information sharing platforms and using databases managed by credit reference agencies and other reputable organisations. This will help us verify your identity and carry out tracing exercises. We may also share your information and undertake searches with third party organisations such as public bodies, credit reference agencies, fraud prevention agencies and our regulators (which include the FCA, and ICO).

If you give us false or inaccurate information and we suspect fraud, we will record this to prevent further fraud and money laundering. We can supply on request further details of the agencies and databases we access or contribute to and how this information may be used. If you require further details contact Computershare Investor Services PLC The Pavilions, Bridgwater Road Bristol, BS99 6ZZ, United Kingdom.

We will store your information for as long as you hold shares in the Vodafone Group and will keep certain records after you cease to be a shareholder for as long as is necessary to comply with our obligations under the applicable law. If there’s no legal requirement for us to retain the data, we’ll only store it for as long as we need to.

We maintain a data retention policy which we apply to the records we hold.

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.

Under the law, you have a number of rights that you can exercise free of charge. We have included a summary of these below; if you would like to discuss or exercise any of these, please contact us through the details provided.

Right to correct personal data
If you believe any of the personal data we hold about you is incorrect, you can request we update it. Please contact Computershare in the first instance if any of your shareholding details are incorrect.

Right to access personal data
You have a right to request a copy of the information that we hold about you, and how it has been processed.

Right to data portability
In some circumstances, you have the right to receive the personal information about you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party.

Right to object to use of personal data
Where we are processing your data for any legitimate interests that Vodafone is reliant upon, you can object at any time to this processing.

Right to restrict use of your data
In some circumstances, you can request that we temporarily suspend the processing of your data.

Right to erasure
In some circumstances, such as where we no longer have a justifiable reason to continue to process your data, you can request we delete it.

How to lodge a complaint
If you have a complaint, you can contact us on the details provided. We’ll do our best to help but if you’re still unhappy, you can contact the ICO, which is the UK data protection regulator – their details are at www.ico.org.uk.

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