Statement About Partner Communications and Privacy

Last modified: October, 2022

Huawei Mobile Services are provided by Aspiegel SE, a subsidiary of Huawei incorporated in Ireland (hereinafter referred to as "we", "us" or "our"). This Statement describes the processing we carry out in relation to the business cards, other contact information and feedback we receive from our partners and prospects when registering to and during conventions, conferences, workshops and other events as well as information we receive from our websites or third party websites such as through contact forms filled in by prospects. This Statement also describes how we process data that we obtain from other sources, such as from third parties or publicly available websites of our partners and potential partners, for the purposes of contacting them in order to propose business cooperation.

1 What data do we collect about you?

We process the personal data that you provide to us during an event, sales activity, meeting or on our websites or third party websites such as in LinkedIn when you fill in a contact form. Depending on what you choose to share with us, the personal data we process may include e.g. your name, professional title, phone number, email address, IM account, country, gender, the name of the company you represent and other possible information included in your business card or form that you fill in. The data may also include possible feedback or other comments you provide to us during the event or sales activity.

We may also process information you have made publicly available (such as your name, contact information, gender and public information relating to your product) e.g. in your websites or in connection with your products being distributed in various platforms or data, such as your contact information, that we obtain from other sources or third party data vendors.

If you register to our events, the registration data, such as your contact information, is used for the purposes of managing and organizing the event. The photographing and video recording practices for each event will be communicated separately before and/or during the event.

2 How do we use your data?

We process the personal data of individuals 1) who choose to share their contact information, feedback or other similar information with us; or 2) that is made publicly available in their websites or in other platforms or otherwise obtained by us or third party data vendors, in order to fulfil our legitimate interest to facilitate communications with our partners and prospects, including sending emails and other messages, and to market our products, services, events and cooperation opportunities that may be of interest to the partner or prospect. We will ask your prior consent for receiving communications from us when required by applicable local laws. You can opt-out from receiving communications from us in accordance with Section 5.

3 How long do we store your data?

We will retain your personal data for up to 2 years after the event where you have provided us the data or after two years of inactivity. In case you wish or do not wish to receive communication from us, we will retain your marketing consents and opt-out logs for up to 7 years. 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?

The location where we store the data provided by you depends on the location of the event where you provided the data to us:

•If the event was held in the EU or the European Economic Area (EEA), we store your data within the EU or EEA.

•If the event was held outside the EU or EEA, we may store your data in the country or region where the event was held or elsewhere in the EU or EEA, such as Singapore.

The data collected about you from other sources for the purposes of this Statement is stored, as a main rule, within the EU/EEA, but may also be stored and processed outside the EU/EEA in the country where you are located.

In addition, we share your data:

•When our third party vendors need to process your personal data in order to provide us data center, consent management, and email marketing tools and services. All such third parties are operating under contract and acting on behalf of us.

•When required in response to a legal process or request from a competent authority based on 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 transition of service to a Huawei group entity or other company.

In case we transfer your personal 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.

Please note that when you use third party social media platforms such as LinkedIn, your personal data will be processed and shared in accordance to their privacy policy.

5 What are your rights and choices?

You have the following rights and choices:

•Access your data – You can request information and a copy of personal data that we have collected and stored about you in accordance with this Statement.

•Rectify your data – You can request rectification of your personal data that is not accurate. When making the request, please specify the scope of the data that you want to rectify.

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

•Erase your data – You can contact us to request the deletion of your data if you e.g. think that the data is no longer necessary for the purposes described in section 2 above, or that the processing of your personal data is unlawful. We will erase or anonymize your personal data without undue delay, unless we have a legal obligation or right to retain the data.

•Withdraw your consent – If you have opted to receive direct marketing from us, you can withdraw your consent by replying directly to the message you received from us that you do not wish to receive such messages anymore, using the unsubscribe function in the message, or changing your consent settings on any given third party service you have consented on, depending on the communications scenario.

•Object to processing – You can object to the processing of your personal data where we process it on the basis of our legitimate interest in accordance with section 2 above. You can opt-out and unsubscribe from receiving direct marketing from us by replying directly to the message you received from us that you do not wish to receive such messages anymore or by using the unsubscribe function in the message, depending on the communications scenario.

•Restrict processing – You have the right to restrict the processing of your personal data under certain circumstances, such as when your data is processed unlawfully but you do not want to erase it, or when your request for objection is pending our verification.

•Lodge a complaint with supervisory authority – If you think that we are not processing your personal data in accordance with this notice or applicable data protection laws, you can lodge a complaint with your data protection authority, or the Data Protection Commissioner in Ireland.

You can exercise your rights by contacting us in accordance with section 6 below. When making the request, please specify the scope and the grounds for your request. We may 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..

7 How do we update this statement?

We encourage you to regularly check for the latest version of this Statement 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 so on, depending on the nature of the change.