Privacy Policy

Privacy Policy

Effective date 14th of October 2016

Your privacy is important

HMD Global Oy, including its affiliates (“HMD Global”), is committed to respect your personal privacy and to comply with applicable data protection and privacy laws as we understand that you care about your privacy. This Privacy Policy (“Policy”) describes:

1. What personal data we collect;

2. How we collect your personal data;

3. How we use your personal data.

HMD Global may from time to time provide you with additional information which is specific to certain product or service in addition to this Policy. HMD Global may also give you additional notices while using our products or services. If there is a difference between such notices and this Policy, the notices prevails

Third party software downloaded and/ or installed on your device may access your personal data. HMD Global products or services may contain links to other companies’ websites and services that have their own privacy policies. HMD Global is not responsible for the privacy practices of others. HMD Global encourages you to read their privacy notices in order to protect your personal data.

Please do not use our products and services or provide HMD Global with your personal data if you do not agree with this Policy.

How We Process Personal Data

There are circumstances which you provide HMD Global your data directly, e.g. when you make a transaction with HMD Global, use or register into HMD Global products and services, take part in campaigns or research or otherwise interact with HMD Global. Depending on the products and services you use, the data we collect can include

Contact details such as your name (including first, middle and last name), your email address, your phone number, postal address and any other contact details

Demographic information such as gender, age, country, language

Transaction information such as user names, password, feedback, payment data (e.g. bank account information, credit card details and any other financial information), delivery information. HMD Global also may also maintain a record of your agreement, consent, preference, settings relating to, for example, location data, marketing and sharing of personal data. HMD Global may, subject to applicable law, record your communication with HMD Global customer care or with other such contact points

Product information such as information of your hardware and software, the network you use to connect to HMD Global products and services, operating systems, software installed in your products, IP addresses, product identifier (such as IMEI number for your mobile devices) and your product settings

Product and service usage information such as IP-address, access times, the sites linked from, pages visited, the links and features used, the content viewed or requested, browser or application type, language and other such information. See also our Cookie and Web Beacon section for more details. Our applications may contact our servers periodically, for example to check for updates or to send us information relating to service usage.

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 HMD Global. Our products may operate on multiple device platforms, applications and services which may also collect your location data. HMD Global do not use this information to identify you personally without your consent.

Personal Data We Collect

HMD Global processes your personal data for the following purposes: (1) providing products and services we offer; (2) managing accounts which helps maintain your content, preference, settings; (3) developing and managing products and services (such as sales, marketing, customer care and support); (4) improving our products and services; (5) communicating with you regarding updated notices relating to our products and / or services; (6) marketing and advertising when we have your consent or otherwise it is allowed.

Providing the 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 HMD Global, 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.

Products & Service Activations and Account Management – We may use your personal data to activate products and services which requires activation. Some services may require an account to help you manage your content, preferences and settings.

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 HMD Global product and/or service with other personal data we may have about you, unless such personal data was collected for a different purpose.

Improving our products and services – We may use your personal data to improve our products and services such as providing you with the latest information of new features and functionalities.

Communications - We may use your personal data to communicate with you personally, for example to inform you about our service change, 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 HMD Global and third party content. 

Cookies and Web Beacons 

HMD Global uses cookies, web beacons and other similar technologies to operate and improve our websites and offering and help collect data.

Our domains may include third party elements that set cookies on behalf of a third party, for example relating to third party social network.

Why 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 - We only share your personal data if we have your consent or as necessary to provide you with the service to complete a transaction as requested and authorized by you.

HMD Global companies and affiliates - We may share your personal data among other HMD Global companies and affiliates

Authorized third parties – We may share your personal data with agents and vendors who process personal data for HMD Global for the purposes described in this Policy. For example, we may hire vendors and agents to provide services such as customer care and support, delivery of your purchases, managing and analyzing consumer data, managing marketing and promotion of our products and services. These companies need to comply with our privacy and security requirements and are not allowed to disclose the personal data received from us for other purposes.

Payment Transaction - This may include for example billing through your network service provider or otherwise. When you purchase a HMD Global product from us with a network service provider plan, we may need to exchange information with your network service provider to provide you with the relevant service. If you provide with us your payment data, we may need to share such data to banks or other entities which enables the completion of the transaction.

These authorized third parties are not permitted to use your personal data for any other purposes. We require them - International transfers of personal data – HMD Global may use using resources and servers located in different countries around the world, hence your personal data may be transferred across international borders outside the country where you use our services. HMD Global ensures that such a transfer has a legal base and provide adequate protection for your personal data as required by applicable law.

To comply with applicable law and valid legal process – HMD Global may be required to disclose your personal data to certain authorities, law enforcement agencies or other third parties in the countries where we or third parties acting on our behalf operate in order to comply with applicable law or to respond to a valid legal process.

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.

Steps Taken To Safeguard Personal Data

HMD Global cares about your privacy and is committed to protect your personal data.  Privacy and security are key considerations in the creation and delivery of our products and services. 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. We use different technologies and have a variety of procedures to protect your personal data from unauthorized access, use and disclosure.

Retention of Personal Data

HMD Global retains your personal data as long as it is necessary to provide you with the relevant products and services, to comply with the applicable legal obligations, to resolve disputes and to enforce our contractual obligations.

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 HMD Global, critical alerts may still be sent to you.

You may exercise your rights by contacting us 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.

The Controller of Your Personal Data 

HMD Global Oy of Karaportti 2, 02160, Espoo, Finland is the controller of your personal data. In addition, the HMD Global 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 HMD Global websites.

If you have questions concerning HMD Global’s privacy practice, you may contact us at: Karaportti 2, 02160, Espoo, Finland

Changes to This Privacy Policy 

HMD Global may from time to time update this Policy or change, modify or withdraw access to this site at any time with or without notice. We will revise the “Updated” date accordingly. If this Policy is changed in a material, adverse way, HMD Global will post a notice advising of such change at the beginning of this Policy. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.

In the event that there is any conflict between this Policy and the agreement with customer, the terms of agreement shall prevail.