Last updated: June 1, 2021
Welcome to TECNO!
1. Acceptance of this Agreement
1.1 By downloading, installing, clicking on the “register” or “agree” button and/or accessing or using the TECNO Device, Software or Service, you agree to comply with and be bound by this Agreement. If you do not agree to this Agreement, you may not access or use TECNO Software or Service.
1.2 The TECNO Software and Service are not intended for or directed to children under the age of 14 (or the age considered as a "child" in the jurisdiction where you use TECNO Software or Services). If you are under the age of 14, you may not use the TECNO Software or Service or provide TECNO with any personally identifiable information. If you are 14 or older but under the age of 18 (or under the age of majority in the jurisdiction where you use TECNO Software and Service) which be considered as a "Minor”, you represent that you have reviewed this Agreement with your parent or legal guardian and that you and your parent or guardian understand and consent to this Agreement. If you are a parent or guardian permitting a Minor to use the TECNO Services, you agree to: (i) supervise the Minor’s use of the TECNO Software and Service; (ii) assume all risks associated with the Minor’s use of TECNO Software and Service, including the transmission of content to and from third parties via the Internet; (iii) assume any liability resulting from the Minor’s use of TECNO Software and Service; (iv) ensure the accuracy and truthfulness of all information submitted by the Minor; and (v) assume responsibility and are bound by this Agreement for the Minor’s access and use of the TECNO Software and Service.
1.3 In order to improve your user experience or enhance product safety performance, we will continue to work hard to develop new software and services, and provide you in a timely manner with software updates (including but not limited to software version upgrades, modifications, and functional perfection) or repairs. TECNO may reserve the right to modify this Agreement as necessary in accordance with applicable laws and regulations. The updated Agreement will shall supersede the original Agreement and shall come into effect after the expiration of the period stipulated by applicable law. If there is no special provision in applicable laws, the Agreement shall become effective on the date of renewal. The updated Agreement will be announced on the corresponding official website of TECNO Service for your reference at any time. If you continue to access or use the TECNO Software or Service, you will be deemed as you having read and agreed to be bound by the updated Agreement. If you do not accept the updated Agreement, please stop using TECNO Software or Service.
2. Permitted License Uses
Subject to the terms and conditions of this Agreement, TECNO grants you a non-exclusive, non-sublicensable, personal, revocable, limited license to access and use this Software and Service. You may install, use, display, and run the Software and Service on a TECNO device for non-commercial purposes.
2.1 TECNO system: refers to the custom operating system independently developed and owned by TECNO based on Google Android or an operating system of another brand. TECNO’s ownership over the system includes: (i) information including but not limited to codes stored on the device and other embedded software, documents, interfaces, contents and fonts provided to you via TECNO device and any material protected by the copyright of TECNO or its licensor; (ii) updates or upgrades to the software described in (i).
2.2 This Software: refers to the system application program independently developed by TECNO that comes with TECNO system.
2.3 This Service: refers to the related various services provided by TECNO to users through this Software.
2.3.1 You may enjoy browser, recording, calculator, weather, file management, download, notepad, phone, SMS, camera, photo, address book, Bluetooth and other functions. The specific services provided are subject to the TECNO device you purchased;
2.3.2 You may use this Service through mobile phones, tablets and other terminals launched by TECNO. At the same time, TECNO will continue to enrich the form of terminals for users of this Service.
2.3.3 When you use TECNO devices, some software and services have separate user agreements or other rules. Please read them carefully before using the abovementioned software or services.
3. Intellectual Property; Ownership
TECNO reserves the intellectual property rights to this Software and Service and all related information content (including but not limited to UI interface design, pictures, fonts, audio, etc.) and all rights not expressly granted to you. The above intellectual property rights, including but not limited to copyright, trademark and patent rights, are protected by applicable intellectual property rights, anti-unfair competition and other respective laws, regulations and relevant international treaties. For matters not expressly authorized in this Agreement, such as commercial sales, reproduction, and permission for any third party to use this Software, you should separately obtain formal written permission from TECNO.
4. Restrictions on the use of This Software and Service
4.1 You shall not take any of the following actions when using this Software and Service, including but not limited to:
4.1.1 Releasing, transmitting, spreading or storing contents which violate laws and regulations, policies, public order and good custom, and social ethics, such as insults, defamation, violence, or violation of religion, etc; releasing, transmitting, spreading or storing fabricated information or advertising information for the purpose of misleading or deceiving others;
4.1.2 Renting, lending, copying, modifying, linking, reprinting, compiling, issuing or publishing this Software and similar acts;
4.1.3 Jailbreaking, reverse engineering, disassembling, decompiling, or otherwise attempting to destroy this Software; or, accessing or disturbing this Software by the use of plug-ins, Tag-ons, or third-party tools/services that are not authorized by TECNO;
4.1.4 Copying, modifying, adding, deleting, operating in the form of mounting, or creating any derivative works of data of the Software, data released into any terminal memory in the course of the operation of the Software, interactive data of the client and server side in the course of the operation of the Software, and system data necessary for the operation of the Software; or adding, deleting or changing the functions or operative effect of software by modifying or fabricating the instructions and data that occur in the course of the operation of the software; or operating or publicly diffusing the software and method used for the above purposes, whether commercially or otherwise;
4.1.5 Carrying out other acts which violate laws and regulations, policies, public order and good custom, and social ethics or acts which are not authorized by TECNO in writing.
4.2 You may not, and you agree not to or enable others to, copy (except as expressly permitted by this Agreement), decompile, reverse engineer, disassemble, attempt to derive the source code of, decrypt, modify, or create derivative works of the TECNO Software or any services provided by the TECNO Software or any part thereof (except as and only to the extent any foregoing restriction is prohibited by applicable law or by licensing terms governing the use of open-source components that may be included with the TECNO Software). You agree not to remove, obscure, or alter any proprietary notices (including trademark and copyright notices) that may be affixed to or contained within the TECNO Software.
5. Usage Rules of This Software and Service
5.1 You understand and agree that you should abide by the rights and obligations stipulated in this Agreement when you choose to use a TECNO device.
5.2 As TECNO may develop multiple versions of software for different devices, you should choose the appropriate software for download and follow the tips to install correctly.
5.3 In order to provide services of better quality and safety, TECNO may recommend you install other software during your installation of this Software. You can choose to install them or not.
5.4 You understand and agree that the Software and Service may be suspended or stopped by TECNO based on our business development plans or as required by judicial, regulatory and supervisory authorities.
5.5 Unless permitted by applicable law and with the written authorization of TECNO, you may not use or otherwise export or re-export TECNO Software and Service.
6. Considerations on Your Use of This Software and Service
6.1 You fully understand and agree: when you use a specific service of this Software, relevant permissions and interfaces of your device may be required in order to achieve the corresponding features, while a separate user agreement may also be required for certain services. Please read the aforementioned relevant agreements and rules carefully before using this service;
6.2 TECNO has the right to display all kinds of information to you in the process of providing this Service, including but not limited to prompts for authorization, advertising information and promotional information, etc. The information may appear in the form of system messages or pop-up windows. If you do not agree to receive certain information, you can cancel the relevant service, which may eventually lead to unavailability of the relevant service function;
6.3 You understand and agree: TECNO will make commercially reasonable efforts to protect your data storage security during your use of this Service, but TECNO cannot provide a complete guarantee, including but not limited to the following situations:
6.3.1 To the maximum extent permitted by law, TECNO is not responsible for your deletion or storage failure of relevant data in this Software and Service;
6.3.2 TECNO will retain the data according to the minimum retention period required for business development, unless you agree to extend the retention period or otherwise permitted by law. TECNO also has the right to decide at its discretion the maximum storage space of data in TECNO Device or this Software. You may back up relevant data in this Software and Service by yourself according to your own needs;
6.4 When you use this Service, the specific content displayed may differ depending on the version of the Software you use. You understand and agree: when you are using a certain version of this Software or entering the relevant pages of an application developed by TECNO, in order to provide you with a better service experience, the necessary information such as the installation location, size, and UI interface of the installed application on your terminal device may be adjusted, depending on the actual version provided by TECNO.
6.5 You fully understand and agree that, if you need to register an account when using this Software, you will be responsible for keeping the security of the registered account information and account password properly, and you will be responsible for all acts that occur under the account you registered with the TECNO device, including any contents that you publish and any consequences arising therefrom.
6.6 You shall judge by yourself contents that you have access to in using this Service and bear the risks arising from the use of such contents, including risks arising from the dependence upon the correctness, completeness or practicability of the contents. TECNO is unable to and will not bear any responsibility for any loss or damage suffered by you due to the above risks.
6.7 If TECNO finds or receives a report from others that you violated the terms of this Agreement, TECNO shall have the right at any time without notice to: delete and shield relevant contents; suspend or terminate your use of the corresponding TECNO account or all of the Service; investigate legal responsibility and take other measures. If you violate any terms of this Agreement, thus causing damage to any third party, you shall solely bear all responsibilities arising therefrom and compensate TECNO for any losses suffered by TECNO arising therefrom (including but not limited to possible administrative penalties, lawyer fees, and investigation and evidence collection fees).
7. Updates of this Agreement
In order to better provide you with relevant Service and to guarantee the security of this Software, we may update this Software and relevant Services from time to time (including but not limited to software modification, software upgrades, partial function disabling, function strengthen, new service development, software replacement and function improvement). You may choose whether to upgrade to the corresponding version based on your needs. In order to facilitate your experience of a better service by the TECNO device, and in compliance with applicable laws, this Software may enable automatic upgrade and update function for you by default. You can choose whether to enable this function in software settings. In case of such updates, we will notify you in an appropriate manner (including but not limited to system notifications, site messages, announcements, application store update notifications, etc.), and you have the right to choose whether to accept the updated version. Updating to the latest version may improve your user experience. If you decide not to accept the updated version provided by TECNO, you understand that you may place the Software under serious security risk or cause the Software to be unusable or unstable. Failure to update the software may cause some of the functions of the Software to be limited or rendered unusable.
8. Software and Services Provided by Third Parties
8.1 In order to facilitate your use of the TECNO device, this Software or this Service may use third-party software or services, and the results of such use and access are provided by the third party (including but not limited to the services and contents provided by the third party that you jump to through this Software, this Service, or accessed by said third party through TECNO's open platform). In addition to the terms of this Agreement, you shall comply with the user agreements of third parties in using software or services provided by third parties on the TECNO device. TECNO cannot guarantee the security, accuracy and validity of the services and contents provided by third parties and other uncertain risks, and you shall solely bear relevant risks and responsibilities arising therefrom.
8.2 Whether the third-party software or services are pre-installed in the TECNO device or activated or subscribed by yourself, you understand and agree that TECNO disclaims all express or implied warranties with respect to the security, accuracy and validity of the services and contents provided by third parties and other uncertain risks.
8.3 Any dispute between you and the above third-party software and services providers shall be settled by you and such third party with you taking relevant responsibilities, if any.
9. Fees and Advertisement
You understand and agree that although this Software and Service are currently offered to you free of charge, however, along with the continuous renewal of our Service, you may need to pay for some part of the Software or Service provided by TECNO. TECNO reserves the right to add fee-charging features and functionalities in future Service. TECNO also reserves the right to display advertisements in connection with the TECNO Software and Service to you. We will clearly notify you in case of any paid software and service in this Software before your use and you may choose whether to accept or use such paid software or service. At that time, please use such paid software or service according to our instructions (including but not limited to service fee standards, payment terms and service rules). You can use such paid software and services once you have explicitly agreed to the relevant rules and are willing to pay the fees.
Your use of this Software and Service will consume your device, bandwidth, traffic and other resources. Fees for the above resources such as purchasing a TECNO device, Internet access fees, SMS fees, and payment for the Software's value-added services shall be borne by yourself.
11. Termination and Breach of Contract
TECNO has the right to judge whether your behavior complies with the terms of this Agreement. If you are deemed to have violated relevant laws and regulations or fail to comply with any terms and conditions of this Agreement or related rules, based on the severity of your violation, TECNO and its licensors shall have the right to delete the content in violation, to limit, to suspend or to terminate your use of TECNO Software and Service without notice, and to take other measures that TECNO considers appropriate. And you will be held liable for your incompliance behavior. Once it is terminated, you must stop using this Software and Service, and delete all the Software and associated material s already copied and/or installed on your TECNO device immediately.
You will indemnify, release and hold harmless TECNO, its parent, subsidiaries and affiliates, and all officers, directors, agents and employees thereof, and any party acting on TECNO’s behalf, from and against any and all third party claims, actions, liabilities, losses, damages, judgments, costs and expenses, including reasonable attorneys’ fees (collectively, "Claims") arising out of (i) any use of the TECNO Services or products appearing on the TECNO Services by you or by any person that is not in accordance with the terms of this Agreement; (ii) any breach of this Agreement by you or by any person that you allow to use the TECNO Services; or (iii) any violation of any laws, regulations or the rights of any third party by you or by any person that you allow to use the TECNO Services or products appearing on the TECNO Services.
13.1 DISCLAIMER OF WARRANTIES. TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE TECNO SOFTWARE AND SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT ANY WARRANTIES OR GUARANTEES OF ANY KIND OR NATURE, EITHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT NOT LIMITED TO, ANY (IF ANY) IMPLIED WARRANTIES, DUTIES OR CONDITIONS OF MERCHANTABILITY, OF FITNESS FOR A PARTICULAR PURPOSE, OF ACCURACY OR COMPLETENESS OF RESPONSES, OF RESULTS, OF WORKMANLIKE EFFORT, OF LACK OF VIRUSES, AND OF LACK OF NEGLIGENCE, ALL WITH REGARD TO THIS SOFTWARE AND SERVICE.
13.2 THIS SOFTWARE DOES NOT CONTAIN ANY MALICIOUS CODE DESIGNED TO DESTROY YOUR DEVICE DATA OR TO OBTAIN YOUR PRIVACY INFORMATION. TECNO WILL ALSO DO ITS UTMOST TO ENSURE THE SAFE, PROMPT, EFFECTIVE, ACCURATE, RELIABLE AND CONTINUOUS OPERATION OF THIS SOFTWARE AND SERVICE, BUT WITH THE LIMITATION OF THE EXISTING TECHNOLOGY, THIS SOFTWARE AND RELATED SERVICE MAY BE AFFECTED BY VARIOUS UNSTABLE FACTORS, TECNO MAKES NO WARRANTIES OR REPRESENTATIONS THAT THE SOFTWARE IS COMPATIBLE WITH ALL SOFTWARE AND HARDWARE SYSTEMS, OR IS ERROR-FREE, CAN OPERATE WITHOUT INTERRUPTION OR THAT ANY ERRORS IN THE SOFTWARE OR RELATED SERVICE CAN BE CORRECTED. IN CASE OF CIRCUMSTANCES SUCH AS INCOMPATIBILITY OR SOFTWARE MALFUNCTION, PLEASE CONTACT US FOR TECHNICAL SUPPORT. IF THE COMPATIBILITY PROBLEM CANNOT BE SOLVED, YOU CAN DELETE THIS SOFTWARE. WITHIN THE MAXIMUM SCOPE PERMITTED BY APPLICABLE LAWS, TECNO IS EXEMPT FROM ANY OF YOUR LOSSES CAUSED HEREIN.
14. LIMITATION OF LIABILITIES
TO THE EXTENT NOT PROHIBITED BY APPLICABLE LAW, IN NO EVENT SHALL TECNO, ITS AFFILIATES, SENIOR MANAGEMENT, DIRECTORS, EMPLOYEES OR AGENTS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, BUSINESS INTERRUPTION OR ANY OTHER INTANGIBLE DAMAGES OR LOSSES, ARISING OUT OF THE FOLLOWING REASONS, HOWEVER CAUSED, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT OR OTHERWISE) AND EVEN IF TECNO HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES: (i) YOUR USE OR INABILITY TO USE THE SERVICE;(ii) THE UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (iii) THE DELETION OF, CORRUPTION OF, OR FAILURE TO USE YOUR TRANSMISSIONS OR DATA ON OR THROUGH THE SERVICE; (iv) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICE; AND (v) ANY OTHER MATTER RELATING TO THE SERVICE. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR PERSONAL INJURY, OR OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THIS LIMITATION MAY NOT APPLY TO YOU.
AT THE SAME TIME, TECNO’S MAXIMUM COMPENSATION FOR ALL YOUR LOSSES SHALL NOT EXCEED THE AMOUNT YOU PAID FOR USING/PURCHASING THE CORRESPONDING TECNO DEVICE, SOFTWARE OR SERVICES (IF PAID SERVICE IS INVOLVED) WITHIN 12 MONTHS BEFORE THE DATE OF INITIATING THE CLAIM. IF THE LAW OF YOUR REGION DOES NOT ALLOW THE LIMITATION OF LIABILITY THROUGH AN AGREEMENT. IN THIS CASE, THE APPLICABLE LAWS AND REGULATIONS SHALL APPLY.
15. Governing Laws and Dispute Resolution
15.1 Governing Laws. The execution, performance, interpretation, modification and disputes settlement of this Agreement shall be governed by the laws of Hong Kong Special Administrative Region of the People's Republic of China, excluding its conflict-of-law provisions. You agree that this Agreement is signed in Hong Kong.
15.2 Arbitration. Any dispute or controversy between you and TECNO based on this Agreement shall be first settled through friendly negotiation. If no settlement can be reached through friendly negotiation, you unconditionally consent and agree that any claim, dispute or controversy (whether in contract, tort or otherwise) you may have against any TECNO entity, the directors, agents, and employees of any TECNO entity arising out of, relating to, or connected in any way with TECNO Services, shall be submitted to Hong Kong International Arbitration Center (HKIAC) for settlement before one (1) arbitrator in accordance with the rules of HKIAC. The arbitration shall take place in Hong Kong, China, and the arbitration proceedings and all pleadings and written evidence shall be in the English language, and judgment upon the award rendered by the arbitrators may be entered in any court having jurisdiction thereof. You will only be permitted to pursue claims against TECNO on an individual basis, not as a plaintiff or class member in any class or representative action or proceeding.
16. General Terms
16.1 Heading. The headings of all terms of this Agreement are for reference purpose only, have no actual meanings themselves, and shall not be used as a basis for interpreting the meanings of this Agreement.
16.2 Severability. If any term or provision of this Agreement is held to be invalid or unenforceable by any judicial or administrative authority for any reasons, such determination shall not affect the validity of enforceability of the remaining terms and provisions of the Agreement hereof, and the remaining provisions of this Agreement shall remain in full effect and shall be construed in accordance with its terms.
16.3 Languages. If this Agreement is made in English, Arabic and other languages. In case of any discrepancy, the English version hereof shall prevail.
16.4 No Waiver. The failure of TECNO to enforce at any time any of the provisions of the TECNO Services, or the failure by TECNO to require at any time performance by you of any of the provisions of the TECNO Services, shall in no way be construed to be a present or future waiver of such provisions, nor in any way affect the right of TECNO to enforce such provision thereafter. The express waiver by TECNO of any provision, condition or requirement of the TECNO Services shall not constitute a waiver of any future obligation to comply with such provision, condition or requirement.
16.5 Entire Agreement. This Agreement constitutes the entire agreement between you and TECNO governing your use of the Software and supersedes any prior agreements between you and TECNO relating to the use of the Software. You may also be subject to additional terms and conditions that may apply when you use or purchase open-source software, third-party content, or other TECNO services.
Updated on: June 1, 2021
Effective date: June 1, 2021
It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties. Please choose carefully whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.
We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.
If you have any questions, please feel free to contact us by the following means:
i. How We Collect and Use Your Personal Information
iii. How We Store and Protect Your Personal Information
iv. How We Share, Transfer and Disclose Your Personal Information and Data
v. How Your Personal Information is Transferred Across Borders
vi. Your Rights to Your Personal Information
vii. How We Handle the Personal Information of Children
viii. Third-Party Service Providers and Services
ix. Supplement and Update of the Policy
x. How to Contact Us
I. How We Collect and Use Your Personal Information
TECNO firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by TECNO, regardless of where such natural person lives.
We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the personal information when you use TECNO products or services or when we have requested. You are not required to provide your personal information to TECNO, but in some cases, if you choose not to do so, we will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:
1. Personal information we collect
1.1 Information you provide directly to us
In order to enable you to access our product features and services, we will ask you to provide necessary personal information. The following are some examples:
(1) Account information. When you register for TECNO products or services, such as creating an APP account, participating in community forum interactions, you may need to provide: your phone number, name, nickname, profile picture, date of birth, nationality, age, email address, photos, the city where you are located and other needed information depending on the features of different products or services; In order to log in to the relevant system more conveniently, such as using face recognition or fingerprint unlocking for quick login, you may need to provide the corresponding facial or fingerprint biometric information;
(2) Order information. When you purchase our products or services online or offline, in order to ensure that the products or services can be provided to you accurately in a timely manner, we may ask you to provide information such as the recipient's name, account information, ID number, phone number, zip code, shipping and billing address, and credit card information to process your order;
(3) After-sales information. When you need us to provide after-sales service or customer support or hope that we solve the problem you encountered when using the products or services, you may need to provide information such as your name, phone number, device information, shipping and billing address, problem descriptions when filling out the warranty card / electronic warranty card or giving feedback on the problem;
(4) Other information you provide to us. For example, when you participate in our promotional activities such as sweepstakes, prize quiz and fan trial research, you may need to provide your nickname, profile picture, name, phone number and other needed information according to different scenarios.
1.2 Information we obtain during your use of our products or services
The personal information TECNO collects depends on how you interact with TECNO. During your use of TECNO products or services, as needed to provide you with products or services, we will collect the necessary information with your authorization or consent, including:
(1) Device or SIM-related information. Given that certain services will be for a particular type of device, in the process of activating a business and using the device, we may collect device-related information in the process of activating such service or using such device, such as the device name, device model, IMEI number (International Mobile Equipment Identity ), GAID number(Google advertising Identity), IMSI number (International Mobile Subscriber Identity), IP address(Internet Protocol Address), Mac address(Media Access Control Address), SN (product Serial Number); version and type of HiOS, itelOS and XOS (collectively referred to as "TRANSSION OS") , ROM(Read-Only Memory) version, Android version, Android ID, Space ID, system language; mobile country or region settings, phone latitude and longitude, device manufacturer information and model name, device hardware basic configuration information and status, network operator and network connection type, device or user identification card information (Subscriber Identity Module).
(2) Log information. When you use our products or services, we may collect certain information and store it in log files, such as service access time, access frequencies, usage time, temporary historical messages, standard system logs, event information (errors, crashes, restarts, upgrades), data usage and other log information generated by using the services.
(3) Location information (only applies to specific services). When you need to use certain location-based services, such as using navigation software, checking the weather conditions in a geographic location, retrieving your phone's location, sharing your geographic location with others. We may, with your consent, collect and process approximate or precise and accurate information about the actual location of the equipment you use such as community identifier, location area code, tracking area code, router area code, mobile country code, mobile network code, frequency, latitude and longitude information, time zone settings, country or area code, name of the city, and language settings. Without doubt, unless you provide consent or in order to comply with a legal requirement by the relevant country or region, we will not continue to collect your location information to identify your whereabouts. You can restrict access to location information of each application at any time directly on your mobile device via “Settings” > “Location (paths may differ for different versions)
(4) Cookies information. Our websites, interactive applications, TECNO products and advertisements may use technologies such as Cookies, Pixel Tags and Web Beacons to collect and store your relevant personal information.
(5) Information regarding your use of Applications. When you use applications, we may collect information related to your application usage such as application basic information (e.g. application list, application ID), SDK (Software Development Kit) information, system update settings, application settings (e.g., region setting, languages setting, time zone setting, fonts), access and exit application time, application status record (e.g. downloading, installing, updating, deleting).
(6) Health Information. When you are using certain sports products such as sports health service, we may collect information relating to your health status, including your physical or mental conditions, such as your gender, height, weight, date of birth, heartbeat, heart rate and steps.
(7) Voice information. When you use voice commands to control some certain service, we may store the voice you recorded on our servers. If we work with a third-party service provider that provides speech-to-text conversion services for us, such third-party providers may receive and store certain voice commands.
(8) Third Party Information. We may collect and use the information specific to you that may be assigned by third party service providers and business partners, for example, your advertising ID assigned by a third party.
1.3 Information obtained from other sources
Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. The following are some examples:
(1) when you use third-party social networking services or pre-installed third-party applications, we may also obtain your personal information from these services or applications;
(2) we may collect and use the information specific to you that may be assigned by third party service providers and business partners, e.g., your advertising ID assigned by a third party;
(3) for certain services that might include account and financial transactions, with your authorization, we may also validate the information you provide, such as phone number through legitimate third-party for security and fraud prevention purposes;
(4) when you direct other third parties to share data with TECNO, e.g., you may direct your mobile operator to share information about your account with us for account activation;
(5) information about you that others provided to us, e.g., when other third parties purchase products for you via our service, they will provide us your delivery address.
We will explain it to you at the time of collection of the above information and obtain your consent. TECNO may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
For research purposes, we may use datasets that contain different types of information that could be associated with an identifiable individual. When acquiring such datasets, we will collect them in accordance with applicable law (including the law in the jurisdiction in which the datasets are hosted). We do not and will not attempt to reidentify individuals from such datasets when we are using such datasets for the purpose of research and development.
1.4 Collection and use of non-personal information
We may also collect other types of information that have no direct or indirect connection with individuals. According to applicable local laws, this information may not be defined as personal information. We will give you examples of such information below. Please note that this information without any personal identity cannot be used to identify an individual. The purpose of our collection is to understand how you use our products and services, and to continuously improve our services to better meet user needs based on such information. Since this type of information is not personal information, we will decide on how we collect, use, disclose and transfer such non-personal information. Only when such non-personal information is used in combination with other information to identify a specific natural person, or when it is used in combination with personal information, will this information be regarded as personal information. In this case, we will anonymize and de-identify this type of information, unless with your consent or otherwise according to laws and regulations.
(1) Statistics of device and product sales, and various statistical summary information, such as screen size, device version, registration time, version information.
(2) Statistical data generated when you install, use, uninstall a specific service and/or the applications within, such as non-identifiable device-related information, website visits, downloads, daily usage events, page access events, page access time events and session events; the use of Apps APK name, App version, App usage, opening times, crash data, App data usage.
(3) Requests and execution of server commands, such as data Command ID, OS version number, software version number, command version number.
(4) Network monitoring data, such as request time, number of request or error request;
(5) When users using notification box to receive notifications, such as OS version, task ID, command version, notification package name, notification type, notification status;
(6) Phone Launcher data, such as App ID, application name, APK name, APP version, browser UA parameters, device type, network connection type.
(7) Collection of App data, such as application startup event, application crash event (e.g., logs automatically generated after the application crashed), application installation event, application uninstallation event, battery usage information, brightness adjustments.
2. Purpose of our use of personal information
2.1 To provide you with registration services and account management services. We will use the basic information you filled out during registration to provide you with the corresponding registration services and subsequent account management services.
2.2 To provide customer support and related services for your purchase and post-purchase activities. For example, you may need to provide necessary information when we offer delivery services, warranty services, technical support, or quickly locate and fix existing abnormal issues via feedback of error reports.
2.3 To provide you with information services for your needs or interests. For example, we or a third party may use your location information to provide you with weather forecast push, geographic location navigation and other related information services; we may use your personal information, analyze your usage habits and behavior preferences, and provide you with notification or content push services based on your consent.
2.4 To continue to provide you with better products and services, we may invite you to participate in our product improvement and user experience related programs or interactive activities. After you join our programs or activities, we may collect your necessary personal information such as mobile phone numbers (mainly used for research and revisits), device information, operation behavior data, location information and log information for statistical analysis, so as to continuously improve and optimize products and provide a better user experience.
2.5 To conduct relevant commercial promotional activities. If you take part in a sweepstake, contest, or similar promotion, we may use the information you provide to administer those programs. If you no longer wish to receive certain types of promotional materials, you may opt out by the method provided in the message (e.g., the unsubscribe link at the bottom of the message) unless otherwise specified in applicable laws. You would have more information in the part of "Your Rights to Your Personal Information" below.
2.6 To provide location-based services. When using TRANSSION OS services, location information may also be used by us to provide you with the service and accurate details about that location for the best possible user experience, for example, weather details, location access (as part of the Android platform). You may turn off location services in the “Location Information” option in “Settings” or turn off the use of location services of an app at any time.
2.7 To use security and system up-keeping features in the Security app, for example, security scan, battery saver, blocklist and cleaner.
2.8 To provide push service and notification service for the purpose of evaluating advertising performance and send notifications from TRANSSION OS Service about software updates or new product announcements, including information about sales and promotions, we will collect the application relevant information (for example, the app version ID, APK name), and device relevant information (for example, model type, brand). We may use your personal information for the purpose of sending you push messages that offer or advertise our products and services and/or selected third party products and services. This is only done with your consent, where required under applicable laws. You may opt-out from receiving marketing information from us and third parties at any time by changing your preferences in the “Application and Notification” option in “Settings”, or managing your preferences through the third-party app/website using TECNO push. You can get more information for "Your Rights to Your Personal Information" section below.
2.9 To provide personalized services and content, including advertisements. For better protection of your privacy, we do use a unique identifier rather than your name, email, or other information by which you can be directly identified, to provide you with personalized products, services, advertising and other activities. We may create profiles by analyzing the aforementioned information and building segments (putting your personal information in one or more segments). Targeted advertising will be conducted with your consent only to the extent required by applicable laws.
We may combine the aforementioned information with other information (including information across different services or devices such as computers, mobile phones, and other connected devices) to provide and improve our products, services, content, and advertising. You have the right to opt-out from receiving personalized advertisements and to object to user profiling at any time, including identification analysis for direct marketing and automated decision-making purposes. In order to exercise these rights, you can opt out at any time through the opt out option in the corresponding software and product.
1. What are Cookies and Similar Technologies
III. How We Store and Protect Your Personal Information
1. How we store your personal information
The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Currently, TECNO may store your personal information in: India and/or Ireland.
The personal information collected and generated during our operations in India will be stored on servers located in India.
The personal information collected and generated in our business outside India will be stored on servers in Ireland.
According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.
2. How we protect your personal information
We will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
IV. How We Share, Transfer and Disclose Your Personal Information and Data
When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
1. How we share your personal information
We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, when you purchase TECNO products, TECNO may need to provide your relevant personal information to the logistics service provider to arrange delivery; when providing you with after-sales service, we may need to provide your relevant personal information to the after-sales service provider in order to offer better service and support. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system). When we embed the SDK of an authorized partner or other similar applications in the Software, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.
In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated data to help partners (e.g., advertising service providers) understand the effectiveness, feedback and usage trends of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.
2. How we transfer your personal information
TECNO will not transfer your information to any other parties, except in the following circumstances:
(1) Obtain your explicit consent.
(2) If TECNO involves in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your personal information, and any choices you may have about your personal information.
3. How we disclose your personal information
According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, TECNO may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
(1) Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.
(2) Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within the TECNO Group.
Other third parties, for example, the disclosure of specific information with your authorization.
V. How Your Personal Information is Transferred Across Borders
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
VI. Your Rights to Your Personal Information
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
6.1 Right to confirm and access
6.2 Right to correct and delete
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when TECNO is legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
6.3 Right to withdraw consent
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of TECNO' s products and services. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
6.4 Right to cancel a service or account
You can click on the “Settings” button in a specific app if you wish to cancel a specific product or service, or you can contact us via email@example.com
We hereby kindly remind you that, if you wish to cancel a certain service or account, such cancellation may prevent you from using some of TECNO products and services, and such act of account cancellation is irreversible. Once you cancel your account, we will delete or de-identification your relevant information.
If you sign in to the accounts of TECNO through a third-party account (e.g., via Facebook, Google ID), you need to apply for cancellation of the account from the third party.
VI.5 Right to complain
You have the right to lodge a complaint by sending us an email at firstname.lastname@example.org. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
VI.6 Right to control your privacy settings
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings, below are some examples of your control over your privacy settings:
(1) Choose to sign in or log out of your TECNO account, such as the Hi Account.
(2) Select to turn on or turn off the User Experience Program and Location Access features.
(3) Switch on or off for other services and features which deal with sensitive or personal information (e.g., face unlock, fingerprint lock). You may obtain more details regarding your device's security status in the TECNO Security app as well.
If you have previously agreed to our use of your personal information for the above-mentioned purposes, you may change your decision by contacting us via email@example.com.
VI.7 Rights in some jurisdictions
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:
(1) Right to restriction processing. You have the right to request our restriction on the processing of your personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the compliance with applicable data protection laws, we will process your personal information under applicable circumstances in such laws and notify you before the restriction of processing is lifted.
(2) Right to automated decision-making. You have the right to refuse the processing based on automated decision-making, including profiling and other automated processing which may have legal or similar effects on you.
(3) Right to data portability. You have the right to apply for your personal information to be transmitted to another data controller in a structured and commonly used format.
We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
VII. How We Handle the Personal Information of Children
TECNO understands the importance of safeguarding the personal data of children, therefore, children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children) are not allowed to use our products or services without the consent and guidance of their legal guardians and such practice shall be permitted by relevant laws and regulations. In principle, we do not provide services directly to children, do not actively collect children’s personal data or do not use children’s personal information for the purposes of marketing. We will only collect, use and disclose a child's personal information with the explicit permission and consent of the child's guardian, to the extent permitted by law, and when it is indeed necessary to collect such information. If at any time the guardian needs to access, modify or delete the personal information related to the child under guardianship, please contact us by methods as described herein, and we will respond in a timely manner. If you find that a child’s information has been collected to us without the awareness of the legal guardian, please send an email to firstname.lastname@example.org to contact us. We will remove the relevant information as soon as possible. If we find that we have collected the personal information of a child without the prior consent of a verifiable guardian, we will also remove the relevant content as soon as possible.
VIII. Third-Party Service Providers and Services
IX. Supplement and Update of the Policy
The content of TECNO products or services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
X. How to Contact Us
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.