vivo Data Policy

vivo (collectively, "we", "us", or "our") is the manufacturer and provider of vivo products (including smartphones, earphones, and other connected products), and is also the organization responsible for processing data related to vivo products. For fulfilment of the transparency obligations under the EU Data Act, in this vivo Data Policy (referred to as "this Policy"), we therefore cover the following content:

1. Data: What data do vivo products and related services generate? How is such data generated?

2. Storage: How is such data stored?

3. Using, Sharing and Transfer: How we use, share or transfer such data?

4. Your Rights: What rights and options do you hold with respect to such data?

5. Contact Us: How to contact us?

We have formulated and publicly released the vivo Privacy Policy (referred to as the "Privacy Policy"). Our Privacy Policy explains how we collect, use, store, share, transfer or otherwise process your personal data according to applicable personal data protection legislation, as well as your rights with respect to the personal data about you when you use our products and accessories, applications, operating system, websites, and other products or services. Therefore, in this policy, we will primarily provide details regarding data generated by vivo products and related services (referred to as "data"). For details regarding personal data, please refer to our Privacy Policy. You can access our latest Privacy Policy at: https://www.vivo.com/global/about-vivo/privacy-policy.

For more information on connected products and related services, please refer to the product manual and the user agreement or terms of use in the settings of relevant service.

1. Data

In order to provide you with our products or services, vivo products and related services generate various types of data. Depending on the products or services you choose to use, such data may include the following categories:

(1) Device and system information:

Device identifiers (such as IMEI, serial number, eMMC ID, UFS ID, MAC address, GAID, GUID, Android ID, etc.), device manufacturer and device model, country or region code, software version, operating system information, customization information, language and other settings, device hardware information (temperature, CPU information, screen configuration and parameters, etc.), device activation time, device usage, and other necessary information.

(2) Application software information:

Such as the list of installed applications, application identifiers, application names, application versions and status, application usage, etc.

(3) SIM card information:

Such as SIM card serial number, IMSI, phone number, mobile operators, etc.

(4) Account information: 

Such as account registration information (including the phone number or email address used to register the account), account ID, username, profile photo, account login status, and login history. 

(5) Network information: 

Such as IP (Internet Protocol) address, cell ID of the area where the device is located, network type, network connection status, etc. 

(6) Sensor data: 

Such as location, motion, environmental readings, etc.

(7) Location information: 

When you access certain location-based services (such as using navigation software, or viewing the weather for a specific location), the relevant services may need to obtain the approximate or precise location of your device. Such information may be obtained through the GPS, Wi-Fi, or service provider network ID. You can refuse to share your device's location information by disabling location services or limiting the access of certain applications and features in Settings.

(8) Log information: 

When you use products or related services, we need to retain information related to your use of certain features, applications, and websites. This may include information related to Cookies and other local storage technologies, IP addresses, network request information, temporary message history, standard system logs, crash information, and log information generated when using a service (such as registration time, access time, activity time, etc.).

(9) Other data generated during your use: 

For example, when you use the Phone feature, call records are generated; when you use the Camera feature, photos are generated; when you use the Recorder feature, audio information are generated; when you use the Note feature to input text, files are generated; when you use the Face or Fingerprint feature to enter biometric data, corresponding facial and fingerprint feature information is generated. Generally, such data will only be processed on your device and will not be uploaded to our servers. You can decide how to manage and use such data.

Such data is typically generated continuously while you use products or relevant services. The estimated volume of data generated depends on usage patterns but may range from several megabytes to several gigabytes per month. When you stop using the product/service or cancel the service, the product and relevant services will gradually stop generating data.

2. Storage

Such data is typically stored in standardized, machine-readable formats such as CSV, JSON, or proprietary app databases.

Data may be stored:

－ On-device (internal storage or SD card)；

－ On remote servers (cloud backup, app servers) if cloud features or remote services are enabled.

The retention period depends on device settings, app configurations, and user choices. For example, call logs and messages may be kept until deleted by the user, while some data (e.g., temporary files) may be automatically cleared after a set period.

3. Using, Sharing and Transfer

We may use data generated by vivo products and related services to fulfill the following purposes:

(1) To provide the products and services you need

We use such data to (i) provide, maintain, update, improve, protect and develop all of our services, products, content, analyze and solve abnormal issues; (ii) interact with you about your products, services, or any of your questions and requests; (iii) identify risk and ensure security of your service account, and improve our loss prevention and anti-fraud programs; (iv) judge software compatibility, provide customized products or services.

(2) To carry out necessary internal audit, data analysis and service evaluation

We use the aggregated user usage information to analyze service performance, compile reports or conduct evaluations, such as service satisfaction evaluation, product usage statistics and product sales statistics, in order to provide our customers with better products and services, and optimize our resources and its management.

(3) For compliance with legal obligations

To comply with applicable law or a lawful governmental request, such as retaining transaction information, and satisfying tax or reporting obligations.

(4) For other legitimate purposes

Other purposes described in the specific terms or statement.

Such data may be shared with third parties only with your explicit consent or as required by law. You will be informed about potential data recipients and the conditions of data sharing before any such transfer occurs.

You acknowledge and agree that in order to provide you with products or relevant services, such data may be shared in the following circumstances:

(1) Entrusted processing 

We will process such data by ourselves, or by entrusting our affiliates and service providers to process such data in accordance with our instructions. We will sign agreements with relevant companies to ensure that their processing practices comply with this Policy and provide protection for your data at a standard that is no less than ours.

(2) Service provision and statistics 

In order to ensure the provision of specific features to you, or to complete the statistic and settlement of advertising service, we may provide such data to the corresponding service providers or other parties designated by you, including advertising companies, logistics companies, online service providers, e-commerce platforms, third-party technical service providers, mobile operators, etc. We require data recipients to comply with applicable data protection laws and to take necessary and reasonable measures to protect such data.

(3) Legal compliance

We may be required to disclose such data by local judicial or governmental authorities, agencies, or as mandated under applicable laws.

(4) Change of control 

In the event of any actual or prospective merger, restructuring or sale, we may need to provide such data to related third parties. We will send prior notifications to you to specify the recipients' names and contact information, and require them to abide by this Policy when processing your data. 

(5) Public disclosure

We will publicly disclose such data only in the following cases: (i) after obtaining your consent; (ii) on legal or reasonable grounds: we may disclose such data when required by laws, legal procedures, litigation, or at the request of public and government authorities.

Please be aware that our products or services may include third-party products or services. Third-party data use is subject to laws, regulations, and their data policies. We are not responsible for and cannot control how such third parties use your data. We recommend that you read and understand the third-party data policies before using such products or services and decide whether to use them. You use these third-party products or services at your own risk.

4. Your rights

Under the EU Data Act, users have the right to access, obtain, erase, and share data generated by connected products and related services with third parties or to stop sharing data. You also have the right to lodge a complaint with a supervisory authority.

In order to exercise the above rights, you may send your request by visiting our Data Support Website. We will respond to your request without undue delay. 

Upon your request, we will confirm whether we hold or are processing the data generated by connected products and related services. Under some circumstances, we will not be able to fulfill your request, such as if we cannot verify your identify, it interferes with our legal obligations, the data involved contains our trade secrets, it may harm the interests or rights of others, or it involves disproportionate cost or effort. But in any event, we will respond to your request within a reasonable timeframe and provide you with an explanation. 

Please note that we may retain records of our communications with you and other information regarding your exercise of your rights.

5. Contact us

If you have any questions about this Policy or if you would like to exercise your rights under applicable laws, please tap here to visit our Data Support Website. We will seek to deal with your request without undue delay and within any time limits provided for in applicable laws.

Our addresses: vivo Mobile Communication Co., Ltd., registered at No.1, vivo Road, Chang'an, Dongguan, Guangdong, China

Our representative in the European Economic Area: vivo Mobile Communication Iberia S.L., registered at Calle Orense 58, Planta 12 - C, 28020 Madrid, Spain

We reserve the right to update our Policy at any time. This Policy may be updated from time to time to reflect changes in our practices or changes in applicable laws. We will notify you of any material changes in an appropriate manner, and we will update the "last updated" date at the top of this Policy. You may access our latest Data Policy at the bottom of the vivo official website.