BlackBerry Limited and its subsidiary companies and affiliates (“BlackBerry”) are committed to and have a long-standing policy of maintaining the privacy and security of your personal information. Personal information is information about an identifiable individual (as defined by applicable privacy or data protection laws).
- Purposes for Using Your Personal Information
- Types of Personal Information Processed
- Processing Your Personal Information
- Accuracy of Your Personal Information
- Safeguarding Your Personal Information
- BlackBerry’s Ongoing Efforts to be Transparent
- Accessing Your Personal Information
- Questions or Concerns?
BlackBerry is responsible for personal information under its control, including the onward transfer of personal information to a third party for processing on BlackBerry’s behalf.
2. Purposes for Using Your Personal Information
When you use a BlackBerry Offering, correspond with BlackBerry, enter a contest sponsored by BlackBerry or otherwise interact with BlackBerry, BlackBerry may process your personal information for the following purposes:
- to understand and meet your needs and preferences, and to provide you with BlackBerry Offerings, e.g.:
- for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, repair, refurbishment, replacement, upgrade or update of BlackBerry Offerings;
- to ensure BlackBerry Offerings are technically functioning as intended and to help identify and troubleshoot issues;
- to understand your use of the network or BlackBerry Offerings by interpreting network performance and use metrics;
- to fulfill or enforce Notices applicable to a BlackBerry Offering;
- to manage or respond to your inquiries;
- to develop new and enhance existing BlackBerry Offerings including to communicate with you about them using various means, e.g. to make available or send to you:
- upgrades or updates, or notices of upgrades or updates of BlackBerry Offerings or third party content or related products, services and software;
- notices of promotions and upcoming events;
- to manage and develop our business and operations, e.g.:
- to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect BlackBerry property;
- to allow for business continuity and disaster recovery operations;
- to enforce BlackBerry’s legal rights;
- for statistical purposes;
- to meet legal and regulatory requirements and to respond to emergency situations, e.g.:
- to respond to court orders, warrants or other lawful requests or legal processes;
- to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
- for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable law.
Before using BlackBerry Offerings, you may be required to agree to an applicable Notice that may contain additional information regarding BlackBerry’s processing of your personal information. Your agreement to the Notice or use of BlackBerry Offerings indicates your consent for BlackBerry to process your personal information for BlackBerry’s identified purposes.
If you provide BlackBerry with personal information about another person, you are responsible for ensuring you have that individual’s consent to do so. All personal information provided to BlackBerry is subject to this policy.
a) When Obtaining Consent is Not Required
In certain circumstances, your personal information may be processed without your consent depending on the jurisdiction and any applicable laws. For example, BlackBerry may not seek consent:
- in the case of an emergency where the life, health or security of an individual may be threatened;
- when legal, medical, or security reasons make it impossible or impractical to seek consent;
- when personal information is necessary to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect BlackBerry property;
- when disclosure is to a lawyer representing BlackBerry;
- to collect a debt;
- to comply with a subpoena, warrant or other court order, lawful request or legal process; or
- as may be otherwise required or permitted by law.
BlackBerry does not knowingly process personal information from individuals under the age of 13 without the consent of their parent or legal guardian.
c) Aggregated or Anonymous Information
BlackBerry reserves the right to process, sell, trade or rent aggregated or anonymous information that is not associated with or linked to an identifiable individual.
4. Types of Personal Information Processed
The types of personal information that BlackBerry may process can vary. For example:
a) Account and membership information: Personal information processed could include your name, postal address, email address, telephone number, BlackBerry ID, device identifier information such as your BlackBerry PIN, airtime service provider information, communications with BlackBerry and any recorded complaints. BlackBerry may also process your account credentials, passwords, profile information and other personal information you provide to facilitate the BlackBerry Offerings you use.
b) Applications: In some cases, BlackBerry may process personal information about applications used on your device including Third Party Offerings (i.e. applications, products, services, software, websites or content provided by a third party, including an airtime service provider or application developer, that may be used in conjunction with BlackBerry Offerings, but are not offered, operated or supported by BlackBerry). Also, if you choose to use Third Party Offerings with your BlackBerry account or device, certain personal information may be collected and disclosed to the third party, or from the third party to BlackBerry, in order to facilitate or improve the services and functionality provided.
c) Cloud-based or back-up data: If you use a cloud-based or back-up and restore service provided by or on behalf of BlackBerry, personal information including contacts, email addresses, calendar, memo, tasks, display pictures, status messages, media files and other on-device information may be sent to BlackBerry in order to facilitate or improve the use, remote access and restoration of that data on your device through the service provided.
e) Financial information: If you purchase a product, service, software or customer support directly from BlackBerry or our service providers, BlackBerry may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable. Similarly, BlackBerry may process payment or other financial information when you use Near Field Communications functionality.
f) General usage data: In some cases, personal information that includes technical properties and general usage information of software and hardware utilized in conjunction with a BlackBerry Offering might be processed when you use such products, services or software (e.g. type of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address), or when you use a BlackBerry troubleshooting tool (e.g. basic usage statistics or information about your device including event logs, application configurations, battery life, radio or Wi-Fi signal levels, device reset and memory or system performance information).
h) Quality assurance and customer service: Your customer service telephone calls with BlackBerry and BlackBerry’s service providers may be recorded or monitored for quality assurance and customer service purposes such as to assist in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to BlackBerry Offerings.
j) Gmail user data use limitations: When you allow BlackBerry Offerings to access your Gmail account, BlackBerry Offerings will only access and use Gmail user data, which includes messages, attachments, contacts, metadata, and settings, to provide you the ability to compose, send, read, and process email messages and manage your contacts. BlackBerry Offerings will not transfer Gmail user data to Third Parties unless necessary to provide or improve the features of the BlackBerry Offering, comply with applicable law, or as part of a merger, acquisition, or sale of assets. BlackBerry Offerings will not use Gmail user data for serving ads, or interest-based advertising. BlackBerry personnel will only access aggregated and anonymized data and will not access Gmail user data unless you have provided your affirmative consent for specific messages, or unless doing so is necessary for security purposes such as investigating abuse, to comply with applicable law.
5. Processing Your Personal Information
BlackBerry retains personal information as long as necessary for the fulfillment of BlackBerry’s identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for BlackBerry’s identified purposes, or required by applicable laws, BlackBerry will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, BlackBerry continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.
b) International operations and onward transfers
You agree that, to be able to better serve you and facilitate the use or functioning of BlackBerry Offerings, your personal information may be collected, used, processed, transferred or stored by or on behalf of BlackBerry in multiple jurisdictions including Canada, the United States, the European Economic Area, and any other country where BlackBerry or our service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of BlackBerry.
Given the international nature of our business, BlackBerry may also be required to disclose or otherwise provide access to your communications data, including the contents of your communications, and other personal information under the laws of countries where BlackBerry, our service providers, affiliates and data are located. By using BlackBerry Offerings, you consent to our compliance with applicable laws including any legal process that BlackBerry believes requires that we produce or provide access to your communications data and other personal information.
c) Marketing communications from BlackBerry
BlackBerry may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your existing business relationship with BlackBerry. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, where you use free services which rely upon advertising (including targeted advertising based on profile information), or through utilizing aggregated data or data that has been made anonymous. BlackBerry may ask you from time to time if you would like to receive from BlackBerry or authorized third parties selected by BlackBerry additional announcements, news, offers or event invitations regarding BlackBerry and BlackBerry Offerings. You may also choose to provide BlackBerry with personal information in response to various BlackBerry promotions. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that BlackBerry sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives in order to obtain further details about how your personal information will be managed. An unsubscribe mechanism is included with every BlackBerry marketing or commercial communication. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from BlackBerry.
d) Service-related communications from BlackBerry
BlackBerry may also send you certain service-related communications. For example, BlackBerry may send a welcome email or message when you first activate a BlackBerry Offering to inform you about the service and its terms, to notify you of important changes, to tell you how to manage your credentials or account, to provide service infrastructure notifications or information about upgrades or updates, to provide warranty information, product recall information, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of BlackBerry Offerings, you may not opt-out of receiving these communications.
e) Information sharing
BlackBerry uses contractual or other means to provide a comparable level of protection while the personal information is being processed by our service providers. It is BlackBerry’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from BlackBerry. For example, except where BlackBerry is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the personal information in confidence and only use the it for the purposes for which it was provided or to comply with applicable laws.
In the event of the sale of all or a portion of BlackBerry’s assets, BlackBerry may provide personal information to the third party purchaser.
BlackBerry may utilize third parties (e.g. advertising networks) to target advertisements at non-personally identifiable attributes or aggregated data that is derived from profile data processed by BlackBerry, and provide such third parties with general statistics relating to the advertisements delivered. Please visit the section below on “Withdrawing Your Consent” for more information on managing marketing or commercial communications from BlackBerry.
f) Third Party Offerings
BlackBerry does not own or operate all the applications or services that you download and use on your device or through other BlackBerry Offerings. When you download or utilize Third Party Offerings, personal information from your device or other BlackBerry Offerings may be accessed by such third parties. For example, a Third Party Offering might access on-device data such as contacts, calendar entries, email, location-based information, or it may access or share files or data stored on the device (including with additional Third Party Offerings). You should review the privacy policies and any agreements with such third parties to understand how your personal information will be processed by those entities, as BlackBerry is not responsible for your dealings with third parties or their applications, products, services or software. BlackBerry does not directly control how such third parties process the personal information they collect in connection with the Third Party Offerings you use.
In some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
6. Accuracy of Your Personal Information
BlackBerry takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date. BlackBerry also depends on you to update or correct your personal information whenever necessary.
7. Safeguarding Your Personal Information
BlackBerry continues to evolve our physical, organizational and technological measures used to protect your personal information. For example, if a BlackBerry website requests your name and password, it will have a variety of security measures in place that are designed to protect against the loss, misuse and unauthorized alteration of the personal information submitted to BlackBerry. Through BlackBerry’s Code of Business Standards and Principles, BlackBerry employees are made aware of the importance of appropriately and securely handling personal information, to keep it in secure locations and systems, and to limit access to personal information to those with a need to know it for business reasons.
In addition, certain BlackBerry systems and processes are externally certified on a regular basis (e.g. certification to ISO/IEC 27001:2013 Information Security Management System standard).
a) Your obligations to safeguard your personal information
You have an obligation to safeguard your personal information. You can reduce risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your device and computer system, such as creating a strong password that cannot be easily guessed by others (e.g. by including punctuation marks, numbers, capital and lowercase letters, and choosing a password of an appropriate length and which does not include your name or account name), using different passwords for different services and using up-to-date antivirus software.
As noted above, in some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.
If you return, sell, discard, or transfer your device or other BlackBerry product to another person or entity (such as providing your device to BlackBerry or another entity for repair, refurbishment or replacement), you should ensure that the device and any associated accessories and peripherals are removed or securely wiped of any personal information or other sensitive data they might contain (e.g. SIM cards, microSD cards). You should also disassociate your device from all email accounts and other data services so that email and data are no longer directed to the device (e.g. push services, emails delivered through the BlackBerry Internet Service, remote backup). Otherwise, your personal information may be available to a subsequent user of the device, and you may incur subscription and network data charges. You may learn more about how to take steps to protect yourself through the Options or Settings menu on your device, searching support articles online at www.blackberry.com, or by contacting your airtime service provider.
8. BlackBerry’s Ongoing Efforts to Be Transparent
9. Accessing Your Personal Information
Upon written request, BlackBerry will inform you whether it holds personal information about you and provide you with access to your personal information within a reasonable timeframe and at minimal or no cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your personal information, BlackBerry will amend your information and notify any third parties as required by applicable laws.
Upon written request, and to the extent authorized under applicable law, BlackBerry will also erase any personal data it holds about you using reasonably appropriate technical measures when:
- it is no longer necessary to process your personal information;
- you withdraw your consent to processing unless some other lawful basis exists for BlackBerry to continue to process your data;
- you object to the processing and no overriding legitimate grounds exist for BlackBerry to process your personal data;
- the personal data has not been lawfully processed by BlackBerry; or
- you have a legal obligation imposed under EU or EU member state law to which BlackBerry is subject.
In certain situations, and depending on applicable laws, BlackBerry may not be able to provide access to the personal information it holds about you if access may adversely affect the rights and freedoms of others. For example, BlackBerry may not provide access to personal information if doing so:
- would likely reveal personal information about a third party;
- would reveal BlackBerry or third party confidential information;
- could reasonably be expected to threaten the life or security of another individual;
- includes information that is protected by solicitor or attorney client privilege; or
- includes information that was processed in relation to the investigation of a breach of an agreement or a contravention of a law.
In order to safeguard your personal information from unauthorized access, BlackBerry may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.
Depending on the circumstances and subject to applicable laws, BlackBerry may deny to process your request if:
- we are unable to verify and authenticate your identity;
- it is unreasonably repetitive or systematic, or
- it would be extremely impractical or require disproportionate technical effort which renders the request manifestly excessive.
Depending on the jurisdiction where you are located, you may also have rights to contact your local data protection supervisory authority to lodge a complaint against BlackBerry.
10. Questions or Concerns
- by email: email@example.com, or
- write to one of the following BlackBerry offices closest to you:
- BlackBerry Privacy Office c/o BlackBerry (attention Legal Department), 2200 University Avenue East, Waterloo, Ontario, Canada N2K 0A7
- BlackBerry (attention Legal Department), The Pearce Building, West Street, Maidenhead, Berkshire SL6 1RL, United Kingdom
- BlackBerry Privacy Office c/o BlackBerry (attention Legal Department), 1 International Business Park, The Synergy Building, 2nd Floor, Singapore 609917
a) Withdrawing Your Consent
You may withdraw your consent at any time by notifying the Privacy Office at BlackBerry at firstname.lastname@example.org.
Marketing or commercial communications: You may unsubscribe from receiving marketing or commercial communications about BlackBerry or BlackBerry® products, services and software by:
- clicking the unsubscribe link at the end of any marketing or commercial communication from BlackBerry;
- by indicating your preference at www.blackberry.com/unsubscribe; or
- by writing to BlackBerry Privacy Office c/o BlackBerry (attention Legal Department), 2200 University Avenue East, Waterloo, Ontario, Canada, N2K 0A7 and advising what particular types of marketing or commercial communications you no longer wish to receive.
- Remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain BlackBerry Offerings as they may not work well or at all with Cookies disabled.
If material changes are made that impact you, we will notify users by placing a prominent notice at www.blackberry.com/legal. Depending on the circumstances, we may also decide to send users a notice electronically. If you continue to use your BlackBerry Offerings after notice of the change has been given, you will be deemed to have accepted such changes.
Last Updated March 10, 2020
March 10, 2020
- Updates to right of access, rectification and erasure.
- Inform data subjects of right to submit a complaint to competent data protection authority.
- Provide list of exemptions to deny data subjects the right of access or erasure.