Enterprise products, solutions & services
for processing the personal data
in the context of Electronic Direct Marketing
Huawei Europe Electronic Direct Marketing (hereinafter, referred to as “EDM”) is an activity organized by Huawei European Subsidiaries listed in Chapter 6 below (hereinafter “Huawei Subsidiaries”) and Huawei Technologies Duesseldorf GmbH (hereinafter referred to as "Huawei Duesseldorf”) acting as joint controllers, to promote Huawei products, solutions, and to submit surveys to Huawei customers, partners, contacts etc. through electronic digital means.
We understand and respect the importance of privacy. This Statement describes how your personal data are used and protected and how the obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”) and the Privacy and Electronic Communications Directive 2002/58/EC (“ePrivacy Directive”) and its respective implementations in the EU member states legal system, are fulfilled.
This Statement also contains a summary of your rights in relation to your personal data. Some of the terminology in this Statement may be unfamiliar to you – there is a glossary at the end of the Statement which you may find useful. Terms which are included in the glossary are in capital letters.
Huawei Subsidiaries listed in below in this Statement and Huawei Technologies Duesseldorf GmbH (hereinafter individually as “Controller” and collectively as “Controllers”, "we", "our" and "us") work together closely. This also concerns the processing of your personal data.
Under the provisions of GDPR, we are “joint controllers” of the processing of your personal data described in this Statement. This means that we all decide why and how your personal data is processed. It also means that we are jointly responsible to you for that processing (Art. 26 of GDPR).
As part of our joint controllership, we have concluded a written agreement specifying who is responsible for which obligations under GDPR and who fulfils which obligations. In particular, we have concluded an agreement on who is responsible to fulfil data subject rights in accordance with Art. 15-22 of the GDPR and to fulfil information obligations in accordance with Art. 12-14 of the GDPR.
| Personal Data collected and processed | |
|---|---|
| The source of personal data | We may obtain the personal data directly from you or from events organized by Huawei subsidiaries |
| Will we process special categories of data? | No |
| For what purposes do we process your personal information? | What categories of personal data do we process for this processing purpose? | Legal basis of processing | Legal basis of processing |
|---|---|---|---|
| Promotion/Lead Generation, in order to contact you to promote Huawei products or solutions that you may be interested in | name, email, country/ region, telephone, company, job title, and industry; | Your consent (Art 6 (1) a GDPR). You have the right to unsubscribe or withdraw your consent at any time as described in Section 4 of this statement. | Until you withdraw consent, or after 2 years of inactivity |
| Survey by Email: In order to improve the quality of our events organized by Huawei Subsidiaries and knowing your valued opinions and comments, we may contact you via email to conduct surveys after events organized by Huawei Subsidiaries. | name, email, country/ region, telephone, company, | Your consent (Art 6 (1) a GDPR). You have the right to unsubscribe or withdraw your consent at any time as described in Section 4 of this statement. | Until you withdraw consent, or after 2 years of inactivity |
| In the case your personal data will be further processed for other purposes, you will be informed separately by the Controllers. Unless otherwise stated hereunder, your personal data will be stored in Ireland & France. After the retention period expires, we will erase or anonymize your personal data, unless otherwise required by laws and regulations. |
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| Recipients of the personal data | Disclosures related to legal requirements and business transactions Huawei may share your data in response to a legal process or request from a competent authority based on applicable law or in connection with legal proceeding or process. Your data may also be disclosed as part of merger, acquisition, sale of assets (such as service agreements) or transition of service to a Huawei group or other company. |
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| Within the scope of their joint controllership, we have agreed which of them fulfills which obligations under the GDPR, as follows: | |
|---|---|
| Obligation under the GDPR | Controller which fulfills the obligation |
| Information obligations according to Art. 12 and Art. 26 point 2 of GDPR collecting and keeping records of consents | Huawei Duesseldorf and Huawei Subsidiaries |
| Fulfillment of requests from data subjects according to Art. 15-21 of GDPR | Huawei Subsidiaries, with assistance from Huawei Duesseldorf |
| Data protection incidents: Fulfilment of obligations according to Art. 33 and 34 of GDPR | Huawei Subsidiaries, with assistance from Huawei Duesseldorf |
| Ensuring appropriate technical and organizational measures in accordance with Art. 24, 25, 32 of GDPR | Huawei Duesseldorf and Huawei Subsidiaries |
| Sending EDM communications | Huawei Duesseldorf and Huawei Subsidiaries |
| Responsible for any survey regarding the MKT event or related activities. | Huawei Subsidiaries with assistance from Huawei Duesseldorf |
| Collection of personal data from marketing activities | Huawei Duesseldorf and Huawei Subsidiaries |
| The Controllers independently have committed themselves to ensure that the legal obligations regarding deletion of data and the restriction of data processing are complied with. | |
Transfer to other Huawei companies:
We use a system deployed by Huawei affiliate companies in China. While your data is stored in the European Union, the system administrator has access to data stored in Ireland and France for purposes of system administration. Huawei ensures adequate protection of your data by conducting Transfer Impact Assessment, implementing appropriate safeguards, which include technical and organizational measures as well as contractual mechanisms, to ensure that the personal data you provide is protected as required by applicable data protection laws.
These jurisdictions may have different data protection laws. In such circumstances, Huawei will take measures to ensure that data is processed as required by this Policy and applicable laws, which includes when transferring the data subject ’s personal data from the EU to a country or region which has not been acknowledged by the EU commission as having an adequate level of data protection, we use Data Transfer Agreements which incorporate the Standard Contractual Clauses approved by the EU Commission. You can obtain a copy of the Standard Contractual Clauses here: http://www.huawei.com/en/personal-data-request.
Transfer to our suppliers
For the purposes of managing the registration pages for events and for EDM and the database, and for providing the subscription form, we have contracted the services of suppliers located in China. Your personal data will be processed by them on our behalf and under the protection of relevant data processing agreements, with all the security guarantees. The transfer of personal data to those suppliers is protected by Data Transfer Agreements which incorporate the Standard Contractual Clauses approved by the EU Commission. You can obtain a copy of the Standard Contractual Clauses here: http://www.huawei.com/en/personal-data-request.
As a Data Subject, you have certain legal rights in relation to your personal data, which you can find described below. Depending on the case and the legal basis for processing your personal data, these rights may be subject to certain restrictions under the applicable data protection rules. To exercise these rights or contact us on privacy or data protection issues, please send your request at the dedicated contact channel: http://www.huawei.com/en/personal-data-request.
| Right of Access | You have the right to obtain from Huawei confirmation as to whether or not Personal Data concerning you is being processed and, where that is the case, access to a copy of the Personal Data and specific information about how Huawei or any of its affiliates processes your Personal Data. |
| Right of Rectification (Correction) | You have the right to obtain from Huawei the correction of inaccurate Personal Data concerning you and also the right to have incomplete Personal Data completed. |
| Right of Erasure (Deletion) | You have the right to obtain from Huawei the erasure (deletion) of your Personal Data in particular circumstances. |
| Right of Restriction | You have the right to obtain from Huawei restriction of processing in particular circumstances. |
| Right of Objection | You have the right to object to the processing of your Personal Data in particular circumstances. |
| Right of Portability | In certain circumstances, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. Please bear in mind that the right of portability does not apply in the case of processing personal data on legal obligation or legitimate interests’ basis. |
| Right to Withdraw Consent | Where the legal basis of processing Personal Data is based on consent, you have the right to withdraw your consent at any time by providing a withdrawal notice to Huawei. Please note, however, that the withdrawal of your consent will not affect any use of the Personal Data made before you withdrew your consent. |
| Right to lodge a Complaint | If you consider your Personal Data is not being processed in compliance with the applicable laws, you have the right to lodge a complaint with any relevant supervisory authority. You can obtain a list of Supervisory Authorities here: EU List of Supervisory Authorities The data protection officer of North Rhine-Westphalia (where Huawei Technologies Duesseldorf GmbH has its headquarters) can be contacted at: Landesbeauftragte für datenschutz und informationsfreiheit Nordrhein-Westfalen Postfach 20 04 44 40102 Düsseldorf Tel: 0211 / 38424-0 Fax: 0211 / 38424-10 E-mail: poststelle@ldi.nrw.de |
Despite the above stated regulations, you can exercise each of your rights through contacting any of the Controllers using the following contact details:
For Huawei: You can contact the Data Protection Officer (“DPO”) at: Huawei DPO Office, Hansaallee 205, 40549 Düsseldorf, Germany and via Huawei DPO Office.
Name and contact details of the joint controllers:
Huawei Technologies Duesseldorf GmbH
Hansaallee 205
40549 Düsseldorf
Tel: +49 211 88254 8000
Fax: +49 211 88254 8939
And
1) Belgium
Huawei Technologies Belgium NV, Woluwelaan 2, 1150 Brussels
2) France
Huawei Technologies France SASU (the France company) 18 quai du Point du jour, 92100 Boulogne Billancourt
3) Germany
Huawei Technologies Deutschland GmbH (our Germany office) Hansaallee 205, 40549 Duesseldorf, Germany, Telephone number: 0211 88254 1100.
4) Italy
Huawei Technologies Italia Srl (the Italy company), Via Lorenteggio 257, Torre B, 20152, Milan, Telephone number: +39 0239994000
5) Luxembourg
Huawei Technologies Luxembourg SA (the Luxembourg company), 13 Rue Edward Steichen, 2540 Luxembourg, Telephone number: +352 27 96 80 0
6) Portugal
Huawei Tech. Portugal – Tecnologias de Informação, Avenida D. João II, 51B, 10 Andar, 1900-085 Parque das Nações, Lisboa, Portugal, Telephone: +351 217 828 400
7) Spain
Huawei Technologies España S.L., C/ Isabel de Colbrand, 22, Centro Empresarial Castellana Norte, 28050 Madrid, Telephone number: 0034-913843888
8) Ireland
Huawei Technologies (Ireland) Co., Ltd., Mespil Court, Mespil Road, Dublin 4
9) Switzerland
Huawei Technologies Switzerland AG (the Swiss company), Waldeggstrasse 30, 3097 Liebefeld, Office Address: Zürichstrasse 130, 8600 Dübendorf
10) The Netherlands
Huawei Technologies (Netherlands) B.V. Stationsplein 4, 2275 AZ Voorburg, Telephone number: +31204300808
11) Sweden
Huawei Technologies Sweden AB, Gustav III:s Boulevard 50, 169 73 Solna, Stockholm, Sweden
12) Denmark
Huawei Technologies (Denmark) ApS, Støberigade 14, 2, 2450 København SV
13) Poland
HUAWEI POLSKA Spółka z ograniczoną odpowiedzialnością, UL. DOMANIEWSKA nr 39A, kod 02-672, Warsaw, Poland
14) Serbia
Huawei Technologies doo Beograd, Omladinskih brigada 90D, 11070 Belgrade-New Belgrade, Serbia
15) Hungary
Hungary – data controller
Huawei Technologies Hungary KFT., Hungary -1138 Budapest, Népfürdő str.. 22., building, ‘A’ 12th floor.
16) Norway
Huawei Technologies Norway AS, Rolfsbuktveien 4A, 1364 Fornebu, (Location addr): Rolfsbuktveien 4A, 1364 Fornebu
17) Finland
Huawei Technologies Oy (Finland) Co.,Ltd., Läkkisepäntie 23, 00620 Helsinki, Finland
18) Bulgaria
Huawei Technologies Bulgaria EOOD, 13 floor, Megapark building, 115 G Tzarigradsko shosse blv., Mladost district, Sofia 1784, Republic of Bulgaria.
19) Greece
Huawei Technologies S.A., Greece-Athens-49 Kifisias Avenue & Ziridi, 2nd floor, 15123, Marousi, Athens, Greece
20) Romania
Huawei Technologies S.R.L., Bucharest, 2nd District, 201 Barbu Vacarescu street, 14th, 15th, 16th, 23rd, 24th and 25th floors
21) Austria
HUAWEI Technologies Austria GmbH, Vienna, Austria, Firmenbuch 287255i
22) Czech Republic
Jihlavska 1558/21, 140 00 Prague 4, Czech Republic
23) Estonia
Huawei Technologies Eesti OÜ
A. H. Tammsaare tee 47, 11316 Tallinn Registration Code: 14986789
24) Bosnia and Herzegovina
Huawei Technologies d.o.o. Banja Luka
Bana Milosavljevića8, 78000 Banja Luka
25) Croatia
Huawei Technologies D.O.O.
Ul. Ivana Lučića 2A, 10000, Zagreb, Croatia
26) Latvia
Huawei Technologies Latvia SIA
Duntes iela 3, Riga, LV-1013, Latvia
27) Lithuania
Huawei Technologies (Vilnius), UAB
Lvovo g. 25, Vilnius, LT-09320, Lithuania
28) Moldova
Huawei Technologies S.R.L.
Moldova-Chisinau-29 Sfatul Tarii str. International Business Center Le Roi, floor 7, of. 704
29) Cyprus
Huawei Technologies (Cyprus) Co. Ltd
Cyprus- Kasou Street 21, 1086 Nicosia
30) Slovakia
Huawei Technologies (Slovak) s.r.o.
Slovakia-Bratislava-Einsteinova 23, 851 01 Bratislava Slovakia, Slovak Republic.
31) Slovenia
Huawei Technologies Ljubljana d.o.o
Ameriška ulica 8, 1000 Ljubljana, Slovenia
| Glossary | |
|---|---|
| Controller | An organisation who (alone or jointly with others) determines the purposes and means of the processing of Personal Data. |
| Data Transfer Agreement | An agreement containing standard data protection clauses adopted by the European Union Commission as referred to in Article 46(2)(c) of the GDPR. |
| Data Subject | The identified or identifiable natural person to whom the Personal Data relates. |
| GDPR | Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). |
| ePrivacy Directive | Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications). |
| Joint Controllers | Two or more controllers who jointly determine the purposes and means of processing. |
| Legal Basis | Processing of Personal Data is only lawful if and to the extent that at least one legal basis specified in the GDPR applies. The available legal bases which are applicable for this data processing activity are specified above. |
| Personal Data | Any information relating to an identified or identifiable natural person (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Anonymized data is not considered personal data. |
| Process/ProcessingLegal Basis | Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. |
| Special Categories of Personal Data | Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. |
| Version Control | ||
|---|---|---|
| Version | Publish Date/Revised Date | Reason & Remark |
| V 2.0 | November 2023 | The privacy statement has been extended to all EU subsidiaries countries. |
| V 1.0 | April 2022 | Initial version |
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