The Alphalabs Privacy Policy Alphalabs

Effective date 12.10.2011

Nokia is committed to protecting your privacy and to complying with applicable data protection and privacy laws. This Privacy Policy (“Policy”) explains how we process personal data. Throughout this Policy the term “personal data” means information relating to an identified or identifiable individual (i.e. a natural person). “Nokia” refers to Nokia Corporation, including its affiliates (also referred to as “we”, “us”, or “our”). This Policy applies for processing of your personal data where Nokia is the data controller or where we refer to the applicability of this Policy.

We may provide additional privacy information in connection with our products and services through service descriptions and other notices. Such information prevails over this Policy to the extent of any conflict.

Third party services installed on your device may allow access to information available on your device. Our products or services may contain links to other companies’ websites and services that have privacy policies of their own. We recommend that you read the privacy policies of such third party services. Nokia is not responsible for the privacy practices or contents of any such third party services.

By using this website and/or by submitting personal data to Nokia, you agree to the processing of your personal data as explained in this Policy. If you do not agree with this Policy, please do not use this website or provide Nokia with your personal data.

What Data Do We Collect?

We collect your personal data typically when you make a purchase, use or register into our products and services, take part in a campaign or otherwise interact with us. Below are examples of the categories of data we collect.

Your use of our products and services

When you use our products and services your IP-address, access times, the website you linked from, pages you visit, the links you use, the content you viewed and other such information your browser provides us with is automatically collected by Nokia. Some of our mobile services may collect your unique mobile device identifiers, subscriber identity information, network service provider specific identifiers, network settings and other such information. When you use our products and services or otherwise interact with us over telecommunications networks, certain additional information, such as your mobile subscription number, may be transmitted to us by your mobile network provider

Information you provide us with

We may ask you to provide us with information such as your name, email address, street address, user names and passwords, your consents, preferences and feedback, information relating to your devices, age, gender, postal code and language preferences. Please note that certain non-identifiable information collected from you may become personally identifiable when you provide us with your personal data. We may also obtain, in accordance with applicable law, some personal data from list-rental companies and other such publicly available sources. Some of our services may allow you to submit information about other people, for example, if you make an order for a product that you wish us to send directly to another recipient

Your transactions with us

We collect information relating to your purchase and use of our products and services and your other interactions with us. Such information may include details of the queries or requests you have made, the products and services provided, delivery details, bank account number, credit card details, billing address, credit checks and other such financial information, details of agreements between you and Nokia, records of contacts and communications, information and details relating to the content you have provided us with and other such transactional information. We may, in accordance with applicable law, record your communication with our customer care or with other such contact points

Location data

Nokia’s location based services and features may use satellite, Wi-Fi or other network based location data, for example your IP-address. Assisted positioning methods of the device, for example Assisted GPS, provide you with faster and more accurate location data. Use of assisted positioning methods may involve exchanging your location data, wireless network identifiers along with your unique device or network service provider identifiers with a location server. Nokia processes this information anonymously. Depending on your positioning settings and your use of location services of other service providers your device may connect to other service providers’ servers, which are not controlled or operated by Nokia. We recommend you to check the privacy policies of such service providers to understand how they process your location data. You can modify the positioning settings of your device from the device settings, for example change or disable positioning methods or location servers or modify the accuracy of your location data.

Nokia offers various location based services and features that may require the use of your location data. For example when you make a location based search, use location enhanced weather features or request for map data, your location data may be sent to Nokia to serve you with the right content. This may also include location based advertizing. Some location based services may allow you to associate your personal data with your location. To learn more about available location based services and features, please refer to instructions and other support material for our products and services.

Why Do We Process Personal Data?

Nokia may process your personal data for the following purposes. Please note that one or more purposes may apply simultaneously.

Providing products and services

We may use your personal data to provide you with our products and services, to process your order or as otherwise may be necessary to perform the contract between you and Nokia, to ensure the functionality and security of our products and services, to identify you as well as to prevent and investigate fraud and other misuses.

Developing products and services

We may use your personal data to develop our products and services. However, for the most part we only use aggregate and statistical information for such purposes. We may combine personal data collected in connection with your use of a particular Nokia product and/or service with other personal data we may hold about you, unless such personal data was collected for a different purpose.

Communicating with you

We may use your personal data to communicate with you, for example to send you critical alerts and other such notices relating to our products and/or services and to contact you for consumer care related purposes.

Marketing and making recommendations

We may use your personal data to personalize our offering and to provide you with more relevant services, for example, to make recommendations and to display customized content and advertising in our services. This may include displaying Nokia and third party content. We may use your personal data for direct marketing or research purposes, for example, to conduct market research and we may, in accordance with applicable law, contact you to inform you of new products, services or promotions we may offer.

First use of your Nokia device

Depending on your device a Nokia Account may be created for you or you may need to sign in with your existing Nokia Account when you first use your device. In the activation process your user name, email address, mobile number, unique mobile device identifier and subscriber identity information will be sent to Nokia and we may associate this information with your Nokia Account. This combined information may be used to activate your warranty and certain software licenses and to send you personalized messages, for example emails, text and other messages. These messages may include information about Nokia’s products and services, such as tips and commercial offers. You may unsubscribe from these messages at any time for example by following the information in the message you receive after taking your device into use, instructions in the device or in the messages, through available profile management tools or contacting Nokia customer care. The collected information may also be used to display personalized content as well as to improve Nokia’s products and services. The above information may also apply in case you update the software of your device.

Do We Share Personal Data?

We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.

Your consent and social sharing services

We may share your personal data if we have your consent to do so. Some services may allow you to share your personal data with other users of the service or with other services and their users. Please consider carefully before disclosing any personal data or other information that might be accessible to other users.

Nokia companies and authorized third parties

We may share your personal data with other Nokia companies or authorized third parties who process personal data for Nokia for the purposes described in this Policy. This may include for example billing through your network service provider or otherwise, delivery of your purchases, providing services including customer service, managing and analyzing consumer data, credit checks, conducting market research and managing marketing and other such campaigns. When you purchase a Nokia product from us with a network service provider plan, we may need to exchange information with your network service provider to provide you with such service.We may conduct joint marketing and other communications with our partners, for example your mobile operator. To avoid duplicate or unnecessary communications and to tailor the message to you we may need to match information that Nokia has collected with information that the partner has collected where this is permitted by law.These authorized third parties are not permitted to use your personal data for any other purposes. We require them to act consistently with this Policy and to use appropriate security measures to protect your personal data.

International transfers of personal data

Our products and services may be provided using resources and servers located in various countries around the world. Therefore your personal data may be transferred across international borders outside the country where you use our services, including to countries outside the European Economic Area (EEA) that do not have laws providing specific protection for personal data or that have different legal rules on data protection, for example, the United States of America. In such cases we take steps to ensure that there is a legal basis for such a transfer and that adequate protection for your personal data is provided as required by applicable law, for example, by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.

Mandatory disclosures

We may be obligated by mandatory law to disclose your personal data to certain authorities or other third parties, for example, to law enforcement agencies in the countries where we or third parties acting on our behalf operate. We may also disclose and otherwise process your personal data in accordance with applicable law to defend Nokia’s legitimate interests, for example, in civil or criminal legal proceedings.

Mergers and Acquisitions

If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.

How Do We Address The Privacy of Children?

Nokia products and services are typically intended for general audiences. Nokia does not knowingly collect information of children without the consent of their parents or guardians. Nokia publishes safety guidelines for using internet services in our websites.

How Do We Address Data Quality?

We take reasonable steps to keep the personal data we possess accurate and to delete incorrect or unnecessary personal data.

As certain Nokia products and services may allow you to manage your profile, we encourage you to access your personal data from time to time to ensure that it is correct. Please remember that in case of any changes it is your responsibility to update the personal data you have provided us with.

What Steps Are Taken To Safeguard Personal Data?

Privacy and security are key considerations in the creation and delivery of our products and services. We have assigned specific responsibilities to address privacy and security related matters. We enforce our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security engineering, training and assessments. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. Also, we limit access to our data bases containing personal data to authorized persons having a justified need to access such information.

How Do We Use Cookies and Web Beacons?

Cookies are small text files that are sent to your computer by a web server. We use cookies to provide benefits to you. Session cookies remember the previous activity performed by you, for example an item you placed in a shopping cart. Persistent cookies are used to save your preferences over multiple sessions, for example personalization of settings on our websites. Cookies may be used to display targeted ads and recommendations, for example to eliminate showing the same ads to you multiple times or showing ads that we think are of interest to you based on your past actions on our website. Cookies are also used to determine the effectiveness of our promotions and advertising campaigns and to improve our products and services.

Nokia may use web beacons (or “pixel tags”) in connection with some of our websites. However, we do not use them to identify individual users personally. Web beacons are typically graphic images that are placed on a website and they are used to count visitors to a website and/or to access certain cookies. This information is used to improve our services. Web beacons do not typically collect any other information than what your browser provides us with as a standard part of any internet communication. If you turn off cookies, the web beacon will no longer be able to track your specific activity. The web beacon may, however, continue to collect information about visits from your IP-address.

Some Nokia websites or applications may utilize so called locally stored objects, such as Flash local shared objects (“Flash cookies”) or HTML5 Web Storage. Locally stored objects are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies. For example, in Flash you can use the Flash Player Settings Manager to control the storage of local shared objects, including disabling the local shared objects for certain websites only or disabling the storage of local shared objects completely for all websites.

Some Nokia websites use third party advertizing technologies, such as DoubleClick, to serve ads. DoubleClick uses a cookie to collect information about your visits to Nokia and third party websites. This information will be used to serve ads on Nokia and third party websites. The collected information will not be directly personally identifiable nor will DoubleClick share the information with third parties. You may choose to disable the DoubleClick cookie at any time by usingDoubleClick opt-out cookie. You may also go to http://networkadvertising.org/ to install an opt-out cookie.

Most browsers allow you to disable or allow the use of cookies. You may also delete the cookies on your computer if your browser so permits. If you disable cookies, you may not be able to use certain parts of our services and you may need to re-install the opt-out cookie.

What Are Your Rights?

You have a right to know what personal data we hold about you. You have a right to have incomplete, incorrect, unnecessary or outdated personal data deleted or updated. You have a right to unsubscribe from marketing messages and to request that we stop processing your personal data for direct marketing or market research purposes. However, if you opt-out from marketing and other communications from Nokia, we may still send you critical alerts pertaining to our products and services or contact you for these purposes.

You may exercise your rights by contacting us through the contact points referred to below. To unsubscribe from marketing messages, contact Nokia Care http://www.nokia.com/about-nokia/contacts/customer-service. In some cases, especially if you wish us to delete or stop processing your personal data, this may also mean that we may not be able to continue to provide the services to you. Please note that Nokia may need to identify you and to ask for additional information in order to be able to fulfill your request. Please also note that applicable law may contain restrictions and other provisions that relate to your rights.

We encourage you to use available profile management tools, for example Nokia Account for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it.

Who Is The Controller of Your Personal Data?

Nokia Corporation of Keilalahdentie 4, 02150 Espoo, Finland is the controller of your personal data.

In addition, the Nokia affiliate providing the product or service may be a controller of your personal data. You may find the identity of the controller and its contact details by reviewing the terms and conditions of such a product or service or by using contact information provided in the applicable Nokia websites.

In matters pertaining to Nokia’s privacy practices you may also contact us at:

Nokia Corporation

c/o Privacy

Keilalahdentie 4

02150 Espoo

Finland

US Safe Harbor Privacy Framework

Nokia Inc., 102 Corporate Park Drive, White Plains, NY 10604 USA adheres to the EU-US/Swiss-US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, and is registered with theU.S. Department of Commerce’s Safe Harbor Program. If you have questions or concerns about Nokia’s participation in the Safe Harbor Framework, please contact:

Nokia Inc.,

102 Corporate Park Drive,

White Plains, NY 10604 USA.

Attention: Legal Director, North America.

If you believe Nokia Inc. has not satisfactorily addressed your data privacy concerns, you may contact the EU Data Protection Panel at: Data Protection Panel Secretariat, Rue de Luxembourg 46 (01/126) B-1000 Brussels, BELGIUM, or by visiting http://circa.europa.eu/Public/irc/secureida/safeharbor/home.

Changes to This Privacy Policy

Nokia may from time to time change this Policy or change, modify or withdraw access to this site at any time with or without notice. However, if this Policy is changed in a material, adverse way, Nokia will post a notice advising of such change at the beginning of this Policy and on this site’s home page for 30 days. We recommend that you re-visit this Policy from time to time to learn of any such changes to this Policy.

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