Additional disclosures for individuals residing in select jurisdictions – United States of America

Effective Date: 01, 08, 2026

This US Supplement to the Fairphone Privacy Policy describes personal data processing activities concerning residents of United States that have adopted comprehensive privacy legislation, including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia (“selected United States ”), and should be read in conjunction with the Fairphone Privacy Policy. Our data processing activities within the selected United States are strictly limited to those enumerated herein. For comprehensive information regarding our global privacy practices, please refer to the complete Fairphone Privacy Policy.

Where this section conflicts with the Fairphone Privacy Policy, this section prevails for residents of the selected U.S. states. For all matters not addressed below, including data retention, the location of Your Personal Information, security measures, and the protection of children, please refer to the corresponding sections of the Fairphone Privacy Policy (hereafter “this Privacy Policy”). Any terms not defined in this Addendum have the same meaning as in this Privacy Policy.

Some portions of this Addendum apply only to residents of particular states. In those instances, we have indicated that such language applies only to those residents.

1. Definitions

• “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Personal Information includes “personal data” as that term is defined under the applicable U.S. state privacy laws.  
• “Sensitive Personal Information” means Personal Information that reveals an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account number, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs, or union membership; contents of email or text messages; and genetic data. Sensitive Personal Information also includes processing of biometric information for the purpose of uniquely identifying an individual and Personal Information collected and analyzed concerning an individual’s health, sex life, or sexual orientation. Sensitive Personal Information also includes “sensitive data” as that term is defined in the applicable U.S. state privacy laws.
• “Third Party” has the meaning afforded to it in the applicable U.S. state privacy laws.

2. Personal Information We collect and purposes for which We use Personal Information

Including over the past 12 months, We have collected the categories of Your Personal Information and used them for the purposes described in Section 2 (What Data do we collect and Why?) of this Privacy Policy, where applicable. The categories of Personal Information include:

• Identifiers, such as Your name, postal address, email address, telephone number, account name, IP address, device identifiers (including IMEI and serial number), and online identifiers.
•  Customer records, such as Your name, contact information, and payment information collected for purchases.
•  Commercial information, such as products purchased or considered, and order history.
• Internet or other electronic network activity information, such as browsing history, search history, interactions with Our website, the My Fairphone App, and information regarding Your interactions with advertisements.
• Geolocation data, such as approximate location derived from Your IP address.
• Audio, electronic, visual, or similar information, such as call recordings or content You share through Our customer support channels.
• Inferences drawn from the above, such as Your engagement with Fairphone content and product preferences, used for segmentation and personalization.

3. Sensitive Personal Information

Including over the past 12 months, We have processed Sensitive Personal Information of the following types solely for the limited purposes described below:

• Account login credentials combined with passwords, for authentication, account security, and the delivery of the services You request.
• Payment card numbers combined with required security or access codes, for processing Your purchases and refunds. This information is processed by Our payment service providers and is not stored by Fairphone.

We do not collect, use, or disclose Sensitive Personal Information for purposes other than those permitted under applicable U.S. state privacy laws. We do not sell or share Sensitive Personal Information.

4. Sources of Personal Information

We may have obtained Your Personal Information from a variety of sources, including directly from You, Your device, Your use of Our website, Our devices, the My Fairphone App, and from third parties that We engage to provide services to You, as described in Section 2 (What Data do we collect and Why?) of Fairphone Privacy Policy. Such third parties may include Our payment service providers, recycling and repair partners, logistics providers, identity providers used for single sign-on, and review and feedback platforms.

5. Disclosures of Personal Information

Please refer to Section 4 (Sharing Your Data) of Fairphone Privacy Policy for the categories of recipients to which We may disclose Your Personal Information, including service providers (also referred to as "processors" or "contractors" under certain U.S. state privacy laws) that process Personal Information on Our behalf, business partners, professional advisors, public and governmental authorities, and Our affiliates. Including over the past 12 months, We may have disclosed each category of Personal Information listed above to such recipients for the business purposes described in Section 4 of this Privacy Policy and to advertising partners as described in "Sale or sharing of Personal Information and targeted advertising" below.

6. Sale or Sharing of Personal Information

We do not sell Your Personal Information for monetary consideration. However, certain data collection and disclosures related to You and Your activity on Our websites and applications, including disclosures to third parties for purposes of interest-based advertising and social media features, may be considered a "sale" or "sharing" or constitute "targeted advertising" under applicable U.S. state privacy laws.

Including over the past 12 months, We may have "sold," "shared," or processed for "targeted advertising" the following categories of Personal Information: identifiers, commercial information, Internet or other electronic network activity information, approximate geolocation, and inferences drawn from the above.

We "sold," "shared," or disclosed for the purpose of "targeted advertising" each category to business partners and other third parties as described in Section 4 (Sharing Your Data) of this Privacy Policy, including providers of advertising, marketing, analytics, data augmentation, audience measurement, other online third-party branded tools or functionality (such as video players), and social networks. The purposes for which We "sell," "share," or process Your Personal Information for "targeted advertising" are to assist Us with advertising, marketing, audience measurement, and other functionality on Our digital properties. With Your consent through Our cookie banner, We engage in cross-context behavioral advertising and targeted advertising.

7. Your Privacy Rights

Residents of the selected U.S. states have certain rights relating to the collection, use, disclosure, and other processing of their Personal Information, to the extent applicable to each service in accordance with applicable U.S. state privacy laws, as described below:

• Access: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, “selling,” or “sharing” Personal Information or processing for “targeted advertising,” the categories of third parties to whom we disclose Personal Information, the categories of Personal Information disclosed to third parties, and the specific pieces of Personal Information we have collected about You in a usable format.
• Correction: You may have the right to request that we correct the Personal Information we maintain about You, if that information is inaccurate.
• Deletion: You may have the right to request that we delete certain Personal Information we have collected from You.
• Portability: You may have the right to obtain a copy of Your Personal Information in a format that can be transmitted to another entity.
• Opt-Out of sale, sharing, and targeted advertising:  where applicable, You may have the opt-out rights for certain activities through:
• Adjusting Your cookie preference settings on our website
• Enabling Global Privacy Control (GPC) signals in Your browser
• a privacy request portal URL (e.g., privacy.fairphone.com/us-request)

Non-Discrimination: You have the right not to be discriminated against by Us for exercising Your rights under this Addendum or any applicable U.S. state privacy laws. We will not deny You goods or services, charge You different prices, or provide You a different quality of services because You exercise these rights, although some of the functionality and features available to You may change as a result of Your choices.

How to exercise Your rights: You may submit a verifiable consumer request by Fairphone Privacy Request Center We will verify Your identity using the information We hold about You. Where permitted by applicable U.S. state privacy laws, You may use an authorized agent to submit a request on Your behalf, in which case We will require proof of the agent's authority and may also require You to verify Your identity directly with Us.

Response and appeal: We will respond to Your request within the time period required by applicable U.S. state privacy laws. If We deny Your request, You may appeal Our decision by request by [email protected] under applicable U.S. state privacy laws. We will respond to Your appeal within the time period required by applicable U.S. state privacy laws and explain the reasons for Our decision. If Your appeal is denied, You may contact the attorney general of Your state.

8. Notice for specific states

California residents

In addition to the rights set out in “Your Privacy Rights” above, California residents have the following additional rights.

• Shine the Light: You are entitled once a year, free of charge, to request and obtain certain information regarding Our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own direct marketing purposes.
• Financial incentives. We offer financial incentives to California residents through Our Keep Club loyalty program (each, a "Program"). When You enroll in Keep Club, We collect Your name, email address, IMEI Number, Fairphone account information, and purchase history (identifiers and commercial information) in exchange for points redeemable for discounts, and other rewards, subject to tier-based multipliers. The material terms of each Program are presented at enrollment on the linked pages. You may opt in through those pages and withdraw at any time by Fairphone Privacy Center; withdrawal does not affect points already accrued. For purposes of California privacy law only, We reasonably estimate that the value of the Personal Information collected for each Program is approximately equal to or less than the value of the discounts, rewards, delivered to a participating consumer over the lifetime of enrollment. We reasonably estimate the value of Personal Information by estimating the expenses related to the provision of each incentive program per individual. We incur a variety of expenses for providing financial incentives, such as administrative and technical expenses associated with maintaining the Program, costs associated with the discounts on purchases. Participation is voluntary and does not affect Your other rights under California privacy law.

Nevada Residents

This section applies only to Nevada residents and adds to the information contained in this Privacy Policy. The other state-specific notices in this Addendum do not apply to Nevada residents, except where this section explicitly cross-references them.

• Personal information We collect and purposes of use

Through Our websites, the My Fairphone App, and other online services, We collect the categories of personal information described in "Personal Information We Collect" above in this Addendum, which include Your name; postal address; email address; telephone number; account identifiers; device identifiers (such as IMEI); and other information You provide to Us through Our online services. We use this personal information for the purposes described in Section 2 (What Data do we collect and Why?) of this Privacy Policy, including: to respond to Your inquiries and fulfill Your requests; to send You information about Your purchases, warranty, and account; for fraud prevention and technical security; to develop, improve, and personalize Our products and services; for analytics and to assess the effectiveness of Our communications; and for marketing communications subject to Your consent.

• Your privacy rights

Nevada residents have the right to direct Us not to sell their personal information. We do not currently sell Your personal information within the meaning of applicable Nevada law. If Our practices change, You or Your authorized representative may submit a verified request to opt out by contacting Us through the channels described in "How to exercise Your rights" in the "Your Privacy Rights" section above. 

To exercise the right to review, correct, or update Your personal information, You or Your authorized representative may submit Your request through the channels described in "How to exercise Your rights" in the "Your Privacy Rights" section above.

We will respond to verified requests within 60 days of receipt. If circumstances cause any delay in our response, You will be promptly notified and provided a date for our response.

9. Updates to this Privacy Policy

The most current version of the Privacy Policy governs Our processing of Your Data. We reserve the right to amend our Privacy Policy from time to time. If We do revise this Privacy Policy and make changes that are determined by Us to be material, We will notify You.