Reflection Investment B.V. Privacy Notice

Last Updated: 26/ 04/ 2022

Summary

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.

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, online services, after-sales services we provide, etc. (altogether referred to as “Services”). Please read carefully and familiarize yourself with our privacy practices before using our Services or providing your personal data.

This Privacy Notice will help you understand the following:

I. Responsibilities

II. How and What Types of Personal Data We Collect

III. How We Use Your Personal Data

IV.  Legal Bases for the Processing of Personal Data

V. How We Use Cookies and Similar Technologies

VI. How Long We Keep Your Personal Data

VII. How We Disclose Your Personal Data

VIII. How Your Personal Data Is Transferred Globally

IX. How We Protect Your Personal Data

X. Your Rights Regarding Your Personal Data

XI. How We Process Children’s Personal Data

XII. Third-Party Websites

XIII. How This Privacy Notice Is Updated

XIV. Contact Us

I. Responsibilities

Reflection Investment B.V. and its affiliated companies (hereinafter referred to as "we") a company located in Hofplein 20, 3032AC Rotterdam, is committed to protecting and respecting your privacy.

We provide Services for OPPO products and are the controller of personal data processed in connection with providing our Services to you, which means that we decide on the means and purposes of the processing of your personal data.

II. How and What Types of Personal Data We Collect

The term personal data follows a very broad understanding 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. you provide your personal data to us directly, 2. we obtain certain personal data automatically when you interact with our Services, such as information about how you interact with our Services or us and/or 3. we obtain certain personal data about you from third parties.

The personal data we collect depends on the environment in which you interact with us, 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 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 on your purchase/return/refund or other request 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.

· 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, coupons or other competitions, participate in promotional or marketing activities organized 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 clicked a contained link).

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 the use of our Services—in particular, when you use your device. The personal data we may collect in particular includes the following:

· Device information: This may include 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 settings of the device used to access the Service.

· Other information about your use of the Service: This may include the version of the application or browser type being used, language setting, IP address, device type, IMEI, the website visited and how you interact with the content provided through the Service.

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 activity from 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 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. 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 anonymized data.

We collect non-personal data to understand users’ preferences, improve our operational efficiency and optimize 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 our Services, process your orders or fulfil the contract between you and us;

· to activate Services you have purchased and your warranty service;

· 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 analyze the customer market on the basis of the country where the users use our Services;

· to analyze the efficiency of our business operations;

· to provide you with personalized Services and to recommend and display content and advertisements tailored to you on our Services; 

· to allow and manage your participation in prize drawings, contests or similar promotional activities held by us and to deliver the prizes;

· to communicate with you and reply to your questions or comments submitted to our email or through our online platforms, including social media accounts;

· 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, such as to improve the functional experience of our Services, or improve them in terms of user-friendliness, operational performance, functions and design;

· to pursue or defend against legal claims; and

· 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 about that and ensure that the use of your personal data complies with the law.

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. 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 based on your consent. We may require your consent in connection with our promotional activities in particular, such as sending you promotional messages. 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 our Services, process your orders or fulfil the contract between you and us;

· to activate Services you have purchased and your warranty service;

· to allow and manage your participation in prize drawings, 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: We may be obliged to process personal data to comply with our legal obligations, for example where we are required to retain data for tax law or commercial purposes.

4. Legitimate interests: The processing of your personal data may also be necessary for our legitimate interests. Such cases may include the following in particular:

· to conduct customer surveys in order to enhance your user experience;

· to analyze 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 analyze the efficiency of our business operations;

· to provide you with personalized Services and to recommend and display content and advertisements tailored to you on 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, improve and develop our Services, including the security features such as to improve the functional experience of our Services, or improve them in terms of user-friendliness, operational performance, functions and design;

· to pursue or defend against legal claims.

Where we process your personal data in reliance on such grounds, we will only do so where we have appropriately assessed and balanced our interests against your right to privacy.

V. 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 tag and web beacons (together “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, to monitor and analyse how you use and interact with our Services so that we can continue to improve them (such as to evaluate the information on how often you use the Services, the events that occur within our Services and where an application was downloaded), We do not link the information we store within the analytics software to any personal data you may submit within our mobile applications.

We and our third-party partners also use Cookie to analyze trends, administer the websites, track users’ movements around the websites and to 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 (e.g., html pages, graphics, etc.), operating system, date/time stamp and/or clickstream data.

4. How Long Will Cookies Stay on Your Device?

Session cookies – such Cookies will only last until your browser is closed and will not be stored on your device. Session Cookies are generally used to track the pages on a site that you visit so that information can be customized in relation to a specific visit to a page of the website.

Persistent Cookies – such Cookies will be stored on your device until you actively choose to delete them or when each Cookie reaches its expiry date. Such Cookies can be used to store your preferences when you use our website.

5. Third-Party Tracking and Online Advertising

We partner with third parties to display advertisements on our websites and applications or to manage our advertisements on other sites. Our third-party partners may use cookies or similar tracking technologies to provide advertisement 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.

6. 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 below instructions on how to manage cookies on certain popular 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 on your browser, we will respect your choice.

VI. How Long We Keep Your Personal Data

We will only store your personal data for as long as necessary to achieve the purpose of collection as 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 (e.g., for tax and commercial law reasons), we will delete the personal data after the end of this storage period.

After the expiry of the aforementioned retention periods, we will delete or anonymize 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 unauthorized 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 store your email address in a blacklist to ensure that you will not receive any further communication.

VII. How We Disclose Your Personal Data

At times we may make certain personal data available to other companies that are controlled by or under common control with us (“Affiliates”) and other third parties that work with us in order to provide Services to you. Your personal data will not be shared with third parties for their own independent marketing purposes. We may share your personal data with:

· Affiliates: Your personal data may be shared with our Affiliates for purposes of rendering our Services to you. If the Affiliates wish to change the purpose of processing, they will ask for your consent, unless another lawful basis exists.

· Service Providers and Partners: Some of our Services will be provided with the help of third parties. We may also share some personal data in particular with our partners to provide better Service to you and to improve your user experience. We may also rely on service providers for identifying and serving targeted advertisements, providing mail services, providing tax and accounting services, contest fulfilment, web hosting or providing analytic services. Any such service providers will – by appropriate data processing agreements – be bound to only process personal data on our 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 with 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 agencies’ 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 the one 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.

VIII. How Your Personal Data Is Transferred Globally

1. We may transfer your personal data to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and that does not provide for an adequate level of data protection as the country in which you usually reside in.

2. 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 sufficiently safeguarded.

3. In case your personal data is transferred to jurisdictions located outside the European Economic Area (“EEA”), we will ensure that appropriate safeguards exist and are taken, 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 recognized as providing a sufficient level of protection for your personal data.

4. For more information about the safeguards relating to personal data transfers outside of Europe, please contact us at privacy@oppo.com.       

IX. 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 organizational measures in accordance with industry standards to protect the personal data collected in connection with our Service and prevent it from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. However, please note that although we have taken reasonable measures to protect your personal data, no websites, internet transmissions, computer systems or wireless connections are absolutely secure. In particular:

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 thereof.

X. Your Rights Regarding Your 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.   

· The right to restriction of processing: You have the right, in certain circumstances, to ask us to restrict how we process your personal data, such as where the accuracy of the personal data is contested by you, for a period of time enabling us to verify the accuracy of that personal data. We will keep just enough or process such data necessary for us to make sure we respect 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 concerning 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.

 2. If you wish to make a request, please contact us using the “Contact Us” section.   

XI. How We Process Children’s Personal Data

1. Our Services are mainly adult-oriented. A child should not use our Services without his/her legal guardian’s consent. We treat anyone under 18 years old (or equivalent minimum age for full legal capacity in relevant jurisdiction) as a child.

2. When we find that a child’s personal data is collected, we will delete the relevant 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.

XII. Third-Party Websites

1. Our 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 will lead you to access our official social network accounts (e.g., Facebook, Instagram, LinkedIn, Twitter and etc.) where you can view marketing or promotional information published by us.

2. We do not control third-party privacy and data protection policies and do not accept any responsibility or liability for their policies. At the same time, such third parties are not bound by this Privacy Notice. Before submitting personal data to third parties, we therefore strongly recommend that you refer to the privacy protection practice of such third parties.

XIII. 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.

XIV. Contact Us

If you have questions or concerns regarding our Privacy Notice or practices, please submit your request through:

· Email: privacy@oppo.com

· Postal Address: Hofplein 20, 3032AC Rotterdam