This privacy policy (the “Policy”) describes how HTC Corporation and our related companies (“HTC” or "We/Our/us") collect, use and share personal information that we collect from you as a user of HTC websites, devices, applications and services (together, the “Services”). HTC strives to comply with all laws that apply to our handling of information collected about you. This Policy is subject to those laws that may be more strict than as outlined here. The term “related companies” means HTC Corporation, HTC America, Inc., HTC Europe Ltd. Inc and HTC affiliates which collect and process your personal information in the countries you are located.

We may add to, or amend, this Policy with other notices. We may also post different privacy policies for some Services and, when we do so, this Policy does not apply. For example, where applicable, separate policies apply to information collected from your device through Tell HTC Usage and Tell HTC Error Reporting.

You have the right to object to us using, sharing or carrying out any activity with your personal information (in certain circumstances) including using your personal information for direct marketing (i.e. receiving emails from us notifying you about other services which we think will be of interest to you or being contacted with varying potential opportunities). Contact us at any time with the details provided in the contact section below for more detail and to exercise this right where applicable.

NOTE: Your wireless operator, mobile operating system provider and/or third-party applications, toolbars, services, “plug-ins”, social media platforms and websites may also collect, use and share information about you and your device and your usage. HTC’s privacy policies do not cover any third parties, their products, actions or their services. HTC does not control how third parties collect, use or secure your data. For information about third-party privacy practices, please consult their privacy policies. Only download applications from, and interact and connect with, reputable third parties.

  1. INFORMATION YOU GIVE US

    When you use our Services, you may provide information to us, both online and offline, including, for example: your name, email address, street address, phone numbers, fax number, date of birth, device identifiers, location data, your provider information, photos, videos and demographics (gender, company or organisation name, occupation, language preference, city, country, postcode, area code, time zone, etc.). If you purchase Services from us, we may also store your credit card numbers or other payment information, as required. We may hold and associate any information you provide us with together with information gathered from other sources, including the social accounts that you choose to associate with your use of the Services, or with information we receive from other companies.

  2. INFORMATION WE AUTOMATICALLY COLLECT

    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. We may log, for example, the date you activate your device, your location, 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. We may also log information about you using web beacons, cookies, local shared objects (LSOs) and similar methods as described in our cookie policy. We may automatically link any of the information that we collect about you using these methods, to information that you provide us and any other information that we collect about you in accordance with this Policy.

    For the United States: http://www.macromedia.com/support/documentation/en/flashplayer/help/ settings_manager.html#117118

    For the EU: http://www.youronlinechoices.com/

    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.

  3. INFORMATION COLLECTED THROUGH THIRD PARTY

    Some of our HTC e-store is operated by third parties, such as Digital River. When you purchase products through that e-store you enter into terms and conditions with Digital River and they have a separate privacy policy available on the site. Digital River is a data controller in its own right. Digital River share certain user transaction data with us for our sales reports, better understanding of customer behavioural analysis or other legitimate purpose as described in this Policy.

  4. Other information for Advertising

    We may use third-party ad service providers to serve ads in our Services. We may also use third parties to deliver or help us deliver HTC-branded ads to you on third-party websites. To deliver these ads, third parties automatically collect certain information about you and your devices and your use of the Services. This information may include visits to the websites and applications of HTC and others, your IP address, your Internet service provider, and the browser that you use to visit our website. Third parties may collect information by using cookies as described in our cookie policy. 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.

  5. USE OF YOUR PERSONAL INFORMATION

    HTC may use your information, including personal information, as follows:
      To provide requested services or perform a contract with you
    • To provide and deliver products and Services that you request;
    • To process the post transaction requested by you, such as refund;
    • To send you information related to your requests, queries and purchases, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages; Where we have your consent To send you marketing communications including about contests, promotions, rewards, upcoming events and news about products and services offered by HTC and our selected partners (we do this as per your choices) and to process and deliver contest entries and rewards. Where we have a legitimate interest in improving your customer
    • To operate and improve our websites, products, Services and marketing;
    • To respond to your comments and questions and provide customer service; • To compile information to be able to provide you with a personalised and customised experience, content, marketing and recommendations across all our Services (in line with your choices as relates to receiving any direct marketing communications);
    • To link or combine your personal information with other information we get about your use of other HTC Services and from third parties for the purposes that we disclose in this policy, including to help understand you and your needs, and provide you with recommendations, better service and customised marketing;
    • To filter the content to be displayed as part of the Services;
    • To compile usage and other statistics and insights relating to the Services;
    • To prevent, investigate and deter against fraudulent, unauthorised or illegal activity, and ensure network and information security; and
    • To facilitate sharing of information and content that you choose to upload via social media (for example if you choose to upload content on the HTC forum or other applications, this may be made available for others to see through such forum). Where we have a legal obligation
    • To protect, investigate and deter against fraudulent, unauthorised or illegal activity.
      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 are obliged, according to data protection law, to enter the required data (name, e-mail address) into our internal emailing system in order to ensure the ongoing observance of your objection or of your withdrawal of consent. We will use your blocked data exclusively for this purpose.

  6. MORE ABOUT LOCATION DATA

    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.

  7. SHARING OF PERSONAL INFORMATION 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. We share your personal information with ad network providers where you have given your consent. 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 service providers who process personal information 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.

  8. WHERE WE STORE YOUR INFORMATION AND TRANSFER OF YOUR INFORMATION

    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 have in place the relevant EU Model Clauses* with any party (including HTC Corporation) your information is transferred to outside the EEA, as an adequate safeguard. 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.

  9. * 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.

  10. 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.

  11. YOUR RIGHTS

    By law, you have a number of rights (subject to certain conditions) when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can exercise any of these rights by contacting us through our contact information below.
    • The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing (i.e. receiving emails from us notifying you about other services which we think will be of interest to you or being contacted with varying potential opportunities).
    • The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.
    • The right of access. You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law.
    • The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold. • The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information that we hold.
    • The right to restrict processing. You have rights to ‘block’ or supress further use of your information. When processing is restricted, we can still store your information, but will not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.
    • The right to data portability. You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. This is not a general right however and there are exceptions.
    • The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator.
    • The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your information at any time. 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.

  12. INFORMATION CHOICES AND CHANGES

    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. Some of our third party ad service providers also provide choices for use of cookies to deliver ads tailored to your profile and preferences.
    To learn more visit: http://optout.networkadvertising.org/#!/ http://www.adobe.com/privacy/opt-out.html#measure
    While we and others give you certain choices, as further outlined in this Policy, there are many ways in which Web browser signals and similar mechanisms can indicate your choice to disable tracking, and we may not be aware of nor honour every such mechanism.

  13. PROTECTION OF YOUR PERSONAL INFORMATION

    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 security@htc.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.

  14. CONTACT INFORMATION

    We welcome your comments or questions about this Policy. Please email us at global-privacy@htc.com. 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

  15. APAC: HTC Corporation 23 Xinghua Road, Taoyuan District, 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.)

  16. CHANGES TO THIS PRIVACY POLICY

    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. THIS PRIVACY POLICY WAS LAST UPDATED ON 25th MAY 2018.
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