Huawei Privacy Policy

Dear users,

Huawei Device Co., Ltd. and its worldwide corporate affiliates ("Huawei", "we", "our" and "us") understand how important your privacy is to you and are fully committed to protecting it. Please do not submit personal or private data to Huawei before you have read, understood and agreed to this Privacy Policy ("this Policy").

We created this Policy to help you understand:

1) How Huawei uses your personal data

2) How Huawei uses cookies and similar technologies

3) How Huawei discloses your personal data

4) How to access or modify your personal data

5) How Huawei protects your personal data

6) How Huawei handles the personal data of children

7) Huawei's third party providers and their services

8) How your personal data is transferred internationally

9) How this Policy is updated

10) International users

## 11. How to contact Huawei

Please note that this Policy applies solely to Huawei consumer electronics, including feature phones, smartphones, tablets, home devices, data cards, computer applications, tools, software, websites and services that display or refer to this Policy.

This Policy describes how Huawei handles your personal and private data and affirms its commitment to protecting your privacy. The Policy does not address all possible data-processing scenarios. Information about product- or service-specific data collection is issued by Huawei in supplementary policies. It is recommended that you read both this Policy and any supplements to fully understand Huawei's privacy policies for a specific product or service.

## 1. How Huawei uses your personal data

Personal data is information that can be used on its own or in combination with other information, to identify an individual. Such data is collected when you use Huawei products or services and can include your name, date of birth, address, identity number, telephone number, account number, photo and the location and date when products or services were accessed. Huawei collects and uses your personal data solely for the purposes indicated in this Policy. The following are examples of personal data we may collect and how we use it:

1) Personal data collected by Huawei

We may collect some personal data, including your name, profile picture, phone number, email address, age and location. Below are some examples of the types of personal data we may collect.

a. Data you submit directly: A number of Huawei services allow you to create accounts or profiles. You may be requested to provide account information, such as your email address, delivery address, phone number, product information, time of purchase and method of payment. If you use Huawei services to share content with your friends, we may need you to provide their contact information, including their name, profile picture, phone number and email address. Some Huawei services allow you to communicate and share information with other people. All such communications are secure. If you encounter any errors while using a Huawei device or application, you can choose to send error details to Huawei.

b. Service use data: We may collect system and application data from your devices, including the device name, system and application versions, regional and language settings, device version, device identification number (IMEI, ESN, MEID and SN), geographic location (such as the ID of the area where your device is located), service provider network ID (PLMN), usage habits and IP address. We may also log your service access times, search query terms and the data stored in cookies on your devices.

c. Third party data: We may receive data about you from publicly and commercially available sources as permitted by law. We may also receive data about you from third party social networking services, such as when you log in to our websites using your Facebook or Twitter account.

2) How Huawei uses your personal data

We may use your personal data to:

a. Fulfil purchase orders; deliver, activate, or verify products or services; make changes upon your request; and offer technical support.

b. Contact you; send you information about products and services that may be of interest; invite you to participate in Huawei promotions and market surveys; or send you marketing information with your explicit consent. If you don't want to receive such information, you can opt out at any time.

c. Inform you about operating system or application updates and install them.

d. Offer you a personalized user experience and personalized content and activate your after-sale services.

e. Carry out internal audits, data analysis and research to improve our products and services.

f. Analyse the efficiency of our business operations and measure our market share.

g. Improve customer communications and ensure that provide a secure, quality service to customers.

h. Troubleshoot errors should you choose to send us error details.

i. Synchronize, share and store data you upload or download and data required to implement uploads and downloads.

j. Improve our loss prevention and anti-fraud programs.

3) Location-based services

When you access certain location-based services, for example, when you perform a search, use navigation software or check the weather for a specific location, Huawei may collect, use and process your device's precise or fuzzy location. This is necessary for Huawei to provide the aforementioned services. Huawei may collect your device identification numbers (IMEI, ESN, MEID, and SN), device type, model and real-time location data (obtained through GPS, Wi-Fi and your service provider's network ID). Huawei collects location data to provide and improve its location-based products and services.

We may ask you which applications you want location-based services to be enabled for. You can choose not to share your location data by turning off location-based services on your devices. For detailed information on how to disable location-based services, please contact your network operator.

4) Collection and use of non-identifiable data

Non-identifiable data refers to data that cannot be used to identify an individual. For example, Huawei may collect aggregated statistics, such as the number of visitors to its website. Huawei collects this data to understand how people use its website, products and services. This allows Huawei to improve its services to better satisfy customer needs. Huawei may, at its own discretion, collect, use, process, transfer or disclose non-identifiable data for other purposes.

We endeavour to keep your personal data and non-identifiable data separate, and use each independently. If personal data is combined with non-identifiable data, it will be treated as personal data.

## 2. How Huawei uses cookies and similar technologies

1) Cookies

To ensure that our websites function properly, we sometimes store small data files known as cookies on computers or mobile devices. A cookie is a simple text file that is stored on your computer or mobile device by a web server. Only the server that creates the cookie can retrieve or read the cookie's contents. Each cookie is unique to your web browser or mobile application. Cookies usually contain an identifier, the site name and some numbers and characters. Cookies allow websites to store data, such as your user preferences or the contents of your shopping basket.

Most large websites or Internet service providers enable cookies in order to improve their user experience. Cookies allow websites to remember users, either for a single visit (using a session cookie) or for repeated visits (using a persistent cookie). Cookies allow websites to store settings, such as language, font size and other viewing preferences for your computers or mobile devices. This means that user preferences do not need to be re-configured on each visit. If a website doesn't use cookies, it will treat its users as new visitors each time they open a page. For example, if you log in on a website and move to another page, the website won't recognize you, and you will be logged out again.

Huawei does not use cookies for any purposes other than those specified in this Policy. You can manage or delete cookies according to your preferences. For more information, see AboutCookies.org. You can clear all cookies stored on your computer and most web browsers can be configured to block cookies. However, if you do so, you may have to manually your user settings every time you visit our websites. For more information on how to change your browser settings, please visit the following links:

Internet Explorer

Google Chrome

Mozilla Firefox

Safari and

Opera

2) Web beacons and pixel tags

In addition to cookies, we also use other similar technologies such as web beacons and pixel tags on our websites. For example, when you receive an email from Huawei, it may contain a click-through URL which links to content on Huawei's website. If you click the link, the click-through is tracked by Huawei to help us learn about your product and service preferences and improve our customer service. A web beacon is typically a transparent image that is embedded on a website or in an email. The inclusion of pixel tags in emails allows us to know if our emails have been opened. If you do not want your activities to be tracked in such a way, you may unsubscribe from Huawei mailing lists at any time.

3) Do Not Track

Many web browsers have a Do Not Track feature, which issues Do Not Track requests to websites. Currently, the main Internet standards organization has no policy governing how websites should behave when they receive such requests. However, all Huawei websites do respect the Do Not Track option if it is enabled in your browser.

## 3. How Huawei discloses your personal data

Huawei does not sell your personal data to third parties. However, Huawei may disclose your personal data under the following circumstances:

1) Disclosures with explicit consent: After obtaining your explicit approval, Huawei may share your personal data with other parties.

2) Disclosures to Huawei affiliates: Your personal data may be shared with Huawei's affiliates. As a matter of policy, we will only disclose data that is necessary.

3) Disclosures to authorized partners ("our Partners"): Some Huawei services are provided by our Partners. Huawei may share some of your personal data with its Partners to offer better customer service and an improved user experience. For example, when you purchase Huawei products online, Huawei must share your personal data with logistics providers to schedule a delivery, or arrange for Partners to provide services. Your personal data may only be processed for specified, explicit and legitimate purposes, and only the data that is necessary to offer a service shall be disclosed. Huawei subsidiaries or Partners are not authorized to use shared personal data for any other purpose.

4) Disclosures on legal or reasonable grounds: Huawei may disclose your personal data if required by the law, legal proceedings, litigation or public and governmental authorities. In some jurisdictions, your personal data may also be disclosed to transaction parties if Huawei is involved in a reorganization, merger or insolvency and liquidation proceedings. Huawei may also disclose your data where reasonable need can be demonstrated, such as to enforce its terms and conditions and to protect its customers.

## 4. How to access or modify your personal data

Under Huawei's terms and conditions, you can manage your personal data, such as your account information, at any time. You should ensure that all personal data submitted is accurate. Huawei will make reasonable efforts to keep your personal data accurate, complete and up-to-date.

You have a right to access your personal data, subject to some legal exceptions. Where privacy and information laws differ in some jurisdictions, we will comply with them. If you would like to exercise your right to access data, please inform us by email at consumer_privacy@huawei.com . For security reasons, you may be required to put your request in writing.

You also have the right to delete or amend any personal information about you that we hold. Huawei will delete or amend such information upon your request. To make such a request, you can contact us by email at consumer_privacy@huawei.com. We may decline to process requests if we have a reasonable basis to believe that they are made in bad faith, are impractical or if access is not otherwise required by local law.

## 5. How Huawei protects your personal data

Huawei takes personal data security seriously. We follow industry-standard practices to safeguard your personal data against unauthorized access, disclosure, use, modification, damage or loss. We take all reasonably practicable steps to protect your personal data. For example, we use encryption to ensure data confidentiality; we use trusted protection mechanisms to protect data from malicious attacks; we deploy visit control mechanisms to ensure only authorized personnel can access personal data; and we raise awareness among employees about the importance of protecting personal data through security and privacy protection training sessions.

We take all reasonably practicable steps to only collect relevant personal data. We only retain your personal data for the period necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. While we take the utmost care to protect your personal data, please note that no security measures are completely infallible.

## 6. How Huawei handles the personal data of children

Our products, websites and services are primarily intended for adults. Children are not allowed to create their own user account without the consent of parents or guardians. Where a child's personal data is collected with parental consent, we will only use or disclose this data if the law permits it, if explicit permission is given by parents or guardians or if it is necessary to protect the child. Although the definition of a child may vary according to local laws and customs, we consider any person under the age of 13 years to be a child.

If Huawei learns that it has collected a child's personal data without first obtaining verifiable parental consent, it will take steps to delete the data within the shortest possible delay.

## 7. Third party providers and their services

To ensure a smooth browsing experience, you may be served content or web links from third parties external to Huawei and our Partners ("Third Parties"). Huawei does not have control over such Third Parties. You can choose whether or not to access links, content, products and services offered by Third Parties.

Huawei has no control over the privacy and data protection policies of Third Parties, which are not governed by this Policy. Before submitting your personal information to Third Parties, please refer to their respective privacy protection policies.

## 8. How your personal data is transferred internationally

Huawei products and services are delivered through resources and servers located around the world. This means your personal data may be transferred to or accessed from other jurisdictions which are outside the country where you use our products or services. These jurisdictions may have different data protection laws, or such laws may not even exist. In such cases, Huawei will ensure that a similar and adequate level of protection is afforded to your data as required by all applicable laws and regulations. For example, Huawei may request your consent to transfer personal data across borders, or implement security measures like data anonymisation prior to cross border data transfers.

## 9. How this Policy is updated

Huawei reserves its right to update or amend this Policy from time to time. Huawei will notify you of the changes through various channels. Where changes are made to our privacy policy, we will post the updated privacy policy on our website http://consumer.huawei.com/en . We may also issue you with a separate notice (e.g. an electronic notification) informing you of any changes to our privacy policy.

## 10. International users

Please note that personal information within the scope of Huawei Consumer Cloud Services concerning individuals who reside in a member state of the European Economic Area (EEA) or Switzerland, Albania, Andorra, Bosnia, Faroe Islands, Gibraltar, Greenland, Macedonia, Moldova, Monaco, Montenegro, San Marino, Serbia, Vatican, Japan, Korea, USA, Canada is controlled by Huawei Technologies Deutschland, GmbH. However, Huawei online store www.hihonor.com/us is controlled by Huawei Device USA, Inc.

## 11. How to contact Huawei

If you have any questions, comments, or suggestions, please contact us by email at consumer_privacy@huawei.com or submit them to one of our global field offices. For a complete list of our office locations, please visit our website at: http://www.huawei.com/en/contact-us

Important Notice: The local language version of the Huawei Privacy Policy may vary from this version due to local laws and language differences. Where differences arise, the local language version shall prevail.

Last updated: September 2016

Copyright © Huawei Device Co., Ltd. 2016. All rights reserved.