“Personal Information” refers to any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such natural person;
“Sensitive Personal Data or Information” shall mean as defined in the Information Technology Act, 2000 and the notification dated 11th April, 2011 issued by Ministry of Communications and Information Technology (Department of Information Technology);
B. How We Collect and Use Your Information
We may collect Your Information for efficient operations and to provide you with a good user experience. Our channels for collecting Your Information shall be (a) information directly provided by you to us; (ii) information which we receive from third parties. If you choose not to permit us to collect such information we may not be able to provide you with relevant products and/ or respond to your queries or resolve any problems which you encounter.
a. Information directly provided by you to us:
i. For enrolling yourself in the Pre-Order Campaign, we will require to collect your Name, Mobile Number and Email id.
iii. In case we provide you with a customer support function or any other function through which either we, third parties engaged by us, OEC or retailers selling OPPO Phones contact you or viceversa in respect of the Pre-Order Campaign, we or they may collect Your Information including but not limited to your identity verification documents and/ or details, contact details, communication history (written or recorded, if through calls), complaint or query related details, details about the product or services being enquired, etc.
b. Information which we receive from third parties:
i. We may collect Your Information from the Platform which is linked to your account id maintained with the Platform or your HeyTap account;
ii. We will collect Your Information provided by you to third parties, OECs (OPPO Experience Consultants) and retailers as mentioned in Clause B(a)(iii) herein above.
C. How We Use Your Information
a. Your Information will be processed to implement core functionalities Pre-Order Campaign on the Platform such as enrolment, verification, service inquiry, logistics and distribution, as well as to provide you with other product information;
b. Pursuant to you placing any order on or through the Platform, we will share Your Information and your order information with our partners, OECs, retailers whose services you may need in your city and state as indicated in your shipping address or as may be chosen by you while enrolling for the Pre-Order Campaign;
c. Pursuant to you placing the orders, either we, our partners and/ or our authorized distributor, OEC or retails may (at their discretion) arrange for the delivery of your purchase to you for which they may engage their logistics partners. Consequently, Your Information will be shared with each such logistic partner. In the alternative you may receive a call from the OEC, retailers, OPPO or our partners to visit the retail outlet or other designated place for purchasing the pre-ordered product;
d. As part of the order fulfilment services, we may obtain your delivery tracking number from the third-party service provider, logistic partners, authorised distributors, OEC or retailers;
e. We will analyse the data which is sent by OEC and our authorised third parties (mentioned herein) with whom your Your Information has been shared to solve customer related issues faced during this campaign including while purchasing the device;
f. We will store, use, process, share, transfer and/ or disclose Your Information and/ or your order information for the purposes of after-sales, tax, and financial-related services in accordance with the applicable laws and regulations.
g. We may use Your Information for sending you promotional and other commercial offers. We may use in-house or third-party tools to send you commercial and promotional offers in which you may be interested. You may unsubscribe from these direct marketing messages by clicking the un-subscription link in the email.
h. To provide customer support, such as to communicate with you about your pre-order, purchase order, device, services availed or addressing any general queries or complaints which you may have.
i. To process, generate and provide you with notifications, promotions, pre-approved offers and push services and to analyze statistical information about the use of the Pre-Order Campaign on the Platform for trying to improve them including with the intent to improve/augment user experience;
j. To comply with activities related to the law and legal processes
D. How We Retain Your Information
E. To Whom We Disclose Your Information
We may share, transfer or disclose Your Information to the following:
i. Affiliated Companies: We may share Your Information with our Affiliated Companies or which may include any of the companies under the brand OPPO or companies and/ or enterprises functioning under the multiple brand names owned and/ or controlled by us.
ii. Our Partners and Vendors: We may be required to share, transfer and/ or disclose Your Information for the purpose of being stored, processed and/ or used with our technical, business, marketing, OEC, retailers and delivery partners and vendors for the purpose of continued provision of services including related/ ancillary services in pursuance of the Pre-Order Campaign;
Notwithstanding anything mentioned hereinabove, we shall not be responsible for the actions or omissions of any third parties with whom Your Information is shared by you nor shall we be responsible and/ or liable for any additional information you may choose to provide directly or indirectly to any of the third parties while applying for or activating their services and products whether directly or indirectly or whether through the Platform or otherwise.
F. How We Protect Your Information
a. We have taken reasonable technical security and organizational measures to protect Your Information which is collected and stored with us. However, it is imperative to appreciate and acknowledge, which you must, that although we take reasonable steps to protect Your Information, no website, Internet network or transmission, computer system or wireless connection is completely secure.
b. We will strictly control the access to Your Information and only allow our employees who need to know Your Information to help us process such information, and personnel of companies authorized to handle the services on our behalf to access Your Information.
c. The security of Your Information is of great importance to us. Therefore, we will continue our efforts to protect Your Information and implement safeguard measures, such as providing encryption for information storage and transmission in an effort to prevent Your Information from unauthorized access, usage or disclosure;
d. In the event of Your Information security incident, we, if and how required and in accordance with the requirements of relevant laws and regulations promptly inform you of the same and the preventive measures to be undertaken to mitigate the damage.
G. Your Rights to Your Information
Below is a list of your, non-exhaustive, legal rights as well as the measures that we take to protect your rights.
b. Right to access: You may request access to Your Information which is collected and stored by us.
c. Right to correct: If you find that Your Information stored with us is inaccurate or incomplete you may, on most occasions, have the right to request us to rectify or amend it unless we or any of our partners have acted upon or made to have acted upon such incorrect or incomplete information provided by you. You may have access to rectify or complete Your Information directly on the relevant page of the Platform. However, for that part of Your Information that has not been made available for your modification, you can request correction or supplementation by contacting our grievance officer at firstname.lastname@example.org You undertake to provide us with true, accurate and complete information about yourself and to keep Your Information updated to be true, accurate and complete, at all times, to help us serve you better and that you shall be solely liable for any consequences which ensue as a consequence of you being in breach of this clause including we or any of our partners acting upon Your Information which has been provided by you to us or to any of our partners.
e. Right to Withdraw Consent: You can grant or withdraw your authorisations and consents at any time, unless you have already activated services which prohibit the withdrawal of authorisations and consents, like using Your Information for making delivery of your purchased product. Please also note that, if you withdraw your authorization or consent we may no longer be able to provide you with the corresponding services.
If you withdraw your consent we will no longer process Your Information. But your decision to withdraw your consent will not affect the processing of Your Information already done based on your previous consent prior to the withdrawal.
f. Right to complain: You have the right to file complaints in respect of privacy concerns by contacting us email@example.com. Pursuant to receiving complete information and details of your complaint, we will respond within 30 days from the date of receipt of your complaint and try and resolve your complaint.
Please note that due to security reasons we may verify your identity before processing your request pursuant to any of your rights as described above. In principle, we do not charge any fees if your request is reasonable. However, based on the actual situation we may impose a certain fee to cover our costs for repeated requests or requests that extend beyond reasonable limits. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), may be detrimental to the legal rights and interests of others or are very impractical. In addition, we may not be able to respond to your request if your request is directly related to matters involving national security, national defence, public health, criminal investigation and other public interests, or if the request may severely impair the legitimate rights and interests of yours or those of other individuals and organizations.
H. How We Process Personal Information of Children
a. Our Platform and Services are mainly for adults i.e. for those who are aged 18 years or above. We consider it the responsibility of the parents to monitor their children’s activity. Children (we regard anyone who is under the age of 18 as a child) may not use our services for purchasing products from the Platform without the consent of their parents or guardians. However, if any child uses the Platform, avails any service on it or makes any purchase from it, then we will deem the consent of the Parents or the Guardians, as the case may be, of such child.
I. How Your Information is Stored and Transferred Globally
J. Communications from Us
a. Special Offers and Updates: We may send you information on products, services, special deals, newsletters and such other kinds of promotional offers and messages. Out of respect for your privacy, we present you with the option of not receiving these types of communications. You may unsubscribe via the unsubscribe mechanism provided in each such communication.
b. Service Announcements: On certain occasions or as per requirement of any laws, rules or regulations we may be required to send out service-related announcements and communications. These communications would not be deemed as promotional in nature.
c. Customer Service: We may communicate with you on a regular basis to provide requested services and in regard to issues relating to your user account. We may reply via email or phone, based on your requirements and convenience.
Date: September 2, 2021