Statement Regarding HUAWEI Developer and Privacy

March 24, 2020

HUAWEI Developer provides a range of services and resources for you to develop, distribute and promote your apps, games and themes (hereinafter referred to as "products") throughout their lifecycles within the ecosystem of HUAWEI Developer.

If your products are distributed in the Chinese mainland in accordance with Part 1 of Exhibit A – List of Countries/Regions (“Exhibit A”), Huawei Software Technologies Co., Ltd., a subsidiary of Huawei incorporated in the People's Republic of China, will serve as 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 serve as 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 incorporated in Hong Kong(China) will serve as your contracting entity and data controller.

This Statement covers the following topics:

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. How do we update this statement?

1 What data do we collect about you?

As part of the HUAWEI Developer services we will collect and use your personal data only for the purposes stated in this Statement. The "personal data" herein refers to any information that enables us to identify you as a user of the HUAWEI Developer services.

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

If you are an individual developer:

  • Identification information: such as legal name, identification document(s) (copy of your valid ID, such as passport, national identity card, or driver's license, and copy of your bank card), nickname, 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, and bank information confirmation letter.

  • Product management information: such as developer name, developer user ID, developer registration account (HUAWEI ID account identifier), developer type, country ID, contact information (phone; number and email address), testing account(s), product package, and related technical information such as signature key, product comments and feedback.

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

  • Product management information: developer name, developer user ID, developer registration account (HUAWEI ID account identifier), developer type, contact information (phone number and email address), testing account(s), product package, and related technical information,  such as signature key, product comments, and feedback.

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

If you are a 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; and

  • Information related to your team account, such as your role and the rights granted to you by the team admin.

If you are using remote device testing function:

  • All testing data of your app that you have installed on the remote virtual or physical devices hosted by us.

2 How do we use your data?

To provide you with the HUAWEI Developer services and fulfill contractual obligations, we will use and process your personal data so that you can distribute, manage, and monitor your apps within our ecosystem, and use other HUAWEI Developer services, such as SDKs, APIs, Kits and testing platforms. This requires us to process your data for registration and verification, accounting, and billing promotion, partner relationship management, support and communication, software and system updates, contract management, team management, and remote device testing. We will also process your personal data in order to diagnose and resolve various problems. If you are a user of a team account, we also process personal data related to your team and your role, in order to provide you with the team account functions.

In addition, we use your personal data for the following purposes based on the contracting entity’s legitimate interests (if your products are distributed in the country(ies) or region(s) listed in Part 2 of Exhibit A) ,or on the basis of your consent (if your products are distributed in the country(ies) or region(s) listed in Part 1 or Part 3 of Exhibit A):

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

  • Promotion and marketing purposes:This enables us to communicate with you about our offerings and create aggregated marketing targets. Knowing users' preferences allows us to target our offers and offer products and services that better cater to the needs and desires of our users. You can object to such processing, as detailed in Section 5.5 below.

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

We may send you emails to inform you of new and/or enhanced functions or features available to developers on the website, if you have given consent for such communications during registration on the HUAWE Developer website. You can withdraw such consent at any time, as detailed in Section 5.5 below.

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

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, any and all personal data related to your account and associated services, such as HUAWEI Developer services, will be erased. However, we retain:

  • Your financial and identification information for seven (7) years as of the day when 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, for up to six (6) years from the last interaction;

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

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

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

  • Backups and app logs, which are processed to ensure the security of your data and services, for up to six (6) months from the day when they were captured.

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

4 Do we share your data?

4.1 Data storage location

If you are an individual developer and located in:

  • Japan,  South Korea, Australia, New Zealand, Turkey, Europe, or Canada, 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 (excluding Australia and New Zealand), or Central, South, Southeast, Western, and Northern Asia, your data will be stored in data centers located in Singapore and/or Hong Kong (China), and can be accessed for maintenance from China or India.

If you use the team account functions, 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 contracted suppliers that work on our behalf.

If you are an enterprise developer, your data will be stored in data centers located in China.

4.2 Data sharing

Our business operations, such as marketing, surveys, sales promotion and business development, as well as customer support, may require that our contracted suppliers process your personal data, acting on our behalf as data processors, located outside the EU/EEA and/or Russian Federation.

For verification, partner management, product management, and accounting purposes, we will transmit your contact information, product information, 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 contact information, diagnostics information, problem description and attachments to a Huawei Group company in China that operates under contract, and acts on our behalf.

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

We may also share your data:

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

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

When you distribute your products in the Chinese mainland, we will disclose your identification, financial, and product management information with your contracting entity in China (i.e. Huawei Software Technologies Co., Ltd.).

In addition, as described above your personal data may be transferred, processed and stored outside of your country of residence and therefore it may be available to government authorities under lawful orders and laws applicable also in those countries.

4.3 Safeguards used in data transfers

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 data protection, we comply with applicable legal requirements for providing adequate safeguards by incorporating the EU Commission standard data protection clauses into  such transfers or disclosures. 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 of 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 HUAWEI Developer portal with your HUAWEI ID. Go to Settings > HUAWEI ID > Privacy Center > Request your data.

For additional access requests, please contact us.

5.2 Rectify your data

To keep your data up-to-date and accurate, 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 HUAWEI Developer portal with your HUAWEI ID. Go to Settings > HUAWEI ID > Privacy Center > Request your data.

For your product package, please contact 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 delete the products from your developer account before deleting your HUAWEI ID, in order to have all your personal data stored within the HUAWEI Developer services deleted. Contact us if you have any difficulty removing your information.

  • Object to the processing of your personal data, as detailed in Section 5.5. As a result, we will erase the data within the scope of a valid objection, if we no longer have legal basis to continue said 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 After doing so, you will no longer 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 a request, please specify the scope of the request and provide us with the email address or phone number that you use 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 otherwise keep it;

  • Your request for objection is pending our verification process; or

  • You have contested the accuracy of your personal data, and the accuracy of your data is pending our verification process;

When submitting your request, please specify the scope and basis of the request, and provide us with the email address or phone number that you use 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 information about how to exercise your data subject's rights in Section 5. If you have any questions on your rights as a data subject, or how we process your personal data, or if you would like 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 Software Technologies 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, Kowloon, Hong Kong, P.R. China).

If you believe that we are not processing 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 recommend that you regularly check for the latest version of this Statement from the HUAWEI Developer portal 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 other methods, depending on the nature of the change.

Latest update: March 24, 2020

 

Exhibit A – List of Countries/Regions