Statement About AppGallery and Privacy

Last updated: January, 2020

AppGallery is a service provided by Huawei Services (Hong Kong) Co., Limited, a subsidiary of Huawei incorporated in Hong Kong (hereinafter referred to as "we", "us", or "our"). It provides you with a distribution platform where you can browse, access, download and manage free and paid apps.

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 AppGallery 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, and account identifier service token.

Device information, such as device identifier (such as SN, UDID or IMEI, depending on your device system version), language settings, device model, device operating system version and ROM version, screen size and resolution, mobile country code, delivery country.

Network information, such as IP address, network type, and network connection status.

Service usage information, such as AppGallery version number and download source, app usage duration, app click and exposure times, app search history, app download and installation history and results, app login results, installed app information (such as categories and version), list of uninstalled apps, app purchase order amount, order time, order ID, list of installed apps, user award (gifts) record, app comments, user agreement signing record, app promotion channel ID, link to app webpage, and wishlist apps.

Game Services information, such as Player ID, rankings, achievements, player stats, and game usage data which we receive from the provider of the game app that you are playing.

If you win a prize during one of HUAWEI AppGallery's promotions, your delivery address and phone number/email address will be processed to deliver the prize to you.

If you use HUAWEI AppGallery in the visitor mode (without logging in with your Huawei ID account), the following data is collected and processed:

Device information, such as device identifier such as SN, UDID or IMEI depending on your device system version, language settings, device type, device operating system version and ROM version, screen size and resolution, delivery country.

Network information, such as IP address, mobile country code (MCC), mobile network code (MNC), network type and network connection status

Service usage information, such as AppGallery version number, app open and close time, clicks, exposure, app search history, app download and installation history, installed app information (such as categories and version), list of installed apps, operation logs and error logs, app promotion channel ID, link to app webpage, and user agreement signing record.

To provide you with necessary services, AppGallery requires permissions to access your phone to obtain device information, and your storage to manage installation packages. You can also manage permissions in your device settings.

2. How do We Use Your Data?

To provide you with AppGallery services and fulfil contractual obligations, we require the collection of your personal data so that you can browse, access, download, manage your apps, and enjoy game-related features. This also enables us to process your data for identification, settlement, customer relationship management, support and communication, customer complaint handling, maintenance, system updates, problem diagnosis and fixing.

In addition, we use your personal data for the following purposes with your consent:

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 5.6 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 5.6 below.

We may process your personal data for personalising services by providing recommendations and by displaying targeted apps in AppGallery. You can object to such data processing as described in Section 5.6 below.

If you have HUAWEI Ads personalisation enabled on your device, your installed apps categories (such as games, social media, sports), will be used for serving you more relevant ads on HUAWEI Mobile Services and third party apps by the HUAWEI Ads platform. For more information about HUAWEI Ads and about your rights, click here (https://consumer.huawei.com/ minisite/cloudservice/ad/ privacy-statement.htm?country=HK&language=en-gb).

Information security purposes, including detecting or preventing various types of misuse of services and fraud in order to provide you with secure and reliable services.

If you enable Game Services within a third-party game app, and have authorised the app to obtain your Game Services data (Player ID, rankings, achievements, and player stats), your Game Services data will be disclosed to the third-party game app. You can withdraw such authorisation at any time by going to Settings > HUAWEI ID > Privacy centre > Control account access on your device.

If you comment on an app available in AppGallery, we will be disclosing your comment and nickname to the app developer to help improve the service based on your feedback and ratings.

When you are using HUAWEI AppGallery while logged in with your HUAWEI ID, we may send push notifications to your device to inform you about newly available apps, events, and gift-related activities, after you have given consent in the AppGallery app. You can withdraw your consent at any time by going to AppGallery > Me > Settings, and disabling Notifications.

We may also process your app purchase order amount, order time and order ID for tax and accounting purposes as required by laws and regulations applicable to us.

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 AppGallery app, will be erased. However, we shall retain:

App purchase order amount, order time, and order ID for seven (7) years from the date the payment was made.

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.

Your address and phone number/email address for one (1) year after the prize has been sent to you.

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.

If you disable Game Services, your data will be removed within thirty (30) days unless there are applicable legal grounds for continuing the processing of the data as described above. When using the service in the visitor mode, your network information and usage information will be processed for seven (7) days.

Once the retention period expires, we will delete or anonymise 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 centres located in Hong Kong (China) and Singapore.

Our maintenance operations may require us to access your data from India and China. In addition, your data may also be processed by our customer care centres located, for example, in Mexico, Egypt, South Africa, Saudi Arabia, Pakistan, Myanmar, India and Malaysia, depending on your location.

We only share your data:

When you comment on an app available in AppGallery, your comment, nickname, device model and time of the comment will be disclosed to the app developer to improve service and/or fix issues.

When you enable Game Services and authorise a third-party game app to process your Game Services information, your player ID, rankings, achievements, purchases, and player stats will be disclosed to the third-party game app to provide you with the game features and improve your gaming experience.

When you choose to save you Game Services data on your Cloud, and you have switched the service country/region in AppGallery, the in-game data you saved may then be disclosed to other subsidiaries of Huawei, which provide you with the Cloud services and are located either in China or Ireland (https://cloud.huawei.com/privacyStatementTransit), depending on your HUAWEI ID registration country/region.

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.

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.

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 AppGallery by going to Settings > HUAWEI ID > Privacy centre > Request your data on your device.

For additional access request, including requesting copy of your data when you are using AppGallery in the visitor mode, please contact us (https://consumer.huawei.com/ uk/legal/privacy-questions).

5.2 Rectify your data

To keep your data up-to-date and accurate, you can access and modify your data by going to Settings > HUAWEI ID.

You can access and modify your delivery information by going to AppGallery > Me > Settings > Delivery information.

5.3 Port your data

You can port the personal data that you have provided to us in relation to AppGallery in a commonly-used and machine readable format by going to Settings > HUAWEI ID > Privacy centre > Request your data, on your device.

You can also port your personal data that you have provided to us in AppGallery, when using the service in the visitor mode, in a commonly-used, machine-readable format by contacting us.

5.4 Erase your data

You may at any time:

Delete your app download and installation history, and purchase records by going to AppGallery > Me > Purchase history.

Delete your gifts records by going to AppGallery > Me > Gifts.

Delete the apps in the wishlist by going to AppGallery > Me > Wishlist.

Delete your delivery information by going to AppGallery > Me > Settings > Delivery information.

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 AppGallery.

Object to the processing of your data, as described in Section 5.6. If your objection is valid, and we no longer have legal basis to continue processing your data, we will erase the relevant data within your effective objection.

Contact us (https://consumer.huawei.com/ uk/legal/privacy-questions) if you think the processing of your personal data is unlawful and your data should be erased.

We will erase or anonymise 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 have opted to receive electronic direct marketing from us, you can withdraw your consent by going to AppGallery > Me > Settings, and disable Receive notifications.

If you have authorised third-party game apps to receive your Game Services information, you can withdraw your consent by going to the Settings > HUAWEI ID > Privacy centre > Control account access.

5.6 Object to processing

If you want to object to the processing of your data for analytics, recommendations, development or sales and marketing purposes, please contact us (https://consumer.huawei.com/ uk/legal/privacy-questions).

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, if you used the service in the logged in mode, or your device identifier if you have been using the AppGallery in the visitor mode.

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 (https://consumer.huawei.com/ uk/legal/privacy-questions). 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 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 (https://consumer.huawei.com/ uk/legal/privacy-questions).

Our headquarters' address: Huawei Services (Hong Kong) Co., Limited, Room 03, 9/F, Tower 6, the Gateway, No. 9 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong. Registration number 1451551.

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 Privacy Commissioner for Personal Data in Hong Kong.

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.

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