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Privacy Notice of realme Community
Lastest updated on September 10, 2021
“realme Community” (hereinafter referred to as the “Community”) is a platform/application, provided by realme Mobile Communications (Shenzhen) Co., Ltd. and its affiliates (hereinafter referred to as “realme”, “us”, “we”, or “our”), through which you can discuss realme products, have access to event information, game playing tips and tricks, and interact with other users. As your data controller, we are committed to protecting and respecting your privacy. Through our “Privacy Notice of realme Community” (hereinafter referred to as the “Privacy Notice”), we will explain the purpose, manner and extent to which realme collects and uses your personal information, your rights with respect to your personal information, and the security measures we take to protect your information. In the Privacy Notice, “personal information” refers to any information recorded electronically or otherwise that could be used, either alone or in combination with other information, to identify an identified or identifiable natural person. Such personal information includes but is not limited to the information and device information you provide or upload. Special Notes Before using our products or services or submitting personal information, please familiarize yourself with our personal information protection practices by carefully reading and fully understanding the matters described in the Privacy Notice, such as the collection and use of information and the rights to which you are entitled. If you do not agree to the terms of the Privacy Notice, you may close and exit the Community by clicking “Disagree,” in which case we will not be able to provide you with the related services; by clicking “Agree,” you acknowledge that you have carefully read and fully and clearly understand the following information collection and use practices and the rights to which you are entitled. By using or continuing to use the Community, you consent to our processing of the relevant information in accordance with the Privacy Notice. If you are a minor under the age of 14 (or a person under a comparable minimum age as specified by the relevant jurisdiction), the law requires that you carefully read, fully understand, and expressly agree to the Privacy Notice together with your guardian before using the Community. The Privacy Notice will help you understand the following: A. General Terms Ⅰ How We Collect and Use Your Personal Information Ⅱ How We Use Cookies and Similar Technologies Ⅲ How We Retain Your Personal Information Ⅳ How We Disclose Your Personal Information Ⅴ How We Protect Your Personal Information Ⅵ Your Rights to Your Personal Information Ⅶ How We Process the Personal Information of Minors Ⅷ Third-Party Products or Services Ⅸ How Your Personal Information Is Transferred Globally Ⅹ How The Privacy Notice Is Updated Ⅺ How to Contact Us B. GDPR Exclusive Terms I. Legal Basis for Processing Personal Information II. Additional Information on How Your Personal Information Is Transferred Globally III. Additional Information on Cookies and Other Tracking Technologies IV. Additional Information on Rights to Personal Information V. Contact Information for EU Representatives In addition to the Privacy Notice, specific privacy notices may apply in accordance with the services used. In each case, we will fully provide you with the applicable privacy notice. The general terms and conditions in Section A apply to you wherever you are located. Section B applies only to users located in the European Union, Liechtenstein, Norway, the United Kingdom, or Switzerland (“Europe”). A. General Terms I. How We Collect and Use Your Personal Information We collect your personal information based on the principles of lawfulness, fairness, and necessity. We collect personal information to improve the operational efficiency of the Community and provide you with an optimal user experience. We collect personal information through the following ways: (1) information you provide to us directly; (2) relevant information we obtain when you use the Community; and/or (3) personal information about you obtained from third parties. The information we collect depends on the products and services you actually use, the environment in which you interact with us, and the choices you make, including your privacy settings and the specific products and functions you use. The Community primarily provides you with the basic functions and services for browsing Community content online, as well as additional functions and services, such as posting, commenting, liking, sharing, following, reporting, signing in, viewing messages, performing tasks, participating in activities, shopping in the Store, asking for help, user feedback, customer service, etc. When we collect information, you are not required to provide us with personal information; however, if you do not provide us with the personal information necessary for basic functions and services, you may not be able to use our products or services normally. Your refusal to provide any personal information that needs to be collected for additional functions and services may result in the unavailability of those additional functions and services; however, it will not affect your use of our basic functions and services. It is worth noting that we generally consider the area you selected for your initial login (or through subsequent settings changes) as the actual location in which the product/service is used, and that we comply with the requirements of relevant local laws and regulations including those concerning data protection. 1.We may collect the following types of information: (1)Content Browsing Services When you browse product information or content posts in the Community, we do not need to collect your personal information. (2)Posting, Commenting, Interacting, and Account Registration and Login Services When you use the Community’s additional functions and services, such as posting, commenting, liking, sharing, following, reporting, signing in, viewing messages, performing tasks, participating in activities, shopping in the Store, asking for help, user feedback, customer service, etc., you will need to register and log in to a HeyTap account. The Community’s account login service is provided by Guangdong Huantai Technology Co., Ltd. Please carefully read the “HeyTap Account Privacy Notice” and the “HeyTap Account Registration User Agreement” before using your HeyTap account. The account will collect your mobile phone number or email address, your password, and the contents of registration text messages so that you can complete the account registration process. Once you log in successfully, we will automatically obtain your HeyTap account ID information. Whenever you edit or complete your Community Personal Homepage information in the Community’s Personal Center, we will collect your personal information including your gender, birthday, avatar, nickname, etc. in order to display such information in your personal center. If you use posting, commenting, interacting, or other features, we will collect the content of your posts and interactions in the Community, such as photos, videos, etc., in order to display such content in the Community. (3)Community Activities When you participate in Community activities such as lucky draws, we need to collect your contact name, mobile phone number, and shipping address in order to send physical prizes. In addition, if bonuses are awarded, we need to collect information such as your ID number, real name, and bank account. If no physical prizes or bonuses are involved, we may need to collect your email address in order to get in touch with you. If you are found to be a minor upon submitting your ID information (subject to the minimum age specified by your jurisdiction), you will need to obtain the consent of your guardian when using the services provided by the Community. For this purpose, we may need to collect your guardian’s phone number and text message verification code or other verifiable contact information to verify the authorization. If you fail to provide such information, you may not be able to use our products or services normally. (4)Notification Pushing We can provide you with push services for notifications, surveys and activities, including application update and installation notifications, marketing information and so forth, via the mobile phone number or email address linked to your HeyTap account. You can stop receiving our push or notification messages via text message un-subscription or the notification manager in your device’s settings. Any fees you incur for text messages sent for verification purposes will be charged by the Operators. (5)After-Sales and Customer Service When you use “Customer Service” or request after-sales or customer service in the Community, we may ask you to provide your personal information, such as your mobile phone number, email address, and device information, and may record your conversation with our customer service team. If you fail to provide this information, we may be unable to provide you with effective customer service. We may also use the mobile phone number provided to us in the above scenarios to contact you for user surveys and follow-ups. (6)Network Identification Information When you use the Community, in order to identify users, we need to collect your network identity information (SSOID). If you fail to provide such information, you may be unable to use our additional functions and services normally; however, your use of our basic functions and services will not be affected. In addition, we also collect information generated when you use the services: for example, your badge, user level, sign-in information and browsing history in the Community; your internal messages when you use the Community’s services (viewable only by the sender and receiver); push texts when you use push services; and your behavior (such as clicks, exposure) when you use advertising services. If you fail to provide this information, your use of the Community’s basic functions will not be affected. (7)Location Information In order to select the country/region and language, we need to collect your area and country code information. You can turn off the Community application’s location service at any time in the mobile device’s settings. (8)Log Information Information related to your use of certain features, applications, and websites. This includes, for example, cookies and other anonymous identifier technologies, Internet Protocol (IP) addresses, network request information, temporary message history, standard system logs, error and crash information, and log information generated by using the services (such as registration times, access times, activity times, etc.). We collect this information to verify your identity, analyze service operational efficiency, and prevent fraud. The Android system is designed such that your error or crash events include information that gives an overall picture at the time when the event occurs. We only use this type of information to conduct error log analyses. We do not use such information to identify individuals, nor will we use it for other purposes. In addition, we clear the logs we collect on a regular basis. (9)Operational Behavior Data When you use the Community, we will need to obtain data regarding your activity, such as product feature usage statistics, site browsing data, click behavior, and performance data. We collect this information to optimize product functionality and our interface layout logic, develop new product features, and make the software interface make more sense and have easier-to-use features. Such information cannot identify a specific natural person, and we do not correlate analytical data with your personal information. (10)Real-Name Authentication If the relevant laws and regulations of your country require real-name authentication, we will also collect your real-name authentication information, including your name and ID card number. If you refuse to provide this information, we may not be able to provide you with the corresponding products or services. (11)Other Information Regarding Your Use of the Services This includes, for example, the version of the application used, the websites you have visited, and how you interact with the content offered by the service. (12)realme Store Services When you use the Community’s realme Store services, we may collect the following personal information from you. If you refuse to provide this information, the services may not work; however, your use of the Community’s browsing services will not be affected. A.When you reserve or purchase products, participate in operational activities, we will need to collect information such as your mobile phone number, shipping address, and name. We collect this information so as to facilitate services such as delivering goods, sending notifications and reminders, and so forth. B.If you order products from us, request a return or refund or use a paid service, we may collect your delivery details, bank account information, payment records, billing address and other financial information, contact and communication records, etc., so that we can process your order. We use this data to process purchase orders and provide relevant after-sales services, including customer support, order delivery, invoice printing, etc. If you do not provide this information, you may not be able to order products from us, request a return or refund or use paid services. C.When providing you with after-sales services and customer support, we may ask you to provide and collect your personal information, such as IMEI and other device information, account information, order information (including your name, mobile phone number, shipping address, order number, payment serial number, logistics tracking number, email address, device ID, shipping invoice number, and account number), chat history, payment information, your name, gender, mobile phone number, email address, address, etc. We may also record your call with our customer service team. We use this data to diagnose product problems, repair customer devices, and provide other customer care and support services. We may also collect your email address to respond to questions or comments you send through our website’s “Contact Us” page or through other means. D.Both the Community and realme Store are products operated by realme. Both share infrastructure, systems and technologies to provide you with a relevant, consistent, and secure experience when you use realme products. For example, you can use the same account to log in to the Community and realme Store. Subject to applicable laws and compliance with the terms and policies of for each application, we may process information about you. If you need to learn more about how realme Store processes personal information, you may view realme Store’s privacy notice. If the information you provide contains the personal information of other users, please make sure that you have obtained legal authorization before providing this personal information to us. Please be aware and understand that the features and services we provide to you are constantly being updated and developed. We may also ask you to provide and collect your personal information in other scenarios depending on the characteristics of certain Community products and services. In such cases, we will inform you of this in the separate privacy notice terms and conditions, page prompts, or interactive processes for the relevant products or services to obtain your consent. 2.Device Permissions (1)In order to enhance your user experience when you use the Community, we may ask to invoke the following permissions on your device during your use of the Community to collect and use your personal information, and to provide you with the corresponding functions or services. If you do not authorize or turn on the relevant permissions, you can still use the Community; however, you may be unable to use these additional features that may bring you more convenience. We will need to invoke your location permission to collect your geographic location information and to select the country/region and language; however, we will not combine it with your real-time location information in order to determine your whereabouts. We will also need to invoke your camera permissions in order to upload avatars and photos, as well as your read and write external storage permissions in order for you to upload content to the Community and save pictures locally. (2)Once permissions are turned on, you can turn them off at any time in your device's settings (methods of displaying and turning off permissions may vary by device). Once the permissions are turned off, you may be unable to use the corresponding product functions. Please note that by turning on these permissions, you authorize us to collect and use personal information to perform the above functions. By turning off these permissions, you revoke such authorizations. We will no longer continue to collect and use your personal information, and will be unable to provide you with the features corresponding to such authorizations. Your decision to turn off permissions will not affect the processing of personal information previously performed on the basis of your authorization. Please note that we may collaborate with third-party service providers to implement the business functions described above, and that such service providers may receive and store certain personal information. However, said third parties will not use such information for any other purposes. In addition, depending on the characteristics of certain realme products or services, and where permissible by law, we may obtain data about you from public or commercial sources, and may combine such data with other information received from or related to you. If you opt to log in and use our services through an account with our affiliates, partners, or other third party (QQ, WeChat, Alipay, Weibo, Facebook, etc.), we may also obtain your information from these services, such as your username and avatar. Before you use the Community, we recommend that you carefully read the privacy notices of such third parties. 3.How We Use Your Personal Information We will process your personal information when it is necessary for us to fulfill our obligations to you under the user agreement and/or service contract; when bound by statutory obligations; or, when following an assessment, we deem it necessary to protect our legitimate interests or those of a third party, provided that we have obtained your consent to do so and that your personal information will be processed only for the purposes described in this new Personal Information Protection Notice. We will use your personal information in strict compliance with the Privacy Notice and any updates hereto. You hereby consent to us disclosing your personal information to our affiliates or third-party service providers for the purposes specified in the Privacy Notice. (1)Your personal information will be used only for the purposes specified at the time it was collected and consented to by you. These include: 1)providing, processing, maintaining, improving, and developing our products or the services provided to you, or the services provided through connected devices. 2)implementing security safeguards aimed at preventing loss and fraud, assisting in identifying users, verifying user identity, etc. We will use your information for anti-fraud purposes only when absolutely necessary and when doing so is within our assessed legitimate interests to protect users and services. 3)improving products and user experience. We will conduct statistical analyses of collected information that relates to the use of our products and services in order to better improve and develop our products and services, improve the user experience of our products, and enhance product performance. You may opt out of the user experience improvement program via the Community settings. Once you opt out of the program, we will delete or anonymize all of the data collected from your device under this program. 4)communicating with you and providing customer support or notification push services. We will send you communication regarding your devices, services, or any general inquiries (including updates, device firmware/software upgrades, customer consultations and support, relevant information, and notifications), such as sending notifications and performing service follow-ups. 5)resolving or addressing your questions or requests about devices and services, such as answering customer inquiries, sending system and application message notifications, and managing contests, lucky draws, or other events and activities in which you participate. 6)carrying out the relevant promotional activities, such as providing materials and updates regarding promotions and marketing. Unless applicable laws provide otherwise, if you no longer wish to receive certain types of promotional information, you may use the opt-out method provided in such information to refuse such services. 7)allowing you to comment and post in our Community. 8)using such information for internal purposes, such as internal audits, data analysis, and the research and development of statistical information relating to the use of our products or services to better improve our products or services. 9)storing and maintaining information about you for use in our business operations (such as business statistics) or to fulfill legal obligations. 10)providing local services that do not need to communicate with our servers, such as using sticky notes on your device. 11)other purposes to which you consent. If we intend to use your information for purposes other than those specified in the Privacy Notice, or those given at the time it was collected, yet such use has a direct or reasonable connection to the original purpose, we will obtain your consent in advance. Except where laws and regulations provide otherwise, we will not provide users’ personal information and behavioral data to third parties without user consent. II. How We Use Cookies and Similar Technologies (1)What Are Cookies? Cookies are small files that are transmitted and stored on your device by our websites, applications, or services. realme’s websites, online services, interactive applications, e-mails, and advertisements may use cookies and other similar technologies, such as pixel tags and web beacons. Cookies may be stored on your computer for a short period of time (such as only when your browser is open) or for a longer period of time, even years. We cannot access cookies that are not set by us. (2)The Cookies We Use 1)realme and its partners use cookies or similar tracking technologies to better understand the functionality of mobile software on your device, the frequency that you use the app, the events that occur within the app, aggregated usage, performance data, and where the app was downloaded from. We do not link the information we store within the analytics software to any personal data you may submit within our mobile applications. 2)realme and its partners use cookies or similar tracking technologies to analyze trends, administer websites, track user behavior on the websites, and to collect aggregate demographic information about our overall user base. 3)Many web browsers have a “Do Not Track” feature. This feature sends a “Do Not Track” request to the website. If the “Do Not Track” feature is enabled on your browser, all of our websites will respect your choice. 4)Like most websites, we automatically collect certain information to analyze general usage trends and manage our websites. This information may include Internet Protocol (IP) addresses, browser types, Internet Service Providers (ISPs), referring/exit pages, files viewed on our site (e.g., HTML pages and graphics), operating systems, date/time stamps and/or clickstream data. 5)We may partner with third parties to display advertisements on our website or to manage our advertisements on other sites. Our third-party partners may use cookies or similar tracking technologies to provide advertisements to you based on your browsing activities and interests. If you wish to opt out of interest-based advertising, you may use the “Clear/Disable Cookies” feature as described below to manage cookies and cookie preferences. Please note that when you visit the aforementioned websites, you will continue to receive general advertising that is not targeted toward any specific individual. (3)Clearing/Disabling Cookies Cookies and cookie preferences can be managed from the Options/Preferences panel of your browser. Below are instructions on how to manage cookies on certain popular browsers: • Microsoft Internet Explorer • Microsoft Edge • Mozilla Firefox • Google Chrome • Safari for macOS • Safari for iOS (4)More Information About Cookies For more information about cookies and instructions on how to configure your browser to accept, delete, or reject cookies, see: www.allaboutcookies.org. III. How We Retain Your Personal Information Generally speaking, we only retain your personal information for the period of time necessary to achieve the purposes specified in the Privacy Notice, or those given at the time such information was collected, unless a longer retention period is required by law. Upon the expiration of the retention period, we will delete or anonymize your personal information. In the event that we cease offering some or all of our products or services due to special circumstances, we will promptly inform you and stop the collection and processing of personal information relating to those products or services. In addition, we will also delete or anonymize any personal information in our possession that is associated with such products or services, except where laws or regulations require otherwise. IV. How We Disclose Your Personal Information We do not share or transfer your personal information with or to any company, organization, or individual other than realme, except in the following cases: 1.With your consent: If we have obtained your prior consent, we may share your personal information with third parties. 2.For use in external processing. In some cases, we may engage a third party to process your personal information on our behalf. For example, companies that send text messages or emails or provide technical support on our behalf may use your personal information only to provide services to you on our behalf. 3.From time to time, we may share some of your personal information with our affiliates and strategic partners that work with us to provide products and services in order to provide the products or services you request. Your personal information will not be shared with any third party for their own marketing or commercial purposes. (1)Affiliates: Your personal information may be shared with our affiliates. We will share only necessary personal information, and any sharing thereof will be restricted to the purposes stated in this Privacy Notice. If we or our affiliates wish to change the purpose for which your personal information is used or processed, we will ask for your authorization and consent again. (2)Sharing with authorized partners: Some of our services will be provided by authorized partners, but only to achieve the purposes stated in this Privacy Notice. We may share some of your personal information with our partners to provide better customer service and user experiences. Our authorized partners include but are not limited to operators, data centers, data storage facilities, advertising and marketing service providers, cloud service providers, and technical service providers. In some cases, we may engage a third party to process your personal information on our behalf. For example, companies that send text messages or emails or provide technical support on our behalf may use your personal information only to provide services to you on our behalf. We warrant to share personal information only for legitimate, legal, necessary, specific and clearly defined purposes, and only the personal information that is necessary to provide you with the relevant services. (3)In the event of a merger, acquisition, or bankruptcy liquidation that involves the transfer of personal information, we will require the new company or organization in possession of your personal information to be bound by this Privacy Notice; otherwise, we will require such a company or organization to obtain your authorization and consent again. If there is no transfer of personal information involved, you will be fully informed and all personal information under our control will be deleted or anonymized. Through agreements or other appropriate measures, we will require the aforementioned third parties to take equivalent confidentiality and security measures when processing personal information. 4.For legal reasons. We may disclose your personal information to third parties if we genuinely believe that doing so is necessary to access, use, retain, or disclose your personal information for the following purposes: (1)to comply with applicable laws and regulations or mandatory government requirements; (2)to comply with court subpoenas, judgments, rulings, or other legal procedures, litigation, or other legal requirements; (3)to investigate, detect, prevent, or resolve fraud, security, or technical issues; (4)to execute the relevant service agreements or to safeguard public interests; (5)to make reasonable and necessary disclosures for the purpose of protecting the personal safety and property or other legitimate rights and interests of you, our customers, us, our affiliates, other users, or employees to the extent required or permitted by law; (6)other purposes specified or permitted by law. Special note: Any personal information that you voluntarily share with the public during your use of the Community is not subject to the restrictions under the Privacy Notice (such as forwarding content to other Internet platforms). Please be aware that any information you share can be read, collected, and used by any third party. Please carefully consider the content you post or disseminate in the Community and any information that may identify you personally. You fully understand that when you disclose information on your own initiative, the Community only stores content or system logs containing such information, and has neither the ability nor obligation to proactively identify such information as your personal information. Any information you post publicly may remain in the public domain until you delete it; in some cases, even if you delete the information you post publicly, such information may still be independently cached, copied, or stored by other users or third parties not associated with the Community and therefore not subject the Community’s control; or stored in the public domain by other users or third parties. For example, when you share the content you post in the Community on other Internet platforms, such platforms will independently display, cache, or save your shared content, and other Internet users will also forward and save your published content to, on, or from pages not subject to the control of the Community. V. How We Protect Your Personal Information 1.We use industry-standard security measures to protect the personal information you provide, in order to prevent unauthorized access, public disclosure, use, modification, damage, or loss of data. We take all reasonably practical measures to protect your personal information. In particular: (1)We use technical means such as SSL to encrypt many services. We regularly review our practices in terms of information collection, storage, and processing (including physical security measures) to prevent unauthorized system access. (2)We allow only realme employees and the personnel of service companies authorized to process information on our behalf to access such personal data on a need-to-know basis in order to assist us in processing such information. These employees and external personnel are subject to strict contractual confidentiality obligations. If they fail to fulfill these obligations, they may be held legally liable or their relationship with realme may be terminated. (3)The security of your information is extremely important to us. Therefore, we continuously endeavor to ensure the security of your personal information and implement safeguards such as full security encryption throughout storage and transmission to prevent your information from unauthorized access, use, or disclosure. At the same time, no one can access the specific contents of certain encrypted data except the users themselves. (4)When transmitting and storing your personal information of special categories, we use security measures such as encryption. We use technical measures to process your personal biometric information before storage. For example, we store only the essential components of personal biometric information. (5)We will strictly screen business partners and service providers and implement the requirements for personal information protection into the business contracts or audits, assessments, and other activities between both parties. (6)We hold security and privacy protection training courses to increase employees’ awareness of personal information protection. (7)We use industry-recognized standards to protect your personal information and actively pass the relevant security and privacy protection certifications. 2.We have taken reasonably practical and technical measures to protect the information we collect in relation to the services. Please note that although we have taken reasonable measures to protect your information, there are no websites, Internet transmissions, computer systems, or wireless connections that are absolutely secure. 3.In the event of a personal information security incident, we will, as required by relevant laws and regulations, promptly inform you of the underlying circumstances and possible impact of the security incident, the measures we have taken or will take, the recommendations you may take to prevent and mitigate risks, corrective steps you can take, etc. We will promptly inform you of the incident by email, letter, phone, push notification, etc. When it is difficult to inform personal information subjects individually, we will make a reasonable and effective announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities. VI. Your Rights to Your Personal Information realme respects your rights with respect to your personal information. Legislation in some of the countries/regions where we provide products and services stipulates that personal information subjects have the right to access, correct, and delete the relevant personal information we retain. The following is a list of rights to which you are entitled in accordance with law and how we will protect them: 1.Right to be informed: We publish the Privacy Notice to inform you of how we process your personal information. We are committed to ensuring transparency in the use of your information. 2.Right to access: You can directly search or access your personal information on our official website or in Community applications. If you are unable to search or access your personal information on your own or you experience any problems in exercising your data access rights, you may request access to your personal information by contacting us at [email protected]. 3.Right to rectification: If you find that the personal information we process about you is inaccurate or incomplete, you have the right to ask us to make corrections or additions. For some of your personal information, you can directly correct or modify it on the relevant function page of the product or service. In the case of personal information that has not yet been made available for you to modify on your own, you may contact us at [email protected] request corrections or additions to your personal information. 4.Right to erasure: You may opt to delete certain personal information that you have provided to us. You may delete some of your personal information directly on the relevant function page of the product or service. In the event that you discover we have collected and used your personal information in violation of laws, administrative regulations or the provisions of this Privacy Notice, you have the right to request that we delete the relevant personal information. You may contact us via email at [email protected] request that we delete or anonymize personal information submitted by you. If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and require them to delete the data in a timely manner, unless law or regulations require otherwise or those entities have obtained your independent authorization. When you delete information from our products or services, we may not immediately delete the corresponding information in the backup system, but we will delete the information when the backup is updated. 5.Right to withdraw consent: Each operational function or specific service requires some basic personal information in order to function as intended (see the “How We Collect and Use Your Personal Information” section of this Privacy Notice). You may give or withdraw your consent at any time for the collection and use of additional personal information. If you withdraw your consent, we will no longer be able to continue providing you with the services for which you have withdrawn your consent or authorization. When you withdraw your consent, we will no longer process the corresponding personal information, but your decision to withdraw your consent will not affect the processing of personal information previously performed on the basis of your authorization. You may change the scope of personal information that we are authorized to continue collecting, or withdraw your authorization by deleting information, turning off device functions, etc. 6.Right to account closure: We provide you with the right to close your HeyTap account. You can log in to https://id.heytap.com/profile.html, select “Personal Data Management,” click “Delete Account,” and follow the instructions to submit a request to close your account. Please understand that after you submit a request to close your account, we may need to conduct a manual review to confirm that you meet the account closure requirements. We will assist you in completing the closure of your account within 15 business days of the submission of your request (or within the period specified by the relevant jurisdiction). After you choose to close your HeyTap account, we will delete or anonymize all relevant personal information about you under your HeyTap account, unless otherwise required by law. After you log out, we will no longer be able to provide you with products or services that require you to log in with your HeyTap account. You may also contact us directly at [email protected] to request the closure of your account. 7.Right of complaint: You have the right to contact customer service to file a complaint. We will respond to your complaint within 15 business days (or within an extended period as permitted by law in the relevant jurisdiction) from the date of receipt of your complaint. If you are not satisfied with our response, especially if our processing of personal information harms your legitimate rights and interests, you may also lodge a complaint or report with the regulatory authorities in the relevant jurisdiction, or file a lawsuit with a court of competent jurisdiction. 8.If you wish to make a request, you can submit the request by email to [email protected]. 9.Depending on the applicable data protection laws in your location, you may have additional rights to your personal information. If you reside in Europe, please check the relevant section of the GDPR. Please note that for security reasons, we may need to verify your identity before processing your request. Generally, we do not charge a fee for reasonable requests. However, for multiple and repetitive requests that exceed reasonable limits, we will charge a certain fee to cover some costs depending on the nature of the request. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, requiring the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are highly impractical. In addition, we may not be able to respond to your request if it directly relates to matters linked to national security, national defense, public health, criminal investigations, public interests, etc., or if it may result in serious harm to the legitimate rights and interests of you or other individuals or organizations. VII. How We Process the Personal Information of Minors Our products, websites, and services are primarily intended for adults. Without the consent of their parents or guardians, minors (i.e., persons under the age of 18 or a similar minimum age as specified by the relevant jurisdiction) are not allowed to create their own user accounts. The personal information of a minor collected with parental consent will only be used or publicly disclosed when permitted by law and expressly consented to by the minor’s parent or guardian, or when doing so is necessary to protect the minor in question. If we discover that we have collected the personal information of a minor without first obtaining verifiable parental consent, we will attempt to delete the relevant data as soon as possible. VIII. Third-Party Products or Services Our Personal Information Protection Notice does not apply to products and services provided by third parties. The products or services of the Community may include third-party products and services, links to third-party websites, or third-party access in the form of SDKs, APIs, etc. Please note that we have no control over the personal information and data protection notices of third parties, and such third parties are not bound by the Privacy Notice. Your information may also be collected when you use third-party products or services. We carefully evaluate the purposes for which SDK service providers use your personal information. We conduct a comprehensive assessment of the security capabilities of these partners and require them to comply with the legal terms of the cooperation agreement. We conduct rigorous security monitoring to protect data security. Therefore, we strongly recommend that you understand the personal information protection notices of these third parties before submitting personal information to them. We are not responsible for, nor can we control, how third parties use the personal information they collect from you. The Privacy Notice does not apply to other websites linked through our services. To protect your legitimate rights and interests, if you find that such SDKs or other similar applications pose risks, you are advised to terminate the relevant operation immediately and contact us promptly. The products or services of the Community include SDK plug-ins provided by our affiliates or authorized partners. These service plug-ins collect and process your personal information. For example, HeyTap SDKs request permission to send/receive text messages or acquire logs in order to achieve login functionality. Facebook SDKs and Twitter SDKs need to collect your device information in order to achieve user sharing functionality, while Firebase SDKs need to collect your device information for data statistics and analysis purposes. You may log in to their official websites to view their personal information protection notices. We integrate certain utility class SDKs in order to realize the needs of product or service features. Please understand that such SDKs do not collect your personal information, nor will they invoke sensitive permissions. For example, we integrate OkHttp 3 for the underlying design of network requests, Glide for image loading, JSON formatting tools, etc. IX. How Your Personal Information Is Transferred Globally As a company operating globally, we provide our products or services through resources and servers located around the world, and have set up data centers in China, France, Singapore, India, and other countries. This means that, subject to applicable local laws and regulations, your personal information may be transferred to or accessed from jurisdictions outside the country/region where you use the product or service. In general, personal information collected and generated within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China; personal information collected and generated within the territory of the European Union will be stored in the territory of the European Union. You understand that risks may vary under different data protection laws. In such cases, we will take measures to ensure that the data we collect is processed in accordance with the requirements of the Privacy Notice and applicable laws, and to ensure that your personal information is protected to the same extent as in the country/region where you use the product or service. For example, we will request your consent for cross-border transfers of personal information, or implement security measures such as encryption, de-identification or entering into the necessary data transfer/sharing agreements with the data recipient prior to cross-border data transfers. X. How the Privacy Notice Is Updated We reserve the right to update or modify the Privacy Notice from time to time. We will notify you of changes to the Privacy Notice through various channels. We will notify you of major changes to the Personal Information Protection Notice at the email address provided by you, by posting notices on the website, or by pushing notifications to you via the Community application, so that you can understand the information we collect and how we use such information. Such changes to the Personal Information Protection Notice will apply as of the effective date (or “Update Date”) specified in the notice or on the website, and your continued use of the products, website, and services will be deemed as your acceptance of the updated Personal Information Protection Notice. XI. How to Contact Us 1.If you have any comments or questions regarding the Privacy Notice, or if you have any questions about the collection, use, or disclosure of your personal information by realme, please contact us at the following address: Suite 201, Building A, 1 Qianwan 1st Road, Qianhai Shenzhen-Hong Kong Cooperation Zone, Shenzhen (Shenzhen Qianhai Commerce Secretariat Co., Ltd.) Email: [email protected] 2.If you reside in the EU, you may contact our EU representative through the following means: Baradine Invest, S.L.U. calle Príncipe de Vergara, 112, 1º, 28002, Madrid (Spain) Email: [email protected] 3.If you reside in India, you may contact our India specialists through the following means: Realme Mobile Telecommunications (India) Private Limited 3rd Floor, Tower B, Building Number 8, DLF Cyber City, Gurugram-122002, Haryana, India. Email: [email protected] B. GDPR Exclusive Terms The following terms and conditions apply only to persons residing in Europe. I. Legal Basis for Processing Personal Information Our processing of your personal information, as described in the section “How We Collect and Use Your Personal Information,” is based on the following legal grounds: 1.Consent: We may process your personal information based on your consent. In particular, we may ask you to consent to our promotional activities, such as sending you promotional messages, your participation in the “User Experience Program,” and your use of certain services, including those in which we collect location information. You have the right to withhold consent, or to withdraw consent at any time. Withdrawal of your consent does not affect the legality of our use of your personal information prior to your withdrawal of consent. If you have given us your consent to use your personal information, we will use it only for the purposes specified in the consent statement. Please note that if our processing is based on your consent, and you withhold or withdraw your consent, we may not be able to provide the related services. In addition, neither the initial withholding of consent nor the withdrawal thereof will have any negative consequences for you. 2.Performing a contract or entering into a contract with you. Examples of legal basis scenarios are as follows: • Providing you with realme services or performing a contract between you and realme; • Allowing you to comment or post in the Community; • Allowing and managing your participation in lucky draws, contests, or promotional activities run by us; • Diagnosing product problems or providing other customer service and support services. • Providing you with realme services or performing a contract between you and realme; • Allowing you to comment or post in the Community; • Allowing and managing your participation in lucky draws, contests, or promotional activities run by us; • Diagnosing product problems or providing other customer service and support services. 3.Compliance with legal obligations: realme may be obligated to process personal information in order to comply with our legal obligations, such as realme being required to retain data due to tax laws or commercial purposes. 4.Legitimate interests: For the legitimate interests of realme, it may be necessary to process your personal information. In particular, such cases include the following: • Conducting customer surveys to understand your user experience; • Analyzing customer markets based on the country where you use our services, including the qua tity of users to which the product is marketed and promoted; • Analyzing the efficiency of our business operations; • Analyzing error logs to improve service quality and application functionality; • Providing you with personalized services, and recommending and displaying content and advertising tai ored to your needs within our services; • Communicating with you by any means and responding to questions or comments you submit to us; • Ensuring the functionality and security of our services; • Verifying your identity; • Conducting internal audits to prevent and investigate fraud, cyber security threats, or other mis se; • Improving and developing our services, including security features, such as improving the fun tional experience of our products and improving product user-friendliness, operational per ormance, functionality, and design; • Investigating or defending against legal claims. When we process your personal information based on the reasons stated above, we will do so only after we have fully evaluated and balanced our interests with your privacy rights. II. Additional Information on How Your Personal Information Is Transferred Globally If your personal information is transferred to a jurisdiction outside Europe, we will ensure that appropriate safeguards are in place, such as: 1.The recipient of the personal information is located in a country that is recognized as “adequate” by the European Commission. 2.The recipient has signed a contract obliging them to protect your personal information in accordance with the “Model Contract Clauses” approved by the European Commission. 3.Or, in the absence of appropriate safeguards as described above, we will require your express consent to the cross-border transfer of your personal information, or take any other protective measures that are generally recognized as adequate to protect your personal information. For more information about safeguards relating to personal data transfers outside Europe, please submit your request to [email protected]. III. Additional Information on Cookies and Other Tracking Technologies If you would like more information on the use of cookies and other tracking technologies, please click here. IV. Additional Information on Rights to Personal Information Under the legal requirements of the EU’s General Data Protection Regulation (“GDPR”), you have the following rights: • The right of access: You may request access to the personal information about you in our possession. • The right to rectification: If you find that the personal information we process about you is inaccurate or incomplete, you have the right to request that we make timely corrections and, where appropriate, request that your personal information be supplemented. • The right to erasure: You may submit a request to us to delete your personal information. In some cases (for example, where we have no legitimate reason to continue processing your personal information to the extent required by applicable laws and regulations), we are obligated to delete it promptly. Please note that having deleted all the data contained in your device does not mean that you have deleted all the data collected and processed by realme about you. Therefore, we encourage you to request deletion of your personal information by sending an email to [email protected]. • The right to restrict processing: In certain circumstances, where you dispute the accuracy of personal information, you have the right to request realme to restrict the way we process your personal information for a period of time, so that we can verify the accuracy of the personal information. We will only retain enough, or process as much data as is necessary, to ensure that we honor your request for restriction in the future. • The right to object: You have the right to object at any time to any processing of your personal information, based on legitimate interests in your particular circumstances. If you decide to object to the processing of your personal information, we will stop processing the personal information relating to you, unless we can demonstrate that there are compelling reasons to continue processing your personal information that outweigh your interests, rights, and freedoms, or we initiate, exercise, or defend our legal claims. You may object to direct marketing campaigns at any time and for any reason. • The right to data portability: You have the right to obtain a copy of your personal information in a structured, accessible, and machine-readable format, and to transfer this data to other suppliers and, in some cases, directly to other suppliers. • The right to withdraw consent: If you have given your consent for us to process your personal information, but later change your mind, you have the right to withdraw your consent at any time. Withdrawal of your consent does not affect the legality of our use of your personal information prior to your withdrawal of consent. If you wish to withdraw your consent to receiving promotional messages, you may unsubscribe by the method described in each promotional message. If you withdraw your consent, we may no longer be able to provide you with the corresponding services. • The right of complaint: You have the right to file a complaint with the competent supervisory authority regarding the way we handle or process your personal information, or to file a lawsuit with a court of competent jurisdiction. For information on how to contact your local data protection supervisory authority, please click here. V. Contact Information for EU Representatives If you have any questions or concerns regarding our Privacy Notice or practices, please contact us at the following address: Baradine Invest, S.L.U. calle Príncipe de Vergara, 112, 1, 28002, Madrid (Spain) Email: [email protected]