HMD Global Oy and its Chinese subsidiary (“HMD”, “we”, “us”) comply with the Personal Information Protection Law of the People's Republic of China (the “PIPL”). This statement supplements HMD Global Privacy Policy for products and services and applies only to individuals residing in China from whom we collect personal information as defined in the PIPL. It stipulates how HMD processes personal information as a personal information processor in China.

Purposes of processing your personal information

Information regarding the categories of personal information we process, the purposes for the processing of each category of personal information, and how we share your personal information are described in detail in HMD Global Privacy Policy for products and services and its supplements. The applicable legal grounds for processing are described in the HMD Global Privacy Policy for products and services and its supplements using the European General Data Protection Regulation terminology, and their counterparts in accordance with the PIPL are:

• “Your consent” means we have obtained your voluntary, explicit, and fully informed consent in accordance with the PIPL.

• “Contract between us” means the processing of your data is necessary for the conclusion or performance of a contract in which you are a party.

  • Delivering purchased products: when you have purchased our products, we use your personal information to deliver what you have purchased.

  • Customer support: we deliver customer support services in accordance with what has been agreed with you.

  • Verifying fraud: when we establish customer relations with you, it is necessary for us to ensure that there is no fraudulent purpose behind the contract prior to the engagement.

• “Legal requirement” means that the processing is necessary for the performance of statutory duties or obligations.

• “Legitimate interests” means that the processing is necessary for the protection of your and/or others and/or data processor’s own legitimate interests. For example:

  • Defending HMD's interests in civil and criminal proceedings.

  • Developing products and services: we analyze how our products and services are used in order to make them better. We only use anonymous data for developing our products and services in China.

The following processing of personal information applies to China:

• We do not collect device activation data.

• We do not collect MyAccount data.

• We do not collect Softlock or PayJoy Services data.

• We do not send abandoned shopping notifications for customers.

• We do not collect credit scores or credit card information.

Data Protection Officer and business contact details

Our Data Protection Officer, as per the General Data Protection Regulation, is Jari Koljonen. Our representative in China is Jihui Ni.

For any questions about the processing of your personal information, you may contact us through:

• Hotline: +864008000826

• Email: support.china[at]hmdglobal.com

• Mail: HMD Global Oy, c/o Privacy, Bertel Jungin aukio 9, 02600 Espoo, Finland

Right to withdraw your consent

When the legal ground for processing your personal information is based on your consent, you have the right to withdraw your consent. The withdrawal does not affect the validity of the processing activities conducted prior the withdrawal.

The applicable method of withdrawal, such as using the unsubscribe link at the bottom of the newsletter or opting out from your device’s settings, has been described in the applicable supplement.

Right to access, duplicate, rectify, and erasure

You have the right to access data we have about you and copy your data in computer-readable format on your device to be transferred to other systems. You may also rectify any erroneous data about you or delete your data if we don’t have compelling reasons to process it. Please contact us for requests concerning your data.

Right to request interpretation

You have the right to request HMD to interpret the personal information processing rules. If you want to exercise your right to request interpretation, contact us using the contact details provided above.

Rights of next of kin

HMD allows your next of kin to exercise your rights as a data subject on your behalf in the event of your passing. The next of kin may exercise the rights through contacting us through the contact details provided above. In such cases, we may request the next of kin to provide sufficient evidence of their status to exercise the rights.

Location of your data

HMD adheres to the Chinese data security and privacy laws. Therefore, all personal information in relation to HMD’s data subjects in China are retained locally in China. Your data is not transferred to third countries without your consent.

Children’s personal information

In Mainland China, we define a child as an individual under the age of 14. HMD will treat children's personal information in accordance with its Privacy Policy. HMD also treats children's personal information as sensitive personal information and complies with the rules specific to sensitive personal information under the PIPL.