Effective date 28.3.2013
WE CARE ABOUT YOUR PRIVACY
We will give you additional privacy information that is specific to a product or service in Supplements to this Policy and other notices you may see while using our products or services. If there is a difference between such notices and this Policy, the notices should be considered first.
Software on your device may access your information. Our products or services may contain links to other companies’ websites and services that have privacy policies of their own. Nokia is not responsible for the privacy practices of others and we recommend you read their privacy notices.
If you do not agree with this Policy, do not use our products and services or provide Nokia with your personal data.
What Information Do We Collect?
We collect your personal data and other information when you make a purchase, use or register into our products and services, take part in campaigns or research or otherwise interact with us. This includes following categories:
- Product and service activations Nokia products and services may require electronic activation, where your device and application type, phone number as well as unique device, application, network and subscription identifiers are sent to Nokia. Depending on your device model and settings, device location at the time of the first power up may also be collected.
Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage. Additionally, we may invite you to join voluntary product and service improvement or research programs where detailed information is collected. See Supplements to this Policy for more details.
Information you provide us with When you create an account, make a purchase, request services, participate in research or campaigns or otherwise interact with us, we may ask for information such as your name, email address, phone number, street address, user names and passwords, feedback, information relating to your devices, age, gender, and language, bank account number, credit card details and other such financial information.
We also maintain records of your consents, preferences and settings relating to, for example, location data, marketing and sharing of personal data.
Your transactions with us We maintain records of your purchases, downloads, the content you have provided us with, your requests, agreements between you and Nokia, the products and services provided to you, payment and delivery details, your contacts and communications and other interactions with us. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points.
Positioning and Location data Location-based services establish location through the use of satellite, mobile, Wi-Fi or other network based positioning methods. These technologies may involve exchanging your location data and unique device and mobile, Wi-Fi or other network related identifiers with Nokia. Our products using Microsoft operating system connect to both Microsoft’s and Nokia’s positioning servers. We do not use this information to identify you personally without your consent.
When you use our location based services and features, for example location based search, navigation and routing, or request for map data, your location data is sent to Nokia to serve you with the right content, which may also include location based advertising.
Why Do We Process Personal Data?
Nokia may process your personal data for the following purposes. One or more purposes may apply simultaneously.
- Providing products and services We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and Nokia, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.
- Accounts Some services may require an account to help you manage your content and preferences. If you create a Nokia Account, information about your device and service activations, use of products and services and your other transactions may be combined with your Nokia Account information to enable us to better personalize your experience. With your consent, information collected through voluntary research and improvement programs may also be combined with your account. If you log in to our services using credentials of other services, such credential information is used to identify and manage your information and interactions in Nokia’s systems.
- Developing and managing products and services We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular Nokia product and/or service with other personal data we may have about you, unless such personal data was collected for a different purpose.
- Communicating with you We may use your personal data to communicate with you, for example to inform you that our services have changed or to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.
- Marketing, advertising and making recommendations We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed. We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying Nokia and third party content.
Do We Share Personal Data?
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
- Your consent and social sharing services We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.
Nokia companies and authorized third parties We may share your personal data with other Nokia companies or authorized third parties who process personal data for Nokia for the purposes described in this Policy. This may include for example billing through your network service provider or otherwise, delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting research and managing marketing and other such campaigns. When you purchase a Nokia product from us with a network service provider plan, we may need to exchange information with your network service provider to provide you with such service.
We may conduct joint marketing and other communications with our partners, for example your mobile operator. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that Nokia has collected with information that the partner has collected where this is permitted by law.
These authorized third parties are not permitted to use your personal data for any other purposes. We require them to act consistently with this Policy and to use appropriate security measures to protect your personal data.
- International transfers of personal data Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.
- Mandatory disclosures We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend Nokia’s legitimate interests, for example, in civil or criminal legal proceedings.
- Mergers and Acquisitions If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.
How Do We Address The Privacy of Children?
Nokia products and services are typically intended for general audiences. Nokia does not knowingly collect information of children without the consent of their parents or guardians. Nokia publishes safety guidelines for using internet services in our websites.
How Do We Address Data Quality?
We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data.
We encourage you to access your personal data through your account from time to time to ensure that it is up to date.
What Steps Are Taken To Safeguard Personal Data?
Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our data bases containing personal data to authorized persons having a justified need to access such information.
What Are Your Rights?
You have a right to know what personal data we hold about you. You have a right to have incomplete, incorrect, unnecessary or outdated personal data deleted or updated. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from Nokia, critical alerts may still be sent to you.
You may exercise your rights by contacting Nokia Care or by managing your account and choices through available profile management tools on your device and our services. In some cases, especially if you wish us to delete or stop processing your personal data, this may also mean that we may not be able to continue to provide the services to you.
Your California Privacy Rights
California law requires a business to disclose to its customers, upon the customer’s request, a list of the third parties to which the business disclosed "personal information" regarding that customer within the immediately preceding calendar year. If you are a resident of California and would like to make such a request, please submit your request in writing to:
200 S. Mathilda Ave., Sunnyvale, CA 94086, USA.
Attention: Legal Director, North America.
Please note that we are only required to respond to such a request from you once per calendar year.
Who Is The Controller of Your Personal Data?
Nokia Corporation of Keilalahdentie 4, 02150 Espoo, Finland is the controller of your personal data.
In addition, the Nokia affiliate providing the product or service may be a controller of your personal data. You may find the identity of the controller and its contact details by reviewing the terms and conditions of such a product or service or by using contact information provided in the applicable Nokia websites.
In matters pertaining to Nokia’s privacy practices you may also contact us at:
US Safe Harbor Privacy Framework
Nokia Inc., 200 S. Mathilda Ave., Sunnyvale, CA 94086, USA adheres to the EU-US/Swiss-US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, and is registered with the U.S. Department of Commerce's Safe Harbor Program. If you have questions or concerns about Nokia's participation in the Safe Harbor Framework, please contact:
200 S. Mathilda Ave., Sunnyvale, CA 94086, USA.
Attention: Legal Director, North America.
If you believe Nokia Inc. has not satisfactorily addressed your data privacy concerns, you may contact the EU Data Protection Panel at: Data Protection Panel Secretariat, Rue de Luxembourg 46 (01/126) B-1000 Brussels, BELGIUM, or by visiting http://circa.europa.eu/Public/irc/secureida/safeharbor/home.
Nokia may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, Nokia will post a notice advising of such change at the beginning of this Policy and on this site's home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.