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Please take a moment to familiarize yourself with this Policy before providing your personal data to ZTE.
This Policy helps you understand the following:
1. Personal Data We Process
2. Our Purposes and Legal Basis for Processing Your Personal Data
3. How We Share, Transfer, and Disclose Your Personal Data
4. Cross-Border Transfer of Your Personal Data
5. How You Manage Your Personal Data
6. How We Protect and Retain Your Personal Data
7. How We Process Children's Personal Data
9. Updates to This Policy
10. Contact Us
If you have any questions about this Policy, you may contact us through the channel provided in Article 10 of this Policy.
Personal data refers to any data that, either recorded electronically or otherwise, can be used on its own or jointly with other data to identify a natural person or reflect the activities of the natural person. You may directly or indirectly provide us with such data when you use our products, services or websites, or when you interact with us. For example, you directly provide us with your personal data when calling our hotline, creating a ZTE account, or participating in our branding activities. In addition, we may indirectly collect your personal data via website's cookies and other technologies. In some cases, you may opt not to disclose your personal data to ZTE. However, not providing ZTE with certain personal data may make it impossible for us to provide you with certain products or services or respond to an issue that you have raised.
Based on your cooperation with ZTE and the products and services we provide (or may provide) to you, ZTE will process the following personal data about you and those who are related to you:
(1) Account data
To create a ZTE account, you need to provide your phone number or email address for authentication. You may also provide additional data such as your profile picture, nickname, and date of birth. If you choose to log in to ZTE's business platform by using a third-party account, such as your Facebook, Twitter, or WeChat account (you may opt not to access our products or services by these means), we will, after obtaining your authorization, collect your authentication data from a third-party server. Our server will keep your access tokens provided by third-parties, and such access tokens can be shared among various services that you use to avoid logging in to third-party servers repeatedly.
Some services are designated for specific device models (such as mobile phones of specific models) or applications. Under such circumstances, we will, before and during your use of our services, collect device-related data to provide you with accurate services. The information to be collected includes your device model, system version, unique device ID, network status, sign-in and access information, error information, and IP address, etc.
When you use ZTE's mobile device software with location services (for example, for locating family members or finding your mobile phone) enabled, we may, with your consent, collect and process data related to your location or the location a mobile device. We will not, however, keep collecting your location data to track your whereabouts.
(4) PO-related data
When you make purchases on our website, you will be asked to provide your address, name, phone number, postcode, and information about the products or services you have purchased once a PO is generated by our systems.
When you require us to provide after-sales services or report any problem you come across to us when using our products or services, you will be asked to provide the related data that is necessary for us to provide you with after-sales services. The data to be collected includes your name, phone number, device-related data, and fault descriptions. You may provide your personal data to us according to the type of services that you require. For instance, if you need after-sales mailing services, you need to provide us with your name and address.
(6)Service access data
By using the data collection feature for products, we will collect data related to your access to ZTE's services, including the access time, search and query history, network ID, and IP address. Pursuant to relevant laws and regulations, we may also obtain your personal data from lawful public and commercial sources for the purpose of providing customized services.
For certain services provided by ZTE, such as the cloud backup and cloud disk services provided by ZTE's apps, your personal data such as the contact list, messages, and photos may be stored in ZTE's servers. You may reject the request of providing such data. However, if you do so, you may not be able to use the related services, or only be allowed to use part of the functions of the services. In addition, when you submit a job application on our website, you will be asked to provide your resume.
ZTE processes your personal data only for specific purposes, and only processes the personal data that is necessary for fulfilling such purposes. Based on your relationship with ZTE and the products and services we provide, we may process your personal data for the following purposes on specific legal basis:
●To fulfill a purchase order;
●To create and manage your account;
●To register you or your devices for service providing;
●To provide you with required services or functions;
●To provide you with subscription services;
●To provide you with after-sales maintenance services for your devices;
●To provide you with online consultation services, and to allow you to make suggestions or lodge complaints;
●To send you important security or upgrade service notices;
●To analyze service access data to improve our products and services;
●To provide you with excellent user experience when you use our websites or products;
●To check your error logs and conduct troubleshooting;
●To improve our loss prevention and anti-fraud plans;
●To comply with and implement applicable legal requirements;
●Other purposes based on your consent.
If we want to (1) use the collected data for purposes not specified in this Policy; (2) or use the collected data for purposes other than those you consented to, we will ask for your consent in advance. You may decide whether to give your consent to such changes. You may also withdraw your consent at any time in accordance with applicable laws and regulations. However, if you do so, you may not be able to use all or part of our products or services.
Pursuant to applicable laws, we may collect and use your personal data without obtaining your prior consent in the following situations:
(1) The case is directly related to national security and national defense security.
(2) The case is directly related to public safety, public health, and major public interests.
(3) The case is directly related to any criminal investigation, prosecution, trial, and execution of a court judgment.
(4) The case is directly related to the protection of vital interests (such as personal safety) of a data subject or other individuals.
(5) Data processing is necessary for legitimate news reports.
(6) Other situations in which data processing is required by applicable laws and regulations.
To ensure the security of your personal data, we always adhere to the principle of data minimisation, and share, transfer, or disclose your personal data in accordance with applicable laws and regulations.
(1) As a global company, we may share your personal data inside ZTE if necessary, so that we can provide you with services in a timely manner.
(2) We may also share necessary personal data with our business partners in accordance with the minimisation principle, so that we can provide you with the related services.
(3) If personal data transfer is involved in a merger, acquisition, bankruptcy liquidation, asset transfer, and other similar transactions, we will require the new companies or organizations that hold your personal data to continue to comply with the requirements, commitments and security measures of this Policy. For instance, the new companies or organizations should not use your personal data for purposes other than those mentioned above. Otherwise, we will require these companies or organizations to obtain your consent.
(4) We may also disclose your personal data to law enforcement agencies or government authorities if we believe that such disclosure complies with applicable laws or related legal proceedings.
We sign strict confidentiality agreements with companies, organizations, and individuals with which we share personal data, and require them to process your personal data in accordance with our instructions, this Policy, and other relevant confidentiality and security measures. If the country with which we share, and to which we transfer or disclose your personal data does not have applicable data protection laws that have the same requirements as those in the country where you are located (for instance, your personal data is transferred from the European Economic Area to a country that has no applicable data protection law), we will handle the related issues according to Article 4 of this Policy to guarantee legitimate transfer and security of your personal data.
ZTE is a global company. We usually process your personal data in the country or region where we carry out business activities and provide you with our products or services. However, we may also transfer your personal data to other countries or regions that may have different laws on the protection of personal data. Wherever we may transfer your personal data, we will, pursuant to applicable laws, inform you of the destination, recipient, and other related information in a timely manner and take appropriate measures to comply with this Policy and applicable local laws. For instance, to transfer your personal data, we will ask for your prior consent or sign a necessary data transfer contract with you. For example, we will sign the Standard Contractual Clauses (SCC) approved by the European Commission, and you may click here to obtain a copy of it.
Pursuant to this Policy, we will collect and use your personal data only for the purpose of realizing the functions of our products or services. You may access, modify, or delete the registration information and other personal data you provide to us while using our services. The scope and method of your access to, and modification or deletion of personal data depend on the specific services you use.
When submitting personal data to ZTE, you need to make sure that all personal data you provide to us is correct. If your personal data has changed (for example, your address has changed), you are obliged to update your personal data in a timely manner.
To the extent permitted by applicable laws, you may have the right to, when using our services: (1) access your personal data we maintain; (2) update or correct any personal data that is incorrect; (3) object to our use of your personal data; and (4) require to obtain restriction of processing, or require us to delete your personal data.
If you want to exercise the related rights, you may contact ZTE's Data Protection Compliance Dept. by visiting the Data subject rights response notice page. We will ensure the security of your personal data when you exercise your rights.
When you request to exercise the above rights, we may need to verify your identity to ensure the security of your personal data. Due to technical constraints, and legal or regulatory requirements, we may not be able to meet all of your requirements, but we will respond to your request within a reasonable period of time. Generally, we do not charge for your requests, but we do charge for requests with extra requirements.
If you have any questions about accessing and managing your personal data, you may contact us through the channel provided in Article 10 of this Policy. If you believe that our processing of your personal data does not comply with applicable data protection laws, you may contact local data protection authorities for help. Please click here to obtain the contacts of the data protection authorities in the European Union.
ZTE strictly abides by the "storage limitation", "data minimisation", and "accuracy" principles for personal data protection. For the retention of personal data, ZTE takes appropriate security measures to retain your personal data in a secure manner.
We take appropriate physical, management, and technical measures, such as the establishment of the access control system and monitoring system, encryption, anonymisation or pseudonymisation, employee training, to protect your personal data against unauthorized access, use, disclosure, modification, damage, loss, or other forms of illegal processing. We have also developed a business continuity plan to ensure that services can be provided continuously. Our information security policies and procedures are designed in strict accordance with international standards, and reviewed and updated regularly. In addition, we invite third-parties to inspect our security measures to ensure that our security measures meet the requirements for our business, technical changes, and supervision. ZTE headquarter in China and some of its subsidiaries have passed the ISO 27001 information security certification, and can effectively protect your personal data. In May 2020, ZTE became the first company to be awarded the ISO/IEC 27701:2019 (Privacy Information Management System) certification for its 5G products. This indicates that ZTE is capable of providing global customers with secure and reliable 5G products and solutions that comply with relevant requirements, and delivering high-quality 5G networks.
In general, we retain your personal data only for the shortest time that is required for realizing the purposes stated in Policy, but the data retention period may vary in different scenarios, and for different products and services. The standards ZTE uses to determine the retention period are as follows:
●Special requirements of relevant laws and regulations in a specific field
●The time required to achieve data processing purposes in business activities
●The needs to carry out business activities or the duration of the cooperation between ZTE and the data subject
●The products and services being provided
●Maintenance of the corresponding transaction and business records
●Implementation of the related service agreements or this Policy
●Safeguarding of public interests
●Guarantee of personal or property safety or other legal rights of our customers, affiliates, other users, and employees.
Usually, your personal data will be stored in the country where the business activity is conducted. However, your personal data may also be retained in a place outside your country, depending on the location of our data center. We will take appropriate measures to guarantee that your personal data we collect would be processed in accordance with this Policy and the applicable laws of the place where the data is retained. To the extent permitted or required by law, we will inform you of any loss of, abuse of, or alteration to your personal data, which may give rise to major risks, so that you can take appropriate measures to safeguard your rights.
ZTE takes specific protection with regard to children’s personal data. ZTE will not collect children's personal data without prior consent of their parents or guardians. If children's personal data is collected with prior consent of their parents or guardians, we will only use or disclose such data as permitted by law, and with the explicit consent of the children's parents or guardians. If we accidentally collect a child's personal data without prior consent from the child's parents or guardians, we will delete the data as soon as possible.
A Cookie is a small file of letters and numbers. With your consent, we will store the Cookies in the memory or hard drive of your computer or mobile device, and use such Cookies as an identifier of your computer or mobile device.
Cookies generally include "session Cookies" and "persistent cookies". Session Cookies help you effectively browse our website and enable the website to keep track of your access from page to page, so you don't get asked for the same information you've already given to the site. For instance, if you are redirected to another web page from a website you have already logged in to, your shopping chart won't be emptied. Session Cookies are stored in the temporary memory and are deleted when the browser is closed. Persistent Cookies on your device allow our website to remember your preferences and settings such as the language, country/region, and font size you have selected. This means that you do not need to reset them for every visit.
You may clear all the Cookies on your computer. However, if you do so, you have to change settings every time you visit our website. Most browsers provide the option of blocking cookies. If you want to find out how to manage Cookie settings for your browser, you may refer to the introduction issued by browser developers or look for relevant information on the Internet. For more information about Cookies, please visit: AboutCookies.org.
In addition to Cookies, we may also use web beacons, pixel tags, and other similar technologies on our website. For example, when you receive an e-mail from ZTE, it may contain an account activation link with the aforementioned technologies. If you click the link, ZTE will track your visit to help us learn about your preferences for products and services and improve our customer services. A web beacon is a transparent graphic image embedded in a website or an e-mail. We use pixel tags in e-mails to find out whether an e-mail has been opened. If you do not want to be tracked in this manner, you can change the settings of your mailbox or unsubscribe from the related service website of ZTE at any time.
If you want to learn more about the security of Cookies, please refer to the Cookies Policy.
If you have any questions about this Policy, or have any requests, or need to consult us about your personal data, you may contact us at firstname.lastname@example.org or following mailing information. We will respond to your request within 30 days.
To: Data Protection Compliance Dept. of ZTE Corporation
Address: No. 55, Hi-Tech Road South, Shenzhen, P.R. China
If you believe that we fail to process your personal data in accordance with applicable data protection laws, you may turn to data protection authorities for help.
For the contacts of the data protection authorities in different member states of the European Union, please visit: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
For the contacts of the personal data supervisory authorities in other areas, you may consult the corresponding local governments.
For more information about ZTE's data protection, please click here.
This Policy may change. Without your consent, we will not cut down your rights under this Policy.
We will post any changes to this Policy on this page. For major changes, we will also provide you with direct notifications (including notifications for some services, which will be sent by e-mail to describe the specific changes to this Policy).
Major changes mentioned in this Policy include but are not limited to the following situations:
(1) Our service model has changed, such as changes in the purpose of processing personal data, the type of processed personal data, and the mode of using personal data;
(2) Major changes have taken place in the ownership structure and organizational structure, such as changes in owners caused by business adjustment, bankruptcy, or mergers and acquisitions;
(3) The major parties with which personal data is shared, and to which personal data is transferred or disclosed have changed;
(4) Your rights to participate in the processing of personal data and the way you exercise your rights have changed;
(5) Our department responsible for personal data security, our contacts, or the channel to lodge a complaint has changed;
(6) A major risk is indicated in the data security impact assessment report.
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