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 smartphone or tablet 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 phone identification number (IMEI), international mobile subscriber (IMSI), unique device identifiers & information, network & SIM operator identifiers, IP address and location.
• Net Promoter Score Data (“NPS Data”), which may include inter alia phone identification number (IMEI), unique device identifiers & information, network & SIM network identifiers, IP address, recommendation score and feedback provided by user.

Format of data:

• DA Data & NPS Data: Data passed to the back-end server via a structured Json document (which stores unstructured data).

Estimated volume:

• DA Data: Estimated total of 4KB during the lifetime of the connected product.
• NPS Data: Estimated total of 12KB during the lifetime of the connected product.

How the data may be generated:

• DA Data: At specific intervals, i.e., when completing the first-time setup of the connected product, 6 and 24 hours post such completion, and in case SIM is changed.
• NPS Data: At specific intervals, i.e., when the NPS pop-up appears 7, 56 and 275 days after the first-time setup of the connected product.

Data storage:

• DA Data & NPS Data: 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.

Access & retrieval by user:

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

Usage of product data by HMD:

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