Privacy Notice for California Consumers

LAST UPDTAE: DECEMBER 28, 2022

This Privacy Notice for California Consumers supplements the Privacy Policy of HTC Corporation and its affiliates (collectively, “we,” “us,” or “our”) and applies solely to consumers who reside in the State of California (“you). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws,” provide California consumers with specific rights regarding their personal information. This Privacy Notice describes your rights under the California Consumer Privacy Laws, explains how you may exercise your rights, and provides an overview on the types of personal information we collect.

Your Rights Under California Consumer Privacy Laws and this Privacy Policy

California Consumer Privacy Laws provide you with the following rights:

Right to know. You have the right to know what categories and specific pieces of personal information and sensitive personal information (“SPI”) we collect about you, the sources from which we collect personal information and SPI, our business or commercial purpose for the collection, use, disclosure, selling and sharing of your personal information and SPI, and any categories of third parties to whom we disclose for a business purpose, and with whom we sell or share your personal information and SPI.
Right to delete. You have the right to request that we delete the personal information that we collect about you.
Right to correct. You have the right to request the correction of any personal information we maintain about you.
Right to opt-out You have the right to opt out of the sale or sharing of personal information. If we sell or share any of your personal information, you have the right, at any time, to tell us not to sell or share your personal information. At the time this Privacy Policy was last updated, we do not sell any personal information to third parties for their own marketing purposes. You also have the right to request that we do not share your personal information. You can make this request by clicking Do Not Sell or Share My Personal Information/ Limit the Use of My Sensitive Personal Information.
Right to limit use or disclosure of sensitive personal information (“SPI”). You have the right to limit the use or disclosure of your SPI if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services. You can make a request for us to limit the use or disclosure of your SPI by clicking Do Not Sell or Share My Personal Information/ Limit the Use of My Sensitive Personal Information.
Right to nondiscrimination. If you exercise any of your privacy rights under the California Consumer Privacy Laws, we will not discriminate against you.

For a request to know, a request to delete or a request to correct, contact us at global-privacy@htc.com 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, a conservator, or a person having parental responsibility for you (collectively, the “agent”) to make requests on your behalf to exercise your rights under the California Consumer Privacy Laws. Before accepting such a request from an agent, we will require the agent to provide proof you have designated him/her to act on your behalf, and we may need you to verify your identity directly with us. We will not share any information until we can reasonably confirm your identity.

We will respond to your request within forty five (45) days from when you contacted us. If you have a complex request, the California Consumer Privacy Laws allow us up to ninety (90) days to respond. We will still contact you within forty five (45) days from when you contacted us to let you know we need more time to respond.

The list of the categories of personal information we have or may have collected about you in the preceding 12 months

Personal information does not include:

Information that is lawfully made available from federal, state, or local government records;
De-identified or aggregated information; and
Information excluded from the CCPA and CPRA.

In the preceding twelve months, we have or may have collected the following categories of Personal Information for business purposes. Depending on your level of interaction with us, we may not have collected your personal information from all of the categories.

Personal Information Category	Types of Personal Information
Identifiers	Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, serial number, IMEI, email address, account name, tax ID, tax exempt certificate ID, birth certificate, death certificate
Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
Protected Information under California or federal law	Age (40 years or older), national origin, citizenship, medical condition, gender.
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information	Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and health data.
Internet or other similar network activity	Browsing history, search history, information on a Consumer's interaction with a website, application, or advertisement.
Geolocation data	Physical location or movements.
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information	Employer, employment history, resumes and CVs, background checks, employee performance, education and professional experience, and other employment-related information.
Sensitive Personal Information	Data revealing race or ethnic origin, health related information and reporting and sexual orientation related details where relevant to the HTC’s compensation and benefits programs.
Inferences drawn from other Personal Information.	Profiles reflecting Your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not collect sensitive personal information (“SPI”, which means non-public personal information that reveals: a consumer’s social security, driver’s license, state identification card, or passport number; a consumer’ account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health, sex life or sexual orientation) for general marketing purposes. However, we may collect SPI to provide you with HTC’s compensation and benefits programs. Please refer to “Information We Share.”

To (a) opt out of having your personal information shared with third parties, or of any future instances where our current information processing methods might be designated by California Consumer Privacy Laws as selling or sharing personal information or to (b) limit our use your sensitive personal information to what is reasonable and proportionate to provide the requested goods or services, contact us at global-privacy@htc.com , or call us toll-free at +1 (888) 914-9661 (PIN: 177 303), or visit the Do Not Sell or Share My Personal Information/ Limit the Use of My Sensitive Personal Information. page to submit a request.

How we use your personal information

The table below describes the sources for each category of personal information we collect, the business or commercial purposes for which we use each category of personal information, and the third parties with whom we may share your personal information.

Category	Sources	Business or Commercial Purposes	Third Parties Shared With
Identifiers	• Directly from you • Website cookies • Website analytics providers	• To provide consumers with products or services • To fulfill specific consumer requests • To enhance the website experience • For marketing and analysis	• Website providers • Analytics providers • Advertising providers • Telephone service providers
Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	• Directly from you • Website cookies • Website analytics providers	• To provide consumers with products or services • To fulfill specific consumer requests • To enhance the website experience • For marketing and analysis	• Website providers • Analytics providers • Advertising providers • Telephone service providers
Protected Information under California or federal law	• Directly from you • Website cookies • Website analytics providers	• To provide consumers with products or services • To fulfill specific consumer requests • To enhance the website experience • For marketing and analysis	• Website providers • Analytics providers • Advertising providers • Telephone service providers
Commercial information	• Directly from you • Website cookies • Website analytics providers	• To provide consumers with products or services • To fulfill specific consumer requests • For your participation in HTC’s compensation and benefits programs • To enhance the website experience • For marketing and analysis	• Website providers • Analytics providers • Advertising providers • Telephone service providers • Consulting service providers
Biometric information	• Directly from you during your use of our devices, application and services.	• To provide consumers with products or services • To fulfill specific consumer requests	N/A
Internet or other similar network activity	• Website cookies • Website analytics providers	• To enhance the website experience • For marketing and analysis	• Website providers • Advertising providers • Analytics providers
Geolocation data	• Directly from you during your use of our devices, application and services. • Website cookies • Website analytics providers • Advertising providers	• To provide consumers with products or services • To analyze website traffic • For marketing and analysis	• Website providers • Advertising providers • Analytics providers
Sensory data	• Directly from you during your use of our devices, application and services.	• To provide consumers with products or services • To fulfill your requests	• Customer service providers • Analytics providers • Advertising providers
Professional or employment-related information	• Directly from consumers	• For your participation in HTC’s compensation and benefits programs • To fulfill specific consumer requests	• Website providers • Analytics providers • Advertising providers • Consulting service providers
Sensitive Personal Information	• Directly from consumers	• For your participation in HTC’s compensation and benefits programs • To provide consumers with products or services	• Consulting service providers
Inferences drawn from other Personal Information.	• Website cookies • Website analytics providers	• For marketing and analysis	• Analytics providers • Advertising providers

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:
- to comply with laws or regulatory requirements and to respond to lawful requests and legal processes;
- to protect the rights and property of HTC, our agents, customers and others, including enforcing our agreements, policies and terms of use and protecting our network and physical assets; and/or
- in an emergency, including protecting the safety of our employees and agents, our customers or any other person.
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.

Retention

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:

our contractual obligations and rights in relation to the information involved;
legal obligation(s) under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
(potential) disputes; and
guidelines issued by relevant data protection authorities.

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.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice for California Consumers at our discretion and at any time. When we make substantive changes to this Privacy Notice, we will post a summary at the top of the first page of this Notice and update the Notice effective date.

Privacy Notice for California Consumers | Terms | HTC United States