My Digicel App Privacy Policy

My Digicel App Privacy Policy

This privacy notice (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
FijiDigicel (Fiji) LimitedLevel 3, Digicel House, 5 Vuna Rd, Nabua, Fiji Islands
SamoaDigicel (Samoa) LimitedSNPF Plaza Building, Savalalo, Samoa
TongaDigicel (Tonga) LimitedFatafehi Rd PO Box 875, Nuku’alofa, Tonga
VanuatuDigicel (Vanuatu) LimitedLaw Partners House, Kumul Highway, Port Villa, Vanuatu.
NauruDigicel Nauru CorporationGround Floor Civic Center, Aiwo, Nauru
Papua New GuineaDigicel (PNG) LtdKennedy 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 Information and Contact List

(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 Information and Contact  List

(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 information and Contact List

(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