Statement About HUAWEI Developer and Privacy

September 1, 2019

HUAWEI Developer enables you to upload and distribute your products to Huawei servers and content stores as well as manage and monitor your products throughout their lifecycles within our ecosystem. 

If your products are distributed in Mainland China in accordance with Part 1 of Exhibit A – List of Countries/Regions (“Exhibit A”), Huawei Technology Software Co., Ltd., a subsidiary of Huawei in China, will be your contracting entity and data controller. 

​If your products are distributed in the country(ies) or region(s) listed in Part 2 of Exhibit A, Aspiegel Limited, a subsidiary of Huawei incorporated in Ireland, will be your contracting entity and data controller. 

If your products are distributed in the country(ies) or region(s) listed in Part 3 of Exhibit A, Huawei Services (Hong Kong) Co., Limited., a subsidiary of Huawei in Hong Kong(China) will be your contracting entity and data controller.

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. Do We Share Your Data?

5. What are Your Rights and Choices?

6. How to Contact Us?

7. Howdo We Update this Statement?

1 What Data do We Collect About You?

As part of the HUAWEI Developer 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 us to identify you as a user.

For these purposes, we collect and process the following data:

If you are an individual developer:

  • Identification information: such as legal name, identification document (copy of your valid ID, such as passport, national identity card, or driver license, and copy of your bank card), street address, city, country, phone number, and email address.

  • Financial information: such as bank name, branch name, branch number, IBAN, swift code (BIC), account name, account type, K/C, tax payer ID, VAT number, tax address, tax qualification file, account number, currency type, bank country, bank info, and confirmation letter.

  • Product management information: such as developer name, developer user ID, developer registration account (HUAWEI ID account identifier), developer type, country ID, professional contact information (phone, email), product package, package name, official APK link, distribution country, comments made by the developer and feedback, and app ID.

  • Network and usage information: such as IP address, language, webpage location and title, webpage request type, click events and other browsing information, brief information on problems that occurred during usage, problem description and attachments, and cookie data. Learn more about how we use cookies in the Huawei cookie policy.

If you are an enterprise developer:

  • Identification information: legal entity name, DUNS number, location (country, city, state/province, and street address), business license number, and business license photo, contact person name, job title, work phone number, and work email address.

  • Financial information: bank name, branch name, bank country, bank number, branch number, IBAN, account name, account number, SWIFT code (BIC), account type, K/C, tax payer ID, currency type, bank country, bank info confirmation letter, country of incorporation, tax address, location (state/province, city), VAT number, and VAT registration certification.

  • Product management information: developer name, developer user ID, developer registration account (HUAWEI ID account identifier), developer type, professional contact information (phone, email), product package, package name, product IP information, distribution country, comments made by the developer, feedback, app ID, brief information on problems, and problem description and attachments.

  • Network and usage information: IP address, language, webpage location and title, webpage request type, click events and other browsing information, brief information on problems that occurred during usage, problem description and attachments, and cookie data. Learn more about how we use cookies in the Huawei cookie policy.

If you are member of developer’s team account, the following additional data is collected and processed:

  • Account information, such as your HUAWEI ID account name and email address.

  • Service usage information, such as service use and issues or questions that you submit.

  • Network information, such as your IP address.

  • Information related to the team account you are a member of, such as your role and the rights granted to you by team admin

2 How do We Use Your Data?

To provide you with the HUAWEI Developer service and fulfill contractual obligations, we will use and process your personal data so that you can make, upload, manage, distribute, and monitor your apps within our ecosystem. This also requires us to process your data for registration and verification, settlement, promotion and billing, identification of products for publication and distribution to end users, customer relationship management, support and communication, software and system updates, agreement management as well as for problem diagnosis and fixing. If you are a member of a team account, we also process personal data related to your team and your role in order to provide you the team account function.  

In addition, we use your personal data for the following purposes based on the contracting entity’s legitimate interest (If your Products are distributed in the country(ies) or region(s) listed in Part 2 of Exhibit A) or your consent(If Your Products are distributed in the country(ies) or region(s) listed in other regions)pursued by us:

  • Analytics and development purposes: This enables us to understand our users' needs as customers and to improve the quality and the user experience of our current and future services and offerings. You can object to such processing as described in Section 5.5 below.

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

  • Information security purposes: This enables us to detect or prevent various types of misuse of services and fraud in order to provide you with secure and reliable services.

We may send you emails to inform you about new and/or enhanced functions or features available to developers on the website, when you have given consent during registration on the Huawei Developer website. You can at any time withdraw your consent as described in Section 5.5 below.

We also process your financial and identification information for tax and accounting purposes as required by the laws and regulations applicable to us.

3 How Long do We Store Your Data?

We 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. When you delete your HUAWEI ID account, personal data related to your account and associated services, such as HUAWEI Developer service will be erased. However, we retain:

  • Your financial and identification information for seven (7) years from the date you deleted your HUAWEI ID account for accounting purposes.

  • Personal data processed for customer relationship management such as data subject requests, complaints and customer interaction records up to six (6) years from the last interaction.

  • Personal data processed for contract management purposes up to three (3) years after your HUAWEI ID has been deleted.

  • Personal data that is used for analytics and development purposes for up to 14 months from the date of collection, unless you have objected to such processing.

  • Your identification document (copy of passport or identity card and bank card) as an individual developer and business license as an enterprise developer, will be removed after your developer account has been deleted.

  • Backups and app logs, which are processed for ensuring the security of your data and services, for up to 6 months from the date they were captured.

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

4 Do We Share Your Data?

As to individual developers, if you are in:

  • Japan, Korea, Europe or North America, your data will be stored in data centers located in the EU/EEA.

  • Russia, your data will be stored in data centers located in the Russian Federation.

  • Africa, Latin America, Oceania, or Central, South, South East, Western, and Northern Asia, your data will be stored in data centers located in Singapore and Hong Kong (China), and can be accessed for maintenance from China and India.

If you use the team account function, your team member list, which includes information on e.g. your HUAWEI ID and your role in the team, will be stored in data centers located in China. The data centers are operated by our suppliers working under contract and acting on behalf of us.  

If you use the team account function, your personal data related to the team account may be shared to the admin of your team, as well as other team members, depending on the rights they have been granted by the team admin.

As to enterprise developers, if you distribute your products outside of Mainland China, your data will be stored in data centers located in China.

Our business operations such as marketing, surveys, sales promotion and business development as well as customer support may require processing of your personal data by our suppliers operating under contract and acting on behalf of us as a data processor located outside the EU/EEA and/or Russian Federation.

For verification, settlement, tax, and accounting purposes, we will transmit your contact and financial information to a Huawei Group company in China that operates under contract and acts on our behalf.

For customer support and troubleshooting purposes, we will transmit your developer ID, country ID, diagnostics information, problem description and attachments, and IP address to a Huawei Group company in China that operates under contract and acts on our behalf.

For product management and display purposes, we will transmit your product management information to a Huawei Group company in China that operates under contract and acts on our behalf.

We share your data:

  • When required in response to a legal process or request from a competent authority based on an applicable law or in connection with a legal proceeding or process.

  • When you distribute your products inside Mainland China, we will disclose your identification, financial, and product management information with your contracting entity in China (i.e. Huawei Technology Software Co., Ltd.).

  • When required as part of a merger, acquisition, sale of assets (such as service agreements), or transition of service to a Huawei Group entity or other company.

If your products are distributed in the country(ies) or region(s) listed in Part 2 of Exhibit A,when we transfer or disclose your HUAWEI Developer data outside the EU/EEA, where local laws may not provide the same level of protection, we comply with applicable legal requirements for providing adequate safeguards by incorporating the EU Commission standard data protection clauses into such transfer or disclosure. If you want to obtain a copy of the actual signed standard data protection clauses, please contact us​. 

We respect Hong Kong(China) Personal Data (Privacy) Ordinance and, if your products are distributed in the country(ies) or region(s) listed in Part 3 of Exhibit A, we are committed to complying with Hong Kong(China) Personal Data (Privacy) Ordinance requirements when we transfer personal data outside Hong Kong(China).

5 What are Your Rights and Choices?

You have the following rights and choices:

5.1 Access your data

To request a copy and a description of your personal data that we have collected and stored in relation to HUAWEI Developer, access the HUAWEI Developer portal from your computer, click Log in and log in to your HUAWEI ID, then go to Settings > HUAWEI ID > Privacy Center > Request your data.

For additional access request, 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 HUAWEI Developer portal.

5.3 Port your data

To port the personal data that you have provided to us in relation to HUAWEI Developer in a commonly-used and machine readable format, access the HUAWEI Developer portal from your computer, click Log in and log in to your HUAWEI ID, then go to Settings > HUAWEI ID > Privacy Center > Request your data.

You can request your product package by contacting us.

5.4 Erase your data

You may at any time:

  • Delete your HUAWEI ID. As a result, your personal data will be erased. If you have products, then you will need to first delete the products from your developer account before deleting your HUAWEI ID to have all your personal data stored within the HUAWEI Developer service deleted. Contact us if you have any difficulty removing your information.

  • Object to the processing of your personal data, as described in Section 5.5. As a result we will erase the data in scope of a valid objection, if we no longer have legal basis to continue the processing.

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

We will erase or anonymize your personal data within a reasonable period of time based on your aforementioned actions and in accordance with the retention periods as described in Section 3.

5.5 Withdraw your consent

If you opted to receive electronic direct marketing from us, you can withdraw your consent by going to Console > Settings > Profile and unchecking I agree to receive promotional offers from HUAWEI Developer. Then, you will not receive promotional offers' from Huawei Developer.

5.6 Object processing

If you want to object to the processing of your data for analytics, 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 your HUAWEI ID.

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

5.7 Restrict processing

If you want to restrict the processing of your personal data, please contact us. You have the right to restrict the processing of your data under 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 requested us to keep your data when we would not keep it otherwise.

  • Your request for objection is subject to the pending of our verification process.

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

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

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 data subject's rights under Section 5.If you have any questions 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​. 

For product distributions in the country(ies) or region(s) listed in Part 1 of Exhibit A, your contracting entity and data controller will be Huawei Technology Software Co., Ltd. (NO. 101, Software Road, Yuhuatai District, Nanjing P. R. China). 

For product distributions in the country(ies) or region(s) listed in Part 2 of Exhibit A, your contracting entity and data controller will be Aspiegel Limited. (1F, Simmonscourt House, Ballsbridge, Dublin, D04 W9H6 Ireland. Registration number 561134). 

For product distributions in the country(ies) or region(s) listed in Part 3 of Exhibit A, your contracting entity and data controller will be Huawei Services (Hong Kong) Co., Limited. (Room 03, 9/F, Tower 6, The Gateway, NO.9 Canton Road, Tsim Sha Tsui, KL). 

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 your data protection authority, 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 from the HUAWEI Developer portal settings as we may update it in due course. 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.

Latest update: September 1, 2019

 

Exhibit A – List of Countries/Regions 

HUAWEI reserves the right to update this List from time to time. 

No. Countries/Regions
Part 1 Mainland China
Part 2 Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Republic of Ireland, Italy, Latvia, Lithuania, Luxembourg, Republic of North Macedonia, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Netherlands, Iceland, Liechtenstein, Norway, United Kingdom, Switzerland, Montenegro, Albania, Serbia, Bosnia and Herzegovina, Vatican City, Malta, Moldova, Israel, Netherlands Antilles, Andorra, Monaco, San Marino, Faroe Islands, Gibraltar, Greenland, Guernsey, Isle of Man, Jersey, Sint Maarten, Saint Martin, Saint Pierre and Miquelon (France), Caribbean Netherlands, Aland Islands, Japan, South Korea, Vietnam, India, Bangladesh, Cambodia, Laos, Myanmar, Nepal, Papua New Guinea, Philippines, Singapore, Sri Lanka, Taiwan(China), Thailand, Fiji, Samoa, Tonga, Vanuatu, Indonesia, Solomon Islands, Brunei, Maldives, Bhutan, Kiritimati, Cocos (Keeling) Islands, Cook Islands, French Polynesia, Guam, East Timor, Kiribati, Marshall Islands, Micronesia, Nauru, New Caledonia, Niue, Norfolk Island, Northern Mariana Islands, Palau, Pitcairn Islands, Tokelau, Tuvalu, Wallis and Futuna, American Samoa, Bolivia, Colombia, Costa Rica, Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Jamaica, Mexico, Nicaragua, Panama, Paraguay, Peru, Uruguay, Venezuela, Chile, Puerto Rico, Aruba, Bahamas, Barbados, British Virgin Islands, French Guiana, Grenada, Haiti, Saint Lucia, Saint Vincent and the Grenadines, Suriname, Trinidad and Tobago, Belize, Antigua and Barbuda, Bermuda, Anguilla, Guyana, Martinique, Saint Kitts and Nevis, Turks and Caicos Islands, Cayman Islands, Dominica, Guadeloupe, Montserrat, Saint Barthelemy, Malvinas (Falkland Islands), United States Virgin Islands, Algeria, Bahrain, Cameroon, Chad, Côte d'Ivoire, Egypt, Iraq, Jordan, Kuwait, Mali, Oman, Pakistan, Qatar, Saudi Arabia, Senegal, United Arab Emirates (UAE), Yemen, Republic of Congo (Congo), Benin, Burkina Faso, Equatorial Guinea, Ethiopia, Gabon, Lebanon, Libya, Mauritania, Morocco, South Sudan, Togo, Afghanistan, Central African Republic, Cape Verde, Democratic Republic of the Congo (DRC), Djibouti, Eritrea, Gambia, Guinea-Bissau, Niger, Guinea, State of Palestine, Saint Helena, Ceuta and Melilla, Canary Islands, Angola, Botswana, Comoros, Ghana, Kenya, Liberia, Lesotho, Mayotte, Madagascar, Malawi, Mauritius, Mozambique, Nigeria, Namibia, Reunion, Sierra Leone, Somalia, Swaziland, Sao Tome and Principe, Seychelles, South Africa, Tanzania, Uganda, Zambia, Zimbabwe, Burundi, Rwanda, Belarus, Georgia, Armenia, Azerbaijan, Mongolia, Kazakhstan, Turkmenistan, Uzbekistan, Kyrgyzstan, Tajikistan, Ukraine, Russia, Turkey, Brazil, Argentina; 
Part 3 Hong Kong(China), Macau(China), and Malaysia.