PLEASE REVIEW THIS PRIVACY NOTICE FOR ASSURANT’S MOBILE APPLICATION AND WEB PORTAL CAREFULLY. THIS NOTICE APPLIES TO YOUR USE OF THE VODAFONE DEVICE SUPPORT APP AND WEB PORTAL.

This Privacy Notice describes the information handling and privacy practices of Assurant, Inc. and its subsidiaries and affiliates (collectively, "Assurant") in connection with the mobile app and web portal on which this Privacy Notice is posted. The Privacy Notice describes our practices with respect to the collection, access, use, management, disclosure, transfer, storage and other processing of your personal information processed in connection with the mobile app and web portal.


Device Support App and Web Portal Privacy Notice

What Information We Collect
How We Use & Disclose Collected Information
Your Choices
Important Information
Device Support provides you with access to a mobile device troubleshooting app and Web Portal to help you to address common mobile device issues and access Technical Support.

Lifestyle Services Group Limited, with offices at Emerald Buildings, Westmere Drive, Crewe, Cheshire, CW1 6UN (hereinafter, “We”, “Us”, “Our” or “Company”), which trades as Assurant and is an Assurant group company, respects your concerns about privacy. We operate the App and Web Portal, and We are the data controller of the personal information provided to or collected by the App and Web Portal.

This Privacy Notice describes how We will collect, access, use, disclose, retain, transfer, otherwise process and protect personal information when you use the Device Support App or Web Portal (the “Service”).

The Service will collect personal information from and through your Registered Device and the Web Portal. Where You allow another individual to use your Registered Device you are responsible for their use of the App, and represent and warrant that you have brought this Privacy Notice to their attention and that you have the authority to permit Us to use their information in accordance with this Privacy Notice.

We protect your personal information using industry standard safeguards. We may share information about you with your consent, where it is necessary to carry out the Service or as required by law, and We will always let you know when We make significant changes to this Privacy Notice.

We adhere to the following principles to protect your privacy:

We protect your personal information and will only provide it to third parties:

  1. with your consent;
  2. where it is necessary to carry out your instructions;
  3. as reasonably necessary in order to provide the Service;
  4. to Our service providers (as described in Section 3.2) in connection with providing the Service;
  5. when We reasonably believe it is required by law or by order of a court of competent jurisdiction;
  6. as necessary to enforce our Terms of Service, to protect the rights of the Company, or to prevent physical harm or financial loss; or
  7. as part of a reorganization or sale of all or part of Our business.

We have implemented safeguards designed to protect your information in accordance with industry standards.

This Privacy Notice applies to the Service only and does not necessarily reflect practices with respect to information gathered through other services We offer or websites We operate or the collection of information through off-line means. To review the privacy practices of those other services, please refer to the policies provided associated with each.

If you have any concern about providing information to Us or your information being used in any manner permitted by this Privacy Notice and the Device Support Terms of Service, you should not download the App, visit Our Web Portal or otherwise use the Service. If you have already downloaded the App you can uninstall it at any time. The Device Terms of Use explain how you can cancel the Service which will automatically close your account on the App.

1. What information We collect

When you register for the Service We may collect information (including your email address, mobile phone number or password).

We collect your personal information in the following ways:

1.1 When you register for the Service

Once you have an eligible Vodafone Small Business Plan with Device Support included, or have chosen Device Support as a chargeable extra, to create an account on the App to access its features and so that We can administer the Service, We ask users to provide Us with: (i) email address, (ii) mobile phone number for the Registered Device and (iii) password. We also collect your Registered Device identification number (e.g., IMEI) and Internet Protocol (“IP”) address.

1.2 When you use the App
When users operate the Service, We may collect information from your mobile device. You may request deletion of this personal data whenever you like. We also collect information about your usage of the App.

After you have downloaded the App, information is collected from your Registered Device periodically.

We collect information about your Registered Device, such as device settings (e.g. Wi-Fi On/Off), device name (e.g., "John’s phone"), activities (e.g., Bluetooth was disabled), device performance profiles, malware signatures and application/system logs (to detect application crashes and other potentially harmful occurrences) and your IP address.

We also collect information about your usage of the App and may use third party analytics tools to monitor and evaluate your activity within the App. When you are logged into the App, your usage and device information will be associated by Us with your account. When you are not logged into the App, We log information about devices used to access the Service, including mobile device identifier. For more information about the tracking technologies We utilise on the, please view Our Cookie Notice. However, disabling cookies may result in certain parts of the Web Portal and resources not operating correctly or may prevent you from taking full advantage of some of the features.

Additional information may be collected depending upon the App features that you use. If you use the Secure Backup, Technical Support or Locate, Alert, Lock & Wipe features, the information collected includes:

For Android devices: (i) contacts / address book; (ii) calendar; (iii) bookmarks; (iv) wallpaper (e.g., background images and graphics); (v) photos and videos; (vi) installed mobile apps; (vii) documents; and (viii) audio recordings (e.g., music).

For iOS devices: (i) calendar; (ii) photos and videos; and audio recordings (e.g., music).

In the context of Secure Backup, Technical Support and Locate, Alert, Lock & Wipe, We will process geo-location data with your permission. - Geo-location information is derived either from your mobile network provider, certain third-party service providers, or directly from the Registered Device. This location tracking may occur when the App is not actively open and running, if you have enabled location tracking in the settings for your Registered Device. Such information may also be stored on your device. You may at any time discontinue these geo-location services by turning off location services on your Registered Device or uninstalling the App. You may also remove your personal information by cancelling the Service which will automatically close your account on the App. Please see the Device Support Terms of Use for information on how to cancel the Service.

1.3 When you communicate with Us or contact Us for Technical Support
We collect information when you contact Us for Technical Support.

When you contact Our Technical Support (for example, when you use the Live Help button), We will collect information that you provide to Us in your communications (such as the query or issue that you have raised).

With your permission We will access your personal information contained within the Service or your Registered Device to respond to your request (e.g., lock your device). When Our Technical Support advisor accesses your device for troubleshooting purposes, while the Technical Support Advisor is logged in to your account, she or he can access and extract information (such as settings) from the device. The Technical Support advisor will only access information needed to troubleshoot the device, and once the session is over, they will not retain any of the information on their screen. Please note that when you use Technical Support, Our advisors may be able to view messages and communications sent to the Registered Device while providing support services. We do not retain or use this information for any purpose.

You may report any problems or security concerns with the App by contacting customer support or via the Web Portal.

1.4 When you use the Web Portal
We collect information when you visit Our Web Portal.

We collect information about the device which you use to access the Web Portal, such as web requests, browser type, browser language, referring and exiting pages, platform time and your IP address. We collect information when you use Our Web Portal, and may use third party analytics tools to monitor and evaluate user traffic and how you use and navigate around the Web Portal. For example We collect information when you view a page or click on a link and the amount of time spent on particular pages. We log information about devices used to access the Service. If you are logged in on Web Portal, your usage information and device data such as your IP address, will be associated by Us with your account. For more information about the cookie and tracking technologies We utilise on the Web Portal, please view Our Cookie Notice.

1.5 Links to other Websites
The App or Web Portal may contain links to other websites. We are not responsible for the privacy and security practices of other websites.

The App or Web Portal may contain links to other web sites that may have online information practices different from Ours. We are not responsible for the privacy and security practices of those websites, and We encourage you to learn about the privacy and security practices of those websites if you choose to access and use them.

1.6 What happens if You do not provide your personal information
If you do not provide your personal information, you may not be able to use all aspects of the Service, including features of the App and the Web Portal.

To use the Secure Backup, Anti-Malware, Locate, Lock, Alert and Wipe and Live Help features of the App, to access Technical Support and to use the Web Portal, the provision of personal information is mandatory: if relevant data is not provided, then We will not be able to provide you with these features. For example, users must provide their email address, mobile number and password in order to use Locate, Secure Backup and the Live Help button in the App. To use the Web Portal, the provision of email address and password is mandatory to access the features.

If you choose not to provide your personal information, then you will not be able to access the features listed above, you will only be able to use basic features of the Service in the App, such as device diagnostics, tips, troubleshooting, battery information, and storage management data.

2. We process your personal information for the following purposes:

We collect information from you to provide the Service.

  • To fulfil our contract with you: this means the Device Support Terms of Use and Device Support App and Web Portal Terms. This includes:
    • providing the Service to you;
    • verifying your identity;
    • managing your account;
    • communicating with you.
  • As required by Us to conduct Our business and pursue Our legitimate interests, in particular:
    • providing the Service, managing your account and responding to any comments or complaints you may send Us;
    • monitoring use of the Service, the App and the Web Portal and helping Us to track and analyse preferences and trends, to evaluate possible new features, functionality and services, and to improve Our products and services;
    • recognising you on the Service, improving your experience, increasing security of Our networks and systems, and measuring use and effectiveness of Our Service;
    • customising Our Technical Support responses;
    • investigating complaints received from you and others about the Service, and tracking potential issues and trends to better serve you;
    • Making decisions about, and implementing, reorganisations or sales of all or part of Our business;
    • Monitoring customer accounts to prevent, investigate and/or report fraud, misrepresentation, or crime, in accordance with applicable law;
    • In connection with responding to any complaint you raise about the Service, legal claims (for example, a claim that Our intellectual property rights have been infringed or to bring or respond to any claim relating to your use of, or our provision of, the Service), for compliance, regulatory and investigative purposes (for example, theft and fraud investigations) as necessary (including disclosure of such information in connection with legal process or litigation);
    • Conducting customer satisfaction surveys in relation to the Service;
  • Where you give Us consent:
    • We place cookies and use similar technologies in accordance with Our Cookie Notice and the information provided to you when those technologies are used;
    • We access information on your Registered Device to provide the Service (for example, to provide diagnostic and troubleshooting functions and to identify performance issues);
    • We obtain geo-location information from your mobile network provider, certain third-party service providers, or directly from the Registered Device;
    • On other occasions where We ask you for consent, We will use the data for the purpose which We explain at that time.
  • For purposes which are required by law:
    • In response to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent

Wherever We rely on your consent, you will always be able to withdraw that consent, although We may have other legal grounds for processing your data for other purposes, such as those set out above. Where you have given Us your consent, you can withdraw it by using the mechanism described to you at the time that your consent was obtained, or by contacting Us.

2.3 Communications
We communicate with you through email, Our Web Portal and text messaging. We may send you messages relating to the Service and your use of the Service.

We communicate with you through email, Our Web Portal and other means available through the Service, including mobile text messaging (e.g., SMS) and push notifications. Examples of these communications include: (1) welcome and registration communications, and (2) service communications. These messages will be sent to you based on your registration information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your email settings.

Please be aware that you cannot opt out of receiving Service-related messages from Us.

3. How We share your personal information

3.1 Sharing information with affiliates
We may share your information among the Assurant family of companies.

The Assurant entity that collects or holds your personal information shares

your personal information with Our affiliates (meaning entities controlled by, controlling or under common control with Assurant, Inc.) for the purposes stated in this Privacy Notice.
3.2 Sharing personal information with service providers
We may employ third parties to help Us with the Service.

We employ third party companies and individuals to facilitate the Service (for example, customer support, analysis, audit, application, database hosting).

These third parties have limited access to your information only to perform these tasks on Our behalf and are obligated to Us. The personnel of such third parties who use your personal information is limited to those individuals which are authorised to do so on a need-to-know basis and as necessary to provide these business services to Us. We do not authorise such third parties to disclose or use it for other purposes.

Please see Our List of Service Providers to learn more about the service providers We use and the services that they provide to Us.

3.3 Sharing personal information with other recipients
We may disclose your personal information if required by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.

We may disclose your personal information to public authorities if mandated by law or if required for the legal protection of Our legitimate interests in compliance with applicable laws.

We may also disclose your personal information to parties acquiring part or all of Our assets, as well as to attorneys and consultants. Also, if any bankruptcy or reorganisation proceeding is brought by or against Us, your information may be considered a company asset that may be sold or transferred to third parties.

3.4 Data processing outside of your country
We may process your information outside the country where you live, including in countries that may not provide the same level of data protection.

In providing the Service, Mobile App and Web Portal, personal information may be transferred to, and processed in, countries where data protection and privacy regulations do not offer the same level of protection as the European Economic Area (“EEA”) and other parts of the world.

Sharing Personal Information with Our affiliates involves transfers to the US in order to the provide the Service, such as Secure Backup and Locate, Alert, Lock & Wipe, as described above.

Sharing Personal Information with Our service providers involves transfers to the US (for example – data hosting and storage, data analytics, user communications via email, and Live Help and Locate features) and Romania (for example – Technical Support). To view the list of service providers, please click here.

Where personal information is transferred outside the EEA to a country that is not subject to an adequacy decision by the EU Commission, it is adequately protected by European Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a service provider’s Processor Binding Corporate Rules. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please address these requests to Us.

4. Your Choices and Rights

You may request access to, modify, correct, delete or limit the use and disclosure, where required by applicable law, of your account information or close your account. You can also request additional information We may have about your account.

In some countries, you have the right to request access to, correction of, and deletion of your personal information, and to restrict the processing of your personal information under applicable law. You also have the right to request a structured commonly-used and machine-readable copy of personal information that you have provided to Us for a contract or with your consent, and to ask Us to transmit (port) this personal information to another controller.

You may also object to Our processing of personal information in certain circumstances (in particular, where there is no need to process the information to meet a contractual or other legal requirement ( see section 2).

You can exercise any of your rights by contacting Us. In order to safeguard your personal information from unauthorised access, We may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

Please note that certain personal information can also be corrected via the Web Portal. In addition, you may close your account by cancelling the Service in accordance with the Device Support Terms of Use.

In certain situations and subject to applicable laws, including data protection laws, We may not be able or obliged to comply with all or part of your request. For example, We may not comply with an access request if doing so would reveal personal data about another person, or comply with a deletion request relating to information which We are required by law to keep or have compelling legitimate interests in keeping.

If you have unresolved concerns, you have the right to complain to an EU data protection authority ('supervisory authority') where you live, work or where you believe a breach may have occurred.

5. Important Information

5.1 Data retention
We keep your information for as long as your account is active or as needed. In addition, We may keep certain information even after you close your account if it is necessary to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this agreement

We retain personal information you provide while your account is active or as needed to provide the Service. If you or We cancel or terminate Device Support, your information, including information that you have stored using Secure Backup will be removed from the Service 30 days after cancellation/termination. We delete logs and other backup information through the deletion process within 90 days of account closure. You may access records retention details here.

Our customer support may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but We generally delete or anonymise closed account data consistent with this Privacy Notice. We may retain your personal information for longer than the periods set out above where necessary, for example to comply with Our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce Our Terms of Service.

5.2 Changes to this Privacy Notice
We will notify you when We change this Privacy Notice.

We may update this Privacy Notice from time to time. If We make any material changes to this Privacy Notice, We will notify you by email, SMS, or by means of a notice through the Web Portal or App, or by other means prior to the change becoming effective, so that you may review the changes before you continue to use the Service. As We may make changes to this Privacy Notice, We suggest that you review it each time you access and use the Service. Please review changes carefully. If any changes are made to this Privacy Notice, We will revise the Effective Date that is indicated at the bottom of it.

5.3 Security Procedures
We take privacy and security seriously. Please know that the Internet is not a secure environment.

We have measures in place to restrict access to information to those employees and individuals whom We know have a valid business purpose to have access to such data. We maintain physical, electronic and procedural safeguards. We follow generally accepted standards designed to protect the personal information submitted to Us, both during transmission and once We receive it. We require those who provide services for Us and to whom We provide information collected through the Service to keep such information safeguarded and confidential. However, no method of transmission over the Internet or method of electronic storage is totally secure. Therefore, We cannot guarantee its absolute security.

5.4 Contact Us
If you have questions or comments about this Privacy Notice, please contact Us online or by postal mail.

We welcome your questions or comments regarding this Privacy Notice.

Please write to Lifestyle Services Group Limited, Data Protection Officer, Emerald Buildings, Westmere Drive, Crewe, Cheshire, CW1 6UN, or send Us an email dataprotectionofficer@assurant.com. You may also write to Us at Assurant Privacy Office, Post Office Box 979047, Miami, FL 33197-9047

Effective date: August 5, 2019



List of Service Providers

This List of Service Providers identifies the service providers used in connection with the Device Support App and Web Portal:

Service Provider (Name) AWS
Location (Country) United States
Service Provider’s Processing Purposes Website and mobile app hosting
Service Provider (Name) MixPanel
Location (Country) United States
Service Provider’s Processing Purposes Mobile and web analytics to improve user experience.
Service Provider (Name) LogEntries
Location (Country) Unites States, Ireland
Service Provider’s Processing Purposes Log management and reporting for benchmarking and performance.
Service Provider (Name) NewRelic
Location (Country) Unites States
Service Provider’s Processing Purposes Manage and track technical performance.
Service Provider (Name) SendGrid
Location (Country) Unites States
Service Provider’s Processing Purposes Email for mobile app users.
Service Provider (Name) Wootric
Location (Country) Unites States
Service Provider’s Processing Purposes Support in-app Net Promoter Score surveys and Client Reporting.
Service Provider (Name) Twilio
Location (Country) Unites States
Service Provider’s Processing Purposes SMS verification before filing a claim from the app.
Service Provider (Name) LogMeIn-Rescue
Location (Country) Unites States
Service Provider’s Processing Purposes Remote support via remote device control and screen sharing.
Service Provider (Name) Intercom
Location (Country) Unites States
Service Provider’s Processing Purposes In app chat service.
Service Provider (Name) Fabric
Location (Country) Unites States
Service Provider’s Processing Purposes Supports measurement of mobile app performance (for example – when the app crashes).
Service Provider (Name) Virus Total
Location (Country) Unites States
Service Provider’s Processing Purposes Supports malware database for antivirus feature
Service Provider (Name) Hyperlync
Location (Country) Israel
Service Provider’s Processing Purposes Data backup services
Service Provider (Name) Microsoft
Location (Country) United States
Service Provider’s Processing Purposes Provides customer relationship management support.
Service Provider (Name) CGS
Location (Country) Romania
Service Provider’s Processing Purposes Call Center services for the EU region.
Service Provider (Name) Google Maps
Location (Country) United States
Service Provider’s Processing Purposes Google Maps API supports the Locate feature of the mobile app.
Service Provider (Name) Google Analytics
Location (Country) United States
Service Provider’s Processing Purposes Mobile and web analytics to improve user experience.

Service Providers for US-based customers
(Note: Such service providers do not process personal information of EEA-based users.)

Service Provider (Name) SpeedOfMe
Location (Country) United States
Service Provider’s Processing Purposes Speed test (e.g., Wi-Fi) API provider.

Effective Date: August 5, 2019