Last updated October 3, 2017

1 Foreword

This Jolla Privacy Policy provides information on what personal data we collect from you and how we process that data. This Privacy Policy applies to all our products, software and services covered by the terms available at http://www.jolla.com/legal (“Terms of Service”), as well as our website located at http://www.jolla.com (our products and services and our website are collectively referred to as “Jolla Services” below).

Please review this Privacy Policy carefully as we want to make sure you fully understand how your personal data is used. We understand that sometimes understanding the implications of legal documents can be difficult. Therefore, if you have any questions, comments or concerns about this Privacy Policy, please contact us by submitting a query here.

2 Jolla’s privacy principles

Protecting the privacy of our users is one of the key building blocks of our business. We believe it is important because it is what our users want and thus it is something we will work hard for to provide. Our approach towards your privacy can be summarized in the following principles:

  • You have the right to the utmost protection of your privacy. It should be for you to decide what personal data you want to share and when.
  • We do not share your personal data with third parties without your express authorization. We are not building a business on monetizing your personal data. We can succeed as a business when our users are happy and know that they can trust us not to share their data with others if they have not authorized it expressly.
  • We work hard to protect your data. We will dedicate time and resources to ensuring that your data is protected against intrusion from third parties. This means we seek to protect you from not only criminal intrusion, but also unauthorized access from governmental sources.

We have aimed to incorporate these principles in the sections below, which set out the legally required rules of how we process your personal data. These principles are our goals, and sometimes we can fail to meet those goals. We are a small and young company, and we still have a lot to learn. However, we do promise that if we ever fail to live up to our principles, we will work twice as hard to get there in the end.

3 The type of information we collect

We collect and process both personal data and usage data when you use Jolla Services. Not all data is collected at every instance, and where applicable, you will be clearly notified of what kind of data you are providing in any given situation.

Collection of personal data. We collect the following types of personal data from you when you use Jolla Services.

Your personal details: We require you to provide us with your name and your birthday.

Contact details: We require you to provide us with your phone number, your physical address and your e-mail address.

Device details:
If you have a Jolla or a Jolla partner device, we can also collect information about your device. The information we collect includes the IMEI number of the device, the IP address when it is connected to the internet, and various types of diagnostics data. The diagnostics data is, however, collected anonymously and not tied to your specific account.

Information from third party sources. If you connect your device to a third party service such as Facebook, Google or Twitter, we can collect information, including, but not limited to, contacts, calendar entries, photos, check-ins, and similar entries you have stored in the third party service in question. We will never collect such information without your permission. You will always be told what information we would like to collect when you link your account. If you do not grant us explicit permission, we do not collect that data.

Location data: If your device uses our location services, we can collect information about your location, including GPS coordinates, WiFi SSID’s and WiFi signal strength. As some of our location services are provided by third parties, those third parties can also collect such information. In such cases you will be asked to expressly accept the third party’s privacy policy or other comparable set of terms governing their processing of your data.

Collection of usage data. When using Jolla Services, we can also collect information about how you use Jolla Services, including, in case of our website, what webpages you access and any user specific settings (such as your preferred language) you set. This non-personal data is not stored in our personal data register, but is instead stored anonymously (subject to the exception set out below). In some cases, such as webpage analytics, we analyze the data in an aggregate format for the purpose of improving and developing Jolla Services.

The usage data generally does not contain any personal data. However, in some limited cases usage data can be stored together with your personal data in such a way that the usage data could be considered to be personal data as well. In such cases we process it in accordance with the personal data provisions of this Privacy Policy.

4 The purposes for which we use the information

We collect personal data for various purposes.

Development of Jolla Services. We use all the personal data we collect to better understand who our users are and how you use Jolla Services. This information enables us to develop and improve our Jolla Services to better meet your needs.

Customer Support: We can use your contact details, device details and usage data to provide you with support services, as well as facilitating warranty repairs. For example the IMEI number can be used to ascertain your right to warranty repairs, thereby enabling easier warranty processing.

Contacting you. We can use the contact details you provide to let you know about new developments related to Jolla Services, contacting you in specific cases such as, but not limited to, troubleshooting your account or informing you of the shipment of a product you ordered from us.

Enhancing your Jolla Services experience. We can also use the personal data we have collected from you in order to enhance your Jolla Service experience. For example, the location data can be used to provide you with services that take into account your location. Information from third party sources such as Facebook can be used to synchronize your Facebook data with your device, enabling you to easily take advantage of that data on your device as well.

Marketing. We can send you information about our products and services unless you tell us that you do not want to receive such messages. Your personal data will never be shared with third parties unless you expressly authorize it.

5 Storing of your personal data

We store and process your personal data (if any) on third party servers (”Hosting Providers”) located in in the European Economic Area. By using Jolla Services, you give us consent to store, process and transfer your personal information (if any) outside of your country of residence to the countries where our Hosting Providers are located. If you object to your personal information (if any) being transferred or used in this way please do not use Jolla Services.

6 Your right to inspect the information

We cannot verify the accuracy of the personal data you provide. If you have reason to believe that some of the data we stored about you might be inaccurate, you can request to inspect that data. You can exercise your inspection right by sending a written request to our address stated below, together with sufficient proof that enables us to verify your identity:

Jolla Ltd. / Legal
Kalevantie 2
33100 Helsinki
Finland

7 Disclosure of the information to third parties

Apart from Hosting Providers, we do not disclose your personal data to third parties unless

  • you have provided us with your express opt-in consent for doing so;
  • the disclosure is reasonably necessary for us to be able to enforce our Terms of Service;
  • the disclosure is reasonably necessary for the purposes of detecting and preventing fraud, security breaches, or criminal behaviour; or
  • applicable law requires us to disclose it .
  • We may share non-personal data (provided that it is anonymous) to select third parties.

Note that we might include third party services (“Third Party Services”) on our devices or in our software. Such Third Party Services may collect personal data from you in accordance with their own privacy policies. You will be presented with these privacy policies before you start using Third Party Services so that you can make an informed decision about whether you can accept their processing of your personal data.

8 Removing of information from the register

You can request the removal of any of your personal data by sending a written request to our address stated in section 6 above, together with sufficient proof that enables us to verify your identity.

9 Cookies

We do not use cookies for the purpose of collecting personal data. The only cookies we might set are technical in nature, used for purposes such as tracking session ids and user state.

When using Jolla Services, you may be exposed to cookies provided by third parties. These third party cookies are mainly used for analytics purposes, but can also be set by other third party plug-ins and services providing for example sign-in features. Although we seek to ensure that our users’ privacy is protected at all times, we cannot be responsible for how these third party cookies are used. You should consult the privacy policies of these third parties for more information about how they treat your personal data.

10 Data Security

We and our Hosting Providers use industry standard security mechanisms to protect the collected personal data. We ensure that any Hosting Provider we use commits to using both software based security measures (including, but not limited to firewalls and SSL communications where appropriate), as well as physical security measures such as controlled access to server facilities.

11 General information

The name of the data controller is Jolla Ltd., business id 2399817-6, with a registered office at Kalevantie 2, 33100, Tampere, Finland.

The name of the personal data register is the Jolla Account User Register.

If you are under the age of 13, please ask your legal guardian’s permissions before using our products and services. We do not knowingly collect personal data from anyone under the age of 13. If you are under 13, please do not use any of the features of our products and services that require you to provide personal data to us.

Note also that as we want to ensure that this Privacy Policy properly reflects the way we handle your data, we need to reserve the right to make changes to it in our sole discretion whenever it is necessary. Although we will use reasonable efforts to notify you of all substantial changes to this Privacy Policy, you should also do your best to review this document on a regular basis.