ZTE Smart Router Privacy Policy

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                                                                                                                           Updated:Aug of 2021

                                                                                                                           Effective Date:Aug of 2021

This policy applies only to ZTE Corporation smart router products.

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 Corporation

Registered Address: ZTE Building, No. 55, Hi-Tech Road South, Nanshan District, Shenzhen, P.R. China

ZTE 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, ZTE 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:

  1. 1. How we collect and use your personal information
  2. 2. How we share, transfer, and disclose your personal information
  3. 3. How we protect your personal information
  4. 4. Your rights
  5. 5. How we process the personal information of children
  6. 6. How to transfer your personal information around the world
  7. 7. GDPR-Specific Provisions
  8. 8. Notice to California Consumers
  9. 9. How to update this policy
  10. 10. Contact us
  11.  

Ⅰ. How we collect and use 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:

Business function : Version update

To update your system in the timely manner and to make sure your routers work properly, the following information needs to be collected: IMEI, SN and software version of router device.

The data mentioned above will be stored in the FOTA servers that are deployed by ZTE. Because ZTE provides service all over the world, ZTE deploys FOTA servers globally. For example, EU’s servers are deployed in Frankfort, Germany, the personal information we collect and generate in the People's Republic of China will be stored within the territory of the People's Republic of China.

We will use your personal information in the following ways: in accordance with the router device information you provided, we will check for the right version for your device; with your authorization or certain conditions are met, we will download and update new version in order to resolve possible risk in the system. Meanwhile, we provide auto-update feature in order to resolve critical failures your device might have and to update security patch. This feature is enabled by default. To disable this feature, please go to advanced Settings > upgrade on our web-based management page to set it. Besides, updating version will consume mobile data.

If you do not provide the information, you will not be able to check for the latest version of software, perform update or fix security issues in current system.

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. 1. Sharing

We will not share your personal information with any company, organization, or individuals other than ZTE Corporation and its subsidiaries, 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.

  1. 1. 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 a merger, acquisition, or bankruptcy liquidation, we will require new companies or organizations that hold your personal information to continue to be subject to this privacy policy. Otherwise, we will require the companies or organizations to re-request authorization from you.

  1. 1. 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 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 provide the safe browsing mode of https for services. 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. In addition, we will hold the training course on security and privacy protection to enhance employees' awareness of the importance of personal information protection.

  1. 1. 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.

  1. 1. 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.
  2. 2. 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.
  3. 3. 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:
  4.  

E-mail: [email protected]

  1. 1. 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.
  2. 2. 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.

Ⅳ. 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. 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:

You can send an e-mail to [email protected]. We will respond to your access request within 15 working days.

If you cannot access this personal information through the method, you can 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.

  1. 1. Correct your personal information

When you find that your personal information processed by us is incorrect, you have the right to request us to correct it. You can apply for a correction through the method listed in "(1) Access to your personal information". If you cannot correct this personal information through the above method you can submit the request by login the data subject right response system: pdsr.zte.com.cn at any time.

  1. 1. Delete your personal information

You can submit a request for deleting personal information in the following cases:

(1) we violated laws and regulations.

(2) we did not obtain your consent.

(3) we violated an agreement with you.

(4) you will not use our products or services any longer, or your account is canceled.

(5) we do not provide products or services for you.

If we decide to respond to your deletion request, 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 you delete information, we may not immediately delete the corresponding information in the backup system, but we will delete the information during the backup update.

  1. 1. Personal information subjects obtain copies of personal information

You have the right to obtain a copy of your personal information. You can perform the following operations by yourself:

You can apply for a copy of your personal information through the method listed in "(1) Access to your personal information". If you cannot obtain the copy through the above method you can submit the request by login the data subject right response system: pdsr.zte.com.cn at any time.

Under the prerequisite that the technology is feasible, for example, data interface matching, we can transmit the copy of your personal information directly to the third party specified by you.

  1. 1. Restrain Automatic decision-making of the information system

In some business functions, we may make decisions only based on non-manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions have a significant impact on your legal rights and interests, you have the right to ask us for an explanation, and we will provide appropriate relief methods.

  1. 1. Respond to your above requests

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.

Ⅴ. How we process the personal information of children

Our products, websites, and services are mainly for adults. Without the consent of parents or guardians, children are not allowed to create their own user accounts.

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.

Ⅵ. How to transfer your personal information around the world

Because we provide products or services through resources and servers around the world, as a result, your personal information may be transferred to an overseas jurisdiction of the country or area in which the products or services used by you are, or may be accessed from these jurisdictions. Any such transfer of personal information shall take place only in accordance with applicable law.

We will take steps designed to comply with all applicable local laws when Processing personal information, including any local law conditions and restrictions on the transfer of personal information. We may also protect your data through other legally valid methods, including international data transfer agreements.

Ⅶ. 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 ZTE's Services, process your orders or fulfil the contract between you and ZTE;

• 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: ZTE may be obliged to process personal data to comply with our legal obligations, for example where ZTE is 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 ZTE's 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 personalized 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, cyber security 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 ZTE 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 ZTE 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.

Ⅷ. Notice to California Consumers

California consumers have the privacy rights listed below. The rights listed below under the California Consumer Privacy Act and Shine the Light are not the same. To exercise your rights, you will need to follow the directions below that are specific to each law.

California Consumer Privacy Act (“CCPA”)

Please note that the CCPA provides certain exceptions with respect to the Personal Information that we collect in connection with providing products or services to other businesses. Similarly, it does not apply to information we collect in the context of a person’s role as a job applicant, employee or contractor of ZTE. With respect to the Personal Information collected in connection with the above individuals or circumstances, you may not have any or all of the privacy rights listed below. 

Collection, Use and Disclosure of Personal Information in the Past 12 Months

The CCPA requires that we make certain disclosures about our general collection, use and disclosure of Personal Information over the past 12 months. Accordingly, in the past 12 months: 

  • we collected the categories of Personal Information detailed in the policy of how do we collect and use your personal information above.
  • [we did not sell Personal Information, as we understand the term “sale” in the CCPA and its implementing regulations][we sold to the entities described in the policy of how do we share, transfer, and disclose your personal information, the following categories of Personal Information: [●]]. 
  • [we did not disclosed Personal Information to any entities.][we disclosed to the entities described in the policy of how do we share, transfer, and disclose your personal information, the following categories of Personal Information: [●]].

You have the right to request to know more specific disclosures about your personal information as detailed under “Request to Know” below. 

California Privacy Rights

You have the following privacy rights under the CCPA:

  • Request to know. You have the right to request to know the following information about our practices over the past 12 months: (i) the specific pieces of Personal Information we have collected about you; (ii) the categories of Personal Information we have collected about you; (iii) the categories of sources from which we collected Personal Information about you; (iv) the categories of third parties with which we share Personal Information; (v) the categories of your Personal Information that we sold or disclosed and for each category, the categories of third parties to which we sold or disclosed that particular category of Personal Information; and (vi) our business or commercial purpose for collecting or selling your Personal Information. 

You may exercise your right to request to know twice a year, free of charge. If we are unable to fulfill your request to know, we will let you know the reason why. Please note, in response to a request to know, we are prohibited from disclosing your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions or answers, unique biometric data generated from measurements or technical analysis of human characteristics.

  • Request to delete. You have the right to request that we delete the Personal Information that we have collected from you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request to delete, we will let you know the reason why.
  • Right to opt-out of the sale of your Personal Information. You have the right to opt out of the sale of your Personal Information. While we never exchange personal information for money or other consideration, the CCPA’s definition of “sale” is very broad and may include the use of services to deliver interest-based ads to you. We do not knowingly sell the Personal Information of minors under 13 years old without consent from the minor’s parent or guardian. We do not knowingly sell the Personal Information of minors between 13 and 16 years old without the minor’s own consent. If you do not affirmatively opt out, and you are not a minor, your Personal Information may be sold as disclosed in this privacy policy.  
  • Right to non-discrimination. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of the app.

To make a request to know or a request to delete, contact us at 001-877-817-1759 or send an e-mail to [email protected]. If you are an authorized agent making a request on behalf of a California resident, contact us at 001-877-817-1759 or send an e-mail to [email protected].

To opt-out of the sale of your Personal Information, contact us at 001-877-817-1759 or send an e-mail to [email protected]. If you are an authorized agent making a request on behalf of a California resident, contact us at 001-877-817-1759 or send an e-mail to [email protected].

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you so that we can verify your identity. We will only use the Personal Information you provide to verify your identity and to process your request, unless you initially provided the information for another purpose. 

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

Shine the Light

California consumers may also request information from us once per calendar year about any Personal Information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please send an e-mail to [email protected] or contact us at 001-877-817-1759. Your inquiry must specify “Shine the Light Request” in the subject line of the email or the first line of the letter, and include your name, street address, city, state and ZIP code. 

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.

Ⅹ. 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.

In addition, you can send letters to 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: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm