Huawei WEU (Western Europe) Electronic Direct Marketing (hereinafter, referred to as “EDM”) is an activity organized by Huawei Subsidiaries listed in Chapter 6 below (hereinafter Huawei Subsidiaries) and Huawei Technologies Duesseldorf GmbH (hereinafter referred to as "we", "us" or "our") to promote Huawei products, solutions, and to submit surveys to Huawei customers, partners, contacts etc. through electronic digital means.

We understand the importance of your privacy, and pledge to take all appropriate security measures to protect it in accordance with the industry's well-established safety standards.

The Statement describes:

1. How do we use your data?
2. How long do we store your data?
3. How do we share your data?
4. What are your rights and choices?
5. How to contact us?
6. List of controllers and task allocation

1.    How do we use your data?

Personal data means any information that enables Huawei to identify you as a natural person.

1.1 Huawei processes your personal data for the purpose of Electronic Direct Marketing (EDM), based on your consent:

Promotion/Lead Generation: With your consent, we may use your personal information including your name, email, country/ region, telephone, company, job title, and industry collected from different events organized by Huawei Subsidiaries, in order to contact you to promote Huawei products or solutions that you may be interested in. After the promotion, we will process your email reading status.

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.

You have the right to unsubscribe or withdraw your consent at any time as described in Section 4 of this statement.

2.    How long do we store your data?

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

In particular:

Name of process/purposes	Retention period of relevant personal data
Promotion/Lead Generation	Until you withdraw consent, or after 2 years of inactivity
Survey	Until you withdraw consent, or after 2 years of inactivity

Unless otherwise stated hereunder, your personal data will be stored in China & EU. After the retention period expires, we will erase or anonymize your personal data, unless otherwise required by laws and regulations.

3.    How do we share your data?

(1)  Disclosure of your personal data outside of the [EU/EEA]:

            -Disclosure with our suppliers: We procured supplier located in China, which provide promotion and email survey services.

            -Disclosure with Huawei Technologies Co. Ltd affiliates in China: We use system deployed in China, to store your personal data we processed, while only the system administrator is authorized to access to the data stored in China.

Huawei complies with applicable legal requirements for providing adequate safeguards by incorporating the EU Commission Standard Data Protection Model clauses in such transfer. To obtain a copy of such agreement, please raise your request in the Privacy Portal.

(2)  Disclosure of your personal data within the [EU/EEA]:

            -Disclosure with our supplier: To contact you to promote Huawei products or solutions that you are interested in, your data will be shared to our service provider who is located in the EU. Your personal information will be processed by them on our behalf and under the protection of relevant data processing agreement. To obtain a copy of the data transfer agreement, please raise your request in the Privacy Portal.

 (3) 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.

           

4.    What are your rights and choices? 

You can enter into the Privacy Portal to exercise your data subject right or follow the steps listed below.

•   The right to receive information about the data processing and a copy of the processed data (right to access, Art. 15 GDPR);

•   The right to demand the rectification of inaccurate data or the completion of incomplete data (right to rectification, Art. 16 GDPR);

•   The right to demand the erasure of personal data and, in case the personal data has been made public, the information towards other controllers about the request of erasure (right to erasure, Art. 17 GDPR);

•   The right to demand the restriction of the data processing (right to restriction of processing, Art. 18 GDPR);

•   The right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller (right to data portability, Art. 20 GDPR);

•   The right to object the data processing in order to stop it (right to object, Art. 21 GDPR);

•   If applicable, the right to withdraw a given consent at any time to stop a data processing that is based on your consent. The withdrawal will not affect the lawfulness of the processing based on the consent before the withdrawal (right to withdraw consent, Art. 7 GDPR);

If you think that we are not processing your personal data in accordance with this Statement or the applicable data protection laws, you are entitled to lodge a complaint with your data protection authority.

5.    How to contact us?

You can contact our Data Protection Officer (DPO) through our Privacy Portal

6.    List of controllers and task allocation

1)     Belgium

Belgium – Data Controller:

Huawei Technologies Belgium NV, Woluwelaan 2, 1150 Brussels

2)     France

France - Data Controller:

Huawei Technologies France SASU (the France company), Registered address: 18 quai du Point du jour, 92100 Boulogne Billancourt

3)     Germany

Germany - Data Controller:

Huawei Technologies Deutschland GmbH (our Germany office) Registered address: Hansaallee 205, 40549 Duesseldorf, Germany, Telephone number: 0211 88254 1100.

4)     Italy

Italy – Data Controller:

Huawei Technologies Italia Srl (the Italy company), Registered address: Via Lorenteggio 257, Torre B, 20152, Milan, Telephone number: +39 0239994000

5)     Luxembourg

Luxembourg – Data Controller:

Huawei Technologies Luxembourg SA (the Luxembourg company), Registered address: 13 Rue Edward Steichen, 2540 Luxembourg, Telephone number: +352 27 96 80 0

6)     Portugal

Portugal – Data Controller:

Huawei Tech. Portugal – Tecnologias de Informação, LDA (the Portugal company), registered address: Avenida D. João II, 51B, 10 Andar, 1900-085 Parque das Nações, Lisboa, Portugal, Telephone: +351 217 828 400

7)     Spain

Spain – Data Controller:

Huawei Technologies España S.L. (the Spain company), Registered address: C/ Isabel de Colbrand, 22, Centro Empresarial Castellana Norte, 28050 Madrid, Telephone number: 0034-913843888

8)     Ireland

Ireland – Data Controller:

Huawei Technologies (Ireland) Co., Ltd. (the Irish company), Registered address: Mespil Court, Mespil Road, Dublin 4

9)     Switzerland

Switzerland – Data Controller:

Huawei Technologies Switzerland AG (the Swiss company), Registered address: Waldeggstrasse 30, 3097 Liebefeld, Office Address: Zürichstrasse 130, 8600 Dübendorf

10)   The Netherlands

The Netherlands – Data Controller:

Huawei Technologies (Netherlands) B.V. (the Netherland company)

Registered address: Stationsplein 4, 2275 AZ Voorburg, Telephone number: +31204300808

11)   United Kingdom

United Kingdom - Data Controller:

Huawei Technologies (UK) Co., Ltd. (the UK company), Registered address: 300 South Oak Way, Green Park, Reading, RG2 6UF, Telephone number: 0118 920 8137

Arrangement between Huawei Technologies Duesseldorf GmbH and Huawei local subsidiaries：

Controller(s)	Responsibility
Huawei Subsidiaries (11 countries)	Sending EDM to participants who give their consent. Responsible for DSR (Data Subjects Rights) requests from their own local participants. Responsible for any survey regarding the MKT event or related activities. Business contact for cooperation and activity.
Huawei Technologies Duesseldorf GmbH	Sending EDM to participants who give their consent. Business contact for cooperation and activity. Help to cope with DSR requests sent to Huawei local subsidiaries regarding the MKT event or related activities and responsible for DSR requests from its own local participants. Assists Huawei local subsidiaries for any survey regarding the MKT event or related activities.

We encourage you to regularly check for the latest version of this Statement as we may change it from time to time. If we make changes to this Statement, we will notify you by an appropriate method.

Latest update: April, 2022