Supplemental Privacy Policy

 

We Care About Your Privacy

Nokia Corporation, including its affiliates, is committed to respecting your privacy and to complying with applicable data privacy laws. This privacy statement (“Statement”) describes how we collect and process your Personal Data when you use Nokia WiFi products and services (“Product(s) and Service(s)”).

These Products and Services are composed of Nokia WiFi network hardware devices and various software components (including mobile applications, web applications and sites, Nokia Home Portal and Product software) that may gather, store and process data. Our Products and Services will be provided using resources and servers located in various countries around the world.

Software on your device may access your information. Our products or services may contain links to other companies’ websites and services that have privacy notices of their own. Nokia is not responsible for the privacy practices of others and we recommend you read their privacy notices.

You are not required to provide certain categories of personal data to Nokia, such as analytics data. However, if you choose not to provide such data to Nokia, we may not be able to provide you with our enhancements of our products or services or all of their functionalities or to respond to queries you have.

What information do we collect?

When you make a purchase, use or register using Nokia WiFi Products and Services, we may need to collect data to provide you the Service as described herein. As transparency and easy access are key factors for us, we have created the list below as an example of what data is processed in the following scenarios.

  • Personal Data means the data which can directly or indirectly identify you. They include, among others, your email address, name, surname, phone number, IP address, mailing address, as well as any other information that is associated with the foregoing Personal Data that are automatically collected when you use the Products and Services, such as network internet providers, network bandwidth usage statistics, etc.

    Personal data may include also Usage Data meaning data which correspond to your download, installation and/or use of the Services, for the purpose of improving the quality and performance of the Products and Services, including, but not limited to: Services versions downloaded, installed and/or used, debugging data, location information, traffic usage of individual devices, usage hours, device state and other usage information and analytics of usage data from your device network.

    To the extent that a user submits Personal Data, such information is encrypted in transit.

  • Feedback means any ideas, opinions, suggestions, and/or proposals (including any reports on bugs or errors in the Services) that you may voluntarily submit to Nokia. We may post your Feedback (and identify you) on our website with the purpose of improving our Products and Services and providing valuable insights to other users.

Why Do We Process Personal Data?

Nokia needs to process your Personal Data in order to provide you with the Products and Services, to ensure their functionality and security and provide warranty and care support and to manage the contents and preferences of your account.

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 in order 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 your Service Provider, to ensure the functionality and security of our products and services, to identify you in order to provide the product or service 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. Nokia support team may also log into an account to do debugging of a problem  in the product or service through administrator  account.
  • 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 that 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.

Nokia processes your personal data with your consent or as necessary to complete any transaction or provide any product or service you have requested or authorized. We may also process your personal data when required by law; to protect our customers; to maintain the security of our products and services; and to protect rights and property of Nokia.

Do We Share Personal Data?

We may need to share your Personal Data with other Nokia companies or authorized third parties who process personal data for the purposes described in this Statement. This may include your Service Provider for example providing services including customer service, managing and analyzing consumer data.  We require these third parties to act consistently with this Nokia Privacy Statement, to use appropriate security measures to protect your personal data and to comply with any privacy or data protection law applicable to your 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 products and services may allow you to share your personal data with other users of the product or 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 Statement. This may include for example delivery of your products, providing services including customer service, managing and analyzing consumer data, conducting research and managing marketing and other such campaigns.

    We may conduct joint marketing and other communications with our authorized third-party partners. To avoid duplication of 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 Nokia authorized third parties are not permitted to use your personal data for any other purposes. We require them to act consistently with this Statement 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. In such cases we use measures to provide adequate protection for your personal data as required by applicable law, for example, by using standard agreements approved by relevant authorities (e.g. the European Commission) and by requiring the use of 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 does not knowingly collect information of children under the age of 13, or equivalent minimum age under applicable law, without the consent of their parents or guardians. 

The U.S. Children’s Online Privacy Protection Act (“COPPA”) regulates online collection of information from persons under the age of 13. Although the Products and Services are designed to support families with children of all ages, the administration, configuration, and management of the Products and Services (e.g. via the Nokia WiFi App) are intended for use by adults over the age of 18. Please do not supply any Personal Data for a person under the minimum age through any of the Services or sites. If you believe that you have provided, or that Nokia may have collected Personal Data for a person under the minimum age, please contact Nokia immediately at https://www.nokia.com/en_int/contact-us so that Nokia can remove such information from its files.

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 will only retain your personal data for as long as necessary to fulfill the purposes outlined in this Statement or otherwise communicated to you, unless a longer period is required by law.

We encourage you to access your personal data through your account from time to time to help us 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 databases containing personal data to authorized persons having a justified need to access such information.

How Do We Use Cookies and Web Beacons?

Nokia uses cookies, web beacons and other similar technologies to operate and improve our websites and offering. We also use cookies for personalization and to display ads. Some Nokia websites use third party advertising technologies to serve ads.

Our domains may include third party elements that set cookies on behalf of a third party, for example relating to third party social network. Please visit our Cookie policy to find out more about how Nokia uses cookies and how you can disable cookies by browser settings or otherwise.

What Are Your Rights?

You have the following rights regarding personal data that Nokia processes about you:

  • Access: You have a right to know what personal data we hold about you and to obtain a copy. 
  • Data portability: Subject to law, you have a right to obtain in machine readable format the personal data you have provided to Nokia. 
  • Rectification and erasure: You have a right to have incomplete, incorrect, unnecessary or outdated personal data about you deleted or updated.
  • Withdraw your consent: You have a right to withdraw your consent for Nokia to process your personal data. 
  • Unsubscribe and object: 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 we delete your personal data on other grounds. Even 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 managing your account and choices through our products and services or, if that is not possible, by contacting us. In some cases, if you withdraw your consent or wish us to delete or stop processing your personal data we may not be able to continue to provide the services to you.

If you are not satisfied with what we provide when you exercise your rights, you can let us know by contacting us. If you are still dissatisfied, you also have the right to lodge a complaint with a relevant supervisory authority.

Who Is the Controller of Your Personal Data?

Nokia Corporation of Karaportti 3, 02610 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 or our Group Data Protection Officer at:

Nokia Corporation c/o Privacy
Karaportti 3
P.O. Box 226
FI-00045 Nokia Group
Finland

Changes to This Privacy Statement

Nokia may change this Statement at any time with or without notice. However, if this Statement is changed in a material, adverse way, Nokia will post a notice advising of such change at the beginning of this Statement and on this site's home page for 30 days. We recommend that you re-visit this Statement from time to time to learn of any such changes to this Statement.