Statement About Referral Program and Privacy(EU)

Last modified: August 20, 2021

Referral Program (Ambassador Program) is a service provided by Aspiegel SE, a subsidiary of Huawei incorporated in Ireland (hereinafter referred to as "we", "us", or "our"). It provides you with the possibility to become Aspigele’s Referral, promoting via your social media publications AppGallery campaigns and services.

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 Referral Program 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.

We shall collect and process the following data:

• HUAWEI ID account information, such as account name (email or telephone number), profile picture, nickname, birthday, country/region, account identifier, account identifier service token.
• Developer account information, such as Developer ID.
• Network information, such as IP address.
• Referral information, such as the number of your followers, social media account information (address), screenshots of your pages.

2. How Do We Use Your Data?

To provide you with Referral program services and fulfill contractual obligations, we require the collection of your personal data so that you can register as an Referral, get the links that shall be promoted, and get the shared revenue This also enables us to process your data for identification, customer relationship management, support and communication, customer complaint handling, maintenance, problem diagnosis and fixing. 

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

• Analytics and development purposes, including creating aggregated groups based on different user groups' usage activity. This also enables us to understand our users' needs as customers and to improve the quality and user experience of our current and future services and offerings, as well as assess the effectiveness of campaigns and promotions. You can object to such data 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 user’s preferences enables us to target our offers and offer products and services that better meet the needs and desires of our user’s. You can object to such data processing as described in Section 5.5 below.
• Information security and fraud prevention purposes, including detecting or preventing various types of misuse of services and fraud, in order to provide you with secure and reliable services.

For the processing of your Huawei Developer Data, you can find necessary privacy information in the Statement About HUAWEI Developers and Privacy.

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 throughout the duration of your customer relationship with us. If you delete your HUAWEI ID account, all personal data and services associated with your account, including the Referral program service, will be erased. However, we shall retain:

• 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 has been deleted.
• Personal data processed for statistical analysis and product development as well as sales promotion and marketing purposes for up to 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 for up to six (6) months from the date they were created.
• Once the retention period expires, we will delete or anonymize 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 centers located in the EU/EEA.

Our third-party vendors, who provide us with IT (including cloud-based) services, business support, and customer care services, may need to process your information. All such third parties are operating under contract and acting on behalf of us, and are located in the EU/EEA, unless you are using the service in the following countries:

• Canada, in which case we may share your personal data to customer service centers located in Mexico and provided by our supplier operating under contract and acting on behalf of us.

• Australia or New Zealand, in which case we may share your personal data to customer support services located in Malaysia and Singapore, as well as to business support entities located in the United Kingdom, Malaysia, and Singapore all operating under contract and acting on behalf of us.

We only share your data:

• When required 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. In the case of users in Canada, this means that the personal data transferred, processed, and stored outside of Canada may be available to government authorities under lawful orders and laws applicable there.
• 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 another company.

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 by incorporating the EU Commission standard data protection model clauses to such transfers. If you want to obtain a copy of the actual signed standard data protection model clauses, please contact us.

5. What Are Your Rights and Options?

You have the following rights and options:

5.1 Access your data

You can request a copy and a description of your personal data that we have collected and stored in relation to the Referral program by contacting us.

5.2 Rectify your data

To keep your data up-to-date and accurate, you can access and modify your HUAWEI ID data by going to HUAWEI ID account center or going to referral program page on AGC to modify impact proof documents.

5.3 Port your data

You can port the personal data that you have provided to us in relation to the Referral program in a commonly-used and machine readable format by contacting us.

5.4 Erase your data

You may at any time:

• Delete your HUAWEI ID account. As a result, all personal data and services associated with your HUAWEI ID account will be erased, including your personal data in The Referral program.
• 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 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 Object to processing

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

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.
• You have contested the accuracy of your personal data and the accuracy of your data is pending our verification.
• Your request for objection is subject to the pending of our verification process.

When making the request, please specify the scope and the grounds for 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 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: Aspiegel SE, First Floor, Simmonscourt House, Simmonscourt Road, Dublin 4, D04 W9H6, 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 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.