Nubia Privacy Policy

I – INTRODUCTION

a.  This Privacy Policy constitutes how Nubia Technology Co., Ltd. and its affiliates (collectively as “Nubia”) collect, use, share, transfer and protect the personal information of the End-users (hereinafter referred to as “You” or “End-user”) and corresponding rights of End-user. Personal information refers to any information relating to a natural person that has been identified or is identifiable. Please let us know if you have any concerns regarding this area.

b.  This Privacy Policy shall apply to platforms on which it is displayed, including without limitation to Nubia site, products and/or services, and other platforms which link to this Privacy Policy. In case this Privacy Policy does not cover certain specific personal information processing scenarios, we will explain it to you in the form of supplementary policies or Pop-up windows.

c.  Nubia may process your personal information in necessary scenarios with reliable reasons, i.e. performing contracts and providing products and/or services to you, based on legitimate business interests with prior consent.

II – Personal Information May Be Collected by Nubia

In any scenario in which you interact with Nubia, we are likely to request you to provide certain personal information. If you don’t provide us with such relevant information, you may not be able to achieve the specific purpose for a particular scenario. Hereafter are some of scenarios where Nubia may collect your personal information:

a.  When you register for an account and purchase a Nubia product, you may provide relevant personal information, such as name, gender, phone number, email, mailing address, Zip code, consignee log, method of payment and bank account information, etc.

b.  Where permitted by applicable law, Nubia may also obtain data about you from third-party sources. For example, when you use a third-party network account to register for an account in Nubia or login to our website, Nubia may obtain your account information from such third-party network service company. Upon your choice of third-party network account, we may collect your WeChat account, QQ number, Alipay account, Facebook, Twitter or Google account information. In such cases, only account information will be obtained.

c.  When you activate and use a Nubia product, Nubia may also collect information about your device or software, such as device name and model, device ID (IMEI and SN), operating system version number, language selected for device, time zone, information of SIM card, Telecom carrier, serious error log of system and other necessary information.

d.  Network information, for example, on type and version of browser used when you login to Nubia online store, language, OS version, resolution, website operating elements, web IP address and web browsing information, as well as user behavior and other information collected by Nubia through cookies and other similar technologies.

e.  Location information regarding real-time from you or other users, including your geographic location, such as the region contained in the account information you have provided, as well as country information displayed by Telecommunications carrier code you use. Certain pre-loaded, location service-based apps such as maps, navigation and weather service apps will collect your location information with your prior consent.

f.  When your call our customer service center for assistance, Nubia may request for information on your name, phone number, product information and receiving time, and record your phone number of calls, date of call, problem encountered and solutions we provide to you.

g.  If you participate in one of Nubia offline product experience events, Nubia may also request for information on your name, gender, email address and phone number.

h.  Your information shared through Nubia Community, such as your personal photos uploaded, your thoughts and experiences shared through forums and friends, etc.

III – How Nubia May Use Personal Information

Nubia will use your personal information based on following legitimate purposes. If we use your personal information beyond following purposes or scope allowed by applicable law, we will obtain your consent again on the basis of special necessary.

a.   Used for authentication, security, fraud monitoring, archiving and backup purposes to ensure security of products and services provided to you by Nubia.

b.  Provide you with services such as order processing, receipt and delivery of goods, refund of payment for goods, after-sales maintenance, implementation of electronic security plans, push system upgrade information as well as other similar purposes.

c.  Help Nubia to improve products and services. For example, Nubia will analyze and study collected data to make user-friendly adjustments to its operating system and interface design in accordance with user characteristics. When you choose to send error details to Nubia, Nubia can modify the software according to certain specific error information, which will help to ensure that such similar software errors cannot occur again.

d.  Nubia may know about its regional distribution of product through receiving address of End-user and the country in which SIM card carrier is located, and adjust our after-sales service network layout, personnel, language and other details, so as to make it more convenient for End-users to purchase Nubia product and experience Nubia services.

e.  Upon your prior consent, Nubia may send you our latest product and service information, and may also send holiday greeting to you. Your may choose to unsubscribe at any time if you do not wish to continue receiving such similar information.

f.  Description of services based on location information, i.e. some pre-loaded apps in Nubia product provide services based on End-users’ precise or unique geographic location. These services are provided by third-parties independent of Nubia. Therefore, your personal information, including location, will be collected and processed by third-parties and not controlled and processed by Nubia. You can choose to turn off location-based services and refuse to share location information.

IV – How Nubia May Share Personal Information

a.  Nubia may disclose End-user personal information between affiliates or subsidiaries and ensure that the same level of protection is provided for such personal information by these affiliates and subsidiaries.

b.  Nubia may disclose your personal information to its partner under certain legitimate circumstances. For example, when your purchase Nubia product through Nubia online store, Nubia will disclose your product purchase and shipping details to our authorized logistics service vender.

c.  In addition, Nubia may disclose your information to public authorities with jurisdiction over territories in which we operate to provide personal information of End-users in compliance with applicable law or in performance of legal procedure.

d.  In any case of sharing your personal information with third-parties, Nubia will endeavor to disclose it to such third-parties only to the extent permitted by applicable law and Nubia require such data recipients to process and protect your personal information in compliance with applicable law and/or regulations.

e.  Nubia promises not in any way to sell personal data to any third-party and guarantees the legitimate and fair use of End-user information only to extent permitted by law.

V – How Nubia Protect and Transfer Personal Information

a.  Nubia will only retain End-user personal information for a period necessary for the purpose described in this Privacy Policy and as required by applicable law and/or regulations.

b.  Nubia uses various management policies (such as establishing information security system; signing a confidentiality agreement with information management employees; allowing only work-related employees to access such information collected; as well as other similar policies) and security techniques and procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) to prevent loss or leakage of information, improper use, and unauthorized reading or disclosure. For example, in some services, Nubia uses encryption technology (such as SSL) to protect personal information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to 100% guarantee security of information, even if all efforts are made to strengthen security measures. You need to understand that systems and communication networks you use to access Nubia services may be subject to problems that are beyond Nubia’s control.

c.  In case Nubia is informed that security of data it had acquired and stored is compromised or End-users’ personal information is disclosed to an unrelated third-party due to external acts (such as hacker attach), Nubia will take all reasonable actions, including without limitation to internal investigation, reporting to law enforcement agencies, and cooperating with law enforcement agency, as it may consider appropriate. Meanwhile, Nubia will take legitimate and reasonable steps as it deems appropriate to notify relevant End-users of the fact of information disclosure and extent to which Nubia are aware of such situation.

d.  End-user personal information may be transmitted and transferred across borders or regions, as well as be stored and processed in target country or region. Depending on applicable law in certain country or region, the receiving country and region of these data may not meet the requirements. Nubia promises that we will take all right security measures to ensure that the protection level of data can meet full requirements of applicable laws and regulations of End-user country and region.

VI – How End-user Access and Control Your Personal Information

a.  Nubia will do its utmost to take appropriate technical measures to ensure that End-user can access, update, correct and delete your own registration information or other personal information provided during using Nubia services. When End-user access, update, correct and delete the aforementioned information, you may be requested for authentication to protect information security.

b.  End-user can control your own personal information. For example, you can turn off location sharing button to cease sharing your device’s location information, or you can revoke prior consent for data collection and processing. However, please understand that once you make above choice, you may not be able to enjoy related services.

c.  Wherever required, End-user can contact Nubia through contact information provided in this Privacy Policy. If Nubia has a reasonable basis to believe that your request is fraudulent and/or cannot be verified, or certain personal data rights are not stipulated by applicable law in your country and region, Nubia may reject your request.

VII – Use of Cookies and Similar Technologies

a.  In order to ensure website works well, Nubia will use cookies and similar technologies such as pixel tags and website beacons. Cookies are plain text files that are stored on a computer or mobile device by web server. The content of cookies can only be retrieved or read by the server that creates is. Each cookie is unique to your web browser or mobile app. Cookies usually contains some identifiers, commonly-used information and other details. For example, you can reduce number of login authentications needed and improve your experience through cookies technology when browsing different web pages of Nubia Website. Or else, you may not be identified as the same person and may be asked to enter the full authentication information again if logging onto to Nubia website and then be requested to go to another web page of Nubia website.

b.  These technologies help Nubia and third-parties to better understand End-user behavior, and notify Nubia of which section of Nubia website you have browsed, as well as measure and improve the effectiveness of Nubia services. Nubia will not use cookies for any purposed other than reasons described in this policy. You can manage or delete cookies based on your own discretion. However, please note that certain Nubia services may be designed to require use of cookies and disabling cookies may affect your rights to use those services or some of their features.

c.  In addition to cookies, Nubia uses other similar technologies such as local storage, web beacons and pixel tags on its website. For example, local storage of HTML 5can cache frequently-used data related to you so that such data can be rendered to you quickly when you switch between two or more different web pages of Nubia website. One more example, an email sent to you may contain a click URL linked to content of the website, if you click on the link, such click will be tracked to help Nubia better understand your product and service preferences and then improve customer service. Web beacons are usually transparent images embedded in websites or email. With help of pixel tags in emails, Nubia can know whether the email content is effectively served to End-user.

VIII – Protection of Minors’ Personal Information

a.  Nubia product and services are primarily designed for adults. Anyone who is identified to be a minor customer under the law of country in which he/she is located must obtain consent from his or her parents or guardians before using our products and services upon purchase.

b.  Nubia value privacy protects of minors and encourages parents to always play an active role in their child’s online experience and consumption.

IX – Third-Party Service

a.  This Privacy Policy does not apply to products and services provided by third-parties. Nubia products and services may include products and services from third-parties, as well as links to third-party websites. When End-user uses these third-party products or services, the privacy policy of third-party on personal information shall apply.

b.  Nubia shall not be responsible for how third-parties collect, use, share, transfer and protect End-users personal information, and cannot control how it is processed.

c.  To avoid any potential misunderstandings, please refer to the specific third-party’s service agreement and read carefully about its privacy policy.

X – Changes and Modifications

a.  End-user may request a copy of this Privacy Policy from Nubia by using below listed contact details. Nubia may amend or update this Privacy Policy from time to time, if any. End-user will be able to see Nubia latest updated privacy policy along with its revision date on website: (www.nubia.com/en/privacy). The revised privacy policy will take effect from its date of publication. Please check the Privacy Policy from time to time to confirm whether Nubia had made any changes with reference to use of personal information.

b.  If any changes to this Privacy Policy have a material impact on your rights, Nubia will take reasonable measures to notify you of such changes.

XI – Notification and Delivery

a.  Any notice form Nubia will be sent to the email address, phone number, and/or mailing address left when End-user register for an account or purchase of Nubia product, or pushed directly through mobile phone system. If sent via electronic methods, notice shall be deemed served when your device of certain used electronic system received the message; if sent by courier, it shall be deemed served on the third day after sending out.

b.  If you have any question, comments, suggestions and/concerns about this Privacy Policy of Nubia products or services, please feel free to give a feedback to us. Nubia contact information is:

c.  Nubia contact information is:
Email address: privacy@nubia.com
Mailing address: 10 Floor, Tower A, Han’s Innovation Mansion, No.9018 North Ring Road, Hi-Tech Industrial Park, Nanshan District, Shenzhen, P.R. China 518057 Telephone: +86 755 86360200

XII – Version Information

This Privacy Policy is upgraded on May 2018.