We may add to, or amend, this Policywith other notices. We may also post different privacy policies for someServices and, when we do so, this Policy does not apply. For example, whereapplicable, separate policies apply to information collected from your devicethrough Tell HTC Usage and Tell HTC Error Reporting.
As described in this Policy, you havethe right to object to us using, sharing or carrying out any activity with yourpersonal information (in certain circumstances) including using your personalinformation for direct marketing (i.e. receiving emails from us notifying youabout other services which we think will be of interest to you or beingcontacted with varying potential opportunities). Contact us at any time withthe details provided in the contact section below for more detail and toexercise these rights where applicable.
NOTE: Your wireless operator, mobileoperating system provider and/or third-party applications, toolbars, services,“plug-ins”, social media platforms and websites may also collect, use and shareinformation about you and your device and your usage. HTC’s privacy policies donot cover any third parties, their products, actions or their services. HTCdoes not control how third parties collect, use or secure your data. Forinformation about third-party privacy practices, please consult their privacypolicies. Only download applications from, and interact and connect with,reputable third parties.
When you use ourServices, you may provide information to us, both online and offline,including, for example:
We may hold and associate any information you provide uswith together with information gathered from other sources, including thesocial accounts that you choose to associate with your use of the Services, orwith information we receive from other companies.
When you use the Services, we automatically collect some information. We may collect information about your usage of and activity on our Services. When you visit our websites, information we may automatically log includes, for example, your operating system, Internet Protocol (IP) address, access times, browser type and language and the website that you visited before visiting our website. When you use our devices, download and use our applications, or access the Services from your device, we may also log information related to your device and your use of our applications and Services depending on your device and application settings. We may log, for example, the date you activate your device, your geolocation, phone service provider, phone number, device type, serial number, device identifiers (e.g., IMEI, MEID, serial number, CID, MID and MCC ID Number or SIM card ID), the types and versions of mobile operating systems on your device, applications and software you install and use and how you use them, content you view or use and time-stamped logs of data exchanges.
If you use the Services to back up and store your device data and content with an independent third party service provider, we will collect certain information needed to help restore your data and content to your device, such as your device settings and the names of files and applications that you wish to back up.
For the United States:
For the EU:
Information created or generated. We infer new information from other data we collect, including generating information about your likely preferences or other characteristics. For example, we may infer your city, state, and country location based on your IP address.
Usage Data and Error Reporting. In addition to the information we automatically collect, as described above, we may collect more detailed de-identified data about your device usage and error report data about your device (formerly called Tell HTC Experience and Tell HTC Error Report on older devices). When you participate in these programmes, you help us to understand how you use your device and improve HTC devices and other HTC and trusted partner products and services. HTC may re-identify this data when appropriate; for example, when you request technical support, choose to use a specific HTC service or app, or create an HTC Account. To learn more about usage and error reporting on your device, and/or to change your option to participate, go to “Settings” on your device. Usage and error data settings will not affect HTC’s collection of de-identified activation data or data about specific HTC apps and services you choose to use, including HTC Account, and are otherwise subject to limitations described in this Policy.
Others, including third party analytics service providers and third party ad service providers, as described in the section below, may also automatically collect the same or similar information about you and your device when you use the Services, including personally identifiable information about your online activities over time and across third party website and applications.
HTC may use information collected through third-party cookies or beacon in our Service or email for purpose to serve better ads to you on third-party websites. We may know when you visit HTC website after you browse such third-party websites and use the information collected about you to serve tailored ads to your interests through our Services or third-party service.
HTC may use your information, including personal information, as follows:
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.
We may share certain non-personally identifiable information with our partners, such as advertisers, or developers. For example, we may share an analytic report which includes aggregate customer usage or other statistics to show the trend of general use of our products or services.
Where your personal information is necessary for us to be able to provide you with requested services we make this clear on collection. If you decline to provide us with this information or object to continued processing of this information we will be unable to provide such requested services to you.
If you object to the processing of your personal data for marketing communication or if you withdraw your consent, we may only process certain required data (for example, name and email address) in our internal emailing system in order to ensure the ongoing observance of your objection or of your withdrawal of consent.
When you use certain Services, we may collect, process, store and share your precise location data. This location information may include real-time geographic location of your device. It may also include the names of places that you have been, where you choose to “check-in”, to determine, log or share your location, places that you mark on a map, the geographic location, dates and other metadata of photos that you’ve taken, routes that you have travelled, how close you are to other devices, such as Bluetooth-enabled devices, Wi-Fi routers and services that use those devices (such as a store’s tracking of your movement for data collection and marketing purposes) and the dates and times that you were at certain locations. HTC may share your location data with application providers who show that they have the right permissions. HTC may associate location data with personally identifiable or identifying information, such as your device ID and your account information. Our Services may also collect precise location data in a de-identified form, and we may share this data with partners and carriers to improve features and services.
INFORMATION YOU SHARE
The Services may allow you to connect and share your actions, comments, content and information publicly or with people you specify. You may also connect to, and share your information on, third-party social media platforms, websites, applications and services (“Third Party Sharing Services”) through “plug-ins,” widgets, buttons, and other third party features made available on and connected with our Services. Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information that you choose to make public or share with others. We also cannot control and are not responsible for any Third-Party Sharing Services or their actions, including the data that these Third-Party Sharing Services collect from you and your device, or how they use such data. Please review the privacy policies of all Third-Party Sharing Services to understand their privacy practices.
INFORMATION WE SHARE
We may share your personal information as follows where it is lawful to do so:
With your consent. For example, we share your personal information with ad network providers where you have given your consent to receive marketing. We also share your personal information with co-branded partners where you have consented to this. Our partners’ use of your personal information will be subject to their privacy policies.
For the purposes of a business deal (or negotiation of a business deal) involving a sale or transfer of all or a part of our business or assets. Business deals may include any merger, financing, acquisition or bankruptcy transaction or proceeding.
For legal, protection, security and safety purposes:
With our subsidiaries and affiliates as needed to provide our products and services and operate our business.
With service providers and vendors who process personal information for the purposes described in this Policy as part of services to us and who are subject to appropriate contractual obligations.
With wireless carriers for their provision of services to you. Their use of your information is subject to their privacy policies.
We may share aggregated and de-identified data with others for any purpose.
Information that we collect may be stored on your phone or stored on our servers and transferred to, stored and processed in the United States, Taiwan, Singapore, People’s Republic of China, United Kingdom, other EU member state countries (such as Poland) and any other country where HTC or its service providers maintain facilities, depending on where you use our product and services.
Where your personal information is transferred from within the EU to outside the European Economic Area (EEA), security measures and appropriate safeguards are put in place to protect your information and we ensure that all transfers of your information comply with applicable data protection law, and are carried out in accordance with our instructions. We may use certain legal mechanisms as an adequate safeguard, including the relevant EU Model Clauses*, with any party (including HTC Corporation) where your information is transferred to outside the EEA. To find out more about how we safeguard your information (including obtaining a copy of such safeguards) in relation to transfers outside the EEA, please contact us via the details provided in the contact section below.
* EU Model clauses means standard clauses for transfer of personal information to a controller established in third party countries under European Commission decision 2001/497/EC of 15 June 2001, as amended by European Commission decision 2004/915/EC of 27 December 2004, and the standard clauses for transfer of personal information to processors established in third countries under European Commission decision 2010/87/EC of 5 February 2010.
Information that we collect may be retained for as long as needed to fulfil the purposes outlined in the “use of your personal information” section above, or for a period of time specifically required by applicable regulations or laws such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
Otherwise, we securely erase your information once this is no longer needed. Contact us if you would like more information on how long we retain your information.
Where your personal information is collected within the European Economic Area (EEA), you can contact us through the contact information of HTC Europe Co. Ltd to exercise any of those rights described above.
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), beginning January 2020 you have certain rights with respect to that information. In particular, you have a right to request the following information to be provided to you:
(1) The categories and specific pieces of personal information we have collected about you.
(2) The categories of sources from which we collect personal information.
(3) The purposes for collecting, using, or selling personal information.
(4) The categories of third parties with which we share personal information.
(5) For companies that disclose personal information for a business purpose, the categories of personal information disclosed about you for a business purpose
(6) For companies that “sell” personal information, the categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.
With respect to (5), the CCPA defines “business purpose” broadly; and because we use service providers for a number of business purposes that require access to our data systems (such as maintaining the security of our systems, supplying cloud data storage, and providing customer service), in the past 12 months we have disclosed for a business purpose all of the categories of personal information that we maintain.
You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. Finally, you have a right not to be discriminated against for exercising rights set out in the CCPA.
For a request to know or a request to delete, contact us at firstname.lastname@example.org or toll free number +1 (888) 914-9661 (PIN: 177 303). You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Our marketing emails tell you how to “opt out” of receiving further marketing emails. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you, and may include a request that you participate in surveys related to your use of, and satisfaction with, the Services.
You may send requests about your personal information to us through our contact information below. You can request to change contact choices or marketing choices and to update, access, delete or make other changes regarding your personal information or content that you post on the Services in line with your rights above. We may not honour all such requests unless required by law.
When you use our Services, we and third parties may give you choices about use of certain mechanisms for tracking, including tracking of your online activities over time and across different websites, applications and online services. We may provide settings on your device that allow you to change how we, and others, collect certain information about you. Read your product manual for more information about settings on your device. Many browsers are set to accept cookies unless and until you change your settings.
Removing or rejecting our cookies could affect how our websites and Services work for you and could delete or disable opt-out cookies set by us and third parties.
While we and others give you certain choices, as further outlined in this Policy, there are many ways in which Web browser signals (including “Do Not Track” or “DNT”) and similar mechanisms can indicate your choice to disable tracking, and we may not be aware of nor honour every such mechanism. Instead, you can use the range of other tools to control data collection and use, including the controls described in this Policy.
We strive to protect personal information by taking appropriate physical, technical and organisational measures to help guard against unauthorised or unlawful access, use, processing or alteration of the personal information that we obtain from you through our Services and against any breaches or loss of such personal information, such as anonymization, pseudonymization, encryption (such as encrypted by Transport Layer Security (HTTPS) during transmission), restricted access, etc.. Although we take steps to use and improve various safeguards, no system or technology is completely secure. If you become aware of a technical vulnerability affecting HTC Services, please email email@example.com or visit this website to report it. If you have a concern related to the protection of personal information or this Policy, please send an email to Global-Privacy@htc.com .
HTC Account lets you use a single user name and password to log on to HTCSense.com and other HTC applications and Services. Some HTC applications and Services require a different user name and password. Please protect your user names and passwords to help prevent anyone from accessing your accounts and your personal information.
We are not responsible for the security of any independent third-party applications and services or the data those third-party applications and services may collect about you. Please ask those third parties how they keep your data safe.
We welcome your comments or questions about this Policy. Please email us at firstname.lastname@example.org . You may also contact us in writing at the addresses listed below:
Americas: HTC America, Inc.
308 Occidental Ave. South, Suite 300 Settle, WA 98005
Attention: Privacy Administrator
APAC: HTC Corporation
23 Xinghua Road,
Taoyuan City 330, Taiwan
Company registration number: 16003518
Attention: Privacy Administrator
EU: HTC Europe Co. Ltd
Salamanca, Wellington Street
Slough, Berkshire SL1 1YP, U.K.
Company registration number: 04826012
Attention: Privacy Administrator
(HTC Europe Co. Ltd is the leads establishment of HTC Corporation for the EU.)
We may make changes to this Policy. If we make any changes to the Policy they will be posted on this page and we will change the “Last Updated” date below.
Additional Information - AGE REQUIREMENTS ON OUR SERVICE OR PRODUCT, and CALIFORNIA PRIVACY NOTICE