privacy

To help you understand how we process your personal data, we have prepared a brief summary of our Privacy Policy. For more details, please see the full version of the Privacy Policy below.

Key Points	Summary
Who is collecting and using your data?	Guangdong OPPO Mobile Telecommunications Corp., Ltd.
Information We Use	We process information about you that you directly provide to us or that we collect when you use our products and services. We may also receive information about you from third parties.
What we use it for	We will always use your personal data only when we have a lawful basis to do so such as to provide you with products and services, for our legitimate interest or with your consent. We may also process your information when you participate in promotional activities such as prize draws.
How long we keep your data	We will not keep your information for longer than we need it. In most cases, we will keep your information only for as long as it 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 products or offers that you may be interested in. If we need your consent to do that we will only do that with your consent and you can opt out of such marketing communications at any time.
Sharing Your Information with Third Parties	We may share your information with other companies in the OPPO group, with 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 security of your data very seriously. We have implemented various organisational and technical measures to protect your information.
Your Rights	Under data protection legislation you have certain rights, including the right: • to access a copy of your information or transfer it in a standard format • to request that we delete or update inaccurate information • to withdraw your consent • to object to our processing of your information • to complain to the relevant regulator if you think that we have infringed any of your rights.
Children	Our products and 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 information to other countries. We will ensure that appropriate legal safeguards are in place for such transfers.
Updates	We may update this Privacy Policy from time to time and will notify you of any updates.
Contact Us	If you have any questions, you can contact us at privacy@oppo.com.

Guangdong OPPO Mobile Telecommunications Corp., Ltd., a company located at NO.18 Haibin Road, Wusha, Chang'an, Dongguan, Guangdong, PRC China, and its affiliated companies (hereinafter referred to as "OPPO",or "we") or are committed to protecting and respecting your privacy.
OPPO is a "data controller" within the meaning of EU General Data Protection Regulation n°2016/679 of 27 April 2016 (GDPR). This means that we are responsible for deciding how we collect and process your personal data, as well as complying with the provisions of GDPR in doing so.
Therefore, we developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data while you are using our Websites or mobile devices or through our mobile applications or services. Please read carefully and familiarize yourself with our privacy practices before using our products (or services) or providing your personal data.
This policy will help you understand the following:

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.

How We Collect and Process Your Personal Data

OPPO collects data to improve operational efficiency and to optimize our Websites and your product experience. Our channels for collecting personal data include: (1) you provide your data to us directly, (2) we obtain certain data about how you interact with our products, and/or (3) we obtain certain data about you from third parties.
The data we collect depends on the environment in which you interact with OPPO, the choices you make, including your privacy settings and the products and features you use. It is worth noting that we usually treat the shipping area recorded on the mobile phone box as the actual location where your phone is used and comply with local laws and regulations, including those for data protection.
1. Personal Data We Collect
(1) Information Directly Provided by You
The services we provide for you require you to provide information directly to us. For instance:
a.Filling out a warranty card/electronic warranty card requires you to complete a personal profile. In these services, we may ask you to provide personal data to set up a personal profile. Types of personal data include name, address, mobile number, device ID, model of phone, etc.
b. If you order products from us, request a return or refund, or use a paid service, we may collect your delivery details, bank account number, credit card details, billing address, information for credit check and other financial information, contact and communication records , etc., so we can process your order.
c.Some of our services allow you to communicate and share with others. The communicated or shared content may be transmitted through and stored in our system.
d.Face and Fingerprints Recognition enables rapid unlocking of your device with your pre-recorded facial or fingerprint information. To achieve this function, you will need to provide your facial information or your fingerprint information from different angles. Such information will only be stored locally within your device and not upload onto our servers. Therefore, it is impossible for us to disclose such information to any third party or use it for any other purpose.
We may ask you to provide personal data and collect it under other circumstances, such as when you enter in prize draws or competitions, participate in promotional or marketing activities organized by us or our business partners, complete questionnaires, participate in user forums or blogs hosted by us or our business partners. The information you provide helps us design and improve the products and services. We may match your information with third-party data to better understand your needs.
(2)Service Usage Information
In addition to the information you provide, we may also collect information about your use of our services through software on your device and other means. We may collect:
a. Device information — such as device name, device model, region and language settings, device identification number (IMEI number, etc.), device hardware information and status, usage habits, IP address, MAC address, operating system version, and settings of the device used to access the service.
b. Log information — such as when and how long the service is used, search terms entered through the service, and error log information of your device. The Android system is designed in such a way that your error or crash logs will include the overall information when the events occur, which may sometimes include your personal data such as phone number, email address, Google account, Facebook account, etc. However, we have implemented security measures to ensure such information will only be used for error log analysis and not for personal identification or other purposes. We clear such data on a regular basis, usually within 30 days after collection.
c. Location information — such as the GPS signal of the device or information about Wi-Fi access points and cell towers nearby, device location ID, network service provider ID. We will ask you if you want to enable location-based services for the various location-based apps. You can modify the location settings of your device from the device settings (such as changing or disabling the method or server used in location-based services or modifying the accuracy of your location information) to change the location information provided to us.
d. Voice information — for example, audio that we record (and may store on our servers) when you use voice commands to control the device.
e. Album information — for example, to provide you with the function to display photo locations as well as to classify your photos and videos, we need to collect the latitude and longitude information of your photo and video files; when you search for a certain picture, we will collect the term you entered and the number of pictures identified locally .
f. Camera — to ensure the camera app works normally, we collect the operational data (e.g., how many times you use the app), information about your device (e.g. IMEI, device model, IP address, version of operating system), characteristic information about the photos taken (e.g. photosensitivity, number of faces captured) and the information of available space left in your mobile.
g. Other information about your use of the service — such as the version of the application being used, the website visited, and how you interact with the content provided through the service.
Please note that we may cooperate with third-party service providers to achieve the above business functions, for instance, when a third-party service provider provides voice to text conversion services on our behalf, it may receive and store certain personal data. These third parties may not use this information for any other purpose.
(3) Obtaining Data from a Third Party
Where permitted by law, we may obtain data about you from public or commercial sources and may combine it with other information received or relevant to you. If you choose to use our services by logging in with third-party accounts such as Facebook, Google etc., we may also obtain your public information from these services, such as your alias, profile picture, etc.
How We Use Your Personal Data
(1) We may process your personal data on the following legal basis:

a. with your prior explicit consent which can be withdrawn at any time at your request;
b. so that we can perform or carry out a contract with you in relation to our products and/or services;
c. for compliance with a legal obligation to which OPPO is subject; or
d. when necessary for the purposes of the legitimate interests pursued by OPPO or a third party to whom it may be necessary to disclose information. Where we process your information in reliance on such grounds, we will only do so where we have appropriately balanced such interests against your right to privacy.
Examples of related usages are as follows:

· Provide Products and Improve Services. The personal data we collect will be used to provide you with OPPO's products and services, process your orders or fulfil the contract between you and OPPO to ensure the functionality and safety of our products and services, to verify your identity, to prevent and investigate fraud or other improper use.

· Customer Support. We use data to diagnose product issues, repair customer equipment, and provide other customer care and support services. Your mobile user identification information, mobile device’s unique identifier, and geographic location information can be used to activate your warranty service and specific software licenses and may be used to invite you to participate in surveys. We also use this information to improve our products and analyze the efficiency of our business operations. However, we will not use this information to track your location. We may also collect your email address to reply your questions or comments raised in the "Contact Us" section of our websites.

· Product Improvements. We use data to constantly improve our products, including the addition of new features and functionality. For example, we use error reports to improve security features and use usage data to determine cell phone sequencing. We use mobile phone numbers obtained through offline sales channels, electronic warranties, and account registrations to conduct survey and return visit to users in order to improve user experience.

· Commercial Promotion Activities. If you participate in prize draws, contests or similar promotional activities held by OPPO, we will use the personal data you provide to manage such activities.

(2) With your consent, the personal data we collect will be used to personalize the product and to provide you with more tailored services, for example: your information can be used to recommend and display content and advertisements tailored to you on our services, or be used to conduct research and pay return visits to customers. In order to improve our products or services, with your consent, we may match your personal data (including but not limited to the location information ) with third-party data to form a user profile so that we can conduct product development or deliver targeted product information to you (through post, email, phone, or fax).

(3) We will strictly abide by the terms of this Privacy Policy and any updates to it (which will be notified to you in advance) where we use your personal data.

(4) When we want to use the information for other purposes not covered by this Privacy Policy, we will obtain your consent in advance.

(5) We do not take any decisions involving the use of algorithms or profiling that significantly affects you. If certain of our services require us to do so in the future, we will inform you in advance and you can exercise your legal rights as set out in section VI.9 of this Privacy Policy.

III

How Long We Keep Your Personal Data

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

How We Disclose Your Personal Data

1. At times OPPO may make certain personal information available to affiliated companies and other third parties that work with OPPO necessary to provide products and services. Your information will not be shared with third parties for their own independent marketing or commercial purposes.
(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. If the affiliated companies wish to change the purpose of processing, they will ask for your consent again.
(2) Sharing with other third parties: to realize the purposes stated in this Policy, some of our services will be provided by other third parties. We may share some personal data with our partners to provide better services and user experience. When you use the security center app, third party service providers are used to scan viruses and clear space on your phone. Third party service providers are also used to provide you with customer service.
(3) 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 that obtains your personal data to be subject to this Privacy Policy, otherwise we will ask such company or organization to acquire your authorization and consent again.
2. 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.
We may also disclose your personal data if it is compulsorily required by laws, such as to comply with a subpoena or other legal proceedings, legal actions or government agencies, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.

How We Protect Your Personal Data

1. We have taken reasonably practical and technical measures to protect the collected information related to the service. However, please note that although 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 unauthorized access, public disclosure, use, modification, damage or loss. We take all reasonably practical measures to protect your personal data. In particular:
(1) We will de-identify your personal data to mitigate the risk that other organizations or individuals may identify you on the basis of that personal information. We use SSL to encrypt many services. We review practices regarding information collection, storage and possessing (including physical security measures), to prevent unauthorized access.
(2) We only allow OPPO employees and personnel of authorized 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 for us. Therefore, we endeavor to ensure the security of your personal data and implement measures such as full security encryption during storage and transmission to prevent your information from unauthorized access, use, or disclosure. At the same time, no one can access the specific content of some encrypted data except the users themselves.
(4) When transmitting and storing your personal data of special categories, we use security measures such as encryption. We use technical measures to process your personal biometric information before storage. For instance, we store only the essential components of personal biometric information.
(5）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.
(6) We conduct security and privacy protection training, testing and other activities to enhance employees’ awareness and proficiency of personal data protection.
(7) We use international and industry-recognized standards to protect your personal data and actively pass relevant security and privacy protection certifications.
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

OPPO will respect your legal rights to your personal data. Below are the rights that you have under law, and what OPPO does to protect those rights. Please note that for the sake of security, we may ask you to verify your identity before processing your request.
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: If you wish to access your personal data, you can access the information you provided by contacting our Data Protection Officer: privacy@oppo.com.
3. The right to rectification: If you find that your personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications. You can rectify your information. You can rectify your information by contacting our Data Protection Officer: privacy@oppo.com.
4. The right to erasure: You can submit a request to us to delete personal data if we do not have a legal reason to continue to process and hold it. You can delete your information by contacting our Data Protection Officer: privacy@oppo.com.
5. The right to restriction of processing: You have the right to ask OPPO to restrict how we process your 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. You can realize your right to restriction of processing by contacting our Data Protection Officer: privacy@oppo.com.
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. For example, if you decide to switch to a new provider, this enables you to move copy or transfer your personal data easily between our IT systems and theirs safely and securely, without affecting its usage. You can exercise your right to data portability by contacting our Data Protection Officer: privacy@oppo.com.
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 statistical purposes. You can object OPPO processing your data by contacting our Data Protection Officer: privacy@oppo.com.
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 our Data Protection Officer: privacy@oppo.com.
9. The right to object automated individual decision-making: You have right not to be subject to a decision based solely on automated processing, including profiling. If these decisions significantly affect your lawful rights, you are entitled to ask for an explanation by contacting our Data Protection Officer: privacy@oppo.com, which we will respond to and take appropriate measures to resolve, as necessary.
10. 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 your national data protection authority.
We will respond and reply to your above requests as soon as possible, and generally no later than one month upon receipt of your request. (If necessary and as permitted by law, we may extend it by an additional two months. We will inform you the reason for the extension within the aforementioned one month, for example, if the request is complex or involves a large volume of data). If you are not satisfied with the response you received, you can refer the complaint to the relevant regulatory authority in 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. Our products, websites and services are mainly adult-oriented. A child should not use our products, websites and 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.

VIII

Third-Party Service Providers and Their Services

1. OPPO websites, products, applications, and services may contain links to third-party websites, products, and services. You can choose whether to access websites, products and services provided by third parties or not. For example, the "follow us" function in the official website will lead you to access to our official accounts in social network platforms (e.g. Facebook, Instagram, LinkedIn, Twitter and etc.) where you can be aware of the marketing or promotional information published by OPPO.
2. We have no control over third-party privacy and data protection policies and such third parties are not bound by this Privacy Policy. Before submitting personal data to third parties, please refer to the privacy protection practice of such third parties.

How Your Personal Data Is Transferred Globally

1. In principle, the personal data collected and produced within the territory of European Union is stored within the territory of the European Union.
2. We provide products and services based on our resources and servers around the world. This means, in compliance with applicable laws, your personal data (e.g., IMEI, mobile phone number, email address, and user name) might be transferred to or accessed from jurisdictions outside of the jurisdiction where you use our products or services.
3. In case your personal data is transferred by OPPO to countries located outside of the European Economic Area (EEA), we will ensure that appropriate safeguards are taken, such as:
(1) the recipient of the personal data is located within a country that benefits from a full "adequacy" decision of the European Commission;
(2) the recipient may have adhered to binding corporate rules (only for intragroup transfers);
(3) the recipient has signed a contract based on "model contractual clauses" approved by the European Commission, obliging them to protect your personal data; or
(4) where the recipient is located in the US, it is a certified member of the EU-US Privacy Shield.
In the absence of the above appropriate safeguards, we will ask you for your explicit consent for cross-border transmission of your personal data. In the meantime, security measures such as encryption or de-identification will be adopted for the safety of your personal data.
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 update of this Privacy Policy in a form we deem appropriate. If you have provided us an email address, we will notify you updates (and seek your consent on such updates if you are an Indonesian resident) by email before such updates take effect. If we do not have an email address of yours, we will post a notice on our website or send push notifications to you through our devices about the aforesaid updates.

Contact Us

If you 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
Our EU representative:
OROPE Germany GmbH
Address: 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.

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.