Privacy Policy
Digicel is committed to respecting your privacy and to complying with applicable data protection and privacy laws. This Data Privacy Statement is provided to help you understand how we may collect, use, protect, and otherwise deal with your personal information.
You acknowledge that by providing your personal information to Digicel, you consent to the processing of your data in accordance with this Data Privacy Statement. You should read this notice in conjunction with the Terms and Conditions of use for our websites, apps and our products and services.
This Privacy Statement covers all Digicel businesses and entities in all countries in which it operates.
Personal Information Collection
Digicel collect and use your personal information with your knowledge and consent and typically when you:
Use Digicel’s wide range of products and services that are offered or for which you may choose to opt-in;
Make customer enquiries, register for information or other services;
Respond to communications from us (such as SMS, emails, questionnaires or surveys);
Interact with Digcel’s websites such as submitting an application form, completing survey form, use online services. (If your browser has Internet cookies enabled it can facilitate Digicel’s tracking of personal preferences, pages visited etc);
Participate on Digicel’s social media pages such as Facebook;
Participate in Digicel’s promotional events, incentive or loyalty programs;
Provide information through Digicel’s customer call centers, dealers and sales channels or any other affiliates or business dealings with Digicel by which you have consented to provide your personal information.
Types of Information Collected
The types of personal information that Digicel may collect include, but are not limited to:
contact information (such as name, address, email address and telephone number)
identification information (such as passport identification number, tax registration number or social security number, driver’s license, date of birth)
demographic information (such as age range, marital status, gender)
photographs such as those that you may submit for contests or prize winning competitions
product specific information (such as preference, closed user group (CUGs), friends and family who you chose to include in your service plan, credit limit)
banking information (such as direct debit and related bill payment banking transactions)
service account information (such as call usage, account balances, transaction history, credit information, billing, loyalty points)
Use
Any personal information collected by Digicel will be used in support of the intended purposes stated at the time at which it was collected, and subject to any preferences indicated by you. We may otherwise use your personal information to assist with service related issues, technical support, billing purposes, to enhance your customer service experience by providing you with specific products and services tailored to meet your needs, for general marketing campaigns, network protection, legal and regulatory compliance.
Mobile Applications
Digicel may from time to time offer and request your participation in various mobile applications to enhance user experience. If you chose to register for an application, we may obtain information about you and/or your mobile device. Digicel will use the information collected in accordance with this Privacy Statement. You may stop the collection of your personal information at any time by uninstalling the relevant applications for which you have registered or contact us and make a request to opt-out.
Digicel may also offer applications developed by third parties to enrich your experience. When you download a third party application to your mobile device, the third party affiliate may collect information about you in connection with your download or use of that application. Digicel is not responsible for the collection or use of information by third party application. Digicel recommend that you carefully review the privacy statement of each third party application prior to downloading or using them.
Linked Sites
Digicel’s websites may contain links to third-party sites not controlled by Digicel or covered by this Privacy Statement, such as those belonging to Digicel dealers, co-branded websites offered in conjunction with a business partner, or independent product review sites. Digicel recommend that you check the Privacy Statement of other sites you visit before providing any personal information.
Digicel Dealers
When you buy service from a Digicel dealer, the dealer will share your information with Digicel as your service provider. While Digicel encourages its dealers to ensure full compliance with all applicable data privacy or data protection laws and policies, and has provided information to our dealers relating to non-disclosure obligations, Digicel is not responsible for dealers’ compliance with applicable laws.
Sharing
Digicel does not sell, trade, transfer or otherwise share your personal information except in the following instances:
as required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process;
when we believe in good faith that disclosure is necessary to protect our rights, protect your security, investigate fraud or respond to a law enforcement request;
with Digicel service providers, field engineers, contractors who work on our behalf and who do not have an independent right to use the information to which they have access or that we disclose to them;
with our business partners for Digicel’s marketing activities, in such case no specific personally identifiable information is provided, as such information is generally aggregated;
with third parties for research and development purposes;
with our subsidiaries and affiliates such as Digicel dealers;
Third parties must in all cases agree to a strict duty to keep all personal information confidential and to use it only for the purpose for which it was obtained.
Data Transfer
Digicel will endeavor to ensure adequate commercial agreement is established with third party affiliates with respect to cloud computing services and exporting of data to countries in accordance with applicable legislation governing different territories. Digicel also ensures secure data transfers using well-known security technologies and practices to secure data from unauthorized access or interception. However, please be aware that communications over the public Internet, such as emails/webmails, facsimile, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered - this is the nature of the World Wide Web/Intranet. Digicel cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
Data Retention
Digicel retains data for a specific period of time required, however certain data can be retained for longer periods as required by the laws of the territory within which the specific service is operated.
Security
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our services. We also engage well-known technologies including but not limited to firewalls, intrusion detection, SSL (Secure Sockets Layer), routine network vulnerability assessment and 24 x 7 monitoring of its network. Please be aware that although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Cookies/Tracking Technologies
Digicel websites use common Internet technologies, such as cookies and web beacons, to keep track of user interaction with the sites, to remember user preferences and to maximize the user experience and performance of the website and services. For example, using cookies on our websites provides benefits to you, such as allowing you to autofill fields on forms, provide details of last time you login online. You can disable the cookie and the information will not be collected. Please refer to your browser Help instructions to learn more about cookies and how to manage their use. If you choose to decline cookies, some of the functionality of a website may be impaired.
Privacy Support & Inquiries
If you have concerns or questions regarding this Privacy Statement or if you wish to update your personal information or stop the collection of your personal information, please contact us at CustomerCareFiji@digicelpacific.com or +679 700 3123.
Changes to Privacy Statement
Digicel reserves the right to amend or modify this Privacy Statement at any time and in response to changes in applicable data protection and privacy legislation. Notice of any such change along with the revised policy will be posted on our website.
This privacy notice (together with our cookie notice) is provided to help you understand how we collect, use, share, protect, and otherwise deal with your personal information when you use our MyDigicel App. Please read it carefully.
Who We Are
The data controller for our site and app depends on the Territory for which you utilize these services from :-
Territory Company Name. Address Fiji Digicel (Fiji) Limited Level 3, Digicel House, 5 Vuna Rd, Nabua, Fiji Islands Samoa Digicel (Samoa) Limited SNPF Plaza Building, Savalalo, Samoa Tonga Digicel (Tonga) Limited Fatafehi Rd PO Box 875, Nuku’alofa, Tonga Vanuatu Digicel (Vanuatu) Limited Law Partners House, Kumul Highway, Port Villa, Vanuatu. Nauru Digicel Nauru Corporation Ground Floor Civic Center, Aiwo, Nauru Papua New Guinea Digicel (PNG) Ltd Kennedy Road, Gordons, Port Moresby, Papua New Guinea
Our Contact Details
If you have any concerns or questions about our privacy notice, you can contact us via email to:
DPO@digicelgroup.com or write to us at:
Digicel (Fiji) Limited
Level 3, Digicel House,
5 Vuna Rd, Nabua,
Fiji Islands
Attention: Data Protection Officer
Information we collect about you.
We currently collect and process the following information about you:
̶ The contact information you provide such as your name, address, mobile number and email address;
̶ Your account information, such as the plans and/or subscriptions you have, or your account identifier;
̶ Your billing information, place of residence and any other information you provide for the provision of payment services, administration and billing processes;
̶ Details about your device(s), for example, the unique device ID, MSISDN, IP address, the device model, browser type, device settings and operating system; and
̶ Information about your interaction with our app including but not limited to, traffic data, communication data, the resources that you access within the app and the services, products or features you use the most.
̶ Location information from your device, which is collected further to your consent. This includes precise geolocation data from or about your device expressed by latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation and other location tracking techniques. This location data may be collected whether the app is in use or inactive.
̶ Our app may contain links to other websites, which are owned and managed by third parties. It is your responsibility, when visiting these links to understand how those third parties will use your data by reviewing their privacy & cookie notices. Once you exit the application or our website, we do not have control over the information that is submitted or collected by those third parties and accept no responsibility for these third party websites.
̶ MyDigicelApp Data Usage also requires your Contact List details (meaning, the names, the phone numbers and the favorites list from your contact lists, if you approved access to them); which will be used after you have consented to use of Contact List.
How we get that information and why we have it
Most of the information that we process is provided to us by you:
- When you register, browse and use the services available on our app;
- When you get in touch with us or respond to communications from us; or
- Directly from our affiliates with your consent.
We also use different methods to collect data from and about you including through:
- Direct Interactions. You may give us your Identity, Contact and Financial Data by filling out online forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
- buy, register, use or subscribe to our services or products;
- sign-up or create an account on our application or website;
- interact with our application and website, including making customer enquiries, registering for information or other services, or download our application;
- enter a competition, promotion or survey, provide feedback, or respond to communications from us (such as SMS, emails, questionnaires); or
- contact us and provide your information via online customer support, customer call centres or our physical locations.
Other data is collected through the use of various technologies:
̶ We collect information about your interaction with our app, for example, through Google Analytics, cookies and software development kits (SDKs ). For more detailed information on the cookies we collect and how we use the information collected, please review the cookie notice.
̶ We take repeated measurements from your device from time to time including location data, network type, network operator, cellular and Wi-Fi signal strength and quality, and the identifiers of connected cell towers and Wi-Fi routers (including both BSSID and SSID).
̶ We measure how data is flowing, both passively (by monitoring how fast it moves through other apps), and actively (by running a test that downloads or uploads data). We do not monitor the content of your data usage through this particular application. This aids us in measuring the experience you have of wireless networks.
̶ We measure internal device conditions – such as battery temperature and voltage. This aids us in understanding how instantaneous device conditions affect experience of mobile networks.
̶ We collect data on your device hardware such as the model, manufacturer, and manufacturers and models of sub-components (such as the cellular radio) and their capabilities, in order to assess and understand differences between devices.
̶ We collect information on the mobile platform version to understand differences caused by software and to understand how device properties affect experience of mobile networks.
̶ When you first use the app a random identification code is generated by our software and allocated to your mobile device and used to identify your device whenever we take measurements. This is collected with other data such as related IP addresses, the device MAC number and/or the Android serial number. We generally pseudonymise and collected this data for aggregate analytics and statistical purposes, such as understanding how much data a device contributes.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
̶ Where we need to perform the contract we are about to enter into or have entered into with you.
̶ Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
̶ Where we need to comply with a legal obligation.
Generally, we will use the information that we have collected to:
‒ verify or authenticate your identity;
‒ validate your subscription;
‒ maintain and provide the services you have requested through our app;
‒ assist with service related issues, account management, customer care and technical support;
‒ gather data on and improve the performance of the service, product and service development, and customer care;
‒ carry out marketing analysis to tailor the services to your preferences – sending you relevant information and promotions;
‒ market our services; and
‒ share with our third-party advertising partners to personalize & improve your online experience;
‒ carry out statistical analysis such as analysing the performance of our website and app and to understand how visitors use them.
‒ comprehensively assess all aspects of the customer experience, from hardware elements to software and network elements, so that we can continue to develop and improve our performance and your experience.
My Digicel App usage of Contact List Data :
1) The MyDigicelApp (“MDA”) specifically, requires the utilization of your Contact List upon the requisite approval.
2) This is needed for the following MDA Services :-
a. Top-Up which is the recharging of mobile service credits requires the contact details so that the Customer simply types the name of the party receiving the Top-Up without having to type full phone numbers.
b. Send Credit to another number likewise requires Contact List to enable the sending of credit already Topped-Up to another Customer on the Digicel network.
c. Call Me is a SMS sent to a user of the Digicel network; which asks that they call the Customer having sent such a message. This likewise requires Contact List details.
d. Credit Me is an SMS sent to another user on the Digicel network; which asks if they can Send Credit to the requestor. This likewise requires Contact List details.
e. BillPay is where payments for Bills can be used. At times the Biller Number is in the Contact List also. This likewise requires Contact List details.
Legal basis for using your information
We will only use your personal data where we have a legal ground to do so. In every case, the legal ground will be one of the following:
̶ Where you give us your consent, for example where you have given your consent for us to collect or process your data or access your contact listing. You can withdraw your consent at any time by contacting us via our contact details or by changing your preferences under your device settings;
̶ For a legitimate business interest, where it is necessary for us to understand how users use our apps, and to analyse what content has been viewed on our app, for marketing and improving our services;
̶ For the performance of our contract with you, for example where you have purchased a subscription from us, we need to process your personal information to provide you with our services and content; or
̶ To comply with our legal and regulatory obligations.
Furthermore and for clarity we have set out below, in a table format, a description of ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Table 1: Purposes for use of your personal data
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To register you as a new customer for a product and/or service (a) Identity (b) Contact (a) Performance of a contract with you (b) Consent To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review, take a survey or participate in a research (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Consent To enable you to partake in a prize draw, or competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Consent To administer and protect our business and our application and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (d) Usage (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Consent To deliver relevant application and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent To use data analytics to improve our application and website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our application and website updated and relevant, to develop our business and to inform our marketing strategy) (b) Consent To make suggestions and recommendations to you about goods or services (i.e. plans and/or subscriptions) that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications (a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent
International Transfer of Data
Where applicable and in order to provide some of our products and services to you, we may transfer your personal information internationally to companies within Digicel Pacific ( which is separate and distinct from Digicel Group ), our partners and service providers involved in delivering and maintaining the products and services you use.
If we do transfer any of your personal information to other countries, we will ensure that there is an adequate level of protection for your personal information and ensure that a proper legal agreement is in place to cover such data transfers to these countries.
If you would like further information about this please contact us via ‘Our Contact Details’ above.
Who We Share Your Information With
We share your information with:
‒ our subsidiaries and affiliates; and
‒ partners and service providers involved on our behalf in delivering the services to you (that includes our payment gateway, app developer, advertising partners and engagement platform provider);
We ensure there is a data processing agreement in place so that your personal information is only processed for a specified purpose and that it is protected in accordance with privacy laws.
How We Store Your Information
We take the appropriate technical and organizational security measures to protect your personal information against unauthorized access and unlawful processing, accidental loss, damage or destruction.
We keep your personal information for no more than is necessary for the purposes set out in this privacy notice unless we are required to so for a longer period to comply with legal, tax or regulatory reasons. When we no longer need or are not required to keep your information we will securely delete your information and ensure all recipients of your data also comply with the same.
Where you have given us your consent to use your data and you decide to withdraw that consent, we will delete your personal data unless we are required to keep it for reasons we have explained above. We may need to keep a piece of your contact information e.g. your email address in our records so we know that you have withdrawn your consent and ensure we honour your choice.
Your Data Protection Rights
You can do the following at any time by contacting us:
‒ Request to see a copy of the information we have about you;
‒ Request to update any incorrect or inaccurate information we have about you;
‒ Restrict or object to us processing your information in certain circumstances;
‒ Have us delete any information we have about you in certain circumstances
‒ Express any concern you have about our use of your information; an
‒ To opt-out of marketing messages - you can also opt-out by clicking the unsubscribe link at the end of any marketing email, text or message to unsubscribe, or disable push notifications, or change your preferences on your device ,
Links
Our app may contain links to other third party websites or apps. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps. We encourage you to read the privacy statements and cookie policies of these third party websites or apps before you use or give them your personal information.
Changes to our Privacy Notice
This privacy notice was last updated on 15 December 2023.
We may change this privacy notice from time to time, when we do we will inform you via our website
This privacy notice (together with our cookie notice) is provided to help you understand how we collect, use, share, protect, and otherwise deal with your personal information when you use our MyDigicel App. Please read it carefully.
Who We Are
The data controller for our site and app depends on the Territory for which you utilize these services from :-
| Territory | Company Name. | Address |
|---|---|---|
| Fiji | Digicel (Fiji) Limited | Level 3, Digicel House, 5 Vuna Rd, Nabua, Fiji Islands |
| Samoa | Digicel (Samoa) Limited | SNPF Plaza Building, Savalalo, Samoa |
| Tonga | Digicel (Tonga) Limited | Fatafehi Rd PO Box 875, Nuku’alofa, Tonga |
| Vanuatu | Digicel (Vanuatu) Limited | Law Partners House, Kumul Highway, Port Villa, Vanuatu. |
| Nauru | Digicel Nauru Corporation | Ground Floor Civic Center, Aiwo, Nauru |
| Papua New Guinea | Digicel (PNG) Ltd | Kennedy Road, Gordons, Port Moresby, Papua New Guinea |
Our Contact Details
If you have any concerns or questions about our privacy notice, you can contact us via email to:
DPO@digicelgroup.com or write to us at:
Digicel (Fiji) Limited
Level 3, Digicel House,
5 Vuna Rd, Nabua,
Fiji Islands
Attention: Data Protection Officer
Information we collect about you.
We currently collect and process the following information about you:
̶ The contact information you provide such as your name, address, mobile number and email address;
̶ Your account information, such as the plans and/or subscriptions you have, or your account identifier;
̶ Your billing information, place of residence and any other information you provide for the provision of payment services, administration and billing processes;
̶ Details about your device(s), for example, the unique device ID, MSISDN, IP address, the device model, browser type, device settings and operating system; and
̶ Information about your interaction with our app including but not limited to, traffic data, communication data, the resources that you access within the app and the services, products or features you use the most.
̶ Location information from your device, which is collected further to your consent. This includes precise geolocation data from or about your device expressed by latitude-longitude coordinates obtained through GPS tools, WiFi data, cell tower triangulation and other location tracking techniques. This location data may be collected whether the app is in use or inactive.
̶ Our app may contain links to other websites, which are owned and managed by third parties. It is your responsibility, when visiting these links to understand how those third parties will use your data by reviewing their privacy & cookie notices. Once you exit the application or our website, we do not have control over the information that is submitted or collected by those third parties and accept no responsibility for these third party websites.
̶ MyDigicelApp Data Usage also requires your Contact List details (meaning, the names, the phone numbers and the favorites list from your contact lists, if you approved access to them); which will be used after you have consented to use of Contact List.
How we get that information and why we have it
Most of the information that we process is provided to us by you:
- When you register, browse and use the services available on our app;
- When you get in touch with us or respond to communications from us; or
- Directly from our affiliates with your consent.
We also use different methods to collect data from and about you including through:
- Direct Interactions. You may give us your Identity, Contact and Financial Data by filling out online forms or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:
- buy, register, use or subscribe to our services or products;
- sign-up or create an account on our application or website;
- interact with our application and website, including making customer enquiries, registering for information or other services, or download our application;
- enter a competition, promotion or survey, provide feedback, or respond to communications from us (such as SMS, emails, questionnaires); or
- contact us and provide your information via online customer support, customer call centres or our physical locations.
Other data is collected through the use of various technologies:
̶ We collect information about your interaction with our app, for example, through Google Analytics, cookies and software development kits (SDKs ). For more detailed information on the cookies we collect and how we use the information collected, please review the cookie notice.
̶ We take repeated measurements from your device from time to time including location data, network type, network operator, cellular and Wi-Fi signal strength and quality, and the identifiers of connected cell towers and Wi-Fi routers (including both BSSID and SSID).
̶ We measure how data is flowing, both passively (by monitoring how fast it moves through other apps), and actively (by running a test that downloads or uploads data). We do not monitor the content of your data usage through this particular application. This aids us in measuring the experience you have of wireless networks.
̶ We measure internal device conditions – such as battery temperature and voltage. This aids us in understanding how instantaneous device conditions affect experience of mobile networks.
̶ We collect data on your device hardware such as the model, manufacturer, and manufacturers and models of sub-components (such as the cellular radio) and their capabilities, in order to assess and understand differences between devices.
̶ We collect information on the mobile platform version to understand differences caused by software and to understand how device properties affect experience of mobile networks.
̶ When you first use the app a random identification code is generated by our software and allocated to your mobile device and used to identify your device whenever we take measurements. This is collected with other data such as related IP addresses, the device MAC number and/or the Android serial number. We generally pseudonymise and collected this data for aggregate analytics and statistical purposes, such as understanding how much data a device contributes.
How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
̶ Where we need to perform the contract we are about to enter into or have entered into with you.
̶ Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
̶ Where we need to comply with a legal obligation.
Generally, we will use the information that we have collected to:
‒ verify or authenticate your identity;
‒ validate your subscription;
‒ maintain and provide the services you have requested through our app;
‒ assist with service related issues, account management, customer care and technical support;
‒ gather data on and improve the performance of the service, product and service development, and customer care;
‒ carry out marketing analysis to tailor the services to your preferences – sending you relevant information and promotions;
‒ market our services; and
‒ share with our third-party advertising partners to personalize & improve your online experience;
‒ carry out statistical analysis such as analysing the performance of our website and app and to understand how visitors use them.
‒ comprehensively assess all aspects of the customer experience, from hardware elements to software and network elements, so that we can continue to develop and improve our performance and your experience.
My Digicel App usage of Contact List Data :
1) The MyDigicelApp (“MDA”) specifically, requires the utilization of your Contact List upon the requisite approval.
2) This is needed for the following MDA Services :-
a. Top-Up which is the recharging of mobile service credits requires the contact details so that the Customer simply types the name of the party receiving the Top-Up without having to type full phone numbers.
b. Send Credit to another number likewise requires Contact List to enable the sending of credit already Topped-Up to another Customer on the Digicel network.
c. Call Me is a SMS sent to a user of the Digicel network; which asks that they call the Customer having sent such a message. This likewise requires Contact List details.
d. Credit Me is an SMS sent to another user on the Digicel network; which asks if they can Send Credit to the requestor. This likewise requires Contact List details.
e. BillPay is where payments for Bills can be used. At times the Biller Number is in the Contact List also. This likewise requires Contact List details.
Legal basis for using your information
We will only use your personal data where we have a legal ground to do so. In every case, the legal ground will be one of the following:
̶ Where you give us your consent, for example where you have given your consent for us to collect or process your data or access your contact listing. You can withdraw your consent at any time by contacting us via our contact details or by changing your preferences under your device settings;
̶ For a legitimate business interest, where it is necessary for us to understand how users use our apps, and to analyse what content has been viewed on our app, for marketing and improving our services;
̶ For the performance of our contract with you, for example where you have purchased a subscription from us, we need to process your personal information to provide you with our services and content; or
̶ To comply with our legal and regulatory obligations.
Furthermore and for clarity we have set out below, in a table format, a description of ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Table 1: Purposes for use of your personal data
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer for a product and/or service | (a) Identity (b) Contact | (a) Performance of a contract with you (b) Consent |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Consent |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review, take a survey or participate in a research | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) (d) Consent |
| To enable you to partake in a prize draw, or competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) (c) Consent |
| To administer and protect our business and our application and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical (d) Usage | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (c) Consent |
| To deliver relevant application and website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | (a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent |
| To use data analytics to improve our application and website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our application and website updated and relevant, to develop our business and to inform our marketing strategy) (b) Consent |
| To make suggestions and recommendations to you about goods or services (i.e. plans and/or subscriptions) that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications | (a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent |
International Transfer of Data
Where applicable and in order to provide some of our products and services to you, we may transfer your personal information internationally to companies within Digicel Pacific ( which is separate and distinct from Digicel Group ), our partners and service providers involved in delivering and maintaining the products and services you use.
If we do transfer any of your personal information to other countries, we will ensure that there is an adequate level of protection for your personal information and ensure that a proper legal agreement is in place to cover such data transfers to these countries.
If you would like further information about this please contact us via ‘Our Contact Details’ above.
Who We Share Your Information With
We share your information with:
‒ our subsidiaries and affiliates; and
‒ partners and service providers involved on our behalf in delivering the services to you (that includes our payment gateway, app developer, advertising partners and engagement platform provider);
We ensure there is a data processing agreement in place so that your personal information is only processed for a specified purpose and that it is protected in accordance with privacy laws.
How We Store Your Information
We take the appropriate technical and organizational security measures to protect your personal information against unauthorized access and unlawful processing, accidental loss, damage or destruction.
We keep your personal information for no more than is necessary for the purposes set out in this privacy notice unless we are required to so for a longer period to comply with legal, tax or regulatory reasons. When we no longer need or are not required to keep your information we will securely delete your information and ensure all recipients of your data also comply with the same.
Where you have given us your consent to use your data and you decide to withdraw that consent, we will delete your personal data unless we are required to keep it for reasons we have explained above. We may need to keep a piece of your contact information e.g. your email address in our records so we know that you have withdrawn your consent and ensure we honour your choice.
Your Data Protection Rights
You can do the following at any time by contacting us:
‒ Request to see a copy of the information we have about you;
‒ Request to update any incorrect or inaccurate information we have about you;
‒ Restrict or object to us processing your information in certain circumstances;
‒ Have us delete any information we have about you in certain circumstances
‒ Express any concern you have about our use of your information; an
‒ To opt-out of marketing messages - you can also opt-out by clicking the unsubscribe link at the end of any marketing email, text or message to unsubscribe, or disable push notifications, or change your preferences on your device ,
Links
Our app may contain links to other third party websites or apps. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps. We encourage you to read the privacy statements and cookie policies of these third party websites or apps before you use or give them your personal information.
Changes to our Privacy Notice
This privacy notice was last updated on 15 December 2023.
We may change this privacy notice from time to time, when we do we will inform you via our website