This Privacy Policy covers how we collect and use Your Data. We are the controller  (meaning we determine the purposes and means by which personal data is processed) of Your Data under this Privacy Policy and we will collect and process Your Data strictly in accordance with this Privacy Policy.

Depending on who you are and how you interact with us, we may process different categories of Personal Data about you. You can select an activity in clause 9 to understand how we process data related to certain activities. 

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.

We will never sell Your Data or information about you to any third parties.

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 authorized to use Your Data only as necessary to fulfill 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 fulfill 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 normally regular links and do not transmit data to social media platforms.

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 privacy@fairphone.com.

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;

Should we be 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.

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 unauthorized 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.

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. We will not ask you for your password, except when you log into our website.

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.

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 privacy@fairphone.com 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.

You can find the information we collect by clicking on the relevant link below:

• Visit our website
• Create a user account on our website
• Buy a Fairphone or another product from our website
• Become a business partner or business customer of Fairphone
• Participate in the Reuse and Recycle Program
• Submit a research request
• Organize an event with or for Fairphone
• Subscribe to our newsletter
• Subscribe to get product updates and availability updates.
• Subscribe to our business newsletter
• Join and post on the Fairphone forum and comment under blogs
• Submit a complaint, feedback, inquiry and or repair requests
• Take part in a survey
• Apply for a job at Fairphone
• Invitation to write a review on Trustpilot
• Participate in the Referral Program

For information collected by Fairphone through the Fairphone 4 Extended Warranty registration, click here. For information collected by Fairphone through Fairphone Easy, click here.

9.1.1 What Personal Data do we collect?

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. We erase the last three numbers of your IP address to make this more anonymous;
• Other information about your use of our digital channels: the links clicked within our newsletter or on our website;
• Preferences you set on our website about language and location;
• Login information and the contents of your shopping cart.
• Any purchases made.

9.1.2 How do we collect Your Data?

We use Google Analytics, Google Tag Manager, Hotjar, VWO to analyze website visits and perform A/B testing. 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 in order to advertise our products only if You have agreed to this collection and use of Your Data. These advertisements are customised to Your interests and needs and help us to better define the needs of others.

9.1.3 What do we use Your Data for?

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 customer segments and show personalised ads for specific user groups e.g. via social media. 

9.1.4 When do we delete Your Data and how can you request Your Data to be deleted?

• Any data about the use of our website is only saved in an anonymised and aggregated form and does not contain Your Data anymore.
• We do not allow third parties  to further process Your Data for any other means.
• As soon as you withdraw your previously given consent to being tracked for advertisement purposes, we delete Your Data. 

You can control the use of cookies on our website, at the individual browser level by installing a cookie-blocker or by removing the cookies from your browser preferences. Please bear in mind that if you disable cookies, parts of our website that contain data from other websites (e.g. Google maps, youtube videos etc)  will be limited.

9.2.1 What Personal Data do we collect?

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. 

9.2.2 How do we collect Your Data?

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.

9.2.3 What do we use Your Data for?

We use this data to create an account for you and to inform you about its creation by email. 

9.2.4 When do we delete Your Data and how can you request Your data to be deleted?

You can request to have your data removed by sending an email to privacy@fairphone.com. You receive a confirmation email that you have to confirm before we proceed with the deletion process. 

9.3.1 What Personal Data do we collect?

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. 

9.3.2 How do we collect Your Data?

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. 

9.3.3 What do we use Your Data for?

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. 
• To calculate our referral rates and operationalise our Referral Program through Referralcandy.

9.3.4 When do we delete Your Data and how can you request Your Data to be deleted?

You can request to have Your Data removed by sending an email to privacy@fairphone.com. You might  be requested to send us a proof of identity before we proceed with the deletion process. If you request more data to be deleted in the same request, we might ask you to provide us with additional proof of identity to ensure we are deleting the right data. Please bear in mind that some data, like the one associated with a past purchase, cannot be deleted because of our legal obligation to provide a two-year warranty or our obligation to maintain financial Data for 7 years. 

9.4.1 What Personal Data do we collect?

• Last name
• First name
• Name of organization/ Company
• Country 
• Email
• Phone number

9.4.2 How do we collect Your Data?

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.

9.4.3 What do we use Your Data for?

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. 

9.4.4 When do we delete Your Data and  how can you request Your Data to be deleted?

You can always request your contact person at Fairphone to delete Your Data, or submit a request for deletion to privacy@fairphone.com

9.5.1 What Data do we collect?

• Your phones IMEI nr.;
• The storage capacity of your phone;
• The Model, Brand and diagnosis of your phone
• Your name;
• Your address;
• Your email address;
• Your declared conditions of your phone
• Phone number
• Your ID information
• Your Bank account information (for the cash back option)
• The declared and validate refund value of your phone

9.5.2 How do we collect Your Data?

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.

9.5.3 What do we use Your Data for?

We use Your Data 

• to calculate the worth of your second hand 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 , if you consent to this.

9.5.4 When we delete Your data and how can you request Your Data to be deleted?

In order to comply with legislation surrounding the purchase of second-hand electronic products, this data will be stored for 5 years. 

9.6.1 What Personal Data do we collect?

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

9.6.2 How do we collect Your Data?

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.

9.6.3 What do we use Your Data for?

We use your Personal Data to contact you in case we are able to support you in your research.

9.6.4 When do we delete Your Data and how can you request Your Data to be deleted?

Your Data will be deleted after three months in case we are not able to follow-up or one year after completion of your research. You can request Your Data to be deleted by sending an email to privacy@fairphone.com. You will receive a confirmation email that you have to confirm before we proceed with the deletion process. 

9.7.1 What Personal Data do we collect?

Your email address.

9.7.2 How do we collect Your Data?

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.

9.7.3 What do we use Your Data for?

To contact you in case we have questions or remarks regarding your event.

9.7.4 When we delete Your Data and how you can request Your Data to be deleted?

Your Data will be deleted from our server three months after the event has passed or upon your request. You can submit a deletion request to privacy@fairphone.com. 

9.8.1 What Personal Data do we collect?

Your email address

9.8.2 How we collect Your Data:

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. 

9.8.3 What do we use Your Data for?

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. 

9.8.4 When we delete Your Data and how can you can request Your Data to be deleted?

We do not automatically delete Your Data. You can request to be removed from the mailing list by clicking the unsubscribe link at the bottom of any email you receive from us.

9.9.1 What Personal Data do we collect?

Your email address

9.9.2 How do we collect Your Data?

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.

9.9.3 What we use Your Data for:

To notify you when a product has become available again. We always send out an update.

9.9.4 When we delete Your Data and how you can request Your Data to be deleted?

You can request to have Your Data removed by sending an email to privacy@fairphone.com. 

9.10.1 What Personal Data do we collect?

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

9.10.2 How do we collect Your Data?

By using a form on our website. Our forms are protected by an SSL encrypted connection. You can verify a secure connection by clicking on the green padlock in your browser. 

9.10. 3 What do we use Your Data for?

To confirm you are the owner of the email address and subsequently to keep you informed of Fairphone in our business newsletter about product and company updates. 

9.10.4 When do we delete Your Data and how can you request Your Data to be deleted?

We do not automatically delete Your Data. You can request to be removed from the mailing list by clicking the unsubscribe link at the bottom of any email you receive from us.

9.11.1 What Personal Data do we collect?

• 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.  

9.11.2 How do we collect Your Data?

Your Data on the Fairphone forum is collected through the sign-up form and through registration of your actions on the forum.

9.11.3 What do we use Your Data for?

• 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. 

9.11.4 When do we delete Your Data and how can you request Your Data to be deleted?

We can only delete your account if you have not made any posts. First delete your posts if you want Your Data removed. Posts older than 60 days cannot be deleted in order to protect the coherence and reliability of our forum. 

If you have posts that are older than 60 days, Your data can be anonymized upon request. You are able to download an archive of Your Data from your profile page before it is anonymized. Please reach out to privacy@fairphone.com for any requests.

9.12.1 What Personal Data do we collect?

• 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;
• Phone unique identifier or IMEI;
• Battery serial number and other serial numbers where applicable; 
• Any other Personal Data you provide us. 

 

If your repair request is approved we will also ask for your pickup and return address.

9.12.2 How do we collect Your Data?

• We collect Your Data using the form on our website.  
• If your repair request is approved we will also ask for your pickup and return address by email.

9.12.3 What do we use Your Data for?

• to contact you. 
• to facilitate the pickup of drop off of your broken phone.
• to assess your problems and to provide you with the requested support. 
• to analyze and improve our customer support and for training of new agents. 

9.12.4 When do we delete Your Data and how can you request Your Data to be deleted?

You can submit a request for deletion to privacy@fairphone.com. 

9.13.1 What Personal Data do we collect?

• Your age range;
• Your country;
• E-mail address;

9.13.2 How do we collect Your Data?

After the purchase of a Fairphone , we send you an email with a link you can click to fill in our survey. 

At the end of the survey you can opt-in to allow Fairphone to contact you for other surveys and consumer panels.

9.13.3 What  do we use Your Data for?

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.

9.13.4 When do we delete Your data and how can you request Your Data to be deleted?

We analyze and aggregate individual responses every month into anonymized datasets. After aggregation has been completed, individual responses and all Your Data are deleted.

If you consented to be contacted again in the future, we store your mailadres in our mailing list database. At the bottom of every email you receive from us, you can find an opt-out link which will remove Your  e-mailadres from the mailing list. 

9.14.1 What Personal Data do we collect?

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

9.14.2 How do we collect Your Data?

The Personal Data that is provided by applicants is stored in our Application Tracking System Homerun, which is also our recruitment database.

9.14.3 What do we use Your Data for?

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 about job/internship opportunities.

 

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.

9.14.4 When do we delete Your Data and how can you request Your Data to be deleted?

If an applicant has consented, we keep their Data for a period of 12 months. The Fairphone People team is responsible for the  deletion of applicant Data from Homerun after 12 months have passed.

If no consent has been given, Personal Data is deleted 3 months after a decision on the position has been reached. 

9.15.1 What Personal Data do we collect?

Pictures, video and other media materials of individuals.

9.15.2 How do we collect Your Data?

Fairphone regularly takes photographs and makes videos (hereafter: materials) during the events we organize and attend. 

9.15.3 What do we use Your Data for?

These materials are used:  

• To report on the event through our blog and social media accounts; and
• To promote future events.

9.15.4 When do we delete Your Data and how can you request Your Data to be deleted?

During events at our office, you will always be able to tell us that you do not want us to use materials in which you are clearly identifiable.

During the events of other organizations, 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 organizer of the event and/or other attendees.

If you are identifiable in our videos and pictures and you want us to remove such materials, you can send a request to privacy@fairphone.com. 

We may contact you via email to invite you to review any products and service you received. The purpose of this is to collect your feedback and make improvements to our product offering. We use an external company, Trustpilot A/S, to collect your feedback which means that we will share your name, email address and reference number with Trustpilot. If you want to read more about how Trustpilot processes your data, you can find their Privacy Policy here.

9.16.1 How are reviews verified? 

We automate and invite via email all customers that purchase directly from the online shop, this means the vast majority of reviews are automatically labelled „Verified“ and shown on our Trustpilot profile page as well as various pages on our website.

Customers who may not have seen or received our email invitation still have the opportunity to go to our Trustpilot profile page and write a review. For these customers, we take additional steps to ensure these types of reviews are real before verifying and displaying them publicly. Any suspicious reviews or reviews which do not represent a genuine buying or service experience are flagged and subject to removal.

 

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.

 

9.16.2 How do we showcase reviews? 

We want to continue building trust with our new and existing customers by transparently showcasing what others think about our products and services. Therefore, we process and publish positive and negative reviews. These can be seen on our Trustpilot profile page as well as various pages on our website.

 

We may also use such reviews in other promotional material and media for our advertising and promotional purposes

 

9.17.1 What Personal Data do we collect?

• Your name (and if given, surname).
• Your email address. 
• Your social media shares.
• Your order number.
• Your coupon shares. 

9.17.2 How do we collect Your Data?

We collect your Data using a 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.

9.17.3 What do we use Your Data for?

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. 

9.17.4 When do we delete Your Data and how can you request Your Data to be deleted?

You can request to be removed from the referral program by sending a request to privacy@fairphone.com.  

We reserve the right to change our Privacy Policy, from time to time. We encourage you to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

History

This privacy policy was updated on the 16 September 2022. The Privacy Policy may be updated in the future. An older version will always be available on our website with indication of changes where possible.