Privacy Notice

This Privacy Notice describes how we collect, use, disclose, transfer, store and otherwise process your personal data when you are using our services, including our websites, our smartphones or wearable devices, apps, online services and other products (hereinafter collectively referred to as "Services"). Please read the Privacy Notice carefully and familiarise yourself with our privacy practices before using our Services or providing your personal data.

In addition to this Privacy Notice, specific privacy notices might apply depending on the Services used. We will, in each case, provide you with the applicable privacy notice.

This Privacy Notice will help you understand the following:

I

Responsibilities

• We operate and offer our Services globally. However, our Services partially differ depending on where you live.
• • OPPO MOBILES INDIA PRIVATE LIMITED (OPPO India), a company incorporated under the provisions of the Companies Act, 1956 bearing CIN U74140HR2013PTC069892 and having its registered office at 5th Floor, Tower-B, Building No. 8, DLF Cyber City, Gurgaon, Haryana, INDIA-122002 collects your personal data to provide you with sales, marketing and aftersales services.
• • In general, Guangdong OPPO Mobile Telecommunications Corp. Ltd. (OPPO), which is a limited liability company and with its principle address being No.18 Haibin Road, Wusha, Chang’an Town, Dongguan, China and registration number being 914419007480321175 is responsible for and controls the processing of your personal data with respect to personal data collected relating to mobile phone services. OPPO is committed to protecting and respecting your privacy. To the extent that personal data localisation requirements apply, we will comply with these requirements. If you would like to better understand how we process your personal data in your jurisdiction, please contact us using the "Contact Us" section.
• The terms "OPPO", "we" and "us" therefore refer to either OPPO or OPPO India depending on the services you concerned.
• Please note that, in relation to aftersales-services, we also work with our authorised exclusive distributors. These authorised exclusive distributors are responsible for the processing of personal data that you provide to them in connection with your requested customer service, or in connection with their marketing activities.

II

How We Collect Personal Data and What Types of Personal Data We Collect

• The term personal data is broadly defined and means any information relating to an identified or identifiable individual. This means that not only the data that, for example, identifies you directly, such as your name or address, is personal data but also other data, which when combined with other information accessible to us, enables us to link that data to you, for example, an IP address.
• Our channels for collecting personal data include: 1. personal data that you provide to us directly; 2. personal data that we automatically obtain when you interact with our Services, such as information on your interactions with our Services or us, and/or; 3. personal data that we obtain about you from third parties.
• The personal data we collect depends on the environment in which you interact with us and the choices you make, including your privacy settings and the features and Services you use.
• 1. Personal Data Directly Provided by You
• You may provide personal data to us directly, in which case you are generally free to choose which personal data you want to provide to us. However, if some personal data is required for the performance of our Services and you choose not to provide that personal data, we may not be able to provide you with the Services you requested. Personal data we directly collect from you may, for instance, include the following:
• • If you order Services from us, or use a paid Service: We may collect your delivery details, bank account number, credit card details, billing address and other financial information relating to the transaction, order number, name and contact details, information about purchase/return/refund requests or other requests and any other communication records, so we can process your order.
• • When you follow our social media accounts or interact with us in any other way: We may collect your profile information, the content and details of the timing of the communication exchanged or other personal data as required to respond to your request. The data we receive is dependent on your privacy settings with the social network.
• • When you share content with others: Some of our Services allow you to communicate and share content with others. The communicated or shared content shall be transmitted through and stored in our system.
• • When you sign up for our User Experience Program: When participating in this program, we may collect your device information (device identification data, configuration data, system and app data, advertising ID, IP address and time zone), your usage data (such as product function usage statistics, product upgrade statistics and data about app installation, uninstallation and error logs), information about the location of your device (to the extent you allow such location tracking separately) and your log information (such as the time and duration for which the service was used, any search terms that were entered using the service and information about device and software events such as reboots, upgrades, errors and crashes). This program may require a network connection, and some data can only be uploaded over Wi-Fi.
• • We may ask you to provide personal data or collect it under other circumstances such as in connection with marketing: Such activities include when you enter prize draws, use coupons or enter other competitions, participate in promotional or marketing activities organised by us or our business partners on our behalf, complete questionnaires or participate in user forums or blogs hosted by us or our business partners. To this extent, we may ask you to provide personal data such as your name, address, email address, phone number and other personal data as indicated in connection with such activities.
• • When you subscribe to our newsletters: We may collect your name, email address and information on how you interact with our promotional communication (such as whether or not you have opened the email or tapped on an accompanying link).
• • In some jurisdictions we may be required to conduct real name authentication for certain Services you might use: In such a case, we will also collect your full name and details of your government-issued ID. If you refuse to provide such personal data we may not be able to provide you with the corresponding Services.
• 2. Personal Data We Automatically Collect About Your Use of Our Services
• In addition to the personal data you provide yourself, we may also automatically collect information about your use of our Services, particularly when you are using your device. The personal data we may collect includes the following:
• • Device information: This may include the device name, device model, region and language settings, device identification number (IMEI number), device hardware information and status, IP address, MAC address, operating system version and the settings of the device used to access the Service.
• • Log information: This may include when and how long the Service is used, search terms entered through the Service and the device error logs. The Android system on your smartphone and/or wearable is designed in such a way that your error or crash log will contain information collected at the time of the event, which allows us to analyse the reasons for the crash. Such information may sometimes include your personal data, such as phone number, email address, Google account or Facebook account. However, we have implemented security measures to ensure that this information is used only for error log analysis and not for personal identification or other purposes.
• • Location information: This may include the GPS signal of the device or information about Wi-Fi access points and base stations near you, or the device location ID and network service provider ID when you access some location-based services (for example when you use the weather app). We will ask you if you want to enable location-based services for each of the various location-based apps. You can disable the location settings of your device from the device settings. If you disable location information, the functionalities of the apps that use location information to provide Services to you may be impaired.
• • Camera: To ensure the camera app functions properly, we collect operational data (such as how many times you use the app and the number of photos taken), information about the photos taken (such as the photosensitivity and number of faces captured) and information about the available space left on your mobile phone.
• • Other information about your use of the Service: This may include the version of the app or browser type being used, language settings, IP address, device type, IMEI, websites visited and how you interact with content provided through the Service.
• Please also see the Section "How We Use Cookies and Similar Technologies" below for further information on personal data that we automatically collect via cookies and other tracking technology when you visit our website.
• 3. Personal Data We Obtain From Third Parties
• We may obtain personal data about you from third parties. For example, where permitted by law, we may obtain data about you from public or commercial sources, including your activity on social networks you use, and may combine it with other information received from you or relevant to you. In particular, if you interact with us through a social media site or third-party service, such as when you like, follow or share OPPO content on Facebook, Twitter or other sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account and any other information you permit the social network to share with third parties.
• 4. Types of Data Processed Locally on Your Device
• For the avoidance of doubt and to ensure transparency about the processing of data, please note that the data set out in this section will only be collected and processed locally on your device and not uploaded to our servers. Therefore, we will neither access, collect nor otherwise process such data, nor will we be able to disclose this information to any third party or use it for any other purpose. This also means that this data processing is done by you only and is thus not subject to this Privacy Notice. If you want to exercise your rights in relation to such data or would like to modify or delete it, we will not be able to support you, except to provide information on how you can handle your data yourself.
• • When you use facial and fingerprint recognition: These functionalities enable rapid unlocking of your device with your pre-recorded facial or fingerprint information. To activate this function, you will need to provide your facial information or your fingerprint information captured from different angles. This type of information will be encrypted and stored using a unique secret key.
• • Photos information: The "Photos" app uses local image and video recognition algorithms on your device to enable you to organise your photos and videos. If you allow the app to use your location information, the device will record latitude and longitude information for your photo and video files. If you do not want to record your location when you take a photo, you can disable this feature at any time in your device's settings. When you search for a picture, the device's technology will identify photos that match the search terms, allowing you to quickly view relevant photos.
• 5. Other Non-personal Data
• Non-personal data refers to information which cannot be directly or indirectly associated with any specific individual. We may process aggregated or otherwise anonymised data.
• We collect non-personal data to understand users' preferences, improve our operational efficiency and optimise our websites and your product experience. If the non-personal data is combined with personal data, all such data will be treated as personal data.

III

How We Use Your Personal Data

• 1. We will use your personal data for the following purposes:
• • to provide you with OPPO's Services, process your orders or fulfil the contract between you and OPPO;
  • to activate Services you have purchased, your warranty service and specific software licenses and provide notifications for software updates;
  • to diagnose product issues and provide other customer care and support Services;
  • to conduct customer surveys in order to enhance your user experience and improve our Services along with their security features;
  • to analyse the customer market on the basis of the country where the users use our Services;
  • to analyse the efficiency of our business operations;
  • to analyse error logs to improve phone quality and app functions;
  • to provide you with personalised Services and to recommend and display content and advertisements tailored to you through our Services;
  • to allow and manage your participation in prize draws, contests or similar promotional activities held by us;
  • to communicate with you and reply to your questions or comments submitted through email or our online platforms, including social media accounts;
  • to ensure the functionality and safety of our Services, verify your identity, conduct internal auditing and prevent and investigate fraud, cybersecurity threats or other improper use;
  • to enhance and develop our Services, so as to improve the product usage experience, user-friendliness, operational performance, functions and design;
  • to pursue or defend against legal claims;
  • to comply with our legal obligations.
• 2. When we want to use the personal data for other purposes not covered by this Privacy Notice, we will inform you thereof and ensure that said use of your personal data is lawful.
• 3. We do not make any decisions involving the use of algorithms or profiling that produces legal effects or other effects that significantly affect you.

IV

How We Use Cookies and Similar Technologies

• We use cookies and similar tracking technologies on our website and other Services.
• 1. What Are Cookies?
• Cookies are small text files that are transferred from our Services and stored on your device. Our Services may use "cookies" and other technologies such as pixel tags and web beacons (collectively referred to as "Cookies"). Cookies may be stored on your computer. Cookies not set by us will not be accessible to us.
• 2. How We Use Cookies
• We and our third-party partners use Cookies to better understand the functionality of our mobile software on your device, and to monitor and analyse how you use and interact with our Services so that we can continue to improve them (such as to evaluate information on how often you use the Services, events that occur on our Services and where an app was downloaded). We do not link information that we store in analytics software to any personal data you may submit through our mobile apps.
• We and our third-party partners also use Cookies to analyse trends, manage websites, track user activity across these websites and collect aggregate demographic information about our user base.
• 3. Types of Personal Data We Collect
• This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, files viewed on our site (such as html pages and graphics), operating system, date/time stamp and/or touch stream data.
• 4. Third-Party Tracking and Online Advertising
• We partner with third parties to display advertisements on our websites and apps or to manage our advertisements on other sites. Our third-party partners may use cookies or similar tracking technologies to provide advertisements to you based on your browsing activities and interests. If you wish to opt out of interest-based advertising, you can manage Cookies as described in the following paragraph. Please note that opting out of interest-based advertising does not mean you will no longer see advertising on your device – it just means that adverts may no longer be tailored to your interests.
• 5. Clear/Disable Cookies
• Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies, you may not be able to use the full functionality of our Services. These settings will typically be found in the "Options" or "Preferences" menu of your browser.
• See the instructions below on how to manage cookies in some common web browsers:
• • Microsoft Internet Explorer
• • Microsoft Edge
• • Mozilla Firefox
• • Google Chrome
• • Safari for macOS
• • Safari for iOS
• For more information about cookies and instructions on how to configure your browser to accept, delete or reject cookies, see www.allaboutcookies.org.
• Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.
• If the "Do Not Track" function is enabled in your browser, we will respect your choice.
• Where required by law, we will provide you with further information about cookies.

V

How Long We Keep Your Personal Data

• We will only store your personal data for as long as necessary to achieve the collection purposes set out in this Privacy Notice, unless a longer retention period is required by law. If we are required by law to store your personal data beyond this period (such as for tax and commercial law reasons), we will delete the personal data at the end of this storage period.
• After the expiry of the aforementioned retention periods, we will delete or anonymise your personal data.
• To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use and disclosure of your personal data, the purposes for which we process the personal data and the applicable legal requirements.
• If, after you sign up for our promotional emails, you unsubscribe from receiving our promotional emails, we will delete your personal data from our mailing lists. However, we will continue to store your email address in a blocklist to ensure that you will not receive any further communication.

VI

How We Disclose Your Personal Data

• At times OPPO may make certain personal data available to other companies that are wholly or jointly controlled by us ("Affiliates") and other third parties that work with OPPO in order to provide Services to you. Your personal data will not be shared with third parties for their own independent marketing purposes.
• • Affiliates: Your personal data may be shared with OPPO's Affiliates for the purpose of rendering our Services to you. If Affiliates wish to process data for a different purpose, they must first seek your consent, unless another lawful basis exists.
• • Service providers and partners: Some of our Services will be provided with the assistance of third parties. We may also share some personal data with our partners in particular so as to deliver you a better service and improve your user experience. For example, when you use the security centre app, third-party service providers are used to scan for viruses and free up storage space on your phone, and we engage third-party service providers to provide you with enhanced customer service. We may also rely on service providers to identify and serve targeted advertisements, provide email services, provide tax and accounting services, organise competitions and deliver web hosting or analytics services. Any such service providers will, through appropriate data processing agreements, be bound to only process personal data on OPPO's behalf and under our instructions, unless such service providers act as independent controllers.
• • Purchasers and third parties in connection with a business transaction: Where a merger, acquisition, bankruptcy liquidation or similar action takes place, we may transfer or disclose your personal data to a limited, but necessary extent to the applicable third party.
• • Law enforcement, regulators and other parties for legal reasons: We may also disclose your personal data to third parties as required by law, or if we reasonably believe that such action is necessary (a) to comply with a subpoena or other legal proceedings, legal actions or government agency requests; (b) when we believe in good faith that a disclosure is necessary to comply with the law and the reasonable requests of law enforcement; (c) to protect and exercise our legal claims, rights and property; (d) to protect your rights, property or personal safety or that of others; (e) to investigate fraud and (f) to protect the security or integrity of our Services.
• • The public, when posted in certain public spaces: Some of our Services allow you to connect and interact with others. Your profile information or information that you post in a forum or on a blog, including personal data, will be accessible to other users or the general public by default when you create it. Such content will be accessible by the general public or the members of the Service depending on the Service used.
• • Otherwise with consent: We may disclose your personal data to certain other third parties with your consent.

VII

How Your Personal Data Is Transferred Globally

• 1. We leverage our resources and servers around the world to provide Services. We have data centres in France, Singapore, India and Indonesia, which means that in compliance with applicable laws, your personal data might be transferred to or accessed from countries or regions outside of where you use our Services.
• 2. Please note that different countries or regions offer different levels of data protection. This means that your personal data could be stored in a country that offers a level of protection that may, in certain instances, be less protective of your personal data than the country or region in which you are located. However, in such cases, we will take measures to ensure that the personal data we collect is processed in accordance with this Privacy Notice and applicable laws, and that your personal data is adequately protected. For example, we might ask your permission to transfer your personal data across borders, and we will implement adequate security measures (such as encryption and de-identification where feasible) and sign the necessary data transmission/sharing agreements with the recipients of your personal data prior to the transfer taking place. We will also specifically ensure that we comply with laws that require us to store data locally within a specific country or region.

VIII

How We Protect Your Personal Data

• 1. The security of your personal data is very important to us. We have taken reasonably practical, technical and organisational measures in accordance with industry standards to protect personal data collected in connection with our Service and prevent it from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. However, please note that while we have taken reasonable measures to protect your personal data, no websites, Internet transmissions, computer systems or wireless connections are absolutely secure. In particular:
• • Where appropriate, we will de-identify your personal data to mitigate the risk that other organisations or individuals may identify you on the basis of that personal data. We may also implement full security encryption during storage and transmission to prevent your personal data from unauthorised access, use or disclosure (such as by using SSL to encrypt many Services). We regularly review practices regarding personal data collection, storage and processing (including physical security measures) to prevent unauthorised access to or tampering with our various systems and your personal data.
• • We only allow OPPO employees and personnel of authorised service companies to access such personal data on a need-to-know basis, in order to process such personal data or provide relevant Services to you. These employees and external personnel are subject to strict contractual confidentiality obligations. If they fail to perform these obligations, they may be held liable and/or their relationship with OPPO may be terminated.
• • When transmitting and storing special categories of personal data, we use extra security measures, such as encryption of the transmitted content. We also use technical measures to process your personal biometric information so that we only need to store essential data (such as basic parameters necessary to identify a person, but not the raw facial and fingerprint data).
• • We carefully select our business partners and service providers and ensure that they are sufficiently bound to protect personal data and will be subject to privacy audits and assessments.
• • We conduct security and privacy protection training, testing and other activities to enhance employee awareness of and proficiency in personal data protection.
• • We use international and industry-recognised standards to protect your personal data and actively pursue relevant security and privacy protection accreditation.
• 2. In case of a personal data security incident, we will act in accordance with applicable law and notify you and/or the competent data protection authority of any such security incident where required, and take measures to mitigate any risks arising therefrom.

IX

Your Rights Regarding Your Personal Data

• 1. Subject to applicable laws in your jurisdiction, you may have specific rights regarding your personal data. This may include the following rights in particular:
• • The right to be informed: OPPO is publishing this Privacy Notice to keep you informed as to how we handle your personal data and what options and rights you have regarding your personal data.
• • The right to access: If you wish to access your personal data, some of our Services provide an interface through which you may directly search for or access certain personal data. You may also request access to the personal data we hold about you and information about its processing by contacting us using the "Contact Us" section.
• • The right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and request the completion of your personal data where appropriate.
• • You can opt out of the User Experience Program at any time through your device settings or by contacting us: (please refer to the section "Contact Us" below). After you opt out of the Program, we will delete or anonymise all data collected from your device for the Program.
• • Unsubscribe from marketing communications: If you no longer wish to receive marketing communications, you may unsubscribe from such communications at any time using the method provided in each promotional message.
• 2. You may also have further legal rights concerning your personal data, depending on the jurisdiction in which you are located. In this respect, please see the GDPR-specific Section if you live in Europe.
• 3. If you wish to make a request, you can submit it through our Data Subject Requests platform ("DSR platform"), which is accessible through https://www.oppo.com/en/privacy-feedback/.
• 4. Please note that, in the interest of security, we may ask you to verify your identity before processing your request.
• 5. Certain jurisdictions might entitle you to refer the complaint to the relevant regulatory authority if you are not satisfied with the response you received.
• 6. In principle, we do not charge a fee for responding to your reasonable request. However, for multiple and repetitive requests that exceed a reasonable limit, we may charge a reasonable fee to cover some of our costs, depending on the nature of the request. We are entitled to refuse requests in whole or in part, and we may refuse requests that are manifestly unfounded, unreasonably repetitive or that require disproportionate technical effort (for instance, requests that require the development of new systems). In addition, we may not respond to requests that directly concern significant issues of public interest or may cause serious damage to the legitimate rights and interests of you or other individuals or entities.

X

How We Process Children's Personal Data

• 1. Our Services are mainly intended for adults. A child should not use our Services without his/her legal guardian's consent. We treat anyone less than 18 years of age (or the equivalent minimum age for full legal capacity in the relevant jurisdiction) as a child.
• 2. If we discover that a child's personal data has been collected, we will delete the corresponding data as soon as possible.
• 3. If you believe that we might have any personal data concerning a child, please contact us using the "Contact Us" section.

XI

Third-Party Websites

• 1. OPPO Services may contain links to third-party websites, products and services. You can choose whether to access websites or accept products and services provided by third parties or not. For example, the "Follow us" function on our official website provides links to our official social media accounts (such as Facebook, Instagram, LinkedIn and Twitter) where you can view marketing or promotional information published by OPPO.
• 2. We do not control third-party privacy and data protection policies and do not accept any responsibility or liability for such policies. At the same time, such third parties are not bound by this Privacy Notice. Therefore, before submitting personal data to third parties, we strongly recommend that you refer to the privacy protection practices of such third parties.

XII

How This Privacy Notice Is Updated

• We reserve the right to update or modify this Privacy Notice from time to time. We will, as appropriate, send you notifications of material updates to this Privacy Notice in a form we deem appropriate and we will update the "last updated" date at the start of this Privacy Notice.

XIII

Contact Us

• If you have questions or concerns regarding our Privacy Notice or practices, please submit your request through our DSR platform (https://www.oppo.com/in/privacy-feedback/)
• If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.