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, VWO, Bloomreach, Facebook, Tiktok, 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 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 other potential Fairphone users.

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.

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.

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.

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.

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.

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.

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:

• IMEI and Serial numbers of devices: This allows us to recognise the device and batch;
• 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;
• Software version and model: In combination with the other data points, it allows us to evaluate which devices are running the latest software, which devices require updating and if a security or other software issue issue is specific to a software version.

During the set-up of Your Fairphone, you can opt-in to providing us with additional information to improve our ability to diagnose quality issues. This information includes:

• IMEI: IMEI numbers are added to devices at production and are used by our operations team to send devices to our customers and provide customers with services, such as warranty service and extended warranty service.
• Operator name: this would allow us, for example, to recognise if an issue occurs with a certain operator; and
• Cell tower and network data: this would allow us, for example, to recognise if an issue is specific to a certain country.

In the device setting, You can control the privacy settings of Your device: Settings > Privacy > Advanced > Longevity & device statistics. You will be able to opt-out of this data collection at any time. In this section, You can also provide us with consent to collect data for marketing purposes. This data is not used to target You specifically but will instead be used to understand our customer base more generally.

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 (e.g. FP3/FP3+/FP4)
• 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.

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.

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 as a trusted third party. 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.

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.

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.

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.

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.

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.

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.

We collect the following information from Your Fairphone 3 or Fairphone 4 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.

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

• First name;
• Last name;
• Gender;
• 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.

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.

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

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.

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.

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.

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.

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, 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 Retargerting 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.

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.

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.

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.

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.