This statement supplements the HMD Global Privacy Policy for products and services and describes the personal data processing conducted by HMD Global Oy and its subsidiaries (“HMD”) when providing you with HMD Watches and HMD DUB Audio accessories, and related applications, websites, and services. For the avoidance of doubt, this Supplement only applies to data processing linked to the following applications and services:

• HMD Watch application: With the HMD Watch application, you can create an account, pair and manage your HMD Watch, track various health and fitness metrics, and monitor your progress across different activity modes.
• HMD DUB Audio application: With the HMD DUB Audio application, you can create an account, pair your HMD DUB Audio accessory, and manage different settings.
• Support Squad Website: The Support Squad Website allows you, or anyone you invite through the HMD Watch application to join your Support Squad, to access your Health Data.

Account Data is collected when you sign up for the HMD Watch or HMD DUB Audio app, or when you accept an invite to join someone else’s Support Squad.

Device Data is collected when you pair your HMD Watch or HMD DUB Audio accessory through the HMD Watch or HMD DUB Audio application.

Location Data is collected when you pair your HMD Watch with the HMD Watch app and when you use features that require location positioning.

Certain HMD Wearable accessories, such as HMD Watches, may collect Health Data. This data is processed only if you provide explicit consent when signing up for the HMD Watch application. You can manage your consent through HMD Watch application settings. Health Data is only processed to deliver the full functionality of the HMD Watch application and the Support Squad Website after you sign up and pair your HMD Watch.

HMD DUB Audio Application

Why are we processing your data?

We process your personal data to provide and enable the use of HMD DUB Audio accessories, the HMD DUB Audio application, and related services.

What data are we processing?

When you sign up to use the HMD DUB Audio application and pair your HMD DUB Audio accessory, we collect the following data:

1. Account Data: Your email address and name
2. Device Data: Certain device and network identifiers related to the paired HMD DUB Audio accessory or the connected device, such as MAC address, software and firmware version, device ID, model, and manufacturer.
   • What is the basis for processing your data? Contract between you and HMD.

HMD Watch Application and Support Squad Website

Why are we processing your data?

We process your data to provide and enable the use of HMD Watches, the HMD Watch application, the Support Squad Website, and related services.

What data are we processing?

1. Account Data: Your email address, mobile phone number, and name are processed when you create an account through the HMD Watch app, or when you accept an invite to join someone else’s Support Squad through the Support Squad Website. In case you enable ICE Contact or Support Squad Member notification messages through the HMD Watch app, your ICE contact’s and Support Squad Member’s phone number and name is processed.

   • What is the basis for processing your data? Contract between you and HMD.

2. Device Data: Certain device and network identifiers related to the paired HMD Watch or the connected device, such as MAC address, software and firmware version, device ID, model, and manufacturer, are processed when you pair your HMD Watch to the HMD Watch app.

   • What is the basis for processing your data? Contract between you and HMD.

3. Location Data: Satellite, mobile, Wi-Fi, or network-based location when you pair your HMD Watch to the HMD Watch app.

   • What is the basis for processing your data? Your consent. You can manage your consent through your connected device’s settings.

4. Health Data: Date of birth, gender, height, weight, BMI, stress score, activity details (such as steps, distance, calories, and session duration), heart rate, heart rate variability (HRV), sleep details (such as duration, sleep stages, nightly breathing rate, and sleep score), oxygen saturation (SpO2), your fitness plans and challenges and their progress.

   • What is the legal basis for processing your data? Your consent. You can withdraw your consent at any time through HMD Watch application settings.

How long do we retain your data?

We retain your personal data as long as necessary to provide you with HMD Watches and HMD DUB Audio accessories, and related applications, websites, and services.

If your account remains inactive for a continuous period of 48 months, or if you ask us to delete your personal data, we will delete all personal data linked to your account from our systems, unless we are legally obliged or entitled to retain certain information for a longer period. Please note that complete deletion of your personal data can take up to 7 days.

Account Data is retained until you ask HMD to delete your account, or the account has been inactive for 48 months.

Device Data is retained while your account is active or until you ask HMD to delete your personal data.

Location Data is retained while your account is active or until you withdraw your consent via your connected device’s settings.

Health Data is retained while your account is active or until you withdraw your explicit consent via the HMD Watch application.

You can request the deletion of your personal data by contacting HMD Support or by using the settings in the HMD Watch app.

Do we transfer personal data?

What personal data is transferred?

1. Account Data

Who are the recipients and where are they located?

• For cloud storage and to support the maintenance of the HMD Watch and HMD DUB Audio applications, as well as their related services, we engage a cloud service provider located in the EU/EEA.
• For email verification and account notification messages related to your HMD Watch account, we engage a service provider located in the United States.
• For notifications and alerts related to the HMD Watch app, we engage a service provider that delivers SMS and instant messaging communications, located in India.
• For technical support and backend maintenance of the HMD Watch and HMD DUB Audio applications, as well as their related services, we engage a service provider located in India.
• What are the transfer safeguards? Personal data is either stored in the EU/EEA, or where transferred outside the EU/EEA, such transfers are carried out in compliance with the European Commission’s Standard Contractual Clauses or Adequacy Decisions.

2. Device Data

Who are the recipients and where are they located?

• For cloud storage and to support the maintenance of the HMD Watch and HMD DUB Audio applications, as well as their related services, we engage a cloud service provider located in the EU/EEA.
• For technical support and backend maintenance of the HMD Watch and HMD DUB Audio applications, as well as their related services, we engage a service provider located in India.
• What are the transfer safeguards? Data is either stored in the EU/EEA, or transferred in compliance with the European Commission's Standard Contractual Clauses.

3. Health Data

Who are the recipients and where are they located?

• For cloud storage and to support the maintenance of the HMD Watch and HMD DUB Audio applications, as well as their related services, we engage a cloud service provider located in the EU/EEA.
• For email verification and account notification messages related to your HMD Watch account, we engage a service provider located in the United States.
• For notifications and alerts related to the HMD Watch app, we engage a service provider that delivers SMS and instant messaging communications, located in India.
• For technical support and backend maintenance of the HMD Watch application, as well as their related services, we engage a service provider located in India.
• What are the transfer safeguards? Personal data is either stored in the EU/EEA, or where transferred outside the EU/EEA, such transfers are carried out in compliance with the European Commission’s Standard Contractual Clauses or, where applicable, the EU-U.S Data Privacy Framework.