Neffos (TP-LINK Technologies Co., Ltd.) understands
how important privacy is to you and will do our best to protect your privacy.
Therefore, we have prepared this privacy policy outlining how we collect, use,
disclose, protect, transmit, and store your information. Please read this
privacy policy carefully before submitting your personal information to Neffos.
If you have any questions, please contact us.
This privacy policy only applies to Neffos mobile
phone products and services.
"Personal
information" refers to data which can be used to identify or that can be
associated with an individual. We will collect certain personal information
when you use Neffos products or services. You do not necessarily have to
provide personal information to Neffos, but in some cases, if you opt out,
Neffos will not be able to provide you with the relevant products or services,
nor respond to the issues you encounter. Neffos will only collect and use your
personal information for legitimate and express purposes as demonstrated in
this statement. If we need to further process your personal information for
other purposes, Neffos will ask for your additional authorization.
Here are some examples of the
personal information we may collect:
1. Personal information you
provide to Neffos
Some Neffos products or
services may collect the personal information you provide, such as your phone
number, email address, etc. Neffos shall take reasonable and necessary measures
to guarantee the security of the aforementioned information, such as
desensitizing the sensitive information.
2. Information obtained by
Neffos when you use its services
When you use some Neffos
products or services, Neffos will collect your device information as well as
the information about how you and your device interact with these Neffos
products and services, including:
• Device information – device
model number, SN, IMEI, IMEI activation time, OS version, ROM version, country
code, etc.
• Location information –
geographical location information (for example, when using services such as
weather and compass). However, you may turn off the location function to stop
our collection of your geographical location information.
• App usage – usage frequency
and duration, and settings.
• Device usage – storage space
utilization rate, network operator, battery charging duration, IP address, etc.
• Log information - some
certain information that Neffos automatically collects and stores in log files
when you use Neffos products or services, such as usage time and duration,
access times, event information (for example, crushes, reboots and upgrades),
etc.
• In
addition, as permitted by law, we may also collect your information from public
sources and combine it with other information received from or related to you.
3. Information that Neffos can
collect without your consent
When relevant laws are
applicable, Neffos may collect and use some certain personal information
without your consent, including, but not limited to, information related to
national security, major public interests, as well as criminal investigation
and judgment.
4. The collection and use of
non-identifiable information
"Non-identifiable
information" refers to data that cannot be used to identify an individual.
With your express consent, Neffos may collect statistical information on how
you use the device and apps to gain insights on how users use our products and
services so we may improve them. Neffos may collect, use, disclose, and
transfer non-identifiable information for any purposes.
The
information collected by Neffos will mainly be used to:
•
provide customized user experiences, content, marketing, and recommendations in
our products and services.
•
send you notifications of OS or app updates and installations.
•
provide maintenance services for your device.
•
prevent, investigate, and stop fraudulent, unauthorized, or illegal activities.
•
help us to better optimize our products and services.
•
fulfill other purposes with your consent.
Neffos
and some third parties that provide contents, advertisements and other
functions via Neffos services may use cookies, beacons and other similar
technologies in some products and services.
1.
Cookies
A
cookie is a text file that is stored on a computer, mobile phone or other
device by a network server. Sometimes, Neffos may store cookies on your device
or use some technologies similar to cookies to collect your information, so as
to improve user experiences of products and services. The purposes include but
are not limited to:
•
Storing login verification or relevant settings Cookies can remember login
credentials. Therefore, you do not need to log in to some websites repeatedly.
For example, when you use Neffos browser, where the cookies function is provided,
to access some third-party websites, those websites may use the information
stored in cookies, allowing you to use the functions on the websites directly.
Please note that Neffos cannot control how third parties store and use cookies
and similar technologies. Therefore, you are suggested to use third-party
websites with caution.
•
Statistical analysis With cookies and similar technologies, Neffos and third
parties may collect your website or application usage information (such as the
times/frequency or duration of page or function access), so as to improve
corresponding services and provide you with a better experience.
•
Providing personalized contents or advertisements Neffos and third parties may
use cookies and similar technologies to collect your online behavior
information and know the content that you browse. Therefore, different contents
or advertisements can be provided each time you visit, or relevant contents or
advertisements can be provided based on your browse or usage preference.
Neffos
promises that information stored in cookies and similar technologies will not
be used for purposes other than those described in this statement. Meanwhile,
Neffos will not be liable for how third parties store and use cookies and
similar technologies. You can cancel the collection and use of your information
by Neffos or third parties by stopping using the corresponding functions and
modifying the settings of browser cookies. Please note that cookies and similar
technologies may be compulsory for some services. Disabling cookies or similar
technologies may affect your use of some or all of these services.
2.
Beacons/pixel tags
A
beacon is usually an electronic image embedded in a website or an email. Its
functions include allowing the server to read some certain types of information
from the device, knowing when you view specific content or email information,
determining the time and date when you view the beacon, IP address of the
device, etc. Neffos and some third parties may use beacons for various purposes,
which include, but are not limited to, analyzing server usage and providing
contents or advertisements that meets your needs better (beacons may be used in
conjunction with cookies). If you do not want Neffos to collect your
information in this way, you can inform us by sending an email to
gdpr@tp-link.com at any time.
3.
Other local storage
Neffos
and some third parties may use other local storage technologies in some
products or services, such as local shared objects (also known as "Flash
cookies") and HTML5 local storage. Similar to cookies, those technologies
can be used to collect information about your activities and preferences, and
files generated by the technologies will be stored in your device as well.
Different tools are adopted by browsers to manage Flash cookies. For guides and
instructions on how to disable or delete information contained in Flash
cookies, please refer to
https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
• After having obtained your
consent. We will only disclose your personal information to third parties after
obtaining your express consent.
• Disclosing to our affiliates
or partners. In order to provide you with better services, we may disclose part
of your personal information to our affiliated companies or partners. Neffos
will sign a strict confidentiality agreement with affiliates or partners. The
affiliates or partners will be required to use or process your personal
information reasonably in accordance with this statement, and will be strictly
prohibited from using the shared personal information for any other purposes.
• Disclosing to third parties
involved in corporate affairs. If a merger, transfer, acquisition, or
bankruptcy process involves the transfer of personal information, Neffos may
disclose your personal information to third parties. Neffos will require third
parties to continue to comply with the contents of this statement or to
re-request your consent to collect, use, and disclose your personal
information.
• If required by law. We may
disclose your personal information when requested by law, regulations, or
judicial or government authorities within and outside of the country you live
in.
We will not disclose your
personal information to third parties other than in the situations described
above.
V. How Neffos protects your information
Neffos takes the security of users' personal
information very seriously. We implement industry-standard practices to protect
your personal information from unauthorized access, disclosure, usage,
alteration, damage, or loss. Neffos protects your personal information through
the following measures:
• Taking all reasonable steps to minimize the
collection of personal information.
• Retaining your personal information within the time
required to achieve the objectives of collection or within the time allowed by
relevant contracts and laws. If the storage time needs to be extended for other
purposes, we will inform you in time and ask for your permission.
• Using encryption technologies and other technical
methods to ensure the confidentiality of data.
• Using anti-virus software, monitoring systems, and
encryption to protect the data center from malicious attacks.
• Deploying access control mechanisms to make sure
only authorized personnel can access the personal information.
• Providing training on security and privacy
protection for our employees to raise their awareness of the importance of
protecting personal information.
• Emphasizing to third parties their need to strictly
fulfill the obligation for confidentiality of personal information.
We will do our best to protect your personal
information. However, please note that no security measures are completely
infallible. If, unfortunately, security incidents such as personal information
leakage do happen, Neffos will assume relevant legal responsibilities and
inform you or the relevant regulatory authorities in accordance with applicable
laws and regulations about the information including, but not limited to, basic
situation and possible effects of the event, measures that have been taken or will
be taken by Neffos, and suggestions on helping you prevent or reduce risks on
your side. Moreover, Neffos will not be liable for information leakage and
other security incidents caused by your personal reasons or actions.
VI. How Neffos stores and transmits information
The personal information we collect may be stored in
your mobile phone or on our servers, and may be transmitted, stored, and
processed outside of the country/region in which you live (e.g. China). This
may include jurisdictions in which the privacy laws may not be able to provide
similar protection as the country/region you belong to. During this process,
Neffos will adopt encryption measures to protect your information and data from
unauthorized access, use, or disclosure. However, due to the inherent defects
and operational risks of networks, we cannot guarantee that your information is
absolutely safe.
VII. Managing your personal information
1. Access, update, or delete personal information
You can manage (including accessing, updating, or
deleting) your personal information at any time. Neffos will provide you with
the permission to manage your personal information, except otherwise stipulated
by law.
When you request to access, update, or delete your
personal information, Neffos will require you to provide sufficient information
to verify your identity prior to processing your request. Neffos will try the
best to respond to your reasonable requests within the time stipulated by law.
Meanwhile, the response time may be extended in some cases when necessary due
to the number and complexity of requests. For extended requests, Neffos will
timely inform you of the detailed reasons for the delay.
Furthermore, if processing your request requires too
many resources, or if you make repeated or similar requests multiple times,
Neffos may charge you a reasonable fee to the extent permitted by law. We will
not handle insignificant, extremely unrealistic, or deceptive requests, as well
as requests regarding information for which local laws have not granted access
rights.
If you want to access, update, or delete your personal
information, please inform us by sending an email to gdpr@tp-link.com. Neffos
will do its best to maintain the accuracy and integrity of your personal
information, and update such information promptly.
2. Withdraw authorization to collect and use personal
information
You can withdraw your authorization to grant Neffos to
collect, use and/or disclose your personal information by means of deleting
relevant information, turning off relevant functions, resetting your device,
etc. After withdrawing your authorization, Neffos may not be able to continue
to provide you with the services corresponding with the withdrawn
authorization, nor to collect, use and/or disclose your personal information
accordingly. The withdrawal of authorization will not affect the processing of
personal information previously completed based on your authorization.
VIII. How Neffos handles children's personal
information
Neffos products and services are mainly designed for
adults. Neffos understands the importance of taking additional precautions to
protect the privacy and security of children under the age of 13 (or similar
minimum ages as per relevant jurisdiction requirements). Children's personal
information that is collected with the consent of the guardians will only be
used or disclosed when the law permits and the guardian expressly agrees, or
when necessary for the protection of the children. Guardians shall have the
right to access, update, or delete their children's personal information for
any reasonable purposes that are permitted by law. If we find ourselves
collecting children's personal information without obtaining the prior consent
of a verifiable guardian, we will take actions to delete such information as
soon as possible.
IX. Third-party products and services
Neffos products and services may include third-party
products and services. All third-party products and services are provided for
your convenience. Neffos has no control over how third parties collect, use, or
protect your information, and takes no responsibility therefor. For the privacy
measures taken by third parties, please refer to their privacy policy.
The privacy policies shall apply when you use the
following specific third-party products and services:
• Google Admob: https://policies.google.com/privacy?hl=en
• Facebook Audience Network:
https://business.facebook.com/privacy/explanation
• Mintegral: https://www.mintegral.com/en/privacy/
• Celltick: https://startgallery.celltick.com/cdocs/site/privacy-policy-magazine.html
• The Weather Company:
https://weather.com/en-US/twc/privacy-policy
• Accu: https://www.accuweather.com/en/privacy
• By using the TouchPal input method, you acknowledge
that you agree to the relevant terms and conditions:
http://www.touchpal.com/privacypolicy.html
X. Confidentiality guarantees
To ensure the security of your personal information,
we have communicated this Privacy Policy to all employees of Neffos, and shall
strictly carry out the privacy protection measures within the company.
XI. Contacting Neffos
If you have any questions about this privacy policy,
please contact us by emailing us at gdpr@tp-link.com, and we will do our best
to answer your questions. If you are not satisfied with our reply, or our
handling of your personal information infringes upon your legal rights, you may
file a complaint to the relevant regulatory bodies in your jurisdiction.
XII. Updates to this privacy policy
To keep consistent with the latest products, services,
and legal requirements, Neffos may update this privacy policy at any time.
Updates to this privacy policy will be published promptly when available. If
you continue to use Neffos products and services after this privacy policy is
updated, it shall be deemed that you have accepted our updated privacy policy.
Once this privacy policy is updated, the "Last updated" date will
change.
Last
updated: February 18, 2019
Copyright
© 2019
TP-Link Technologies Co., Ltd. All rights reserved.