Privacy Statement for Customer Service

This Privacy Statement applies to the collection and processing of your personal data when VIVO MOBILE INDIA PRIVATE LIMITED provides you with customer service (the “Service”) through our service center, website, contact center, or other channels. We care about your privacy and think it is important that you know why and how we process your personal data. In this Privacy Statement for Customer Service (the "Statement"), we therefore explain the following content:

1. Collection and Processing: what data we collect and how we use it;

2. Storage: how we will store your data;

3. Sharing and Transfer: how we share or transfer your data;

4. Your Rights: your rights and options with respect to your data;

5. Contact Us: how you can contact us with any further questions.

Please read the Statement carefully and make sure that you have understood our practices regarding your personal data before you consent and start using the Service. You are not obliged to consent to the processing of your data with respect to the Service, but please be aware of the following: IF YOU DO NOT AGREE TO THE STATEMENT OR IF YOU WITHDRAW YOUR CONSENT, YOU WILL NOT BE ABLE TO USE THE SERVICE.

1. Collection and Processing

Data and purposes:

•  Device Inspection and Repair

In the event of a malfunction or other abnormal problems with your devices, you can visit our official after-sales service centers for device inspection and repair. Some of our service centers also offer remote assistance services to better assist you in solving your problem. In order to provide you with the above services, we need to process your contact information (including your name, country/region, phone number, and email address) and device information (including the IMEI, EMMCID, Serial Number, device model, operating system information, usage information, error logs, and other information necessary to diagnose your device problems), to check the warranty period, diagnose your device problems, provide you with requested repair services and respond to your related queries.

When you use our Appointment Service, Delivery Repair Service, or Query of Repair Progress, we need to process the information you submitted on the page, including your contact information, detailed address, appointment time, device model, and problem description, to provide you with corresponding services.

Besides, we may need to process your contact information (such as phone number) and other information you provided voluntarily (such as verification codes) to verify your identity.

•  Account Login

Some of our services provide the account login function. When you log in to your account in the Service, we need to process your account information (such as the phone number or email address you used to register your account, account ID, nickname, and profile photo) to display your account information and verify your identity.

In order to provide you with the function of receiving and viewing coupons or other benefits, we may need to use your account information to associate the coupons or other benefits you receive with your account.

•  Contact Center Service

When you contact us via Hotline, email, Live Chat, social media, or other customer service channels, we need to process your contact information (such as your name, country/region, phone number, email address, or account information), device information, call recordings or history of communications with us, and other information you provide through the above channels, to respond to your request and solve your problem. We may use your contact information to contact you when necessary.

•  Warranty Service

When you purchase our device warranty services (such as extended warranty or screen crack warranty), we need to process your name, phone number, IMEI and other device identifiers or authentication codes to associate the warranty services you purchased with your devices and provide related query services.

•  Service Center Location and Navigation

When you use the Service Center or Appointment Service, in order to locate the Service Center near you and provide you with navigation service, we need to process your IP address.

•  Transaction Process

In order to complete the transaction with you, including the process, shipping, returning/exchanging, refunding, reviewing, and invoicing of ordering products or services, we need to collect your contact information, device information, and other information that we are required to collect under applicable law in order to fulfill our obligations under applicable law and for internal company management.

•  Customer Relationship Management

We need to process your data subject requests, consents, and customer interaction records to manage our relationship with you.

•  Customer Experience Improvement

We may use your contact details and other information you voluntarily provide (such as the nickname, gender, and physical address) to conduct customer surveys, which will help us to understand the quality of the customer service we provide to you and improve your experience.

In addition, we will also conduct statistical analysis based on the information collected during your use of this Service to further improve and optimize our products and services. Please note that during this process, the above data will only be used for statistical analysis and will not be used to associate or identify you.

We process the data for above purposes upon your consent to the Statement. However, other legal bases may be applicable on certain occasions.

Security:

We are committed to protecting your personal data. We have put in place appropriate security measures, including but not limited to encryption and anonymization techniques, which are designed to protect your personal data from unauthorized access, use, damage, or loss. We will do our best to protect your personal data. If you suspect any unauthorized access, use, damage, or loss of your personal data, please let us know immediately using the contact details set out below.

2. Storage

Period:

We will retain your personal data for the period necessary for the above purposes of processing, or as required by you or applicable laws. More concretely, we will retain:

•   Personal data processed for device inspection and repair and Contact Center service for up to five (5) years from completion of the repairing or your last interaction with us.

•   Personal data processed for account login for up to 180 days from the date of account cancellation.

•   Personal data processed for customer relationship management for up to five (5) years from your last interaction with us.

•   Personal data processed for customer surveys for up to six (6) months since the data was collected.

•   Personal data processed for invoicing or transaction purposes for seven (7) years from the date of issuing the invoice or completing the transaction.

Once the retention period expires, we will delete or anonymise your personal data, unless otherwise required by applicable laws and regulations.

Besides, we will not retain personal data processed for Service Center location and navigation on our server.

Location:

Your personal data will be stored on our server located in India.

3. Sharing and Transfer

We will either process your data ourselves or by use of our affiliated companies, service providers who act on our behalf, or others at your direction. However, we will not share personal data with third parties for their own marketing purposes. More specifically:

•   To the extent necessary to provide the Service you have requested, your personal data will be encrypted and transferred to our affiliated companies or service providers (including dealers, repair service providers, customer service providers, logistics service providers, etc.).

•   For customized devices of operators or enterprises, the device information will be encrypted and transferred to the corresponding operator or enterprise in accordance with your customization contracts with them or their instructions.

•   During the Identity Verification, your phone number will be encrypted and transferred to the following third-party service provider(s): PaaSoo Technology Limited, Orange Business Services Hong Kong Limited, and Firemsg International Co., Limited.

•   In order to provide you with Service Center Location and Navigation, your IP address will be encrypted and transferred to the following third-party service provider(s): Google Inc.

Please be aware that we have signed a data protection agreement with the aforementioned service provider(s) and they will provide protection for your data at a standard that is no less than ours. Otherwise, we will only share your data when required in response to a legal process or request from a competent authority according to applicable laws.

Your personal data will be processed on the server where it is stored. Normally, we would not transmit your personal data to another country/region that may not maintain appropriate data protection standards. Otherwise, we will take all reasonable measures to ensure adequate data protection as stipulated within this Statement and obtain your prior consent.

4. Your Rights

You have various rights with respect to the data which we hold about you.

Withdrawal of Consent:

You may at any time choose to withdraw your consent to this Statement by contacting us. If you withdraw your consent, we will stop processing your related data until you re-agree to such processing.

Other Rights:

To exercise your other rights (such as rectification, erasure, restriction of processing, objection or data portability, depending on applicable data protection laws), please use the contact details set out below.

Complaint:

You have the right to lodge a complaint with a supervisory authority.

5. Contact Us

If you have any questions about this Statement or our processing of your personal data, if you need to report a problem or contact our Data Protection Officer, or if you would like to exercise one of your rights under data protection and privacy laws, please use the contact details below. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection laws.

Address: https://privacy.vivo.com/in/privacyDSR

This Statement may be updated from time to time. We will notify you via an appropriate method of any significant changes.