Fairphone Privacy Policy

At Fairphone, we've got a mission to challenge the tech industry and push for better practices, all based on some core principles we really believe in. And to make that happen, we know transparency is key. So, we're transparent about everything we do, including our Privacy Policy. We want You to know exactly what's going on with Your personal information and be able to make informed decisions. That's why we've put together this Privacy Policy, which tells You all about the personal data (meaning any information through which We can, directly or indirectly, identify You)  we collect, why we collect it, and what we do with it.

This Privacy Policy applies to the website fairphone.com (including Fairphone webshop, forum, blogs and Fairphone support platform) owned and operated by FairPhone B.V. and the processing by Our devices and My Fairphone App. Apart from the device set-up, Your Fairphone comes with a native application called the My Fairphone App. 

In general We only use Your personal data when the law allows us to. Most commonly, we will use Your personal data in the following circumstances:

• Where you have provided Your (explicit) consent for direct marketing activities whereby Fairphone will proactively notify you  e.g. through emails or push-notification. Where consent was required for processing, You can revoke Your consent for future data processing at any time. However, this does not affect the lawfulness of data processing based on the consent before the revocation. In certain cases, we may continue to process Your information after You have withdrawn consent, this would apply when we process the same data for a different purpose or if Your withdrawal of consent was limited to certain processing activities.
• Where there is a necessity for the performance of our contract with you, e.g. providing warranty service. 
• Where it is necessary for our legitimate interests and Your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

1. Your rights and responsibilities

We will provide You with access to Your Data, so You may control and update, modify and, where legally possible, delete it.

You can contact us at our Fairphone Privacy Center,  if You want to:  

• Review, change or delete Your Data;
• Object to certain processing of Your Data;
• Receive a copy of Your Data in a machine-readable format;
• Ask us any other questions regarding Your Data and its protection

When providing us with Your Data, it is Your responsibility to ensure that Your Data is accurate, complete and up-to-date. You should also take all reasonable measures to keep Your Data secure at all times. For instance, You are responsible for keeping Your password and other log-in details confidential. Moreover, You remain responsible for any personal data You freely publish on our forum, in our social media accounts or in the comments section under our blogs or in Your communication with our Customer Support team. We will not ask You for Your password, except when You log into our website or My Fairphone App.

When providing us with the Personal Data of other people, it is Your responsibility to collect this Personal Data in compliance with the GDPR and other local legislation. This includes informing the people whose Personal Data You are providing about this Privacy Policy and obtaining their consent.

2. What Data do we collect and Why?

2.1 To enable you to use our platforms, provide our services and fulfil our contracts with you.

Visit our website

When You visit our website we collect the information sent by Your computing device, such as laptop, mobile phone etc. This could contain:

• Device information (operating system and browser used, plugins and fonts installed, screen size);
• Log information: the time and duration of Your use of our digital channel;
• Use of the website: where do You click and which pages do You visit;
• Location information: Your approximate location derived from Your IP address. For Google Analytics, we erase the last three numbers of Your IP address to make this more anonymous however under Bloomreach we receive the full IP address;
• Other information about Your use of our digital channels; 
• Preferences You set on our website about language and location;
• Login information and the contents of Your shopping cart.
• Any purchases made.

We use Google Analytics, Google Tag Manager, Hotjar, Convert, Bloomreach, Facebook, Tiktok, Snapchat, Twitch, Reddit, Outbrain, Microsoft Ads and Google Ads to analyse website visits. This is done by using real time information of people interacting with our website and by placing cookies or running a piece of java-script code in the browser of a visitor. 

A cookie is a digital file containing a unique ID (a string of letters and numbers) that is sent by our website to Your computer and is stored there. This unique ID is then sent back to our website each time You open our website. This enables our website to recognise and track You.

We will use the persistent cookies mainly to enable our website to recognize You when You visit and keep track of Your preferences, like language settings,  in relation to Your use of our website.

We use both “session” cookies and “persistent” cookies on the website. Session cookies will be deleted from Your computer when You close Your browser. Persistent cookies will remain stored on Your computer until deleted, or until they reach a specified expiry date.

We use advertising cookies to collect information on visitors of our website, solely with your explicit consent, to advertise our products. These targeted advertisements are tailored to your interests and needs, assisting us in better understanding the preferences of potential Fairphone users.

Your advertising cookies will be shared with Our third party service providers to deliver advertising content on other websites. Our third-party service providers may use Demand-Side Platform (DSP), including Xandr DSP, Google DV360 to analyze and manage your advertising cookies to collect data about your online activities and your browsing habits on our websites. You can withdraw your consent for advertising cookies at any time by adjusting your cookie preferences. Additionally, You can find more detailed information about how your cookies are used by Xandr and DV360 in their privacy and cookie policies here (Xandr, DV360).

We use Your Data to:

• Estimate our visitor size and usage pattern so we can optimise our website;
• Analyze the use of our website and to create reports about the use of our website;
• Store data about Your preferences like language and country settings; store Your session data like the contents of Your webshop cart and Your logged-in status; prevent fraud and increase the security of our website;
• Better tailor advertising to Your interests if you consent  to the use of Your Data. This means Fairphone is able to collect aggregated user information and use it to build and show personalised content for example in ads, emails or app notifications for specific user groups e.g. via social media. 

You can manage your cookie preferences at any time by visiting our Cookie Settings. Please be aware that you may need to refresh the page for your changes to take effect. If you wish to disable strictly necessary cookies, including necessary and performance cookies, you will need to do so through your browser settings. (consult your browser's "help" menu to learn how to remove or block cookies). You can find instructions on how to manage cookies on the different types of web browsers at https://www.allaboutcookies.org/.

Create a user account on our website. 

When You create a user account on our website, the mandatory information that we need is Your:

• First name
• Last name
• E-mail address
• You may choose to provide additional information. 

Your data is sent to us by the sign-up form. The sign-up form is protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. We use this data to create an account for you and to inform you about its creation by email. 

We use the data in order:

• To calculate our referral rates and operationalise our Referral Program through Referralcandy.
• Buy a Fairphone or another product from our website.

In order to be able to send You Your Fairphone or other product, we need:

• Your name, address, phone number, email address and payment data to complete the purchases. 
• We store the IMEI number of the Fairphone You bought.
• We also store the serial number of items purchased where applicable e.g. True Wireless Earbuds.

Please note that when You use third party payment providers, such as PayPal, Adyen and Klarna, their Privacy Policy is also applicable to the monetary transaction. We collect Your data during the purchase process. In order to complete the purchase You will have to provide Your personal details in our electronic form. The form is protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. Please note if You purchase Fairphone products via a guest checkout or from Your customer account, we will match Your data under a single account entry based on the email address. We use the data in order: 

• To process Your order;
• Make sure Your product is delivered;
• Keep proof of purchase for guarantee and accounting purposes.
• We use the IMEI for warranty and support reasons. 
• For analysis and segmentation, as well as personalization of content through Bloomreach. 
• To calculate our referral rates and operationalise our Referral Program through Referralcandy.

Apply for a job at Fairphone. 

We collect the following information:

• First name
• Last name
• Email
• Country
• Telephone number
• LinkedIn profile
• Any other information You disclose in Your motivational letter and CV.

The Personal Data that is provided by applicants is stored in our Application Tracking System Homerun, which is also our recruitment database. If hired, our People team will process the information as necessary in relation to Your employment and Your information will be transferred to Your personnel file. This is limited to information relevant to the ongoing employment relationship.

Your Data is only used to communicate with you with regard to Your job/internship/open application:

• Request additional information concerning a new job/internship opportunity and/or assessing the application;
• Inform You about job/internship opportunities.
• Participate in the Reuse and Recycle Program

We collect the following information:

• Your phones IMEI nr.;
• The Model, Brand and (if applicable) the storage capacity of Your phone; 
• Your declared conditions of Your phone; 
• Your name;
• Your address;
• Your email address;
• Your phone number; 
• Your ID information; 
• Your Bank account information ; 
• The declared and validated refund value of Your phone; 
• The diagnosis of Your phone by our recycling partner. 

We collect Your data by using the form on our recycling page of our recycling partner Cordon Electronics (Cadaoz). The form is protected by a SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. 

We use Your Data 

• To calculate the refund value of Your phone;
• To make a label that you can use to send Your old phone to Cordon Electronics (Cadaoz), our recycling partner;
• To send you a discount voucher via Your email address to be used to buy a Fairphone product. 
• To the extent necessary, share relevant data with local authorities to ensure compliance with legislation which addresses obligations for the purchase of second hand devices.
• To fulfil our legal obligations.

Setting up Your Fairphone

Once You start Your device, You will be guided through a series of options for settings. In the below section we explain in more detail what these options entail in terms of data processing. Please note this is applicable to You only if You are operating under the Android Operative System (OS) and not alternative OSes, such as e/os. 

While we aim to provide You with control over Your personal data and other data sent by Your device to us, some data is required to ensure Your device is secure, up to date, and performing as expected. In addition, this data also allows us to estimate how long a device is used and updated, which is core to Fairphone’s mission to increase the longevity of devices and reduce environmental impact. This data is sent by Your device regardless of the options for settings You have set and is collected on a legitimate interest basis. It includes the following data points: 

• Device activation: it allows us to see the number of devices activated, which helps us provide service to You in a number of ways:
• Allows us to create a baseline so that we can recognise quality or security issues in devices more quickly; 
• Allows us to see how many of the devices we sold are active in the field, which can be used to determine the correct course of action. For example, does an issue occur in all devices or certain batches, and are the affected devices in the hands of our customers.
• Allows us to plan spare parts production more effectively to minimise waste at the end of life;  
• IMEIs: The IMEI numbers (IMEI1 and IMEI2) are used for identifying the device. They help our operations team track devices for activities like sending devices to customers and providing services such as warranty service and extended warranty service.
• Device Information: The brand and model of the device are used to recognize the specific make and type, which is important for troubleshooting and identifying device-specific issues. The serial number uniquely identifies each device, making it essential for tracking and warranty purposes.
• Operating System Version: The OS version indicates the software environment the device is running, helping us identify potential issues tied to specific software versions and deploy necessary updates or fixes.
• Fingerprint: The fingerprint is a unique identifier tied to the device’s configuration, helping distinguish different devices when other identifiers may not be sufficient.
• Build ID and Build Time: These fields represent the software build associated with the device, assisting in tracking which versions were used and diagnosing any issues linked to specific builds.
• Commercial Use Allowed: This flag indicates whether commercial use of the device is permitted, which is important for understanding its intended usage and associated terms and conditions.

In the device setting, You can control the privacy settings of Your device in the Settings of Your device..This data is not used to target You specifically but will instead be used to understand the potential quality issues.  

Use the My Fairphone App

Depending on what features of the My Fairphone App You use, we may process different categories of Personal Data about You. This contains:

• First name;
• Last name;
• E-mail address;
• IMEI Number;
• Serial Number of the Device
• Product name and Model
• Device information (operating system and browser used, plugins and fonts installed, screen size; Network Operator; Device Activation date);
• Log information: the time and duration of Your use of the My Fairphone App;
• Location information: Your approximate location derived from Your IP address. We erase the last three numbers of Your IP address to make this more anonymous;
• Preferences You set in the My Fairphone App about language and location;
• Any information You provide us.

We collect this data in various ways:

• When You register for the My Fairphone App, the application creates an account in Fairphone’s website system, Auth0 together with Bloomreach. 
• When You have a Fairphone Forum account, the My Fairphone App will redirect to the forum where You may sign into Your forum accounts. 
• When You create a support ticket in the My Fairphone App, the application creates this ticket in Zendesk. If You have a Zendesk account already, the My Fairphone App will ask You to sign into it.  
• We use Google’s Firebase,Google Analytics and Bloomreach for Mobile to analyze My Fairphone App usage. 
• When you complete the Green Challenges this data is stored within the My Fairphone App.

We use Your data to allow You to set-up an account for the My Fairphone App and grant You access to the different features e.g. customer service questions. Furthermore, this allows us to assess Your problems and provide You with the necessary support and subsequently analyse any customer support request for future training. My Fairphone App also enables Fairphone to improve our services. Where you have provided us with consent, we also collect data for marketing purposes, such as personalisation of content of push-notification so that you only receive information that is relevant for you and Your device.

Notifications from My Fairphone App

You may receive push notifications from the MyFairphone App. These notifications, currently include: 

• NPS Survey: This push notification opens a survey on a website hosted by HelloCustomer and Typeform.We send You this one-time notification 30 to 45 days after Your device has been activated so we can ask You some simple questions about Your experience with Fairphone so far. 
• Warranty Registration Reminder: This push notification redirects You to the warranty registration page. The unique 5 year warranty for Fairphone 4 requires registration and through these reminders we help ensure You can make use of this warranty extension.  
• Longevity Survey: This push notification redirects You to the survey in a Typeform format. The survey collects the answers to the questions along with the Fairphone model, OS version, serial number, at what time the survey has been started, at what time the survey has been finished and the Network ID. We use the responses to the survey to calculate how long our customers intend to use the Fairphone device and what Fairphone can do to improve the longevity of the device. 
• Green Challenges: If You choose to participate in a green challenge through the My Fairphone App, then You will get a notification asking whether You have completed the Green Challenge or not.  

We use the platform called Bloomreach to trigger the notifications, manage the notification content and analyse this for potential improvements. You can manage Your push notification preferences at any time or deactivate these notifications at any time by turning off the notification settings in the MyFairphoneApp or in the Device Settings of Your Fairphone.

This section does not include push notifications received from the Android Operating System or from Third Party applications.

The Fairbuds App 

When you use the Fairbuds App:

• The App will not collect any user identifiable information (e.g. login, behaviour tracking);
• The App will include links to the Fairphone website with a UTM tag. This will enable Us to see how many visits Our web pages get from the Fairbuds App whereby We can view whether traffic comes from the iOS or Android version of the App.

The Fairphone Moments 

The Fairphone Moments app is exclusively available on Fairphone Gen 6 devices. This app comes pre-installed on your Fairphone Gen 6 and can be activated using the dedicated Switch button. You can manage this feature at any time by navigating to Settings > Switch Button Settings. We use Google Analytics to understand how users interact with the Fairphone Moments app. This helps us improve the app experience and guide future development.

When you use the Fairphone Moments App:

• The App will not collect any user identifiable information;
• The App will only collect the first app launch timestamp, app usage frequency and patterns, and session duration via Cookies embedding in this App.  For more information about how Google Analytics processes data, please visit the Google Analytics page ;

Your usage data is collected solely to improve app performance and user experience, guide product development decisions, and fix technical issues. We will never use your data for marketing purposes, share it with third parties, or sell or trade your information.

2.2 To improve and personalise Your Fairphone experience.

Invitations to write a review on Trustpilot and Bazaarvoice

We may contact You via email to invite You to review any products and services You received. The purpose of this is to collect Your feedback and make improvements to our product offering.We also want to share Your experience as transparently as possible with other potential customers, which is why we use Trustpilot and Bazaarvoice as trusted third parties.  We will invite You to write a review via Bazaarvoice. Once You submit Your feedback, Your email address, IP address, device fingerprint, timestamp, and feedback will be collected by Bazaarvoice, Inc. Your review, including Your name and Your feedback, will be shared with our partners and displayed publicly on both our website and theirs. If You want to learn more about how they handle Your data, You can refer to their Privacy Policy here: Bazaarvoice Privacy Policy.

We do not use sponsors, incentivise or pay our customers to write reviews as we believe this creates bias and is not a true representation of what our customers think and feel.

Submit a complaint, feedback, inquiry and or repair request. 

We collect the following information;

• Your email address;
• Any information disclosed in the attachments You add to Your request;
• The Fairphone model You own and specifics of the product;
• Online shop order number where applicable;
• Phone unique identifier or IMEI;
• Battery serial number and other serial numbers where applicable; 
• Any other Personal Data You provide us. 
• We ask you to update Your address in Your Fairphone account and we communicate this via email.

We collect Your Data using the form on our website.  We use Your data:

• To contact you. 
• To facilitate the return of Your repaired or replaced device.
• To assess Your problems and to provide you with the requested support. 
• To analyse and improve our customer support and for training of new agents.
• To allow for personalised communication and ask for feedback.  
• For analysis of device quality and our business processes. 

A/B testing

When You interact with one of our platforms or digital channels (e.g. website, emails, push notifications)we collect the information sent by Your computing device, such as laptop, mobile phone etc. This could contain:

• Device information (operating system and browser used, plugins and fonts installed, screen size);
• Log information: the time and duration of Your use of our digital channel;
• Use of the website: where do You click and which pages do You visit;
• Location information: Your approximate location derived from Your IP address.  For Google Analytics, we erase the last three numbers of Your IP address to make this more anonymous however under Bloomreach we receive the full IP address;
• Other information about Your use of our digital channels; 
• Preferences You set on our website about language and location;
• Login information and the contents of Your shopping cart.
• Any purchases made.

We use this information to perform A/B testing for content on the website. A/B testing, also known as split testing, refers to a randomised experimentation process wherein two or more versions of a variable (web page, page element, etc.) are shown to different segments of website visitors at the same time to determine which version leaves the maximum impact and creates the faster/easier customer experience This is done by using real time information of people interacting with our website and by placing cookies or running a piece of java-script code in the browser of a visitor.

Centralised Authentication and Single Sign-On (SSO)

Some of our services make use of a centralised authentication service, which allows You to sign in to them with one set of credentials (Single Sign-On or SSO). When you make use of this service, we collect some information:

• Username and email address.
• Activity: when you first signed up, and when you last logged in. Which browser you used (if any).
• Primary identity provider: whether you are connecting via another identity provider (like Google, Facebook, Apple ID, etc.) or if you registered directly to the service.
• Security: whether you have enabled Multi-Factor Authentication to protect Your account.

Analytics 

We assess general key performance indicators (KPIs) for all our commercial activities such as; purchase history, engagement with Fairphone content, response rates for surveys to allow us to better understand our customer groups and ensure enhanced decision making. This is important for us to understand the preferences, satisfaction and experiences of our customer base with our products and services.

2.3 To support our promise of product longevity.

Fairphone Activation 

We collect the following information from Your device via a report sent to our servers: 

• Serial number
• Version of the operating system
• Brand
• Model 

This helps us determine when the device was first activated and whether the device is still active. The data serves as an important measurement for our company KPIs concerning device longevity and usage. It is Fairphone’s ambition to enable our customers to actively use their Fairphones for at least 5 years.  We will use Your data to trigger certain longevity activities (e.g. inform You about possible lifecycle updates, e.g. when You need a new battery, software at the end of its life). Furthermore, we will also use this to assign loyalty points for the customers who join Our loyalty program. 

You are always able to opt-out from certain information being sent to us (this includes IMEI 1, IMEI 2, operator name, operator identifiers [MCC and MNC], connection information [tracking area code and cell identifier]). You may also choose to enable us to use the data for marketing purposes. We also use and share Your Data with Bloomreach, this helps us to improve Your longevity experience and personalise our communication based on the age of Your phone. For example, we want to let you know directly and ahead of time when the last possible software update is coming up.

Extended Warranty Registration

When you register for our Extended Warranty, we collect the following information:

• First name;
• Last name;
• Preferred pronouns;
• Birthdate;
• Postcode & City, Country; 
• Email Address;

We use Your data to allow you to benefit from Our Extended Warranty and to assess any problems which you may require support with as well as for statistical purposes. Furthermore if You provide consent, we also use Your data to send you exclusive communication. You can object to this processing by unsubscribing via the link in the emails. Kindly also refer to our Extended Warranty here.

Self Return Merchandise Authorization Portal (Self RMA portal)

When you use our Self-Repair RMA Portal, we collect the following information:

• Location (country);
• Fairphone account details;
• Shipping address;
• IMEI number;
• Email address;
• Purchase history.

We process this data to fulfil your return or repair request, verify Your warranty eligibility, and generate shipping labels. This data is shared only with our contracted repair centre and repair service providers, who are required to delete the relevant personal data upon completion of the relevant service ticket.

2.4 To carry out marketing activities.

Join and post on the Fairphone forum and comment under blogs.

We collect the following information: 

• Username
• Name (if provided)
• Primary email address
• Secondary email address (if provided)
• Associated accounts ( if external services are connected. E.g. Facebook.))
• Profile picture (if provided)
• The last IP address You used to login
• The IP address You used at the moment of sign-up
• Any data You disclose by adding posts or private messages to the forum. For example, administrators of the forum can read Your private messages to other forum users, in order to ensure the forum rules are adhered to.  

Your Data on the Fairphone forum is collected through the sign-up form and through registration of Your actions on the forum. We use Your data:

• To enable you to create an account and to validate that account;
• To monitor the popularity of our forum and make adjustments if needed;
• To fight spam, false logins, trolls and other behavior that violates our forum rules;
• To help resolve any disputes forum members are unable to solve between them; 
• To assess user activity for statistical analysis and diagnostic purposes. 

Subscribe to our newsletter

We collect the following information;

• Your email address
• First name

By using a form on our website and a verification email (double opt-in) sent to Your email account. Our forms are protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. We use Bloomreach to fulfil this however you may unsubscribe or set Your preferences for topics at any time. Please note Bloomreach enables Fairphone to link an email address to a customer profile. 

We use Your data to confirm you are the owner of the email address and subsequently to keep you informed of Fairphone in our newsletter about product, company updates and promotions when applicable. 

When subscribing to the newsletter for the first time, you are automatically receiving emails on the following three topics. You can update Your preferences and unsubscribe partially from any of these three newsletter lists:

• General Fairphone news
• Promotions and sales offers
• Personal product and impact updates

Subscribe to get product updates and availability updates.

We collect the following information:

• Your email address

When a product is unavailable for a period of time, we add a form to the product page. You can use this form to fill in Your details and You will receive an email when the product is available again. We use Your data to notify you when a product has become available again. Furthermore, we may use Your data to notify you of a similar product becoming available on our website.

Participate in the Referral Program. 

We collect the following information from You if you are an “Advocate”:  

• Your name (optional; if given by you via this form). 
• Your email address. 
• Your social media shares (i.e. when you share Your referral link via social media websites, WhatsApp, or Telegram; we do not see or store the content of Your social post, nor Your WhatApp or Telegram messages).
• Your referral link shares.
• Number of people you referred to our Referral Program.
• Discount coupons you received as a result of a successful referral.

We collect the following information from You if you are a “Referred person”:

• Your name (when / if given when purchasing a Fairphone from our webshop with a referral link).
• Your email address.
• Purchase details (i.e. Date and time of purchase; amount spent in our webshop; External Reference ID; Internal Invoice ID). Please refer to the sections on purchasing a Fairphone for further information on what we collect. 

We collect Your Data using a form on our website which is run through ReferralCandy. The form is protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser.

We use Your data to confirm you are the owner of the email address and subsequently allow you to benefit from sharing Your invite link and receive a discount. You can find the Terms and Conditions of the Referral Program here.

Subscribe to our business newsletter

We collect the following information  to confirm You are the owner of the email;:

• Your name;
• Your email address;
• The name of Your organisation.

By using a form on our website and a verification email sent to Your email account. Our forms are protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. We use Bloomreach to fulfil this however you may unsubscribe or set Your preferences for topics at any time. 

We use Your data to confirm you are the owner of the email address and subsequently to keep you informed of Fairphone in our newsletter about product and company updates. 

Become a business partner or business customer of Fairphone. 

We collect the below information to link Your business to a sales representative; 

• First name;
• Last name;
• Name of organisation/ Company;
• Country;
• Email;
• Phone number.

We collect Your Data using a form on our website and from direct conversations between You and our sales representative. The form is protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. This data is retained in Odoo, emails are sent either through the platforms Odoo or Bloomreach. 

We use this data to link Your business to a sales representative. Our sales representative will use Your Data to keep a coherent record on our business together. Ultimately Your Data will be used to  complete business transactions.We may share Your details with a sales representative from one of our distributors or other sales partners, if you provide Your consent to do so. 

Requests about an event with or for Fairphone

We collect the following information: 

• Your email address.

By using the form on our website. The form is protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. 

Kindly note that during events we organise we may collect pictures, videos and other media materials for our social media or promotional purposes. During the events of other organisations, we will use a release form to ask for Your consent to use the materials in which You are clearly identifiable. This only applies to materials Fairphone makes and does not apply to the materials made by the organiser of the event and/or other attendees.

We use Your data to contact you in case we have questions or remarks regarding the event.

Retargeting and other paid media elements. 

Retargeting, also called remarketing, is a method of reaching out to previous visitors to our website or app, often by displaying ads or sending emails.

We collect the following information: 

• Full name;
• Address;
• Email address.

With enhanced conversions for web, first-party customer data such as an email address, name, home address or phone number is captured in Your conversion tracking tags, hashed (hashed in advertising means that you’ll be getting relevant ads while Your data will be protected and anonymized), sent to Google in its hashed form and then used to match Your customers to Google accounts, which were signed-in to when they engaged with one of Your ads. Google will only use the data you shared to provide you services. Google uses encryption and employee access controls to protect Your data from unauthorised access. Google won’t share Your data with other advertisers. 

Google users can control how their data is used by adjusting  their ‘Web and App Activity’ settings in My Activity. Learn more about how to see and control Your search activity.

About the data sharing process

Here are more details about the matching process and how we process the data shared to Google. When using the Google tag:

• Google will always hash any personally identifiable data (for example, email, phone number, first name, surname, street address) prior to the data being sent to Google. 
• We only allow tags to share conversion events if sent using an HTTPS protocol, the industry standard for secure data transmission.
• Email, phone number and address matching: For matching based on our customers’ data, Google maintains the email addresses for Google accounts and the corresponding hashed strings. After we've uploaded Your data with hashed email addresses, Google Ads will compare each hashed string in Your data with the hashed string of Google accounts. If there's a match, Google will mark those transaction records as matched.

For Retargeting purposes, We can only upload data from You if you have consented to Your information being used for marketing purposes. If You  withdraw Your consent from any lists (newsletter, customer database, etc), You will be automatically removed from Custom Audiences in any advertising platform.

Google tags, and other advertising providers like Meta or Microsoft Bing allow for custom audiences from our website, which will target all website visitors, or engagers with our content across different advertising platforms. 

Email Communication

We may send you email communications, including newsletters, product updates, service notifications, and promotional offers. We process your email address and communication preferences for this purpose.

We only send official communications from the following email addresses:

• [email protected]
• [email protected]
• [email protected]

If you receive an email claiming to be from Fairphone but sent from an address not listed above, please do not click any links or provide any personal information, and report it to [email protected].

You can manage your email preferences or unsubscribe from marketing communications at any time via the unsubscribe link included in each email, or through your Fairphone account settings. Please note that even if you opt out of marketing communications, we may still send you transactional or service-related emails necessary for the performance of our contract with you (e.g., order confirmations, repair status updates, or security notices).

2.5 To ensure safety, security and legal conditions.

Handling requests related to Your data. 

We collect the following information:

• Email address. 
• The deletion request which You have sent remains in our system in the form of an email thread.  

We collect this information to assist You with the requests related to Your data.

2.6 To conduct research and development (incl. surveys)

Submit a research request. 

We collect the following information:

• Your name
• Your email address
• The name of Your organization

Your Data is sent to us by submitting the research form. The form is protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in Your browser. We use Your Personal Data to contact you in case we are able to support you in Your research.

We use Your Data to better understand our customers, what motivates them to buy the Fairphone and how we can improve our company and product. If you consent, we also use this data to contact you again in the future with more questions, surveys or interviews.

Receive invitations to provide us with feedback

We collect the following information to send you invitations to give feedback (using short surveys) at various moments throughout Your Fairphone journey:

• Your name
• Your email address
• IMEI number of Your smartphone
• Activation date of Your smartphone

Your feedback helps us to understand our customers better and identify issues or opportunities with the aim to continuously improve our products and services as well as proactively provide support when needed. If You consent, we use Bloomreach to send you these invitations either as email or push-notifications, you can unsubscribe or set Your preferences for these notifications at any time directly via the footer of the email or the settings on Your smartphone.

We also use and share Your Data with a third-party platform called Hello Customer, this helps us to centralise all of our customer feedback, analyse responses and obtain more insights from our customer feedback. 

Subscribe to our research & development newsletter pool 

We collect the following information to confirm You are the owner of the email;:

• Your name
• Your email address

As part of our newsletter, you have the option to subscribe to an additional list through the communication preference centre. We occasionally send surveys or requests for product testing, focus groups or in-depth user interviews. We use Bloomreach to fulfil this, however, you may unsubscribe or modify Your preferences for topics at any time.

3. Data retention

We will not store Your Data for a longer period than permitted by law and only as necessary for the purpose for which we have collected or processed Your Data. Therefore, how long we retain Your Data depends on the type of data and the purpose for which we collected or processed Your Data. Please keep in mind that in certain cases a longer retention period may be required or permitted by Law.

The criteria we take into account when determining our retention periods include:

• How long Your Data is needed to provide You with our product or to operate our business;
• Do You have an account with us? If yes, then we will keep Your Data while Your account is active or for as long as needed to provide our services;
• Are we subject to a legal, contractual, or similar obligation to retain Your Data.

For details on the retention periods for various types of data, please see the different categories below:

4. Sharing Your Data

We will never sell Your Data or information about You to any third parties. Furthermore, we never purchase Data from third-parties to enrich Our database. 

We do not share Your Data except in the limited cases described in this section and only for the following purposes.

• Service providers: We have outsourced certain business functions and their associated data processing activities to third party service providers. These service providers are authorised to use Your Data only as necessary to fulfil these services to us, which include, but are not limited to IT services, advertising services, billing services and shipping services. None of these providers will contact You by electronic means to provide You with any newsletter, marketing e-mail or information, unless You have provided Your consent to them;
• Business Partners: we may share Your Data with business partners, so that they can provide You with the services You requested. None of these partners will contact You by electronic means to provide You with any newsletter, marketing e-mail or information, unless You have provided Your consent to them;
• Professional advisors and others: we may share Your Data with banks, insurance companies, lawyers, auditors, and other professional advisors. These parties only receive Your Data when this is needed to fulfil a contractual obligation.
• Public and governmental authorities: when required by Law, or as necessary to protect our and/or Your rights, we may share Your Data with entities that regulate or have jurisdiction over Fairphone;  
• Affiliates: should Fairphone establish affiliates, we may share Your Data with those affiliates on a need-to-know basis;
• Social Media Plug-ins: our website does not use social media plug-ins. The social media symbols on our website are regular links and do not transmit data to social media platforms.

5. Security

We process Your Data in accordance with the General Data Protection Regulation. To protect Your Data, we will take appropriate measures, including requiring our service providers to use appropriate measures to protect the confidentiality and security of Your Data. Your Data is stored on our secure servers or the servers of our trusted partners.

We want you to feel confident in using our website and we are committed to protecting Your Data that we collect or process. We have implemented appropriate technical and security procedures to help protect Your Data against any unlawful destruction, accidental loss, alteration or unauthorised disclosure or access. However, please be aware that the transmission of information and data over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.

6. Location of Your Data

We attempt to collect, store and, if applicable, process Your Data within the European Union, European Economic Area (“EEA”) and Switzerland.

We may transfer Your Data to countries located outside the European Union, European Economic Area (“EEA”) and Switzerland. Some of these countries are recognized by the European Commission as providing an adequate level of protection. With regards to transfers to countries which are not recognized by the European Commission as providing an adequate level of protection, we will ensure adequate data protection and privacy requirements through the standard contractual clauses approved by the European Commission. You can request a copy of these clauses through [email protected].

7. Data of children

We do not intentionally collect information from children under the age of 16.

• If You are under the age of 16, we advise You to speak with Your parent or guardian and get their consent before sharing Your Data with us;
• If You are the parent or guardian of a child under the age of 16, we recommend You make sure that Your child does not share Personal Data through the use of our products, services, website and other digital channels without asking Your permission.

8. Updates to this Privacy Policy

The most current version of the Privacy Policy governs Our processing of Your Data. We reserve the right to amend our Privacy Policy from time to time. If We do revise this Privacy Policy and make changes that are determined by Us to be material, We will notify You.

9. Contact details

If You have any questions about Our Privacy Policy, please feel free to contact [email protected]. The supervisor of privacy legislation is the Authoriteit Persoonsgegevens (AP) or Dutch Data Protection Authority (DPA).  You can find the contact details of the Personal Data Authority here. For data protection inquiries, please contact our Data Protection Officer: FIRST PRIVACY B.V., Naritaweg 127-137, 1043 BS Amsterdam, The Netherlands.

US Supplement to Fairphone Privacy Policy

Effective Date: 01, 08, 2025

This US Supplement to the Fairphone Privacy Policy describes personal data processing activities concerning residents of United States that have adopted comprehensive privacy legislation, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia (“selected United States ”), and should be read in conjunction with the Fairphone Privacy Policy. Our data processing activities within the selected United States are strictly limited to those enumerated herein. For comprehensive information regarding our global privacy practices, please refer to the complete Fairphone Privacy Policy above.

1. Collection and Use of Personal Information

We may collect (and may have used during the 12-month period prior to the effective date of this Statement) the following categories of personal information about You:

2. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about You from various sources, including:

• You or Your devices;
• business partners;
• internet service providers;
• online advertising networks and services.

3. Sale or Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we have not disclosed Your personal information in a manner that considers as sale or share within the meaning of applicable state laws as we do not place relevant cookies or similar technologies without Your affirmative consent.  

We also do not authorize third parties to collect personal information about Your online activities over time and across different websites when You use our services.

With Your consent, we and third parties that provide advertising or other functionality on our behalf may use cookies and similar technologies to help us advertise our services to You as informed by Your interests. Where You choose to opt in and direct us to disclose this information, You have the right to opt out at any time, as described below.

4. Disclosure of Personal Information for a Business Purpose

During the 12-month period prior to the effective date of this Statement, we may have disclosed the following categories of personal information about You for a business purpose to the following categories of third parties:

• Device Information: Affiliates, ad networks and business partners
• Internet or Other Electronic Network Activity Information: Affiliates, media agency

5. Consumer Privacy Rights

You have certain choices regarding our use and disclosure of Your personal information, to the extent applicable to each Service, as described below. In accordance with applicable state law, if we deny our privacy rights you may appeal our decision by contacting us via [email protected].

• Access: You may have the right to request that we disclose to You the personal information we have collected about You.
• Correction: You may have the right to request that we correct the personal information we maintain about You, if that information is inaccurate.
• Deletion: You may have the right to request that we delete certain personal information we have collected from You.
• Portability: You may have the right to obtain a copy of Your personal information in a format that can be transmitted to another entity.
• Opt-Out:  While we do not engage in selling or sharing Your personal data, You may still exercise opt-out rights for other data collection activities through:
• Adjusting Your cookie preference settings on our website
• Enabling Global Privacy Control (GPC) signals in Your browser
• Non-Discrimination: You have the right to not be discriminated against by us for exercising Your rights under this Statement or any applicable law. We will not discriminate against You or deny, charge different prices for, or provide a different quality of our goods and/or services if You choose to exercise these rights, although some of the functionality and features available may change or no longer be available to You.

California rights:

• Access: In addition to the right of access described above, California residents may have the right to request a copy of Your personal data and information regarding: (i) the categories of personal information; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purposes for collecting, selling, or sharing (for cross-context behavioral advertising purposes) personal information; (iv) the categories of third parties to whom we disclose personal information; (v) the specific pieces of personal information we collected about You.
• Shine the light request: California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal data to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal data with third parties for their own direct marketing purposes.
• Do not track: Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. At this time our websites are not designed to respond to these signals or similar mechanisms from browsers.

6. Request Submit

We will provide You with access to Your Data, so You may control and update, modify and, where legally possible, delete it. You can contact us at Fairphone Privacy Center, if You want to:  

• Review, change or delete Your Data;
• Object to certain processing of Your Data;
• Receive a copy of Your Data in a machine-readable format;
• Ask us any other questions regarding Your Data and its protection.

Please note that when You make a request to exercise Your rights, we may require that You provide information and follow procedures so that we can verify Your identity. Where possible, we will attempt to match the information that You provide in Your request to information we already have on file to verify Your identity. If we are able to verify Your request, we will process it.

We will assess any request to exercise these rights on a case-by-case basis. We will respond to Your request within the periods required by applicable data protection law. However, we may not always be able to comply fully with Your request. We will notify You in that event.