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PRIVACY POLICY | TERMS | HTC UNITED STATES
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PRIVACY POLICY
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This privacy policy (the “ Policy ”) describes how HTC Corporation and our
related companies (“ HTC ” or " we / our / us ") collect, use and share personal
information that we collect from you as a user of HTC websites, devices,
applications and services (together, the “ Services ”). HTC strives to comply
with all laws that apply to our handling of information collected about you.
This Policy is subject to those laws that may be more strict than as outlined
here. The term “ related companies ” means HTC Corporation, HTC America, Inc.,
HTC Europe Ltd. Inc and HTC affiliates which collect and process your personal
information in the countries you are located.
We may add to, or amend, this Policy with other notices. We may also post
different privacy policies for some Services and, when we do so, this Policy
does not apply. For example, where applicable, separate policies apply to
information collected from your device through Tell HTC Usage and Tell HTC Error
Reporting.
As described in this Policy, you have the right to object to us using, sharing
or carrying out any activity with your personal information (in certain
circumstances) including using your personal information for direct marketing
(i.e. receiving emails from us notifying you about other services which we think
will be of interest to you or being contacted with varying potential
opportunities). Contact us at any time with the details provided in the contact
section below for more detail and to exercise these rights where applicable.
NOTE: Your wireless operator, mobile operating system provider and/or
third-party applications, toolbars, services, “plug-ins”, social media platforms
and websites may also collect, use and share information about you and your
device and your usage. HTC’s privacy policies do not cover any third parties,
their products, actions or their services. HTC does not control how third
parties collect, use or secure your data. For information about third-party
privacy practices, please consult their privacy policies. Only download
applications from, and interact and connect with, reputable third parties.
* INFORMATION YOU GIVE US
* INFORMATION WE AUTOMATICALLY COLLECT
* INFORMATION COLLECTED THROUGH THIRD PARTY
* OTHER INFORMATION FOR ADVERTISING
* USE OF YOUR PERSONAL INFORMATION
* MORE ABOUT LOCATION DATA
* SHARING OF PERSONAL INFORMATION
* WHERE WE STORE YOUR INFORMATION AND TRANSFER OF YOUR INFORMATION
* RETENTION
* YOUR RIGHTS
* YOUR CALIFORNIA RIGHTS
* INFORMATION CHOICES AND CHANGES
* PROTECTION OF YOUR PERSONAL INFORMATION
* CONTACT INFORMATION
* CHANGES TO THIS PRIVACY POLICY
1. INFORMATION YOU GIVE US
When you use our Services, you may provide information to us, both online
and offline, including, for example:
* Contact Information: your name, email address, street address, phone
numbers;
* Files: photos, and videos;
* Demographics: gender, company or organisation name, occupation, language
preference, city, country, postcode, area code, time zone, etc.).
* Payment Information: If you purchase Services from us, we may also store
your credit card numbers or other payment information, as required.
We may hold and associate any information you provide us with together with
information gathered from other sources, including the social accounts that
you choose to associate with your use of the Services, or with information
we receive from other companies.
2. INFORMATION WE AUTOMATICALLY COLLECT
When you use the Services, we automatically collect some information. We
may collect information about your usage of and activity on our Services.
When you visit our websites, information we may automatically log includes,
for example, your operating system, Internet Protocol (IP) address, access
times, browser type and language and the website that you visited before
visiting our website. When you use our devices, download and use our
applications, or access the Services from your device, we may also log
information related to your device and your use of our applications and
Services depending on your device and application settings. We may log, for
example, the date you activate your device, your geolocation, phone service
provider, phone number, device type, serial number, device identifiers
(e.g., IMEI, MEID, serial number, CID, MID and MCC ID Number or SIM card
ID), the types and versions of mobile operating systems on your device,
applications and software you install and use and how you use them, content
you view or use and time-stamped logs of data exchanges.
If you use the Services to back up and store your device data and content
with an independent third party service provider, we will collect certain
information needed to help restore your data and content to your device,
such as your device settings and the names of files and applications that
you wish to back up.
We may also log information about you using web beacons, cookies, local
shared objects (LSOs) and similar methods as described in our cookie policy
. We may automatically link any of the information that we collect about
you using these methods, to information that you provide us and any other
information that we collect about you in accordance with this Policy.
For the United States:
https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html#117118
For the EU: https://www.youronlinechoices.com
Information created or generated . We infer new information from other data
we collect, including generating information about your likely preferences
or other characteristics. For example, we may infer your city, state, and
country location based on your IP address.
Usage Data and Error Reporting. In addition to the information we
automatically collect, as described above, we may collect more detailed
de-identified data about your device usage and error report data about your
device (formerly called Tell HTC Experience and Tell HTC Error Report on
older devices). When you participate in these programmes, you help us to
understand how you use your device and improve HTC devices and other HTC
and trusted partner products and services. HTC may re-identify this data
when appropriate; for example, when you request technical support, choose
to use a specific HTC service or app, or create an HTC Account. To learn
more about usage and error reporting on your device, and/or to change your
option to participate, go to “Settings” on your device. Usage and error
data settings will not affect HTC’s collection of de-identified activation
data or data about specific HTC apps and services you choose to use,
including HTC Account, and are otherwise subject to limitations described
in this Policy.
Others, including third party analytics service providers and third party
ad service providers, as described in the section below, may also
automatically collect the same or similar information about you and your
device when you use the Services, including personally identifiable
information about your online activities over time and across third party
website and applications.
3. INFORMATION COLLECTED THROUGH THIRD PARTY
Some of our HTC e-store is operated by third parties, such as Digital
River. When you purchase products through that e-store you enter into terms
and conditions with Digital River and they have a separate privacy policy
available on the site. Digital River is a data controller in its own right.
Digital River share certain user transaction data with us for our sales
reports or other legitimate purpose as described in this Policy.
4. OTHER INFORMATION FOR ADVERTISING
We may use third-party ad service providers to serve ads in our Services.
We may also use third parties to deliver or help us deliver HTC-branded ads
to you on third-party websites. To deliver these ads, third parties
automatically collect certain information about you and your devices and
your use of the Services. This information may include visits to the
websites and applications of HTC and others, your IP address, your Internet
service provider, and the browser that you use to visit our website. Third
parties may collect information by using cookies as described in our cookie
policy. We may also use your email address to target marketing to you on
social media platforms (in accordance with your marketing preferences on
those platforms).
HTC may use information collected through third-party cookies or beacon in
our Service or email for purpose to serve better ads to you on third-party
websites. We may know when you visit HTC website after you browse such
third-party websites and use the information collected about you to serve
tailored ads to your interests through our Services or third-party service.
5. USE OF YOUR PERSONAL INFORMATION
HTC may use your information, including personal information, as follows:
* To provide and deliver products and Services that you request;
* To understand you and your preferences to enhance your experience and
enjoyment using our products;
* To process the post transaction requested by you, such as refund;
* To send you information related to your requests, queries and purchases,
including confirmations, invoices, technical notices, updates, security
alerts and support and administrative messages;
* To send you marketing communications including about contests,
promotions, rewards, upcoming events and news about products and services
offered by HTC and our selected partners (we do this as per your choices)
and to process and deliver contest entries and rewards. You may also
receive targeted advertising on social media platforms (in accordance
with your marketing preferences on those platforms).
* To operate and improve our websites, products, Services and marketing;
* To respond to your comments and questions and provide customer service;
* To compile information to be able to provide you with a personalised and
customised experience, content, marketing and recommendations across all
our Services (in line with your choices as relates to receiving any
direct marketing communications);
* To link or combine your personal information with other information we
get about your use of other HTC Services and from third parties for the
purposes that we disclose in this policy, including to help understand
you and your needs, and provide you with recommendations, better service
and customised marketing;
* To filter the content to be displayed as part of the Services;
* To compile usage and other statistics and insights relating to the
Services;
* To prevent, investigate and deter against fraudulent, unauthorised or
illegal activity, and ensure network and information security; and
* To facilitate sharing of information and content that you choose to
upload via social media (for example if you choose to upload content on
the HTC forum or other applications, this may be made available for
others to see through such forum).
We rely on different lawful bases for collecting and processing personal
data about you, for example, with your consent and/or as necessary to
provide the products you use, operate our business, meet our contractual
and legal obligations, protect the security of our systems and our
customers, or fulfil other legitimate interests.
* To protect, investigate and deter against fraudulent, unauthorised or
illegal activity.
We may share certain non-personally identifiable information with our
partners, such as advertisers, or developers. For example, we may share an
analytic report which includes aggregate customer usage or other statistics
to show the trend of general use of our products or services.
Where your personal information is necessary for us to be able to provide
you with requested services we make this clear on collection. If you
decline to provide us with this information or object to continued
processing of this information we will be unable to provide such requested
services to you.
If you object to the processing of your personal data for marketing
communication or if you withdraw your consent, we may only process certain
required data (for example, name and email address) in our internal
emailing system in order to ensure the ongoing observance of your objection
or of your withdrawal of consent.
6. MORE ABOUT LOCATION DATA
When you use certain Services, we may collect, process, store and share
your precise location data. This location information may include real-time
geographic location of your device. It may also include the names of places
that you have been, where you choose to “check-in”, to determine, log or
share your location, places that you mark on a map, the geographic
location, dates and other metadata of photos that you’ve taken, routes that
you have travelled, how close you are to other devices, such as
Bluetooth-enabled devices, Wi-Fi routers and services that use those
devices (such as a store’s tracking of your movement for data collection
and marketing purposes) and the dates and times that you were at certain
locations. HTC may share your location data with application providers who
show that they have the right permissions. HTC may associate location data
with personally identifiable or identifying information, such as your
device ID and your account information. Our Services may also collect
precise location data in a de-identified form, and we may share this data
with partners and carriers to improve features and services.
7. SHARING OF PERSONAL INFORMATION
INFORMATION YOU SHARE
The Services may allow you to connect and share your actions, comments,
content and information publicly or with people you specify. You may also
connect to, and share your information on, third-party social media
platforms, websites, applications and services (“Third Party Sharing
Services”) through “plug-ins,” widgets, buttons, and other third party
features made available on and connected with our Services. Please be
mindful of your own privacy needs as you choose who to connect with and
what to share and make public. We cannot control the privacy or security of
information that you choose to make public or share with others. We also
cannot control and are not responsible for any Third-Party Sharing Services
or their actions, including the data that these Third-Party Sharing
Services collect from you and your device, or how they use such data.
Please review the privacy policies of all Third-Party Sharing Services to
understand their privacy practices.
INFORMATION WE SHARE
We may share your personal information as follows where it is lawful to do
so:
With your consent. For example, we share your personal information with ad
network providers where you have given your consent to receive marketing.
We also share your personal information with co-branded partners where you
have consented to this. Our partners’ use of your personal information will
be subject to their privacy policies.
For the purposes of a business deal (or negotiation of a business deal)
involving a sale or transfer of all or a part of our business or assets.
Business deals may include any merger, financing, acquisition or bankruptcy
transaction or proceeding.
For legal, protection, security and safety purposes:
* to comply with laws or regulatory requirements and to respond to lawful
requests and legal processes;
* to protect the rights and property of HTC, our agents, customers and
others, including enforcing our agreements, policies and terms of use and
protecting our network and physical assets; and/or
* in an emergency, including protecting the safety of our employees and
agents, our customers or any other person.
With our subsidiaries and affiliates as needed to provide our products and
services and operate our business.
With service providers and vendors who process personal information for the
purposes described in this Policy as part of services to us and who are
subject to appropriate contractual obligations.
With wireless carriers for their provision of services to you. Their use of
your information is subject to their privacy policies.
We may share aggregated and de-identified data with others for any purpose.
8. WHERE WE STORE YOUR INFORMATION AND TRANSFER OF YOUR INFORMATION
Information that we collect may be stored on your phone or stored on our
servers and transferred to, stored and processed in the United States,
Taiwan, Singapore, People’s Republic of China, United Kingdom, other EU
member state countries (such as Poland) and any other country where HTC or
its service providers maintain facilities, depending on where you use our
product and services.
Where your personal information is transferred from within the EU to
outside the European Economic Area (EEA), security measures and appropriate
safeguards are put in place to protect your information and we ensure that
all transfers of your information comply with applicable data protection
law, and are carried out in accordance with our instructions. We may use
certain legal mechanisms as an adequate safeguard, including the relevant
EU Model Clauses*, with any party (including HTC Corporation) where your
information is transferred to outside the EEA. To find out more about how
we safeguard your information (including obtaining a copy of such
safeguards) in relation to transfers outside the EEA, please contact us via
the details provided in the contact section below.
* EU Model clauses means standard clauses for transfer of personal
information to a controller established in third party countries under
European Commission decision 2001/497/EC of 15 June 2001, as amended by
European Commission decision 2004/915/EC of 27 December 2004, and the
standard clauses for transfer of personal information to processors
established in third countries under European Commission decision
2010/87/EC of 5 February 2010.
9. RETENTION
Information that we collect may be retained for as long as needed to fulfil
the purposes outlined in the “use of your personal information” section
above, or for a period of time specifically required by applicable
regulations or laws such as retaining the information for tax and
accounting purposes.
When determining the relevant retention periods, we will take into account
factors including:
* our contractual obligations and rights in relation to the information
involved;
* legal obligation(s) under applicable law to retain data for a certain
period of time;
* statute of limitations under applicable law(s);
* (potential) disputes; and
* guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer
needed. Contact us if you would like more information on how long we retain
your information.
10. YOUR RIGHTS
Subject to the applicable data protection laws, you may have a number of
rights (subject to certain conditions) when it comes to your information.
Further information and advice about your rights can be obtained from the
data protection regulator in your jurisdiction. You can request to exercise
any of these rights by contacting us through our contact information in
Section 14 of this Privacy Policy.
* The right to object to processing. You may have the right to object to
certain types of processing, including processing for direct marketing
(i.e. receiving emails from us notifying you about other services which
we think will be of interest to you or being contacted with varying
potential opportunities).
* The right to be informed. You may have the right to be provided with
clear, transparent and easily understandable information about how we use
your information and your rights. This is why we’re providing you with
the information contained in this Policy.
* The right of access. You may have the right to request obtain access to
the specific pieces of your information we have collected, and certain
other information (similar to that provided in this Privacy Policy).
* The right to rectification. You may be entitled to have your information
corrected if it is inaccurate or incomplete. You can request that we
rectify any errors in information that we hold.
* The right to erasure/deletion. Subject to certain exceptions, this right
enables you to request the deletion or removal of your information that
we hold.
* The right to restrict processing. You may have rights to ‘block’ or
supress further use of your information. When processing is restricted
pursuant to these rights, we can still store your information, but will
not use it further. We keep lists of people who have asked for further
use of their information to be ‘blocked’ to make sure the restriction is
respected in the future.
* The right to data portability. You may have rights to obtain and reuse
your information for your own purposes across different services. For
example, if you decide to switch to a new provider. This is not a general
right however and there are exceptions.
* The right to lodge a complaint. You may have the right to lodge a
complaint about the way we handle or process your information with your
national data protection regulator.
* The right to withdraw consent. If processing of your personal data is
based upon your consent, you have the right to withdraw your consent at
any time (although if you do so, it does not mean that anything we have
done with your personal data with your consent up to that point is
unlawful). You can withdraw your consent to the processing of your
information at any time.
Where your personal information is collected within the European Economic
Area (EEA), you can contact us through the contact information of HTC
Europe Co. Ltd to exercise any of those rights described above.
11. YOUR CALIFORNIA RIGHTS
If you are a California resident and the processing of personal information
about you is subject to the California Consumer Privacy Act (“CCPA”),
beginning January 2020 you have certain rights with respect to that
information. In particular, you have a right to request the following
information to be provided to you:
(1) The categories and specific pieces of personal information we have
collected about you.
(2) The categories of sources from which we collect personal information.
(3) The purposes for collecting, using, or selling personal information.
(4) The categories of third parties with which we share personal
information.
(5) For companies that disclose personal information for a business
purpose, the categories of personal information disclosed about you for a
business purpose
(6) For companies that “sell” personal information, the categories of
personal information sold about you and the categories of third parties to
which the personal information was sold, by category or categories of
personal information for each third party to which the personal information
was sold.
You may make a “request to know” by following the instructions below. Note
that we have provided much of this information in this Privacy Policy.
With respect to (5), the CCPA defines “business purpose” broadly; and
because we use service providers for a number of business purposes that
require access to our data systems (such as maintaining the security of our
systems, supplying cloud data storage, and providing customer service), in
the past 12 months we have disclosed for a business purpose all of the
categories of personal information that we maintain.
With respect to (6), note that, although we do not sell personal
information in the traditional sense, the CCPA defines “sell” very broadly,
and some of our tracking, analytics, and advertising activities with third
parties as described in our “ Cookie Policy ” or “ CCPA- Do Not Sell My
Personal Information ” page may be considered a “sale” under that
definition. You also have a right to opt-out from future sales of personal
information, which you can exercise by visiting our “ Cookie Policy ” or “
CCPA- Do Not Sell My Personal Information ” page.
You also have a right to request that we delete personal information under
certain circumstances, subject to a number of exceptions. Finally, you have
a right not to be discriminated against for exercising rights set out in
the CCPA.
For a request to know or a request to delete, contact us at
global-privacy@htc.com or toll free number +1 (888) 914-9661 (PIN: 177
303). You may designate, in writing or through a power of attorney, an
authorized agent to make requests on your behalf to exercise your rights
under the CCPA. Before accepting such a request from an agent, we will
require the agent to provide proof you have authorized it to act on your
behalf, and we may need you to verify your identity directly with us.
12. INFORMATION CHOICES AND CHANGES
Our marketing emails tell you how to “opt out” of receiving further
marketing emails. If you opt out, we may still send you non-marketing
emails. Non-marketing emails include emails about your accounts and our
business dealings with you, and may include a request that you participate
in surveys related to your use of, and satisfaction with, the Services.
You may send requests about your personal information to us through our
contact information below. You can request to change contact choices or
marketing choices and to update, access, delete or make other changes
regarding your personal information or content that you post on the
Services in line with your rights above. We may not honour all such
requests unless required by law.
When you use our Services, we and third parties may give you choices about
use of certain mechanisms for tracking, including tracking of your online
activities over time and across different websites, applications and online
services. We may provide settings on your device that allow you to change
how we, and others, collect certain information about you. Read your
product manual for more information about settings on your device. Many
browsers are set to accept cookies unless and until you change your
settings.
Removing or rejecting our cookies could affect how our websites and
Services work for you and could delete or disable opt-out cookies set by us
and third parties.
Some of our third party ad service providers also provide choices for use
of cookies to deliver ads tailored to your profile and preferences. To
learn more visit:
https://optout.networkadvertising.org/#!/
https://www.adobe.com/privacy/opt-out.html#measure
While we and others give you certain choices, as further outlined in this
Policy, there are many ways in which Web browser signals (including “Do Not
Track” or “DNT”) and similar mechanisms can indicate your choice to disable
tracking, and we may not be aware of nor honour every such mechanism.
Instead, you can use the range of other tools to control data collection
and use, including the controls described in this Policy.
13. PROTECTION OF YOUR PERSONAL INFORMATION
We strive to protect personal information by taking appropriate physical,
technical and organisational measures to help guard against unauthorised or
unlawful access, use, processing or alteration of the personal information
that we obtain from you through our Services and against any breaches or
loss of such personal information, such as anonymization, pseudonymization,
encryption (such as encrypted by Transport Layer Security (HTTPS) during
transmission), restricted access, etc.. Although we take steps to use and
improve various safeguards, no system or technology is completely secure.
If you become aware of a technical vulnerability affecting HTC Services,
please email security@htc.com or visit this website to report it. If you
have a concern related to the protection of personal information or this
Policy, please send an email to Global-Privacy@htc.com .
HTC Account lets you use a single user name and password to log on to
HTCSense.com and other HTC applications and Services. Some HTC applications
and Services require a different user name and password. Please protect
your user names and passwords to help prevent anyone from accessing your
accounts and your personal information.
We are not responsible for the security of any independent third-party
applications and services or the data those third-party applications and
services may collect about you. Please ask those third parties how they
keep your data safe.
14. CONTACT INFORMATION
We welcome your comments or questions about this Policy. Please email us at
global-privacy@htc.com . You may also contact us in writing at the
addresses listed below:
Americas: HTC America, Inc.
308 Occidental Ave. South, Suite 300 Settle, WA 98005
Attention: Privacy Administrator
APAC: HTC Corporation
23 Xinghua Road,
Taoyuan District,
Taoyuan City 330, Taiwan
Company registration number: 16003518
Attention: Privacy Administrator
EU: HTC Europe Co. Ltd
Salamanca, Wellington Street
Slough, Berkshire SL1 1YP, U.K.
Company registration number: 04826012
Attention: Privacy Administrator
(HTC Europe Co. Ltd is the leads establishment of HTC Corporation for the
EU.)
15. CHANGES TO THIS PRIVACY POLICY
We may make changes to this Policy. If we make any changes to the Policy
they will be posted on this page and we will change the “Last Updated” date
below.
THIS PRIVACY POLICY WAS LAST UPDATED ON January 01, 2020.
(View archived versions)
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