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privacy

Privacy Notice

To help you understand how we process your personal data, we have prepared a brief summary of our Privacy Notice. For more details, please see the full version of the Privacy Notice below. We recommend that you also read the full version of the Privacy Notice so that you fully understand how we handle your personal data and what options and rights you have in relation to your personal data.

Key Points	Summary
Who is responsible for collecting and using your data?	Generally, OPPO is responsible for collecting and using your personal data. However, to the extent you are in Europe, the controller of your personal data is OROPE Germany GmbH.
Data We Use	We process data about you that you directly provide to us or that we collect when you use our Services. We may also receive personal data about you from third parties.
What we use it for	We will use your personal data only when we have a lawful basis to do so, such as the performance of contract to provide you with Services, for our legitimate interest, with your consent or to comply with our legal obligations. We may also process your personal data when you participate in promotional activities such as prize draws.
How long we keep your data	We will not keep your personal data for longer than we need it. In most cases, we will keep your personal data only for as long as necessary to use it for the purposes that we tell you about. Sometimes, though, the law requires us to keep it for longer.
Marketing	We may send you information about Services or offers that you may be interested in. If we need your consent to do that, we will only do so with your consent and you can opt out of such marketing communications at any time.
Sharing Your personal data with Third Parties	We may share your personal data with other companies that are controlled by, or under common control with us, third parties such as our business partners and service providers or where we are required to do so by law. We will ensure that our business partners and service providers are subject to appropriate data protection obligations.
Security	We take the security of your data very seriously. We have implemented various technical and organisational measures to protect your personal data.
Your Rights	Some data protection laws may grant you rights in relation to your personal data, including, for example, the right: • to be informed of how we process your personal data; • to access the personal data we hold about you and information about their processing; • to request that we delete or update inaccurate personal data; or • to complain to the relevant regulator if you think that we have infringed any of your rights. If you are living in Europe, you will have specified rights further outlined in this Privacy Notice.
Children	Our Services are aimed at users who are at least 18 years old. We try not to collect and use children’s data.
International Transfer	We are a global business, so we may transfer your personal data to other countries. We will ensure that we abide by storage localisation requirements and put appropriate legal safeguards in place for such transfers.
Updates	We may update this Privacy Notice from time to time and will notify you of any updates in an adequate manner.
Contact Us	If you have any questions, you can contact us at https://www.oppo.com/ie/privacy-feedback/..

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.

The general provisions of Section A shall apply to you, regardless of your location. Section B only applies to customers located in the European Union, Liechtenstein, Norway, the United Kingdom or Switzerland ("Europe").

This Privacy Notice will help you understand the following:

General Provisions

Responsibilities

We operate and offer our Services globally. However, our Services partially differ depending on where you live.
• OROPE Germany GmbH as Controller: If you live in Europe, OROPE Germany GmbH, a company incorporated in Germany whose registered address is Graf-Adolf-Platz 15, 40213 Düsseldorf, is solely responsible for any processing of your personal data, as described in this Privacy Notice.
• In general, OPPO is responsible for and controls the processing of your personal data with respect to personal data collected by the Services outside of Europe, and 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 OROPE Germany GmbH or the relevant entity, depending on where you live.
Please note that, in relation to aftersales-services, we work with 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.

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.

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.

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.

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.

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/ie/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.

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.

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/ie/privacy-feedback/)
or you can also contact our data protection officer at

      Collegium Auditores GmbH
      Datenschutz OROPE
      Haufeld 2a, 53721 Siegburg, Germany
Our EU representative is：

OROPE Germany GmbH
Graf-Adolf-Platz 15, 40213, Düsseldorf, Germany
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.

GDPR-Specific Provisions

The following provisions only apply to you if you live in Europe.

Legal Bases for the Processing of Personal Data

Our processing of your personal data as described in the Section "How We Use Your Personal Data" is based on the following legal grounds:
1. Consent: We may process your personal data with your consent. In particular, we may ask for your consent to participate in promotional activities, such as to send you promotional messages or enable you to participate in the User Experience Program and certain Services, including services through which we collect location information. You have the right not to provide consent, or to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you have granted us consent to use your personal data, we will use it only for the purposes specified in the consent declaration. Please note that to the extent our processing is based on your consent and you deny your consent or withdraw it, we may not be able to provide the service relating thereto. Besides from that, neither the initial denial nor a withdrawal will have any negative consequences for you.
2. Perform or enter into a contract with you:
We rely on this legal basis in particular in the following cases:

• 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 allow and manage your participation in prize draws, contests or similar promotional activities held by us; and
• to diagnose product issues, repair customer equipment and provide other customer care and support Services.
3. Compliance with a legal obligation: OPPO may be obliged to process personal data to comply with our legal obligations, for example where OPPO is required to retain data for tax law or commercial purposes.
4. Legitimate interests: The processing of your personal data may also be necessary for OPPO's legitimate interests. In particular, such cases may include the following:

• to conduct customer surveys to enhance your user experience;
• to analyse the customer market on the basis of the country where you use our Services, including the number of users for product marketing and promotion;
• 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 communicate with you and reply to your questions or comments submitted to us by any means;
• to ensure the functionality and safety of our Services;
• to verify your identity;
• to conduct internal auditing and to prevent and investigate fraud, cybersecurity threats or other improper use;
• to enhance and develop our Services, including relevant security features, so as to improve the product usage experience, user-friendliness, operational performance, functions and design;
• to pursue or defend against legal claims.
Your personal data will only be processed on the above grounds after we have appropriately assessed and balanced our interests against your right to privacy.

Additional Information on How Your Personal Data Is Transferred Globally

In case your personal data is transferred to jurisdictions located outside of Europe, we will ensure that appropriate safeguards exist and are applied, such as:
1. the recipient of the personal data is located within a country that benefits from an "adequacy" decision of the European Commission;
2. the recipient has signed a contract based on "model contractual clauses" approved by the European Commission, obliging them to protect your personal data;
3. or in the absence of the above appropriate safeguards, we will ask you for your explicit consent for the cross-border transfer of your personal data or take any other measures that are recognised as providing a sufficient level of protection for your personal data.
For more information about the safeguards relating to personal data transfers outside of Europe, please submit your request via our DSR platform (https://www.oppo.com/ie/privacy-feedback/).

III

Additional Information on Cookies and Other Tracking Technology

If you wish to obtain detailed information on the use of cookies and other tracking technology, please read our Cookies Statement.

Additional Information on Your Rights Regarding Personal Data

Subject to the legal requirements under the GDPR, you have the following rights:
• The right to access: You may request access to the personal data we hold about you.
• 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 to request the completion of your personal data where appropriate.
• The right to erasure: You can submit a request to us to delete personal data, and we shall have the obligation to erase it without undue delay in some circumstances – for example, if we do not have a legal reason to continue to process the personal data to the extent required by applicable laws and regulations. Please note in so far as you delete all the data that is contained in your device, this does not mean that you have deleted all data that OPPO collects and processes about you. Therefore, we encourage you to contact us (please refer to the section "Contact Us" above) to request that your personal data is deleted.
• The right to restriction of processing: You have the right, in certain circumstances, to request OPPO to temporarily restrict the processing of your personal data, such as where the accuracy of that personal data is contested by you, while we verify the accuracy of that personal data. We will keep just enough data, or process such data as is necessary to ensure that we comply with your restriction request in the future.
• THE RIGHT TO OBJECT: You have the right to object to any processing justified by legitimate interests based on grounds relating to your particular situation at any time. Should you decide to object to the processing of your personal data, we will stop processing personal data that concerns you, unless we can demonstrate compelling reasons for continuing to process your personal data that override your interests, rights and freedoms, or in the case that we establish, exercise or defend our legal claims. You can object to direct marketing activities at any time for any reason whatsoever.
• The right to data portability: You have the right to obtain a copy of your personal data in a structured, commonly-used and machine-readable format and transmit such data to another provider or have such data transmitted to another provider under certain circumstances.
• The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you want to withdraw your consent with regard to receiving promotional communications, you can unsubscribe through the method described in each promotional message. If you withdraw your consent, we may no longer be able to provide you with the corresponding Service.
• The right to lodge a complaint: You have the right to lodge a complaint with a competent supervisory authority about the way we handle or process your personal data, or file a lawsuit in a court with jurisdiction. Information about how to contact your local data protection supervisory authority is available here.

Contact Details of the Data Protection Officer

You can submit your request through our Data Subject Rights platform (https://www.oppo.com/ie/privacy-feedback/), or you can also contact our data protection officer at:
Collegium Auditores GmbH
Datenschutz OROPE
Wilhelmstrasse 74, 53721 Siegburg, Germany

Guangdong OPPO Mobile Telecommunications Corp., Ltd. and its affiliated companies (hereinafter referred to as "OPPO" or "we" or "us" or "our") are committed to protecting and respecting your privacy. Therefore, we developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data while you and your business interact with us to supply us with your products or services or purchase our products or services. This Privacy Policy does not apply to the processing of personal data while you use our mobile applications or services, which is governed by the policy available here. Please read carefully and familiarize yourself with our privacy practices and how your personal data are processed.

Definitions

"Affiliated Company" refers to a company that is related to OPPO due to joint ownership or control.
"Third Parties" refer to companies or persons who do not have a related relationship arising out of joint ownership or control with OPPO (i.e., a non-affiliated company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and OPPO.
"Personal Data" refers to any information relating to an identified or identifiable natural person.
"Process" refers to any operation or set of operations which is performed on personal data or on sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration,retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

How We Collect and Use Your Personal Data and on What Legal Grounds

We have set out below, in a table format, a description of all the data we process and the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Type of data we process	Purpose / Activity	Legal grounds for processing
If you are an employee or representative of a company that supplies products or services to us
Full name of the company's legal representative Full name of main contact person(s) Phone Address Email Job Title Log info and user account (if you are using our databases) Other information you might share with us	To sign contract and register your company as a new supplier in our databases	Necessary for our legitimate interests (to maintain efficient databases of the suppliers we interact with)
	To interact with you and complete our order including arrange for payments, fees and charges	Necessary for performance of a contract with you
	To communicate with you and invite you to participate in our marketing activities relevant to your services or that might be of interest to you for business purposes	Necessary for our legitimate interests (to promote our business)
	To provide you access to databases used during our daily business and are relevant to your services	Necessary for our legitimate interests (to run our business, and maintain databases that can increase our work efficiency)
	To protect our business and our databases (including troubleshooting, support, system maintenance, reporting and hosting of data)	Necessary for our legitimate interests (to run our business, provide administration and IT services, network security); Necessary to comply with a legal obligation
If you are an employee or representative of a company that we sell products to for distribution
Full name of the company's legal representative Full name of main contact person(s) Phone Address Email Job Title Passport details (for booking and traveling authorisation) Traveling details Log info and user account (if you are using our databases) Other information you might share with us	To sign contract and register your company as a new customer in our databases	Necessary for our legitimate interests (to maintain efficient databases of our products’ distributors)
	To interact with you and complete your order including process your purchase order, provide after-sales services, technical support, training, collect and recover money owed to us	Necessary for performance of a contract with you; Necessary for our legitimate interests (to recover debts owed to us)
	To communicate with you and send details of our marketing activities relevant to our services or that might be of interest to you for business purposes	Necessary for our legitimate interests (to promote our business)
	To communicate with you and ask you to leave a review or complete a survey; to reply your requests about us or handle any complaints you might have	Necessary for our legitimate interests (to collect our business partners'feedback, improve the level of our services and grow our business)
	To communicate with you and arrange your visit to our premises or any other place agreed, including flight and accommodation booking and the completion of the procedures for traveling authorisation use (if needed)	Necessary for our legitimate interests (to strengthen our relationship with you) Consent (if you ask us to assist you with accommodation, transportation, visas etc.)
	To provide you access to databases used during our daily business and are relevant to your services	Necessary for our legitimate interests (to run our business, and maintain databases that can increase our work efficiency)
	To protect our business and our databases (including troubleshooting, support, system maintenance, reporting and hosting of data)	Necessary for our legitimate interests (to run our business, provide administration and IT services, network security); Necessary to comply with a legal obligation
If you are an employee or representative of a company that explores business opportunities with OPPO
Full name Address Phone Email Job Title Other information provided on your business card or you have otherwise chosen to share with us	To communicate with you, reply your questions and send details of our marketing activities relevant to your services or that might be of interest to you for business purposes	Necessary for our legitimate interests (to maintain our relationship with you and promote our business)
If you are an employee or representative of a company or an individual freelancer that has established contact with us and you do not fall in any of the above-mentioned categories, e.g. journalist, member of the press, key opinion leader (KOL), designer
Full name Address Phone Email Job Title/Profession Passport details (for agreement execution and booking and traveling authorisation) Traveling details Bank details (if payment is needed) Other information provided on your business card or you have otherwise chosen to share with us	To communicate with you, invite you to take part in our marketing activities or contests that might be relevant to your services/profession or that might be of interest to you and facilitate your access to such activities	Necessary for our legitimate interests (to maintain our relationship with you and promote our business) Necessary for performance of a contract with you Consent (if you ask us to assist with arranging accommodation, transportation, visas etc.)
	To conclude and execute agreement with you including make payments or send you samples of our products
	To communicate with you and arrange your visit to our premises or any other place agreed, including flight and accommodation booking and the completion of the procedures for traveling authorisation (if needed)

We do not take any decisions involving the use of algorithms or profiling that significantly affects you.

III

How Long We Keep Your Personal Data

Our retention period for personal data is the minimum time necessary to realise the purpose of collection unless a longer retention period is required by law. Beyond the above retention period, we will delete or anonymise your personal data.

How We Disclose Your Personal Data

1. At times OPPO may make certain personal data available to affiliated companies and other third parties that work with or for OPPO.
(1) Affiliated Companies: your personal data may be shared with OPPO's affiliated companies. We only share necessary personal data subject to the purposes stated in this Privacy Policy.
(2) Sharing with other third parties: to realise the purposes stated in this Policy, some of our services will be provided by other third parties. We may share some personal data with them to provide better services and user experience. Where a merger, acquisition or bankruptcy liquidation takes place, if the transfer of personal data is involved, we will ask the new company or organization which obtains your personal data to be subject to this Privacy Policy, otherwise we will ask such company or organization to obtain your consent for such transfer.
We will only share your personal data for lawful, legitimate, necessary, specific and clear purposes, and only personal data necessary for service provision will be shared. Our partners are not allowed to use the shared personal data for any other purposes.
2. We may also disclose your personal data if it is required by laws, such as to comply with a subpoena or other legal proceedings, legal actions or government requests, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others investigate fraud.

How We Protect Your Personal Data

1. We have taken reasonably practical and technical measures to protect the collected personal data related to our services. While we have taken reasonable measures to protect your information, no websites,Internet transmissions, computer systems or wireless connections are absolutely secure.
2. We have taken safeguarding measures in accordance with industry standards to protect the personal data you provided and prevent data from unauthorised access, public disclosure, use, modification, damage or loss. We take all reasonably practical measures to protect your personal data. In particular:
(1) We use SSL to encrypt many services. We review practices regarding information collection, storage and possessing (including physical security measures) periodically to prevent unauthorised access.
(2) 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 information 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 or their relationship with OPPO may be terminated.
(3) The security of your information is extremely important to us. Therefore, we endeavour to ensure the security of your personal data and implement measures such as full security encryption during data storage and transmission to prevent unauthorised access, use, or disclosure.
(4) We will prudently select business partners and service providers and implement the requirements for personal data protection to the business contracts or audits and assessments between both parties.
(5) We conduct security and privacy protection training, testing and other activities to enhance employees' awareness and proficiency of personal data protection.
3. In case of personal data security incident, we will act, in accordance with the applicable law.

Your Rights with Regards to Your Personal Data

We respect your legal rights to your personal data. We list below your legal rights which can be exercised under certain circumstances:
1. The right to be informed: OPPO is publishing this Privacy Policy to keep you informed as to what we do with your personal data. We strive to be transparent about how we use your data.
2. The right to access: This right is commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
3. The right to rectification: This enables you to have any incomplete or inaccurate information we hold about you corrected.
4. The right to erasure: This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
5. The right to restriction of processing: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. The right to data portability: To the extent permitted by laws and regulations, you have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format so that you transmit them to another party.
7. The right to object: You have the right to object to OPPO processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics. More information about this right is available at the end of this Privacy Policy.
8. The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time, and OPPO must stop processing your data. You can withdraw your consent by contacting us (see below). Please note that if you withdraw your consent, we may no longer be able to provide you with the corresponding services for which you have withdrawn your consent.
9. The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with the data protection authority of your jurisdiction.
Please note that for security reasons, we may ask you to verify your identity before processing your request on a strict need-to-know basis. In principle, we do not charge a fee for your reasonable request. However, for multiple and repetitive requests that exceed reasonable limit, we may charge a reasonable fee to cover some costs depending on the nature of the request. We may refuse requests that are manifestly unfounded, unreasonably repetitive, or require disproportionate technical effort (for instance, 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.

VII

How We Process Children's Personal Data

1. This Privacy Policy covers how we collect, use, disclose, transfer, and store your personal data while you and your business interact with us to supply us with your products or services or purchase our products or services. Therefore, in principle, we do not expect to collect or process data of children for such reason. We treat anyone under 18 years old (or equivalent minimum age for full legal capacity in relevant jurisdiction) as a child.
2. If you believe that we might have any information from or about a child under 16, please contact us (see below).

VIII

How Your Personal Data Is Transferred Globally

1. We provide products and services through resources and servers around the world. This means, in compliance with applicable laws, your personal data might be transferred to or accessed from jurisdictions outside of the jurisdiction where you use our products or services.
2. In case your personal data is transferred to countries located outside of the European Economic Area (EEA), we will ensure that it will be protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of different ways, such as:
(1) Ithe recipient of the personal data is located within a country that benefits from a full “adequacy” decision of the European Commission;
(2) Ithe recipient may have adhered to binding corporate rules (only for intragroup transfers);
(3) Ithe recipient has signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
(4) Iwhere the recipient is located in the US, it is a certified member of the EU-US Privacy Shield scheme.
In all cases, however, we will ensure that any transfer of your personal data is compliant with the applicable data protection law.
For more information about the safeguards relating to personal data transfers outside of the EEA, please contact our Data Protection Officer: privacy@oppo.com.

How This Privacy Policy Is Updated

We reserve the right to update or modify this Privacy Policy from time to time. We will send you notifications of updates of this Privacy Policy in a form we deem appropriate or post a relevant notice online. This Privacy Policy was last revised on the date identified at the top of this Privacy Policy.
If you would like to exercise your rights or have questions or concerns regarding our Privacy Policy or practices, please contact our Data Protection Officer at the following address:
NO.18 Haibin Road, Wusha, Chang'an, Dongguan, Guangdong, PRC China
Email: privacy@oppo.com

Information about Your Right to Object in Accordance with Art. 21 of the General Data Protection Regulation (GDPR)

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 (1) (f) GDPR. This concerns processing personal data for the purposes of legitimate interests pursued by us or a third party including profiling based on those provisions, cf. Art. 4 No. 4 GDPR.

Should you decide to object to the processing of your personal data, we will stop to process personal data concerning you, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the purpose of establishment, exercise or defence of legal claims.

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