My Fairphone App Privacy Statement

Welcome to the My Fairphone App Privacy Statement. This text explains what personal data we, Fairphone, collect through the My Fairphone App, why we collect it and what we do with it. With personal data (‘​Your Data​’) we mean any information through which we can identify you. In general, we collect Your Data to provide you our services through the My Fairphone App. If you want to know more generally how Fairphone collects and processes data, for example, what data we collect when you visit our website or when you order a product in our webshop, please read our ​Fairphone Privacy Policy.

If you have any questions about your data and its protection, you can contact us by sending an email to ​privacy@fairphone.com​or by sending a letter to Fairphone Privacy, Jollemanhof 17, 1019 GW, Amsterdam, the Netherlands.

What Personal Data do we collect?

Depending on who you are and what features of the My Fairphone App you use, we may process different categories of Personal Data about you. This could contain:

●First name;

●Last name;

●E-mail address;

●IMEI Number;

●Device information (operating system and browser used, plugins and fonts installed, screen size; Network Operator);

●Log information: the time and duration of your use of the My Fairphone App;

●Location information: your approximate location derived from your IP address. We erase the last three numbers of your IP address to make this more anonymous;

●Preferences you set in the My Fairphone App about language and location;

●Any information you provide us.

How do we collect Your Data?

●When you create a support ticket in the My Fairphone App, the application creates this ticket in Fairphone’s ticketing service, Zendesk.

●We use Google’s Firebase and Google Analytics for Mobile to analyze My Fairphone App usage.

What do we use Your Data for?

We use this date for the following purposes:

●To allow you to submit customer service questions to our team;

●To assess your problems and to provide you with the requested support;

●To analyse and improve our customer support and for trainings of new agents;

●To improve our services through the My Fairphone App.

●To provide the necessary network security​.

Data of children

We do not intentionally collect information from children under the age of 16.

●If you are under the age of 16, we advise you to speak with your parent or guardian and get their consent before sharing Your Data with us;

●If you are the parent or guardian of a child under the age of 16, we recommend you make sure that your child does not share Personal Data through the use of our products, services, website and other digital channels without asking your permission.

Sharing Your Data

We will never sell Your Data or information about you to any third parties. We do not share Your Data except in the limited cases described in this section and only for the following purposes.

●Service providers:​We have outsourced certain business functions and their associated data processing activities to third party service providers. These service providers are authorized to use Your Data only as necessary to fulfil these services to us, which include, but is not limited to IT services, warranty services, billing services and shipping services. None of these providers will contact you by electronic means to provide you with any newsletter, marketing e-mail or information, unless you have provided your consent to them;

●Business Partners:​We may share Your Data with business partners, so that they can provide you with the services you requested. None of these partners will contact you by electronic means to provide you with any newsletter, marketing e-mail or information, unless you have provided your consent to them;

●Professional advisors and others:​We may share Your Data with banks, insurance companies, lawyers, auditors, and other professional advisors. These parties only receive Your Data when this is needed to fulfil a contractual or legal obligation.

●Public and governmental authorities:​When required by law, or as necessary to protect our and/or your rights, we may share Your Data with entities that regulate or have jurisdiction over Fairphone;

●Affiliates​: should Fairphone establish affiliates, we may share Your Data with those affiliates on a need-to-know basis;

Location of Your Data

We attempt to collect, store and, if applicable, process Your Data within the European Union, European Economic Area (“EEA”) and Switzerland.

We may transfer Your Data to countries located outside the European Union, European Economic Area (“EEA”) and Switzerland. Some of these countries are recognized by the European Commission as providing an adequate level of protection. With regards to transfers

to countries which are not recognized by the European Commission as providing an adequate level of protection, we will ensure adequate data protection and privacy requirements through the standard contractual clauses approved by the European Commission. You can request a copy of these clauses through ​privacy@fairphone.com​.

Data retention

We will not store Your Data for a longer period than permitted by law and only as necessary for the purpose for which we have collected or processed Your Data. Therefore, how long we retain Your Data depends on the type of data and the purpose for which we collected or processed Your Data. Please keep in mind that in certain cases a longer retention period may be required or permitted by law.

The criteria we take into account when determining our retention periods include:

●How long Your Data is needed to provide you with our product or to operate our business;

●Do you have an account with us? If yes, then we will keep Your Data while your account is active or for as long as needed to provide our services;

●Are we subject to a legal, contractual, or similar obligation to retain Your Data.

Data Security

We process Your Data in accordance with the General Data Protection Regulation. To protect Your Data, we will take appropriate measures, including requiring our service providers to use appropriate measures to protect the confidentiality and security of Your Data. Your Data is stored on our secure servers or the servers of our trusted partners.

Although we want you to feel confident in using My Fairphone App and we are committed to protecting the Data we collect or process, no application can guarantee complete security. We have implemented appropriate technical and security procedures to help protect Your Data against any unlawful destruction, accidental loss, alteration or unauthorised disclosure or access. However, please be aware that the transmission of information and data over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.

Your responsibilities

When providing us with Your Data, it is your responsibility to ensure that Your Data is accurate, complete and up-to-date. You should also take all reasonable measures to keep Your Data secure at all times. For instance, you are responsible for keeping your password and other log-in details confidential. We will not ask you for your password, except when you log into the My Fairphone App.

When providing us with the personal data of other people, it is your responsibility to collect this personal data in compliance with the GDPR and other local legislation. This includes

informing the people whose personal data you are providing about this privacy statement and obtaining their consent.

Your rights

We will provide you with access to Your Data, so you may control, update, modify and, where legally possible, delete it.​Data​ protection laws regulate that we are only allowed to collect and process your data, if we have lawful bases for processing. The lawfulness of data processing derives from:

●your (explicit) consent in cases where you have given (explicit) consent to the processing;

●the necessity for the performance of our contract with you, e.g. providing warranty service; or

●legitimate interests pursued by Fairphone, e.g. protecting you and Fairphone from security threats; complying with applicable laws, managing and improving our business.

Where consent was required for processing, you can revoke your consent for future data processing at any time. However, this does not affect the lawfulness of data processing based on the consent before the revocation. In certain cases, we may continue to process your information after you have withdrawn consent, if we have another legal basis to do so or if your withdrawal of consent was limited to certain processing activities.

You can contact us if you want to:

●Receive confirmation whether or not Your Data is being processed;

●Review or change Your Data. Please note that it is not technically possible for us to rectify all kinds of data in the My Fairphone App, for example because it is stored on your phone.

●Delete your Data. You will receive a confirmation e-mail that you have to confirm before we proceed with the deletion process. Please bear in mind that some data cannot be deleted because of our legal obligation, for example data associated with a past purchase because we have to provide warranty service.

●Object to certain processing of Your Data;

●Receive a copy of Your Data in a machine-readable format;

●File a complaint.

●Ask us any other questions regarding Your Data and its protection.

Updates to this Privacy Statement

This privacy statement may be updated in the future to reflect legal and business developments. An older version will always be available on our website with indication of changes where possible. This statement was last updated 8 April 2020.