Statement About Customer Support and Privacy
Last updated: June 2023
Huawei Mobile Services are provided by Aspiegel SE, a subsidiary of Huawei incorporated in Ireland (hereinafter referred to as "we", "us", or "our"). This Privacy Statement applies to the processing of your personal data when we provide customer support services and/or when you provide feedback on our services. Our customer support may be contacted for example through online forms, live chat and email. If you contact Huawei group customer support, the separate privacy statement of such Huawei customer support channel shall apply.
This Statement describes:
1. What Data do We Collect About You?
3. How Long do We Store Your Data?
7. How do We Update this Statement?
1 What Data do We Collect About You?
As part of providing customer support services related to our products and services 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 or as an individual (e.g. a potential user/customer).
We shall process the following categories of personal data depending on your customer support query or feedback:
•Account information such as Huawei ID (phone number/email address), security email address, security phone number, direct marketing and other consents, withdrawals, objections and restrictions, security events (e.g. password changes, account deletions, app authorisation cancellations, account freezing) as well as user agreement information.
•Contact details such as name, email address, phone number and home address.
•Device information such as device identifier (IMEI or UDID, depending on your device system version), serial number, country/region code, language setting, device type and name, version number, operating system and ROM version.
•Customer support services correspondence and feedback such as a record of your queries and replies provided via different channels, screenshots and other documentation provided related to your queries, data subject rights’ related requests and execution records of such rights as well as feedback and comments.
•Service usage, campaign and network information such as such as IP address, Service ID, registration log, login/logout, time stamps of usage activities, application log, marketing campaign records and other records related to using the services and/or participating in campaigns to the extent needed to handle your query and solve your issue.
•Payment information such as order ID, payment method information, payment transaction and reimbursement records.
We collect the personal data mainly from you and from your correspondence with us, but we may also receive your queries via Huawei group common web-portals as well as from other Huawei group entities and from Huawei Data Protection Officer, if they request our assistance or transfer your matter to be handled and replied by us in case that your query relates to our services and/or personal data processing. We may also collect “voice of customer” and other feedback about our services from comments posted on our apps, from social media channels or other publicly available online sources. We remove direct identifiers (e.g. email addresses and phone numbers) from such data.
2 How do We Use Your Data?
To provide you with customer support services related to our products and services, and to fulfill contractual obligations, we process your data for customer support purposes such as;
•Handling and responding to queries as well as assisting you in using our services
•Investigating and managing complaints as well as data breach notifications
•Technical customer support e.g. troubleshooting, identifying, examining and fixing errors and malfunctions
•Executing data subject’s rights requests and verifying your identity
•Handling reimbursements and refunds or other compensations as well as defending claims
The above mentioned processing of your personal data is based on your contract with us regarding use of any of our products and services. However, if you are not yet our customer, but contact our customer support e.g. as a prospect customer to query general information on our services and products, we will process your personal data that you share with us based on legitimate interests pursued by us in order to handle your query.
In addition, we use your personal data for the following purposes based on legitimate interest pursued by us:
•Analytics and development purposes. This enables us to provide reliable and good quality customer support services, improve the quality and user experience of our current and future products, services and offerings as well as to develop services and products that meet our customers’ needs and expectations.
•Information security purposes, including detecting or preventing various types of misuse of services and frauds to provide you with secure and reliable services.
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 shall retain:
•Personal data processed for customer support purposes such as data subject requests, complaints and customer interaction records for up to six (6) years from the last interaction.
•Feedback, suggestions and comments for up to two (2) years for analytics and development purposes. In addition, service specific retention times defined in the privacy statements of our services apply as to comments submitted by you to each service.
•Backups and logs, which are processed to ensure the security of your data and services or systems, 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 laws and regulations.
4 How Do We Share Your Data?
We share your data in the following ways:
•Our third party vendors, who provide us with IT (including cloud-based) services as well as business support, data protection/privacy and legal services, may need to process your personal data. All such third parties are operating under contract and acting on behalf of us and located in the EU/EEA, unless stated otherwise in this Statement.
•When needed for investigating and solving your issue, we may share your app log data provided by you via “Feedback” or “Problems and Suggestions” –form in our apps and/or description of your issue with Huawei group company in China. However, your contact details or other direct identifiers are not shared. Such company is operating under contract and acting on behalf of us providing technical support and product development services.
•When you contact us via our different support channels, our third party vendors who provide customer support services, may need to process your personal data. All such vendors are operating under contract and acting on behalf of us and located in the EU/EEA except, if you are a user in Turkey, the local customer support vendor will process your personal data in Turkey and Singapore.
•When you contact our customer support via email, the email and related data may be routed through servers in Chinese mainland provided by a Huawei group company operating under contract and acting on behalf of us. We have different available routing options to ensure successful communications. The actual emails will be stored in servers located in the UK which European Commission considers to have adequate level of data protection.
•If you are a user in a country outside the EU/EEA, our local business support vendors may need to process your personal data for customer support purposes outside the EU/EEA in the country where you are located in.
•If you are using services from Canada, your personal data, as described above, is transferred, processed, and stored outside Canada and therefore may be available to government authorities under legal orders and applicable laws in the local jurisdiction
•If you contact us on a matter that relates to another Huawei group entity, we may transfer your query and disclose also your contact details to the correct Huawei entity, so that they can handle matter and reply to you.
•When required in response to a legal process or request from a competent authority according to an applicable law or in connection with legal proceeding or process.
•When required as part of a merger, acquisition, sale of assets (such as service agreements) or transitions of service to a Huawei group entity or other company.
When transferring and disclosing your data outside the EU/EEA, where the local law may not provide the same level of protection, we shall comply with applicable legal requirements for providing adequate safeguards to such transfers by incorporating the European Commission's Standard Contractual Clauses (SCC). If you want to obtain a copy of the actual signed SCC, please contact us.
5 What are Your Rights?
You can contact us to exercise any of the following rights regarding your personal data:
-Access your data
-Rectify your data
-Port your data
-Erase your data
-Restrict processing of your data
-Object processing of your data that is based on legitimate interests
Please inform us on the scope of your request and what right you would like to exercise. We will contact you to verify your identity in order to proceed with your request.
6 How to Contact Us?
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, 3rd floor, Mespil Court, Mespil Road , Ballsbridge, Dublin 4, D04 E516, Ireland. Registration number 561134.
If you believe that we don’t 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 on our website 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.
