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 and provide you with 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?

1. Providing our products and services

We measure your device warranty and provide you with the related customer support services.

What data are we processing?

- 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.
- What is the basis for processing data? Contract between us.

- Location data: Satellite, mobile, Wi-Fi or network-based location.
- What is the basis for processing data? Your consent: You can withdraw your consent in your device’s settings.

2. Prevention of fraud, misuses, and legal claims

We identify and prevent fraud and other misuses as well as protect against claims and other liabilities.

What data are we processing?

- 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.
- What is the basis for processing data? Our legitimate interest of preventing fraud, misuses, and claims.

- Location data: Satellite, mobile, Wi-Fi or network-based location.
- What is the basis for processing data? Your consent: You can withdraw your consent in your device’s settings.

3. Notifications and software updates

We inform you about software updates as well as send you critical alerts and other important notices relating to our products and services. Additionally, we process your data to provide software updates for your devices.

What data are we processing?

- Software update data: Phone identification number (IMEI), IP address as well as other unique device, application, network, and subscription identifiers.
- What is the basis for processing data? Contract between us.

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?

1. Device activation data

Who are the recipients of the personal data and where are they located?

Cloud platform in the EU/EEA.
- What are the transfer safeguards? Data in the EU/EEA.

2. Feature phone software update data

Who are the recipients of the personal data and where are they located?

Firmware Over-The-Air (FOTA) service in the United States and Singapore.
- What are the transfer safeguards? Standard Contractual Clauses of European Commission.

3. Location data

Who are the recipients of the personal data and where are they located?

Cloud platform in the EU/EEA.
- What are the transfer safeguards? Data in the EU/EEA