This statement supplements the General Terms and Conditions for HMD Enable Pro, the General Terms and Conditions for HMD FOTA, and Softlock Solution Services Agreement when HMD acts as a processor of personal data.

HMD uses third party subcontractors when providing you with services. When our service providers help us with processing of personal data on behalf of you, they act as our sub-processors. Our sub-processors are subject to written agreements which ensure that they provide at least the same level of data protection as we do. HMD remains fully responsible for the acts and omissions of its sub-processors.

Our sub-processors are listed below:

HMD Enable Pro

1. Google LLC / Google Finland Oy / Tuike Finland Oy

Processing purposes:

• Hosting servers to be managed by HMD
• Storing data
• Device management and messaging

Processing locations and our safeguards to protect the data:

• Finland, backups in Europe
  • Data in the EU/EEA

2. Foundever Europe Limited

Processing purposes:

• Providing customer support services

Processing locations and our safeguards to protect the data:

• Romania during European business hours for European customers
  • Data in the EU/EEA
• 24/7 global support in Colombia
  • Standard Contractual Clauses of the European Commission

Softlock

1. Google LLC / Google Finland Oy / Tuike Finland Oy

Processing purposes:

• Hosting servers to be managed by HMD
• Storing data
• Device management and messaging

Processing locations and our safeguards to protect the data:

• Finland, backups in Europe
  • Data in the EU/EEA

2. Foundever Europe Limited

Processing purposes:

• Providing customer support services

Processing locations and our safeguards to protect the data:

• Romania during European business hours for European customers
  • Data in the EU/EEA
• 24/7 global support in Colombia
  • Standard Contractual Clauses of the European Commission

3. Twilio Inc.

Processing purposes:

• Sending email notifications through SendGrid service

Processing locations and our safeguards to protect the data:

• United States
  • Standard Contractual Clauses of the European Commission

HMD FOTA

1. Google LLC / Google Finland Oy / Tuike Finland Oy

Processing purposes:

• Hosting servers to be managed by HMD
• Storing data
• Device management and messaging

Processing locations and our safeguards to protect the data:

• Finland, backups in Europe
  • Data in the EU/EEA

2. Foundever Europe Limited

Processing purposes:

• Providing customer support services

Processing locations and our safeguards to protect the data:

• Romania during European business hours for European customers
  • Data in the EU/EEA
• 24/7 global support in Colombia
  • Standard Contractual Clauses of the European Commission

3. Microsoft Ireland Operations Limited

Processing purposes:

• Identity and access management for HMD FOTA Management Console

Processing locations and our safeguards to protect the data:

• Ireland
  • Data in the EU/EEA