Language Option
German：https://ztedevices.com/en-eu/legal/zte-smart-life-de
Finnish: https://ztedevices.com/en-eu/legal/zte-smart-life-fi
Swedish：https://ztedevices.com/en-eu/legal/zte-smart-life-se
Chinese：https://ztedevices.com/en-eu/legal/zte-smart-life-cn
Updated：Aug 31, 2023
This policy applies only to ZTE Deutschland GmbH（Hereinafter referred to as "we"） ZTE Smart Life (and all third-party applications or services accessed by them). If a third-party application or service has a separate privacy policy, the privacy policy of the application or service is applied preferentially. For the contents that are not covered by the application or service privacy policy, refer to this privacy policy.
This Privacy Policy is available in other languages. If there is any inconsistency, the English version shall prevail.
If you have any questions, comments, or suggestions, please contact us through the following means:
E-mail: [email protected]
Company Name: ZTE Deutschland GmbH
Registered Address: Fritz-Vomfelde-Straße 26, D-40547 Düsseldorf. Germany
We understands the importance of personal information to you, and will make every effort to ensure the security and reliability of your personal information. We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: consistency of authority and responsibility, clear purpose, selection of consent, minimum sufficiency, security, subject participation, openness and transparency. Meanwhile, We promises to take appropriate security measures to protect your personal information in accordance with well-established security standards in the industry.
Please read and understand this Privacy Policy carefully before using our products or services.
This policy helps you understand the following:
I. How we collect e your personal information
II. How we share, transfer, and disclose your personal information
III. How we use cookies and similar technologies
IV. How we protect your personal information
V. Your rights
VI. How we process the personal information of children
VII. How to transfer your personal information around the world
VIII. GDPR-Specific Provisions
IX. How to update this policy
X. Contact us
I. How we collect e your personal information
Personal information refers to the information that is recorded electronically or in other ways and that can be used independently or in conjunction with other information to identify a specific natural person or reflect the activities of a specific natural person. ZTE will collect and use your personal information only for the following purposes described in this policy:
1. Basic functions:
(1) Business function 1: Region settings
To access region-specific services, you must select your region when using the app (options currently available include: Sweden, Finland, Norway, Denmark, Iceland, among other countries or regions).
The above information provided by you will continue to be authorized to us for use while you are using this service. When you clear app storage space, we will stop using any information collected and promptly delete it. Information of this kind will not be stored on servers.
（2） Business function 2：Accounts from outside China
To enable remote device management, you need to register and log in using the Overseas ZTE Smart Life account from outside China.
To register/log in, you need to provide the following information: email/username, account password, region, and verification code.
You can manage personal information such as email, username, and password in your account.
You can also cancel your account. To do so, you need to provide a verification code and the account password for identity verification.
The above information provided by you will continue to be authorized to us for use while you are using this service.
Once you cancel your account, we will stop using the information collected and either delete or anonymize it. All information collected besides the verification code will be stored on the rented Alibaba Cloud (deployed in Frankfurt, Germany). For troubleshooting and other necessary processing scenarios, our affiliate company, ZTE Corporation, may access the server from China. If you agree to this Privacy Policy, then you also agree to authorize us to cross-border processing your above information.
Personal information storage period: Until the user cancels the account.
（3） Business function 3：Smart device discovery and binding
To manage smart devices remotely and bind the device, you will need to provide the following information: device information — model of the device to be added, device name, MAC address, and its SN (or IMEI), device network information — SSID and BSSID (location permissions must be granted for this).
To discover devices by scanning the device QR code, you must also provide the device QR code and grant camera permissions.
The above information provided by you will continue to be authorized to us for use while you are using this service.Once you have unbound a device, we will stop using the information collected and either delete or anonymize it. All information collected besides the verification code will be stored on the rented Alibaba Cloud (deployed in Frankfurt, Germany). For troubleshooting and other necessary processing scenarios, our affiliate company, ZTE Corporation, may access the server from China. If you agree to this Privacy Policy, then you also agree to authorize us to cross-border processing your above information.
Personal information storage period: Until the user unbinds the device.
（4） Business function 4：Smart device management
To facilitate the management of smart devices, you will need to provide the following information: device IP address and device SN (or IMEI); device functionality status — traffic information and information about connected devices (e.g., IP, MAC address); device service parameters — network configuration information, used to check the operational status of the device or to set device parameters.
The above information provided by you will continue to be authorized to us for use while you are using this service. The above information will not be stored on servers.
2. Non-basic functions:：
（1） Business function 1：Smart device firmware upgrade
To enable the device firmware upgrade function, you will need to provide the following information: device firmware version number and status of the automatic firmware detection switch; new firmware version information — version number, version description, size of the update package, and last update time; device SN (or IMEI), device manufacturer, and device model.
The above information provided by you will continue to be authorized to us for use while you are using this service. The above information will not be stored on servers.
（2） Business function 2：Application upgrade
To facilitate the application version upgrade function, you will need to provide the following information: the version of the application software and its package name.
The above information provided by you will continue to be authorized to us for use while you are using this service. The above information will not be stored on servers.
（3） Business function 3：User Experience Improvement Program
So that we can continue to improve the user experience of this application, we have created a User Experience Improvement Program, for which you will need to provide the following information: IP address of the user terminal, operating system name, mobile phone model, screen resolution, application software version, and usage behavior records of user browsing and click actions within the Smart Life App.
The above information provided by you will continue to be authorized to us for use while you are using this service. Once you disable this function, we will stop using the information collected and either delete or anonymize it. The information mentioned is stored on Firebase Analytics Servers, with data from the Nordic region stored within Europe. For the purpose of analytics and other necessary processing, our affiliate company, ZTE Corporation, will access the information from China. However, only analytics reports with anonymized data will be transferred to China. If you agree to this Privacy Policy, then you also agree to authorize us to cross-border processing your above information.
Personal information storage period: Data is retained for 30 days, after which it is anonymized.
If we want to use the information for other purposes not specified in this policy, we will seek your approval in advance. If we want to use the information collected for specific purposes for other purposes, we will seek your approval in advance.
II. How we share, transfer and disclose your personal information
To ensure the security of your personal information, we shall follow the minimization principle and share, transfer, or disclose your personal information in accordance with applicable laws and requirements.
For the companies, organizations, and individuals that share personal information with us, we will take organizational and technical measures in accordance with the local laws and regulations, and require them to process personal information in accordance with our security standards, this policy, and related confidentiality and security measures.
1. Sharing
We will not share your personal information with any company, organization, or individuals other than ZTE Deutschland GmbH, except in the following cases:
(1) After obtaining your explicit consent, we will share your personal information with other parties.
(2) We may share your personal information in accordance with laws and regulations or mandatory requirements of government authorities.
(3) We may share your personal information with our affiliates. We only share necessary personal information, which is subject to the purposes stated in this privacy policy. If the affiliates want to change the processing purpose of personal information, they will ask for your consent again.
We only share your personal information for legal, legitimate, necessary and specific purposes, and only share the personal information necessary for the provision of services. Our partners have no right to use the shared personal information for any other purpose.
Our affiliates include: ZTE Corporation, which is parent company of ZTE Deutschland GmbH. We have authorized the ZTE Corporation to provide us with technical and operational support. For this purpose, ZTE Corporation will process your personal information locally and may also remotely access your personal information from China.
We will sign strict confidentiality agreements with companies, organizations, and individuals with which we share personal information, and require them to process personal information in accordance with our instructions, this privacy policy, and any other relevant confidentiality and security measures.
2. Transfer
We will not transfer your personal information to any company, organization or individual except in the following cases:
(1) Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties.
(2) If personal information transfer is involved in case of merger, division, dissolution, acquisition, or bankruptcy liquidation, we will inform you of the name and contact information of the recipient, and require the new company or organization that holds your personal information to be subject to this privacy policy. Otherwise, we will request the company or organization to re-request authorization from you.
3. Public Disclosure
We will disclose your personal information only in the following cases:
(1) With your express consent.
(2) Disclosure based on law: We may disclose your personal information in case of law, legal procedure, litigation, or mandatory requirements of government authorities.
III. How we use Cookies and similar technologies
1. SDK
To ensure the stable operation and function implementation of our products and/or services, and enable you to enjoy and use more services and functions, our products and/or services will embed the SDKs or other similar applications of authorized partners. We will perform strict security checks on the API and SDK of the authorized partner that obtained relevant information. We will agree with the authorized partners on strict data protection measures to make sure that they will process personal information in accordance with this policy and any other related confidentiality and security measures.
The SDKs of our access to authorized partners are as follows.
a. The third-party SDK: firebase SDK
Purpose of collecting personal information: implement the User Experience Improvement Program statistics function.
Type of personal information: IP address of the user terminal, operating system name, mobile phone model, screen resolution, application software version, and usage behavior records of user browsing and click actions within the Smart Life App.
Privacy Statement or Development Guide of the third-party SDK: https://firebase.google.com/support/privacy?hl=en
b. The third-party SDK: google play
Purpose of collecting personal information: complete the Smart Life App Android version upgrade function.
Type of personal information: the version of the application software and its package name.
Privacy Statement or Development Guide of the third-party SDK: https://play.google.com/intl/en-US/about/console/terms-of-service/
IV. How we protect your personal information
1. We have taken the security protection measures that comply with industry standards to protect the personal information provided by you against unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information.
We use encryption technologies to ensure data confidentiality. We use trusted protection mechanisms to prevent data from being maliciously attacked. We will deploy access control mechanisms to ensure that only authorized personnel can access personal information. We regularly scan for security vulnerabilities and solve them in a timely manner. In addition, we will hold the training course on security and privacy protection to enhance employees' awareness of the importance of personal information protection.
2. We have obtained the following certifications:
ZTE products and services have passed a series of authoritative international certifications, such as ZTE and some of its subsidiaries have passed the ISO 27001 :2013 information security certification, the MyOS system of ZTE terminal and some of its applications have passed the authentication of the ISO/IEC 27701 :2019 privacy information management system, ePrivacy certification and TRUSTe certification, ZTE terminal after-sales hotline and other services have passed the TRUESTe certification. We can effectively protect your privacy experience and personal information security.
3. Our data security capabilities:
We have been committed to protecting your personal information security.
We have taken various security measures, such as access control system, monitoring system, encryption, anonymization or pseudonymisation, employee training and so forth, to protect your personal information from unauthorized access, use, disclosure, modification, damage or loss and other forms of illegal processing.
We have developed a business continuity plan to ensure that services can be provided continuously. Our information security policies and procedures are designed in strict accordance with international standards, and reviewed and updated regularly, and the effectiveness of the security management architecture and measures is ensured through regular third party security audits. ZTE Corporation and some of its subsidiaries have passed the ISO 27001 information security certification, and can effectively protect your personal information. In case of personal information leakage, we will initiate an emergency plan, take effective measures to prevent the situation from getting worse, and notify the relevant supervisory authority and you in a timely manner.
4. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will retain your personal information only for the period required to achieve the objectives specified in this policy, unless the retention period needs to be extended or is permitted by law.
5. The Internet is not absolutely secure, and most communications, such as emails and instant messaging, are not encrypted. We strongly recommend that you do not send personal information through such means. Please use a complicated password to help us ensure the security of your account.
6. We shall regularly update and publicize the contents related to reporting such as security risks , personal information security impact assessments and so forth . If we affect your personal information rights in security assessment reports, we will actively disclose security risks. You can obtain detailed report contents in the following way:
E-mail: [email protected]
7. The Internet environment is not 100 percent secure. We will do our best to ensure or guarantee the security of any information you send us. If our physical, technical or management protection facilities are damaged, which results in unauthorized access, public disclosure, tampering or damage that affects your legal rights and interests, we shall assume the corresponding legal responsibilities.
8. When personal information security incident occurs, we will inform you of the basic situation and possible impact of the security incident in a timely manner, the measures we have taken or will take, suggestions for voluntarily preventing and reducing risks, and remedial measures for you. We will inform you of the incident by email, letter, telephone or pushing notification in a timely manner. If it is difficult to inform the subjects of personal information one by one, we will release the notice in a reasonable and effective manner.
In addition, we will actively report the handling of personal information security incidents in accordance with the requirements of the regulatory department.
V. Your rights
In accordance with personal information protection laws, regulations, standards, and common practices in other countries and regions, we guarantee that you have the following rights over your personal information:
1. Access to your personal information
You have the right to access your personal information, except for exceptions as required by laws and regulations. If you want to exercise data access rights, you can access the data by yourself in the following ways:
Region settings: ZTE Smart Life App settings provide a menu where you can view your region.
Register/Login/Manage/Logout: view your personal account information in ZTE Smart Life App settings.
Smart device management: view device operational status and set parameter information using ZTE Smart Life App.
Smart device firmware upgrade: check the current device firmware version number using ZTE Smart Life App.
Application upgrade: view the current application version number in ZTE Smart Life App settings.
Except the above information, other information collected by this application cannot be accessed by you. You can contact us for help.
If you cannot access this personal information through these links/methods, you can send an e-mail to [email protected], or submit the request by login the data subject right response system: pdsr.zte.com.cn. As long as we do not need to make too many efforts, we will provide you with other personal information generated when you use our products or services.
2. Correct and supplement your personal information
When you find that your personal information processed by us is incorrect, you have the right to correct and supplement your personal information. You can perform the following operations by yourself:
Region settings: ZTE Smart Life App provides a region settings menu for you to select from.
Account management：You can set and change your email, password, and username.
Smart device management：You can modify device configuration parameters using the Smart Life App.
Except the above information, other information collected by this application cannot be corrected or supplemented by you. You can contact us for help.
If you cannot correct this personal information through the above links/methods, you can email to [email protected] or submit the request by login the data subject right response system: pdsr.zte.com.cn at any time.
3. Delete your personal information
You can delete your personal information in the following cases:
(1) We violated laws and regulations.
(2) We violated this policy.
(3) The purposes for which the personal information is processed as stipulated in this policy are achieved or cannot be achieved, or the personal information is no longer necessary for the purposes.
(4) You will not use our products or services any longer, or your account is canceled.
(5) You changed the scope of authorization that we have no right to process your personal information.
(6) We do not provide products or services for you, or the storage period expires.
You can delete your personal information as follows:
Cancel the ZTE Smart Life account from outside China.
Except the above information, other information collected by this application cannot be deleted by you. You can contact us for help.
Once you have deleted your personal information, we will also notify the entities that obtain your personal information from us and require them to delete your personal information in a timely manner, unless required by other laws and regulations, or these entities obtain your independent authorization. After your personal information is deleted , due to the limitations of applicable laws and regulations and safety technologies, we may not immediately delete the corresponding information in the backup system, but we will securely store your personal information, restrict further processing of it, and delete it during the backup update.
4. Change the scope of your authorization
Some business functions can be selected whether to use, and you may grant or withdraw your authorization at any time for these functions. If you do not wish to accept the non-basic functions or services provided by us, you can perform the following operations by yourself:
If you do not want to participate in our User Experience Improvement Program, you can cancel at any time by turning off the User Experience Improvement Program in ZTE Smart Life App settings.
If you cannot correct this personal information through the above links/methods, you can email to [email protected] or submit the request by login the data subject right response system: pdsr.zte.com.cn at any time.
Please understand that each business function can be implemented only after some basic personal information is obtained. When you withdraw your permission or authorization, we cannot provide you with the corresponding service. If the information is necessary for us to fulfill our obligations under laws and regulations or to provide major services, we may not be able to respond to your request or the normal use of our services will be affected. After you withdraw your consent, we will not process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.
5. Personal information subjects cancel accounts
You can cancel your ZTE Smart Life account from outside China in the app at any time.
After your account is canceled, we will stop providing you with products or services and delete your personal information as required by you, unless otherwise specified by laws and regulations.
6. Personal information subjects obtain copies of personal information
This application cannot provide you with a way to copy or transfer your personal information. You can contact us for help.
7. Restrain Automatic decision-making of the information system
This application does not use any automatic decision-making and related technologies.
8. Respond to your above requests
If your request cannot be implemented through these links/methods, or you need to contact us for help, you can send an e-mail to [email protected], or submit the request by login the data subject right response system: pdsr.zte.com.cn.
To ensure security, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.
We will make every effort to ensure that a response is made within one month since we received your request. Considering the complexity and quantity of the request, this period may be extended by another two months if necessary. In the case of postponed respond, we will notify you of the relevant circumstances and the reason for the delay. If the time limit set in this paragraph conflicts with local laws and regulations, the local laws and regulations shall prevail.
In principle, we do not charge for your reasonable requests, but we will charge for repeated requests that exceed a reasonable limit. We may reject requests that repeat unreasonably, require excessive technical means (for example, development of a new system or a fundamental change of current practice), and bring risks to other people's legitimate rights and interests or that are extremely impractical (for example, involving information stored on the backup tape).
We will not be able to respond to your request in accordance with laws and regulations if:
(1) The case is directly related to national security and national defense security.
(2) The case is directly related to public safety, public health, and major public interests.
(3) The case is directly related to any criminal investigation, prosecution, trial, and execution of a judgment.
(4) There is sufficient evidence that you have subjective malice or abuse of rights.
(5) Responding to your request will cause serious damage to the legal rights and interests of yours or other individuals' and organizations'.
(6) Business secrets are involved.
VI. How we process the personal information of children
Our products and services are mainly for adults. Without the consent of parents or guardians, children are not allowed to use our products or services.
If the personal information of children is collected with the consent of their parents, we will only use or disclose this information with the permit of law, the express consent of parents or guardians or the necessary protection of children.
Although local laws and customs define children differently, we regard anyone under 16 as a child.
If we find that we have collected personal information of children without obtaining confirmed parental consent, we will try to delete the information as soon as possible.
VII. How we store your personal information
1. Storage location and cross-border transfer of personal information
Your personal information collected by this application will be stored in the rented Alibaba Cloud (deployed in Frankfurt, Germany) and Firebase Analytics Servers, with data from the Nordic region stored within Europe. Under certain necessary circumstances, such as troubleshooting, your personal information may be remotely accessed from China by the ZTE Corporation.
The above cross-border transfer shall be implemented within the scope of applicable laws and regulations and the necessary limits for providing services to you. We will complete cross-border transfer prerequisites in accordance with relevant laws and regulations, including the international data transfer agreement.
There may be different data protection laws or even no laws in such jurisdictions. In such cases, we will ensure that your personal information is protected properly as it is protected in the People's Republic of China. For example, we will implement security measures such as data de-identification before cross-border data transfer.
2. Personal Information Storage Period
Unless otherwise specified in this Policy, we will retain your personal information within the period required to achieve the purposes described in this policy, unless as required by law that retention period need to be extended or be permitted by law. The data storage period may vary with different scenarios and products and services. The criteria for determining the retention period (the longer one prevails) include: the time when personal information needs to be retained for the purpose of the service which including the provision of products and services, maintenance of corresponding transaction and service records, control and improvement of product and service performance and quality, the guarantee of system, product and service security and respond to possible user queries or complaints; whether users agree to a longer retention period; and whether there are special requirements for keeping information such as laws and contracts.
After the storage period expires, we will delete your personal information or anonymize it according to the requirements of applicable laws and regulations.
For the storage period of your personal information, please refer to Part I of this privacy.
VIII. GDPR-Specific Provisions
The following provisions only apply to you if you live in Europe.
1.Legal Bases for the Processing of Personal Data
Our processing of your personal data as described in the Section "How We Collect and Use Your Personal Data" is based on the following legal grounds:
1.1 Consent: We may process your personal data with your consent. In particular, we may ask for your consent to participate in promotional activities, such as to send you promotional messages or enable you to participate in the User Experience Program and certain Services, including services through which we collect location information. You have the right not to provide consent, or to withdraw it at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you have granted us consent to use your personal data, we will use it only for the purposes specified in the consent declaration. Please note that to the extent our processing is based on your consent and you deny your consent or withdraw it, we may not be able to provide the service relating thereto. Besides from that, neither the initial denial nor a withdrawal will have any negative consequences for you.
1.2 Perform or enter into a contract with you:
We rely on this legal basis in particular in the following cases:
• to provide you with our Services, process your orders or fulfil the contract between you and us;
• to activate Services you have purchased, your warranty service and specific software licenses and provide notifications for software updates;
• to allow and manage your participation in prize draws, contests or similar promotional activities held by us; and
• to diagnose product issues, repair customer equipment and provide other customer care and support Services.
1.3 Compliance with a legal obligation: We may be obliged to process personal data to comply with our legal obligations, for example where we are required to retain data for tax law or commercial purposes.
1.4 Legitimate interests: The processing of your personal data may also be necessary for our legitimate interests. In particular, such cases may include the following:
• to conduct customer surveys to enhance your user experience;
• to analyse the customer market on the basis of the country where you use our Services, including the number of users for product marketing and promotion;
• to analyse the efficiency of our business operations;
• to analyse error logs to improve phone quality and app functions;
• to provide you with personalised Services and to recommend and display content and advertisements tailored to you through our Services;
• to communicate with you and reply to your questions or comments submitted to us by any means;
• to ensure the functionality and safety of our Services;
• to verify your identity;
• to conduct internal auditing and to prevent and investigate fraud, cybersecurity threats or other improper use;
• to enhance and develop our Services, including relevant security features, so as to improve the product usage experience, user-friendliness, operational performance, functions and design;
• to pursue or defend against legal claims.
Your personal data will only be processed on the above grounds after we have appropriately assessed and balanced our interests against your right to privacy.
2.Additional Information on Your Rights Regarding Personal Data
Subject to the legal requirements under the GDPR, you have the following rights:
The right to access: You may request access to the personal data we hold about you.
The right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and to request the completion of your personal data where appropriate.
The right to erasure: You can submit a request to us to delete personal data, and we shall have the obligation to erase it without undue delay in some circumstances – for example, if we do not have a legal reason to continue to process the personal data to the extent required by applicable laws and regulations. Please note in so far as you delete all the data that is contained in your device, this does not mean that you have deleted all data that We collects and processes about you. Therefore, we encourage you to contact us (please refer to the section "Contact Us" ) to request that your personal data is deleted.
The right to restriction of processing: You have the right, in certain circumstances, to request us to temporarily restrict the processing of your personal data, such as where the accuracy of that personal data is contested by you, while we verify the accuracy of that personal data. We will keep just enough data, or process such data as is necessary to ensure that we comply with your restriction request in the future.
THE RIGHT TO OBJECT: You have the right to object to any processing justified by legitimate interests based on grounds relating to your particular situation at any time. Should you decide to object to the processing of your personal data, we will stop processing personal data that concerns you, unless we can demonstrate compelling reasons for continuing to process your personal data that override your interests, rights and freedoms, or in the case that we establish, exercise or defend our legal claims. You can object to direct marketing activities at any time for any reason whatsoever.
The right to data portability: You have the right to obtain a copy of your personal data in a structured, commonly-used and machine-readable format and transmit such data to another provider or have such data transmitted to another provider under certain circumstances.
The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of our use of your personal data before your withdrawal. If you want to withdraw your consent with regard to receiving promotional communications, you can unsubscribe through the method described in each promotional message. If you withdraw your consent, we may no longer be able to provide you with the corresponding Service.
The right to lodge a complaint: You have the right to lodge a complaint with a competent supervisory authority about the way we handle or process your personal data, or file a lawsuit in a court with jurisdiction. Information about how to contact your local data protection supervisory authority is available here at https://edpb.europa.eu/about-edpb/board/members_en.
3.Additional Information on Cross-border transfer
We takes steps to ensure that appropriate technical and organizational security measures and safeguards are applied when transferring personal information outside of the EEA and that privacy rights outlined in this Policy are preserved. We has established Standard Contractual Clauses of the EU Commission as providing an adequate level of protection to the personal information we Process globally. We ensures that all transfers of Personal Information are subject to appropriate safeguards as defined by the regulation.
IX. How to update this policy
Our privacy policy may change.
Without your express consent, we will not reduce your rights under this privacy policy.
We will release any changes to this policy on this page. For major changes, we will also provide more noticeable notifications (including notifications for some services, which will be sent via email to describe the specific changes in the privacy policy).
Major changes mentioned in this policy include but are not limited to the following situations:
1. Our service model has significantly changed. For example, the purpose of processing personal information, the type of processed personal information, and the mode of using the personal information.
2. Major changes have taken place in the ownership structure and organizational structure. Such as changes in owners caused by business adjustment or bankruptcy or mergers and acquisitions.
3. The major objects of personal information sharing, transfer, or public disclosure are changed.
4. Your right to participate in the processing of personal information and the way you exercise it have changed significantly.
5. Our responsible department for personal information security, contact method, or complaint channel have changed.
6. The personal information security impact assessment report indicates a high risk.
We will also archive the old version of this policy for your reference.
IX. Contact us
We have established a special personal information protection department – Data Protection Compliance Dept. If you have any questions, comments, or suggestions on this privacy policy, please feel free to send an email to us at [email protected], which will be replied within at the appropriate time.
[email protected] is only used to handle problems related to users' personal information and privacy protection. For problems about terminal equipment failure or account settings, please send emails to [email protected]. Our terminal after-sales staff will reply to you at the first time.
In addition, you can send letters to us or the Data Protection Compliance Dept. of ZTE headquarters.
To: Data Protection Compliance Dept. of ZTE Corporation
Address: 26/F, R&D Building, No. 55, Hi-Tech Road South, Shenzhen, China (Post Code: 518057)
If you are unsatisfied with our response, especially when our personal information processing activities have damaged your legal rights and interests, you can seek solutions through the local data protection agency.
For contact information about personal information supervisory authority in other areas, you can consult the local government. For the contact information of the European Union data protection agency, please refer to: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm