Effective April 17, 2023
This statement supplements HMD Global Privacy Policy for products and services.
We are processing your device activation and location data for measuring your device warranty, providing you with customer service and for preventing fraud, misuses, and legal claims. We also process your data to notify you about software updates as well as to send you critical alerts and other important notices concerning our products and services.
Device activation data is collected from your device automatically as you activate it. Location data is collected by establishing either your exact or approximate location by satellite, mobile, Wi-Fi or other network-based positioning methods. From KaiOS based devices, we receive activation data from KaiOS Technologies Ltd.
| Device activation and notifications | ||
|---|---|---|
| Why are we processing your data? | What is the basis for processing data? | What data are we processing? |
| Providing our products and services: We measure your device warranty and provide you with the related customer support services. | Contract between us. Your consent: You can withdraw your consent in your device’s settings. | Device activation data: Phone identification number (IMEI), international mobile subscriber identity (IMSI), IP address as well as other unique device, application, network, and subscription identifiers. Location data: Satellite, mobile, Wi-Fi or network-based location. |
| Prevention of fraud, misuses, and legal claims: We identify and prevent fraud and other misuses as well as protect against claims and other liabilities. | Our legitimate interest of preventing fraud, misuses, and claims. Your consent: You can withdraw your consent in your device’s settings. | Device activation data: Phone identification number (IMEI), international mobile subscriber identity (IMSI), IP address as well as other unique device, application, network, and subscription identifiers. Location data: Satellite, mobile, Wi-Fi or network-based location. |
| Notifications: We inform you about software updates as well as send you critical alerts and other important notices relating to our products and services. | Contract between us. | Device activation data: Phone identification number (IMEI), international mobile subscriber identity (IMSI), IP address as well as other unique device, application, network, and subscription identifiers. |
How long is the data retained?
Device activation and location data are retained 6 months from the device activation. However, unlinked device identifiers such as IMEIs are retained indefinitely to ensure the uniqueness of the identifiers.
Do we transfer personal data?
The data is stored principally within the EU/EEA, unless the local legislation requires that the data is stored locally, such as in China.
| What personal data is transferred? | Who are the recipients of the personal data and where are they located? | What are the transfer safeguards? |
|---|---|---|
| Device activation data | Cloud platform in the EU/EEA | Data in the EU/EEA |
| Location data | Cloud platform in the EU/EEA | Data in the EU/EEA |
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