Statement About HUAWEI Mobile Cloud and Privacy

Last updated: June, 2023

HUAWEI Mobile Cloud (hereinafter referred to as "Cloud") is a service provided by Aspiegel SE, a subsidiary of Huawei incorporated in Ireland (hereinafter referred to as "we", "us", or "our"). Cloud automatically syncs, backs up, and uploads your data to cloud servers so that you can access and manage your data on any device logged in to your HUAWEI ID.

This Statement describes:

1 What Data Do We Collect About You?

2 How Do We Use Your Data?

3 How Long Do We Store Your Data?

4 How Do We Share Your Data?

5 What Are Your Rights and Options?

6 How to Contact Us?

7 How Do We Update This Statement?

1 What Data Do We Collect About You?

As part of the Cloud service, we shall collect and use your personal data only for the purposes stated in this Statement. Personal data refers to any information that enables Huawei to identify you as a user.

We will collect and process the following data:

Account information: such as the account name (email address or phone number), profile picture, username, country code, account identifier, and user service token. We may use your account information to send you a welcome message with an introduction to Cloud by email, push message, and/or text message. If another Cloud user wants to share content on Huawei Drive with you based on your phone number or email address linked with your HUAWEI ID, we will query the existence of your account and provide access rights accordingly. At no point do we share your account information with the sharer or any other third parties.

Device information: such as the device identifier (such as MEID, UDID, or IMEI, depending on your system version), device model, operating system, APK version, and language settings.

Network information: such as the IP address, network type, and connection status.

Service usage information: such as Cloud version, source of download, app open and close time, clicks and exposure (including opening or closing of push notifications), package information (name, capacity, and duration), purchase information (time, amount, and order ID), total number and size of photos, number of contacts, system logs, error logs, list of installed apps (including the app name, app size, app installation time, app version, app package name, app icon, and app installation source), and when and for how long the installed apps are used. If you allow third-party apps to upload files to Huawei Drive, we will collect the identifier of the third-party app as well as other operation records, such as timestamps, file size, and file ID. When you view documents on Huawei Drive online, we will collect information about the documents you open, temporary files generated when the document is being opened, and document encoding settings. When you modify a document, we will collect the document's editing records, the data generated during the editing process, the watermarks you create, and the comment creation records.

Synced, backed up, or uploaded data (results may vary based on the available features in your registered HUAWEI ID country/region): synced data (including Contacts, Calendar events, Wi-Fi settings, notes, photos, videos, album tags, and the data of apps that you selected), Cloud backup data (including Contacts, Calendar events, Wi-Fi settings, notes, photos and videos, recordings, call log, harassment filter and settings, messages, Optimiser settings, browser bookmarks, Weather settings, screen layout, Camera settings, phone settings, FM radio settings, Alarm settings, AI Tips settings, documents in Safe, Support settings, and list of installed apps), Huawei Drive files (including local files or files from third-party apps you choose to upload), file metadata (including picture location, video duration, and file name and type) for search and listing purposes, third party app-specific data you authorise to store on Drive, file thumbnails for user-friendly display, and pseudonymous bank card numbers (last four digits). The bank card information will be used for managing (removing and suspending) your bank cards on the Cloud website and will not be stored on the cloud. In order to allow you to restore data using the Time Machine feature, a copy of the historical data will be retained for thirty (30) days. When you use the Find Device feature to find or lock your device, we will also process your lock screen password, contact number, and lock screen message sent to the lost device.

If you log in to the official Cloud website (cloud.huawei.com) with your HUAWEI ID to manage your data, the following data will also be collected: Browser and usage information, such as cookies, IP address, browser type, time zone, language, and mouse and keyboard operation. For more information on cookies, please read our cookie policy.

If your device is lost, you can use the Find Device feature to locate, ring, lock, and erase the data on your device remotely. When you use the Find Device feature, we will process your device's location information in the following ways:

When you locate your device remotely, we will process your device's location information only when tracking your device.

When you lock your device remotely, we will process your device's location information continuously until you unlock the device.

When you use the Find Device feature to send a lock screen message to the lost device, we need to process the content of the message in order to deliver the message.

The Find Device feature can also process and display to you the battery level of the lost device. In addition, the SIM card number and network status of the lost device can be accessed by you, giving you the best chance of getting your device back.

To find and manage Bluetooth devices (such as earphones, watches, bands, and glasses) paired with your device, we need to process the status of such Bluetooth devices together with the device identifier and model. In order for Find Device to display the location of a Bluetooth device when it is disconnected from your device, your device will report the location of the Bluetooth device upon the disconnection. During the process, Location Services will be enabled automatically and then disabled after the location is reported. For sports watches and bands, you can only find and manage these devices through the Health app after pairing these devices with your phone in Health.

When you participate in our marketing activities, we may record information about your participation and winning of any prizes (e.g. if you win any physical prizes, we will collect your shipping address and phone number to deliver the prizes to you) in accordance with the campaign terms and conditions.

Cloud requires the Phone permission to obtain device information, and the Storage, Camera, Messaging, Contacts, Call logs, and Calendar permissions to provide synchronisation and backup services. Find Device requires the Location permission to locate a lost device and the Phone permission for calling the lost device directly from the Find Device app.

2 How Do We Use Your Data?

To provide you with the Cloud services, including Cloud sync, Cloud backup, Huawei Drive, and other app data services, as well as to fulfil contractual obligations, we will collect and use your personal data for customer relationship management, support and communication, customer complaint handling, maintenance, software and system update, user identification, and diagnostics and repair purposes. For information on the processing of your personal data for customer support purposes, please read the Statement About Customer Support and Privacy.

In order to handle and reply to the questions you have submitted through our Help feature, we will process your account identifier, service identifier, device type and model, IP address, operating system version, language settings, and the questions (and other information) you have sent to us. A specific reply may be automatically generated based on the question (that is, generated by the robot) and stored together with your account identifier.

In addition, we use your personal data for the following purposes based on our legitimate interest:

Statistics and product improvement purposes, including creating aggregated groups based on your usage activity. This enables us to understand your needs and to improve the quality and user experience of our current and future products and services. You can object to such processing as described in Section 5.5 below.

Marketing purposes, including communicating about our offerings, sales promotion, and other marketing purposes, as well as creating aggregated target groups for marketing. Knowing our customers' preferences enables us to target our offers and offer products and services that better meet the needs and expectations of our customers. You can object to such processing as described in Section 5.5 below.

Information security purposes, including detecting or preventing various types of misuse of services and fraud in order to provide you with secure and reliable services.

With your consent, we may send you push notifications, emails, and text or multimedia messages about the latest activities and offers from us and our partners. You may at any time withdraw your consent by disabling Notifications. To disable Notifications, go to Settings > Account centre > Cloud, touch the More options menu in the top-right corner, and select Notifications on your device. You may also choose different communication channels based on your preferences at the same place.

We may send you service-related notifications (such as system maintenance notices, transaction records, and cloud storage usage reminders) when necessary. You may not be able to opt out of receiving important service-related notifications that are not promotional in nature.

We also process your package and purchase information for tax and accounting purposes as required by laws and regulations applicable to us.

Cloud adopts industry-leading privacy protection technologies and security protection mechanisms based on multi-layer encryption to ensure that no one else can view or obtain your data without your authorisation. For more information about Cloud security and privacy, see Cloud Security and Privacy (https://cloud.huawei.com/security).

3 How Long Do We Store Your Data?

We will retain your personal data for no longer than is necessary for the purposes defined in this Statement.

We will process and retain your data for the duration of the customer relationship. If you stop using Cloud for a period of twelve (12) months, your data will be deleted. In this case, we will remind you of the deletion in advance by email and other appropriate means. When you delete your HUAWEI ID, personal data related to your account and its associated services, such as Cloud will be erased. However, we shall retain the data as follows:

Cloud package and purchase information will be retained for seven (7) years from the date the transaction was made.

Information for receiving campaign prizes (including the phone number, shipping address, and contact person) will be retained for up to twelve (12) months from prize delivery.

Data in relation to Huawei Drive, including document editing records (such as the editor and time of the edits), as well as data about file conversion and file embedding, will be retained for six (6) months after these operations were performed or be deleted when you delete the document or delete your HUAWEI ID. The temporary file generated when a document is being opened on Huawei Drive will be deleted immediately after the document is opened. Records of you inserting comments in a document on Huawei Drive will be deleted when you delete your HUAWEI ID or within twenty-four (24) hours after the document is deleted. Information about the document character encoding and the watermarks you set will be deleted when you delete your HUAWEI ID.

Personal data processed for customer relationship management such as data subject requests, complaints, and customer interaction records will be retained for up to six (6) years from your last interaction with Huawei.

Location data used for tracking your device, when you have locked your device using the Find Device feature, will be retained for twenty-four (24) hours from the time of collection. If you unlock your device, all location data will be immediately erased.

Your device's location information obtained by the Find Device feature will be retained for seven (7) days and will be immediately deleted when you disable the Find Device feature. The remaining battery level displayed in Find Device, and the SIM card number and network status information of the lost device will be retained for seven (7) days. The track data sent, as well as the lock screen information, contact information, and lock screen password will all be automatically cleared when you disable Lost mode. If you request to unlock the device when you forgot the password, the device verification code delivered to your device will be deleted immediately after you disable the Find Device feature.

Files you have requested to download in the Retrieve your data from Cloud section in the Cloud web portal will be retained for seven (7) days by default.

Personal data processed for contract management purposes will be retained for up to three (3) years after your HUAWEI ID is deleted.

Personal data processed for analytical analysis and product development as well as sales promotion and marketing purposes will be retained for twelve (12) months from the date of collection, unless you object to such processing.

Data backups and app logs processed to ensure the security of your data and services will be retained for six (6) months from the date of creation.

Activity logs and system logs will be deleted immediately upon completion of the relevant statistical analysis. Error logs will be retained for seven (7) days from the date of collection and then be automatically deleted.

Once the retention period expires, we will delete or anonymise your personal data, unless otherwise required by applicable laws and regulations.

4 How Do We Share Your Data?

We store your data in the data centres located in the European Union (EU)/European Economic Area (EEA).

We share your data in the following circumstances:

If you authorise a third party app to configure your Huawei Drive, we will share your Drive status to the third party as part of the authorisation.

We may share your data in response to a legal process or request from a competent authority according to applicable laws or in connection with a legal proceeding or process.

Your data may also be disclosed as part of a merger, acquisition, sale of assets (such as service agreements), or transfer of services to a Huawei group entity or another company.

If you are using the Cloud service, including uploading and downloading to and from Cloud, when you are travelling outside the EU/EEA, your data may be transferred through the local site of a Huawei group entity in China, Russia, or Singapore operating under contract and acting on behalf of us. To determine the correct site for your data, we need to process your account identifier and registration country information in the local site of the country where you are travelling.

To allow you to locate your device using the Find Device feature, we will transfer your location information to a map service provider in the EU operating under contract and acting on behalf of us.

Cloud will permit others to access content on your Drive when you have authorised such sharing from third party apps.

If you have authorised non-Huawei apps to access your HUAWEI ID account information and to view and manage your Huawei Drive files and/or store app-specific data on your Drive, you can revoke such authorisation in the third party app or by going to Settings > HUAWEI ID > Privacy centre > Configure Your Privacy Settings > Authorisations to Account Information. You can also view and manage app-specific data from the Cloud website (cloud.huawei.com), including how much storage space has been used, deleting app data, and revoking app access authorisation.

When transferring and disclosing your data outside the EU/EEA, where the local law may not provide the same level of protection as in the EU/EEA, we shall comply with applicable legal requirements for providing adequate safeguards to such transfers by incorporating the European Commission's Standard Contractual Clauses (SCC). If you want to obtain a copy of the actual signed SCC, please contact us.

5 What Are Your Rights and Options?

You have the following data subject rights and options regarding your personal data:

5.1 Access your data

You can obtain information about and a copy of your personal data in relation to Cloud by going to Settings > HUAWEI ID > Privacy centre > Manage Your Data and touching Request Your Data.

You can also access and download the data you have synced, backed up, or uploaded from the Cloud app or official website (cloud.huawei.com).

For additional access requests, please contact us.

5.2 Rectify your data

To keep your data up-to-date and accurate, you can access and modify your data by going to Settings > HUAWEI ID.

You can also access and modify the data you have synced, backed up, or uploaded from the Cloud app or official website (cloud.huawei.com).

5.3 Port your data

You can port the personal data that you have provided to us in relation to Cloud in a commonly-used machine readable format by going to Settings > HUAWEI ID > Privacy centre > Manage Your Data and touching Request Your Data.

You can also download the data you have synced, backed up, or uploaded from the Cloud app or official website (cloud.huawei.com). Files you have requested to download in the Retrieve your data from Cloud section of the Cloud web portal will be retained on our server for seven (7) days by default. During this period, you can choose to download these files to your device or delete them.

5.4 Erase your data

You may at any time:

Delete the local data from your device, to delete the data that you have synced, backed up, or uploaded to the cloud and other types of app data. The deletion will automatically sync and update to the cloud.

Delete your stored data by deleting it directly on Huawei Drive.

Delete all data collected by Find Device by disabling the feature.

Delete all data from your lost device and memory card using the Find Device feature.

Log in to the official Cloud website (cloud.huawei.com) to delete your data, including contacts, photos, recordings, and Huawei Drive files.

Delete your HUAWEI ID. This will erase your personal data linked with your HUAWEI ID, including your personal data in Cloud.

Object to the processing of your data, as described in Section 5.5. If your objection is valid, and we no longer have legal basis to continue processing your data, we will erase the relevant data within the scope of your effective objection.

Contact us if you think the processing of your personal data is unlawful and your data should be erased.

We will delete or anonymise your personal data without undue delay when necessary based on your aforementioned actions and in accordance with the retention periods as described in Section 3.

5.5 Object to processing

If you want to object to the processing of your data for statistical, product improvement or sales and marketing purposes, please contact us.

When making the request, please specify the scope of the request and provide us with your email address or phone number that you used to log in to Cloud with your HUAWEI ID.

We will contact you to verify your identity in order to proceed with your request.

5.6 Withdraw your consent

If you have opted for receiving advertising messages from us, you can withdraw your consent by disabling Notifications. To disable Notifications, go to Settings > Account centre > Cloud, touch the More options menu in the top-right corner, and select Notifications on your device. You may also choose different communication channels based on your preferences at the same place.

5.7 Restrict processing

If you want to restrict our processing of your personal data, please contact us. You have the right to restrict the processing of your data in the following circumstances:

Your data is unlawfully processed, but you do not want to erase it.

You have a legal claim that you need to establish, exercise, or defend, and you have requested us to keep your data when we would not keep it otherwise.

You have contested the accuracy of your personal data and the accuracy of your data is pending our verification.

Your request for objection is pending our verification.

When making the request, please specify the scope and the grounds for the request and provide us with the email address or mobile number that you use to log in to Cloud.

We will contact you to verify your identity in order to proceed with your request.

6 How to Contact Us?

You can find guidance on how to exercise your rights as a data subject in Section 5. If you have any questions, comments, or suggestions on your rights as a data subject or the processing of your personal data by us, or if you want to contact our Data Protection Officer, please contact us.

Our headquarters' address: 3rd floor, Mespil Court, Mespil Road, Ballsbridge, Dublin 4, D04 E516, Ireland. Registration number 561134.

If you believe that we do not process your personal data in accordance with this Statement or the applicable data protection laws, you can lodge a complaint with the data protection authority in your country/region, or the Data Protection Commissioner in Ireland.

7 How Do We Update This Statement?

We encourage you to regularly check for the latest version of this Statement in the app settings as we may update it from time to time. In the event of material changes to this Statement, we will notify you in advance by means of notification dialogs, push messages, emails, and so on, depending on the nature of the change.

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