In line with Article 3(2) of the Data Act, this document contains the relevant information regarding the product data which the connected product, meaning the data enabled feature phone manufactured by HMD Global Oy (“HMD”), is capable of generating. Additionally, this document provides information on how HMD may use such product data.

Types of data:

• Device Activation Data (“DA Data”), which may include inter alia UUID (Universal Unique Identifier), IMEI(1/2) (International Mobile Equipment Identity), IMSI(1/2) (International Mobile Subscriber Identity), IMSI change Flag, PSN (Product Serial Number), SKUID (Stock Keeping Unit Identifier), APK Version, Bootup time, Marketing name, Market Version, Phase, Phase data, Project name, Product name, factory reset time, IP address, MCC (Mobile Country Code), MNC (Mobile Network Code), ICCID (Integrated Circuit Card Identifier), IMSI (International Mobile Subscriber Identity), network.
• Net Promoter Score Data (“NPS Data”), which may include inter alia uuid (Universal Unique Identifier), Score, imei1 (International Mobile Equipment Identity), imei2, SW version, survey Language, Device name, Version, Source, Generic Parameters, Generic Parameters value, Date, First Boot Time, Offset Time, Market Name, Market Version, SKUID (Stock Keeping Unit Identifier), IP address, Cumulative Session Length, Feedback, MCC (Mobile Country Code), MNC (Mobile Network Code), Sim MCC (SIM Mobile Country Code), Sim MNC (SIM Mobile Network Code).
• Software Update Data 1, which may include inter alia Product Name, MCC (Mobile Country Code), MNC (Mobile Network Code), CTR, SKUID (Stock Keeping Unit Identifier), SW version (Software version), IMEI (International Mobile Equipment Identity).
• Software Update Data 2, which may include inter alia Device ID, SKU number (Stock Keeping Unit number), Firmware version, Language, Operator code, Product nickname, OS version, Location, APP Key, CellID.

Format of data:

• DA Data, NPS Data & Software Update Data 1: Data passed to the back-end server via a structured Json document (which stores unstructured data).
• Software Update Data 2: Data is in unstructured format.

Estimated volume:

• DA Data: Estimated total of 2.5KB during the lifetime of the connected product.
• NPS Data: Estimated total of 0.66KB during the lifetime of the connected product.
• Software Update Data 1: Estimation of 0.26KB per boot up of the connected product and again one month after each boot up.
• Software Update Data 2: Estimated total of 0.275KB per day.

How the data may be generated:

• DA Data: At specific intervals, i.e., when completing the first-time setup of the connected product 0, 6 and 24 hours after such completion, and in case the SIM card is changed.
• NPS Data: At specific intervals, i.e., when the NPS pop-up appears 7 (retry at 14), 56 (retry at 63), and 275 (retry at 283) days after the first-time setup of the connected product.
• Software Update Data1: Data may be generated after each boot up of the connected product and one month thereafter.
• Software Update Data 2: At specific intervals, i.e., once per day.

Data storage:

• DA Data, NPS Data & Software Update Data 1 and 2: On device and on a cloud platform.

Data retention period:

• DA Data: For any personal data included in the DA Data, please see HMD Global Privacy Policy for Products and Services and Phones and Tablets Supplement. For non-personal data included in the DA Data, the data is retained on cloud platform.
• NPS Data: For any personal data included in the DA Data, please see HMD Global Privacy Policy for Products and Services. For non-personal data included in the DA Data, the data is retained on cloud platform.
• Software Update Data 1 and 2: For any personal data included in the Software Update Data, please see HMD Global Privacy Policy for Products and Services and Phones and Tablets Supplement. For non-personal data included in the Software Update Data, the data is retained on cloud platform.

Access & retrieval by user:

• DA Data, NPS Data & Software Update Data 1 and 2: The data can be viewed in, as well as downloaded from, the settings of connected product.

Usage of product data by HMD:

• DA Data, NPS Data & Software Update Data 1 and 2: HMD may use the DA Data, NPS Data & Software Update Data for the purposes described in HMD Global Privacy Policy for Products and Services and Phones and Tablets Supplement.