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PRIVACY NOTICE

Last updated: 18 June 2021


SUPPLEMENTAL PRIVACY NOTICES

 * California Consumer Privacy Act Supplement


SUPPLEMENTARY LANGUAGES

 * Finnish
 * Chinese
 * French
 * German
 * Japanese
 * Spanish


WHO WE ARE

Nokia is a global company that is made up of many legal entities.  Excluding
those legal entities that have their own separate privacy notices, this privacy
notice applies to all legal entities within the Nokia group of companies. 


WE CARE ABOUT YOUR PRIVACY

Nokia respects your privacy and we are committed to protecting it. For your
understanding and reference, this privacy notice describes how we collect, use
and disclose personal data.

Here you will find our privacy practices in connection with the websites we
operate, the software applications we make available for use through computers
and mobile devices, our social media pages, email messages we send to users of
Nokia brand licensed products and services (such as Nokia branded phones and
tablets) and offline business interactions with you.  Collectively, we refer to
the websites, apps, social media pages, emails (including to users of Nokia
brand licensed products and services), and offline business interactions as the
“services.” 

This privacy notice does not apply to personal data collected and processed by
Nokia brand licensed products and/or services (such as Nokia branded phones and
tablets). These products and services are manufactured and sold by Nokia
brand licensees (such as HMD Global Oy) as authorized third parties.
Please consult the relevant licensee’s respective privacy notices regarding
these products and services for information on how they use personal data.
However, please note that Nokia may provide a service to communicate information
about such products and services to you, and in connection with those
activities, we may collect and process personal data from you as further
clarified below.

You are not required to provide personal data to Nokia. Please keep in mind that
if you choose not to provide your personal data to Nokia, we may not be able to
provide you with either our products or services or all of their functionalities
or to respond to queries you may have.

We may provide supplements to this notice providing additional and/or updated
privacy information regarding our privacy practices that are specific to a
product or service. Our products or services may contain links to other
companies’ websites and services that have privacy notices of their own. Please
access those notices to understand their privacy practices which are outside our
responsibility.

What personal data do we collect?

Personal data is information that identifies you as an individual or relates to
an identifiable individual. Personal data we may collect includes:

 * Name

 * Postal Address (including billing and shipping addresses)

 * Telephone number

 * Email address

 * IP address (we may also derive your approximate location from your IP
   address)

 * Payment card data or bank account number

We and our services collect and use personal data in a variety of ways,
including: 


THROUGH PRODUCT AND SERVICE ACTIVATIONS

Nokia products and services may require electronic activation, where your device
and application type, as well as unique device, application, network and
subscription identifiers are sent to Nokia.


THROUGH THE PRODUCTS AND SERVICES

When you access our services online, our web servers automatically create
records of your visit. These records typically may include IP-address, access
times, the sites linked from, pages visited, the links and features used, the
content viewed or requested, browser or application type, language and other
such information. See also our Cookies & Similar Technologies Notice. Our
applications may contact our servers periodically, for example to check for
updates or to send us information relating to service usage. Additionally, we
may invite you to join voluntary product and service improvement or research
programs where detailed information is collected from participants. 


INFORMATION YOU PROVIDE US WITH

When you create an account, make a purchase, request services, participate in
research or campaigns or otherwise interact with us, we may ask for information
such as your name, email address, phone number, street address, user names and
passwords, feedback, information relating to your devices, age, gender, and
language, bank account number, credit card details and other such financial
information. We also maintain records of your consents, preferences and settings
that may include location data, marketing and the sharing of personal data.


YOUR TRANSACTIONS WITH US

We maintain records of your purchases, downloads, the content you have provided
us with, your requests, agreements between you and Nokia, the products and
services provided to you, payment and delivery details, as well as your
interactions with us. We may, in accordance with applicable law, record your
communication with our customer care team or with other such contact points
(including communications with our brand licensees).


FROM THIRD-PARTY SOURCES

We receive your personal data from third-party sources, for example publicly
available databases and joint marketing partners that share information with us.

Third party service providers that assist us with our business operations also
collect and use information through the services they provide and also may share
the collected information with us. For example, our suppliers collect and share
information with us to analyze use of the services, to help us detect and
prevent fraud and to improve user experience.

When and how do we use and share your personal data?

We and our service providers use personal data for the following purposes:


PROVIDING THE FUNCTIONALITY OF PRODUCTS AND SERVICES AND FULFILLING YOUR
REQUESTS

We use your personal data to provide you with our products and services, to
process your requests or as otherwise may be necessary to perform the contract
between you and Nokia. This may include the need to ensure the functionality and
security of our products and services, to identify you in order to provide the
product or service and to prevent and investigate fraud and other misuses. We
will engage in these activities to manage our contractual relationship with you
and/or to comply with a legal obligation.


CREATING ACCOUNTS

Some services may require an account to help you manage your content and
preferences. We will engage in these activities to manage our contractual
relationship with you and/or to comply with a legal obligation.


DEVELOPING AND MANAGING PRODUCTS AND SERVICES

We use personal data to develop and manage our products, services, customer
care, sales and marketing. We engage in these activities to manage our
contractual relationship with you, to comply with a legal obligation, and/or
based on our legitimate interest including product development and quality
control.


COMMUNICATING WITH YOU

We use personal data to communicate with you, for example to inform you that our
services have changed or to send you critical alerts and other such notices
relating to our products and/or services, or products and/or services offered by
our brand licensees, and to contact you for customer-care related purposes. We
will engage in these activities to manage our contractual relationship with you,
for our legitimate interests and/or to comply with a legal obligation.


MARKETING, ADVERTISING AND MAKING RECOMMENDATIONS

We use your personal data to contact you to inform you of new products, services
or promotions we may offer, to connect you with our licensees that offer Nokia
branded products and/or services and to conduct market research. We will engage
in this activity with your consent or where we have a legitimate interest.


ANALYZING PERSONAL DATA FOR BUSINESS REPORTING AND PROVIDING PERSONALIZED
SERVICES

We use personal data to personalize our offerings so that they match your
specific situation and to provide you with more relevant services, for example,
to make recommendations and to display customized content and advertising in our
services. This may include displaying Nokia and third-party content (such as
Nokia branded products by our licensees). We will provide personalized services
based on our legitimate interests, and with your consent to the extent required
by applicable law.


AGGREGATING AND/OR MAKING YOUR PERSONAL DATA ANONYMOUS

We may aggregate and/or anonymize personal data so that it no longer relates to
an identified or identifiable person. We do so to generate other data that we
may use and disclose for any purpose, as it no longer is personal data.


ACCOMPLISHING OUR BUSINESS PURPOSES

We employ data analysis based upon personal data for an extensive list of
purposes including:

 * Improving the efficiency of our services

 * Conducting audits to verify that our internal processes function as intended
   and to address legal, regulatory, or contractual requirements

 * Preventing fraud and monitoring for fraud security purposes, for example, to
   detect and prevent cyberattacks or attempts to commit identity theft

 * Enhancing, improving, repairing, maintaining, or modifying our current
   products and services, as well as undertaking quality and safety assurance
   measures

 * Identifying usage trends, for example, understanding which parts of our
   services are of most interest to users; determining the effectiveness of our
   promotional campaigns, so that we can adapt our campaigns to the needs and
   interests of our users

 * Operating and expanding our business activities, for example, understanding
   which parts of our services are of most interest to our users so we can focus
   our energies on meeting our users’ interests

We engage in these activities to manage our contractual relationship with you,
to comply with a legal obligation, and/or based on our legitimate interest.

When and how do we share personal data?

We disclose personal data:


TO OUR AFFILIATES FOR THE PURPOSES DESCRIBED IN THIS NOTICE 

We provide our affiliates (see list) with access to your personal data to use in
the ways described in this notice. Our affiliates will be responsible for
addressing any questions or requests you have regarding their use of personal
data shared with them, and in some cases the response may also come from the
central Nokia team.


BY USING OUR SERVICES, YOU MAY ELECT TO DISCLOSE PERSONAL DATA

Some of our products and services allow you to share your personal data with
other users of the product or service, or with other services and their users.
Please use your judgment before disclosing any personal data or other
information that might be accessible to other users.


TO AUTHORIZED THIRD PARTIES 

We may share your personal data with other authorized third parties (including
Nokia brand licensees) that process personal data for Nokia for the purposes
described in this notice. This may include, for example, billing through your
network service provider or otherwise, delivery of your purchases; providing
services including customer service; managing and analyzing consumer data;
credit checks; conducting research and managing marketing and other such
campaigns.


INTERNATIONAL TRANSFERS OF PERSONAL DATA

Our products and services may be provided using resources and servers located in
various countries around the world. It is possible that your personal data may
be transferred across international borders including to countries outside the
European Economic Area (EEA) that do not have laws providing specific protection
for personal data or that have different legal rules on data protection. In
certain circumstances, courts, law enforcement agencies, regulatory agencies or
security authorities in those other countries may be entitled to access your
personal data. To address concerns about transfers from the UK or EEA to
countries not considered adequate by the European Commission, we have
implemented appropriate measures to protect your personal data.  For example, we
use standard contractual clauses adopted by the European Commission and binding
corporate rules and we require the use of appropriate technical and
organizational information security measures.

We also use and disclose your personal data when we have a legal obligation or
legitimate interest in doing so:


TO COMPLY WITH APPLICABLE LAWS AND REGULATIONS

This may include laws outside your country of residence.


TO COOPERATE WITH PUBLIC AND GOVERNMENT AUTHORITIES

We may disclose your personal data to respond to a request from authorities or
to provide information we believe is necessary or appropriate. These can include
authorities outside your country of residence.


TO COOPERATE WITH LAW ENFORCEMENT

We may disclose your personal data to certain authorities or other third
parties, for example, to law enforcement agencies in the countries where we, or
third parties acting on our behalf, operate.


FOR OTHER LEGAL REASONS

We may also disclose and otherwise process your personal data in accordance with
applicable law to defend Nokia’s legitimate interests, for example, in civil or
criminal legal proceedings.


IN CONNECTION WITH A SALE OR BUSINESS TRANSACTION

If we decide to sell, buy, merge or otherwise reorganize our businesses in
certain countries, this may involve us disclosing personal data to prospective
or actual purchasers and their advisers, or receiving personal data from sellers
and their advisers.

What other information do we collect?

Other information is any information that does not reveal your specific identity
or does not directly relate to any individual’s identity. We may collect other
information such as:

 * Browser and device information such as your Media Access Control (MAC)
   address, computer type (Windows or Mac)

 * Applications usage data

 * Information collected through cookies, web beacons and other similar
   technologies

 * Demographic information and other information provided by you that does not
   reveal your specific identity

 * Information that has been aggregated in a manner such that it no longer
   reveals your specific identity

We and our service providers may collect other information in a variety of ways
including: 

 * Your browser or device
   Certain information is collected by most browsers or automatically through
   your device, such as your MAC address, computer type (Windows or Mac), screen
   resolution, operating system name and version, device manufacturer and model,
   language, internet browser type and version and the name and version of the
   services (such as the app) you are using.  We use this information to ensure
   that the services we provide function properly.  

 * Your use of our applications
   When you download and use our applications, we and our service providers may
   track and collect applications usage data, such as the date and time the
   applications on your device accesses our servers and what information and
   files have been downloaded to the applications based on your device number.
   When you download and use our applications, we and our service providers may
   track and collect applications usage data, such as the date and time the
   applications on your device accesses our servers and what information and
   files have been downloaded to the applications based on your device number.

 * Cookies and Web Beacons
   Nokia uses cookies, web beacons and other similar technologies to operate and
   improve our websites and offerings. We also use cookies for personalization
   and to display advertisements. Some Nokia websites use third party
   advertising technologies to present ads. Our domains may include third party
   elements that set cookies on behalf of a third party, for example relating to
   third party social network. Please visit our Cookies & Similar
   Technologies Notice to find out more about how Nokia uses cookies and how you
   can disable cookies by browser settings or by other means.

We may use and disclose other information for any purpose, except where we are
required to do otherwise by law. If we are required to treat other information
as personal data under applicable law, we may use and disclose it for the
purposes for which we use and disclose personal information as described in this
notice. In some instances, we may combine what we define as other information
with personal data. If we do, we will treat the combined information as personal
data for as long as it is combined.

Third-party services

This notice does not address, and we are not responsible for, the privacy,
information, or other practices of any third parties, including any third party
operating any website or service to which our services link.  The inclusion of a
link on our services sites does not imply endorsement of the linked site or
service by us or by our affiliates.  In addition, we are not responsible for the
information collection, use, disclosure, or security policies or practices of
other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any
other application developer, application provider, social media platform
provider, operating system provider, wireless service provider, or device
manufacturer, including with respect to any personal data you disclose to other
organizations through or in connection with the applications or our social media
pages.

Third-party advertising

We use third-party advertising companies to place advertisements regarding goods
and services that may be of interest to you when you access and use our services
and other websites or online services.  You may receive advertisements based on
information relating to your access to and use of our services and other
websites or online services on any of your devices, as well as on information
received from third parties.  These companies place or recognize a unique cookie
on your browser (including using pixel tags).  They also use these technologies,
along with information they collect about your online use, to recognize you
across the devices you use, such as a mobile phone and a laptop.  If you would
like more information about this practice, and to learn how to opt out of it in
desktop and mobile browsers on the particular device on which you are accessing
this notice, please
visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.
You may download the AppChoices app at www.aboutads.info/appchoices to opt out
in mobile apps.

How do we address the privacy of children?

Nokia’s products and services are not intended for use by children. If you are
under the age of majority in your place of residence, you may use Nokia products
and services only with the consent of or under the supervision of your parent or
legal guardian. Consistent with the requirements of the US Children’s Online
Privacy Protection Act (COPPA), if we learn that a child under age 13 has
provided personal data to or through the products or services without first
receiving their parent’s verified consent, we will dispose of such personal
data.

If you believe Nokia may have collected any information from a child under age
13, please contact our Privacy Office by using the form available here - Contact
us – and selecting “Privacy” as the relevant category for the question or
feedback.

How do we address data quality?

 * We take reasonable steps to keep the personal data we possess accurate and to
   delete incorrect or unnecessary personal data. We retain personal data for as
   long as needed or permitted to fulfill the purposes outlined in this notice
   or otherwise communicated to you, unless a longer period is required by law.

 * The criteria used to determine our retention periods include: 
   
   * The length of time we have an ongoing relationship with you and provide the
     products or services to you (for example, for as long as you have an
     account with us or keep using the services)
   
   * Whether there is a legal obligation to which we are subject (for example,
     certain laws require us to keep records of your transactions for a certain
     period of time before we can delete them)
   
   * Whether retention is advisable in light of our legal position (such as in
     regard to applicable statutes of limitations, litigation or regulatory
     investigations)

 

We encourage you to access your personal data through your account from time to
time to help us ensure that it is up to date.

The steps we take to safeguard your personal data

Privacy and security are key considerations for us in the creation and delivery
of our products and services. We take appropriate steps to address online
security, physical security, risk of data loss and other such risks.  We take
into consideration the risk represented by the processing of your personal data
and the nature of the data being protected. Also, we only give access to our
databases containing personal data to authorized persons with a justified need
to access such information. Unfortunately, no data transmission or storage
system can be guaranteed to be 100% secure. If you have reason to believe that
your interaction with us is no longer secure, please immediately notify us by
using the form available here - Contact us – and selecting “Privacy” as the
relevant category for the question or feedback.

You may choose to unsubscribe from direct marketing

You may unsubscribe from direct marketing messages and to request that we stop
processing your personal data for direct marketing purposes by using the links
provided to you with the direct marketing messages you have received. Please
note that critical alerts may still be sent to you even if you opt-out from
marketing and other communications from Nokia.

How can you access, change or delete your personal data?

If you would like to request to access, correct, update, suppress, restrict, or
delete personal data, object to or opt out of the processing of personal data,
or if you would like to request to receive a copy of your personal data for
purposes of transmitting it to another company (to the extent these rights are
provided to you by applicable law),  you may do so by managing your account and
choices through our products and services or by  contacting us using the form
available here - Contact us – and selecting “Privacy” as the relevant category
for the question or feedback. We will respond to your request consistent with
applicable law.  

If you are a California resident, please refer to the “Additional Information
Regarding California” section below for more information about the requests you
may make under the California Consumer Privacy Act (CCPA).

In your request, please make clear what personal data you would like to have
changed or whether you would like to have your personal data suppressed from our
database. For your protection, we only implement requests with respect to the
personal data associated with the particular email address that you use to send
us your request, and we may need to verify your identity before implementing
your request. We will try to comply with your request in a timely manner to the
best of our ability. In some cases, if you withdraw your consent or wish us to
delete or stop processing your personal data we may not be able to continue to
provide the services to you.

If you are not satisfied with what we provide in response to your request(s),
you can let us know by contacting us using the form available here - Contact
us – and selecting “Privacy” as the relevant category for the question or
feedback. If you are still dissatisfied, you may also lodge a complaint with an
EU/EEA data protection authority for your country or region where you reside or
your place of work or where an alleged infringement of applicable data
protection law occurs. A list of EU/ EEA data protection authorities is
available
at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Contacting us

If you are using a Nokia product or service, Nokia Corporation of Karakaari 7,
02610 Espoo, Finland is the controller of your personal data.

In addition, the Nokia affiliate providing the product or service may be a
controller of your personal data. You may find the identity of the controller
and contact details by reviewing the terms and conditions of such a product or
service or by using contact information provided in the applicable Nokia
websites where such products or services are offered.

In matters pertaining to Nokia’s privacy practices you may also contact us or
our Group Data Protection Officer at:

Nokia Corporation c/o Privacy
Karakaari 7
P.O. Box 226
FI-00045 Nokia Group
Finland

You may contact us by using the form available here - Contact us – and selecting
“Privacy” as the relevant category for the question or feedback. 

Please do not include credit card or other sensitive information in your email
to us.  Please only send sensitive personal data if we specifically request it. 

Changes to this privacy notice

The LAST UPDATED  text at the top of this privacy notice indicates when it was
last revised. Nokia may change this notice at any time with or without notice.
Any changes will become effective when we post the revised privacy notice on
this site’s home page. We recommend that you re-visit this notice from time to
time to learn of any such changes.  If this notice is changed in a material way,
Nokia will add text advising of such change at the beginning of this notice and
on this site's home page for 30 days.

Additional information regarding California

California Consumer Privacy Act Supplement

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