Last Revised: March 8, 2017

Through this Privacy Policy (the “Policy”) we, Huawei Device USA, Inc. (together with our affiliates, “Huawei”, "us", "we") would like to inform you about the way we collect and process your personal data and information. Please note this Policy applies to hihonor.com/us, Huawei's other online locations, apps and social media (collectively, the "Sites"), Huawei's consumer electronic products branded as "Huawei" or "Honor" ("Products"), and services and software provided by Huawei and certain third parties ("Services") in connection with the Products. Huawei may provide you with information regarding additional policies that apply to specific Sites, Products or Services (e.g., certain devices, operating systems, or apps) or portions thereof, which supplement this Policy and will act as notice to you when Huawei is collecting and processing information from those Sites, Products or Services. Please pay attention to our notifications when using our Products or Services.

1) Acceptance of Privacy Policy

2) Types of Information We Collect

3) How Your Information Is Collected

4) How We Use Your Personally Identifiable Information

5) How We Use Your Non-Personally Identifiable Information

6) Non-Promotional Communications With You

7) Disclosures To Third Parties

8) How We Respond to "Do Not Track" Signals

9) Request to Update Your Information

10) Children

11) Links

12) Security

13) Changes To This Policy

14) Questions and Contact

## 1. Acceptance of Privacy Policy

Each time you access, use or browse the Sites, Products or Services; interact with Huawei; or participate in any events, promotions, sweepstakes, surveys, questionnaires, or other activities sponsored by Huawei (collectively, "Activities"), you signify your acceptance of the then-current Policy. If you do not accept this Policy, please do not provide information to Huawei; access, use or browse the Sites, Products or Services; or participate in any Activities.

## 2. Types of Information We Collect

We collect certain personally identifiable information about you, which includes, without limitation, information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual. This includes first and last name, email addresses, delivery and billing addresses, telephone numbers, fax numbers, user names and passwords, dates of birth, transaction history, refund history, the precise or approximate geo-location of your Product, refund and repair information relating to your Product, comments or feedback regarding the Sites, Products or Services, and other non-public information. We use this information for various purposes, for example to process your order, to send you relevant marketing messages and to invite you to our Activities, and in other ways that are further detailed below.

As is true of most websites, we gather certain information automatically. This includes, without limitation, information that does not personally identify you as the individual to whom the information relates, such as information that is aggregated by Huawei or a third party, or information that is not linked to contact information or other personally identifiable information about you. Automatically collected information may include information about your use of the Sites, Products and Services, such as your IP address(es), usage statistics, performance statistics, browsing and navigational history when visiting the Sites and, general geographic location such as the city from which your computer or device is connecting to the Internet, webpages requested and visited, timestamps, sites you visit prior to and after visiting the Sites, type of operating system you use on your computer (e.g., Microsoft Windows or Mac OS) or device (e.g., iOS or Android) to access the Sites, the type of browser you use (e.g., Firefox, Chrome, Internet Explorer, Safari), the domain name of your internet service provider, and information regarding your Internet location if and when you see Huawei ads and whether you click on such ad. This information is collected to analyze trends in the aggregate and to administer the Sites.

In addition, Huawei may collect information regarding your age, gender, zip code, occupation, interests, purchase preferences, language preferences, account IDs and passwords for the Sites, and content you access, view, click on or search for when on the Sites, the device from which you access such content and the length of time for which you view same, information regarding the number of times you share content on the Sites through social plugins such as Facebook, Twitter, Instagram, YouTube, Pinterest, LinkedIn and Google+ as well as other information regarding your sharing of such content, information regarding what you purchased or placed in your shopping cart when on the Site, how you interact with content through the Sites, Products or Services, information regarding what you access, input, save, send and/or receive on or through the Products or Services, and other information regarding the Sites, Products and Services and your use of same, as further described below. In the event that such information is maintained in a manner that identifies your name or contact information, it will be treated as personally identifiable information; otherwise, such information will be treated as non-personally identifiable information. Huawei may combine personally identifiable information collected through the Sites, Products and Services and with information available from other sources (such as offline records or publicly available information). We will treat the combined information as personally identifiable information.

## 3. How Your Information Is Collected

• Personally Identifiable Information That You Give Us or That is Generated by Your Actions

When you make use of the Sites, Products and Services we collect certain personally identifiable information about you. For example, you may choose to provide us with personally identifiable information when you create an account or profile on the Sites or on your Product or Service, purchase Products or Services, register or return your Products or Services, have your purchases fulfilled, have your Products or Services delivered, conduct Product or Service activation or verification, make changes to or use your Huawei account, request and receive technical support or authorized updates, communicate or interact with customer service or other Huawei personnel, participate in an Activity, or when you provide other information to us through the Sites or otherwise. This information may include your delivery or billing address, user ID, password, order number, telephone number, your payment details when ordering from the Sites, your email-address, gender, date of birth, certain personal preferences, and other personally identifiable information described in Section 2 above. Similarly, you may have the option to backup your Product to a cloud Service offered by Huawei, and doing so may result in the sharing of certain personally identifiable information with Huawei.

Actions that you take such as making a purchase on the Sites, returning a Product or Service, or requesting technical support, may automatically create certain personally identifiable information that we collect, such as transaction and order history, order numbers, return history, and ticket numbers. The Sites may provide you with an option to log into the Sites using your profile information from a social network that you are registered with. By using such a method to log in, Huawei may collect your username, email and/or any other information associated with your account on such social network that we request and you choose to share with us.

• Information Collected through Technology

Your personally identifiable information and non-personally identifiable information may be collected through a wide range of technologies, many of which are detailed below. In the event that such information is maintained in a manner that identifies your name or contact information or is combined with personally identifiable information, it will be treated as personally identifiable information; otherwise, such information will be treated as non-personally identifiable information.

o Cookies And Other Identifiers

Huawei and its partners use cookies or similar technologies to collect information when you visit our Sites ("Collection Technology"). When you visit the Sites, your web browser may store cookies on your computer or device, or your computer or device may be exposed to other Collection Technology that work independently or in conjunction with cookies. Our cookies and other Collection Technology will enable the Sites to "remember" you, either during your single visit (using a "session cookie") or for repeated visits (using a "persistent cookie"), and may be used to analyze the way you interact with our Sites in order to optimize our services, to improve your experience and to provide you with personalized advertisements. Cookies may help the Sites remember your settings, such as font size, and other preferences for how you want to view the Sites on your computer or mobile device. Further, some of the interactive features of the Sites also rely on Collection Technology placed by third parties. The following are examples of the types of cookies that we use and for what purpose:

Essential cookies. These cookies are used to facilitate essential functionalities on the Sites, such as to keep your shopping basket during the checkout process or to facilitate payment.

Functional cookies. We use these cookies to provide a smooth experience on the Sites, for example by saving your preferences and storing your shopping basket for later visits.

Performance and analytics cookies. These cookies help us to understand the behavior of the visitors to the Sites to optimize our services and to improve your experience.

Social media. The Sites may provide you with social plug-ins from various social networks such as Facebook, Twitter, Instagram, YouTube, Pinterest, LinkedIn and Google+. These plug-ins might rely on cookies, which could, among other things, be used to offer certain functionalities, but also to track your behavior on the Sites and across the web. If you submit personal information to any of those social networks, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any social plug-in you use or third party website you visit.

Advertisements. Some of the cookies on the Sites are used for advertisement purposes. This enables us to show our advertisements on partner websites to visitors who are interested in our products. Retargeting technologies analyze your cookies and display advertisements based on your past surfing behavior. Further details about our marketing and use of retargeting technologies are discussed below.

You can change your browser settings to delete or prevent cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings. Find out how this works for your browser here:

Explorer: support.microsoft.com/gp/cookies/en

Firefox: support.mozilla.com/en-US/kb/Cookies

Chrome:google.com/support/chrome/bin/answer.py?hl=en&answer=95647

Safari: support.apple.com/kb/PH5042

Adobe (flash cookies): www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

o Automatic Collection from the Sites - Server Logs/Browsers

A visit to the Sites automatically may result in certain data being sent from your browser to our servers, which, among other purposes, makes it possible to optimize our services and personalize and improve your experience on the Sites. This information may include information you enter on the Sites, your IP address, date and time of your visit, referral URL (the site from which you originate) and information about the browser you used (browser type and version, operating system, etc.), as well as other automatically collected information described in Section 2 above. Please note that if you are logged into your Huawei or Honor account certain information such as the content you access, view, click on or search for when on the Sites, the devices from which you access such content, the length of time for which you view same information, and the content in your shopping cart on the Sites, may become personally identifiable.

• Automatic Collection from Products and Services

Registration and use of the Products and Services also may result in certain data being sent from the Product or Service to us. This information may include hardware model, MAC address, IMEI number, IMSI number, and other distinctive identifiers for Products and Services, information regarding the operating system of the Product and certain of the selected settings with respect to the Products and Services; the apps and software that you download to the Products; the cellular carrier that provides the Product with cellular services; certain information and content sent and/or received through the Products or Services; websites visited through the Products or Services; how you interact with content through the Products or Services; information regarding what you access, input and/or save on or through the Products or Services; and general usage and performance information and statistics relating to the Product or Service.

• Location Based Services through Products and Services

We also may collect and use the geo-location data from the Products or Services when you use certain location-based service features, such as when you search for weather based on specific geo-locations or try to track a lost or stolen Product using geo-location. The information collected using these location-based service features also may include the ID, type and model of the Product, and the real-time geo-location information of the Product (including Global Positioning System information (“GPS”), Wi-Fi or ID number of the signal tower of your carrier network). You can turn on or off your GPS information by going into the GPS settings on the Product, but you may not have the right to control Wi-Fi and ID numbers of Product or the signal tower of your carrier network as this depends on your carrier’s policy.

• Google Analytics

The Sites may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies or similar technologies to collect and store anonymous information about you, which may include non-personally identifiable information. You can read Google Analytics’ privacy policy at http://www.google.com/analytics/learn/privacy.html and Google Analytics Terms of Use at http://www.google.com/analytics/tos.html. If you have a supported browser, you can opt-out from being tracked by Google Analytics in the future by downloading and installing Google Analytics Opt-out Browser Add-on for your current web browser at: http://tools.google.com/dlpage/gaoptout?hl=en.

• Other Means of Collection

Huawei also may acquire personally identifiable and non-personally identifiable information from other sources (such as offline records or publicly available information); from third parties that provide you with cellular or wireless networks, products, software or apps that you utilize with your Products and Services; from third parties such as our business partners, Activities partners and sponsors, vendors, merchants and other third parties; or from the owners or operators of sites or applications where our advertisements appear, some of which partner with Huawei or with an advertisement network used by Huawei. Non-personally identifiable information also may be obtained by these other sources from inferences based upon the sites you visit; third party data; information you share on other sites, social media platforms and applications; or demographics derived from profiles or accounts that you create, to the extent permitted in their privacy policies.

## 4. How We Use Your Personally Identifiable Information

• For the Purposes Provided

We may use the personally identifiable information you provide for the purposes consistent with this Privacy Policy. For example, we will use your information to process and respond to your requests, orders and inquiries and provide services to you; deliver your Products and Services to you; to administer and process payments; to register, activate, validate and/or update your Products or Services; to provide maintenance or to troubleshoot the Sites or your Products or Services; and to send you notices regarding your transactions.

• Promotional Activities

We may use your information to provide you with the promotional services you have requested from us. This may include processing your submissions and using your contact information in connection with Activities. You can unsubscribe from promotional emails by clicking on the unsubscribe link that is contained in each such email or by sending us a message for Huawei products at SUPPORTUSA@HUAWEI.COM and for Honor products contact us at support.us@hihonor.com.

• Marketing and Improvements

We may use your information for marketing and survey purposes. Below you can find a more detailed description of the information we use and how we use it.

o Analytics Information

The way you interact with our brand provides us valuable information about your interests and preferences. To learn about you and your interests, we monitor and analyze your overall interactions with our brand using various kinds of information, such as your age, your location, your demographics and interests, your orders on the Sites and your product reviews, your social media accounts, and how you use the Sites, Products and Services and information regarding your browsing and viewing preferences on the Sites. We use this information to develop, deliver, and improve the Sites, Products, Services and our advertising.

o Marketing Communications

When you provide us with contact details such as your email, phone number, or social media account, or when you connect your social media account to the Sites by logging into the Sites through your social media account, you authorize us to use your contact details to send you promotional messages we think may be relevant to you. If you no longer want to receive promotional messages via a specific email address, phone number or social media network, please follow the instructions in the promotional message to unsubscribe from receiving such messages. Please note that unsubscribe requests may take up to ten (10) business days to become effective. In addition, you can send us a message for Huawei products at SUPPORTUSA@HUAWEI.COM and for Honor products at support.us@hihonor.com. to opt-out from our promotional messages. Promotional messages we send you may contain new developments, advertisements and commercial information about our products and services, events, promotions and other Activities, as well as other announcements, promotions, and newsletters. We may use your information to personalize such promotional messages. We may also use different means such as email, social media etc. for opinion research and to learn about your experience with our brand. Depending on the situation, these messages may be tailored to your individual preferences and interests as described above.

• Other Purposes

We also use the information we collect to diagnose problems with the Sites, Products and Services; for administration and improvement of the Sites, Products and Services; to enhance the user experience with respect to the Sites, Products and Services; to provide you with updates and upgrades for the Sites, Products and Services; to send important notices such as communications about Activities, changes to our terms, conditions, and policies; to better serve you; for fraud prevention, internal operations, legal compliance, and other public and security related purposes; and to enforce the Terms of Use and any supplemental terms and/or policies of Huawei. We will ask for your consent if we wish to use your personally identifiable information for other purposes than those listed in this Policy.

## 5. How We Use Your Non-Personally Identifiable Information

We may use non-personally identifiable information in similar ways as we use your personally identifiable information, but we reserve the right to use your non-personally identifiable information for any legal purpose. Some examples of how we may use your non-personally identifiable information is for the following marketing purposes:

• Your non-personally identifiable information may be used to analyze and develop advertisements and advertising campaigns, provide you with special offers and promotions and determine the effectiveness of same, optimize and determine the effectiveness of content and advertisements, analyze your interactions with the content and advertisements you are presented with, and how same relates to your visits to the Sites and use of the Products and Services.

• Your non-personally identifiable information also may be used by Huawei in conjunction with retargeting technologies which allow us to show advertisements or targeted content to you on the Sites, Products or Services or on our partners' websites or apps. Retargeting technologies analyze your cookies and other Collection Technology, and display advertisements based on your past surfing behavior, past ads that you have viewed and non-personally identifiable information collected over time by us and third parties. Some of Huawei's third party partners may participate in the Digital Advertising Alliance’s Self-Regulatory Program for Online Behavioral Advertising and allow consumers the ability to opt-out of targeted advertising based on web activity tracking. For more information regarding the foregoing, please visit http://www.aboutads.info/choices/. Please note you will continue to receive generic ads. You may need to re-click the link and follow the instructions provided therein if you delete cookies or other Collection Technology or use a different computer, device or browser. Please see Cookies and Other Identifiers in Section 3 above for further information on cookies.

## 6. Non-Promotional Communications With You

You authorize Huawei to send email to you, telephone you and/or send you direct mail to respond to your communications, communicate with you about your transactions with Huawei or technical information about the Sites, or provide you with other non-promotional communications about us, the Sites, Products or Services. You may not opt out of such communications.

## 7. Disclosures To Third Parties

We use various companies, including some of our affiliates, as service providers which process data and perform other functions on our behalf, such as hosting providers, payment providers, repair centers, logistic companies, merchants and vendors engaged for the purpose of managing, administering or executing an Activity, and other agents, vendors, advertisers, consultants. We may share your information with these companies, and these companies are authorized to use your personal information only as is necessary to provide these services to us.

Huawei also may disclose the information it collects to others: (i) to confirm or update information provided by you; (ii) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of Huawei’s business or operations (including without limitation in connection with bankruptcy or any similar proceedings); (iii) that are cellular carriers that use information to provide services that you request from them; (iv) that are its business partners, strategic partners, Activities sponsors or partners for our internal purposes; or (v) as otherwise authorized by you.

In certain situations, Huawei may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a government request.

Huawei does not share personally identifiable information with third parties for the purpose of allowing the third party to directly market to you.

Your geo-location data and other information regarding the Products or Services and your use thereof, may be shared with third party apps, cellular networks, Wi-Fi providers, websites, operating systems, services and software that you utilize with your Products or Services. Please review the privacy policies of the apps, cellular networks, Wi-Fi providers, websites, services and software that you utilize with your Products or Services, prior to using them. Please note that you can opt-out from sharing your location information with third party apps by turning the GPS feature off in the Product's settings.

In certain situations, Huawei may be required to disclose personal data in response to requests by public authorities, including to meet national security or law enforcement requirements. We also may share your information when we believe you have acted in violation of the Terms of Use or supplemental terms and/or policies of Huawei, to investigate, prevent or take action regarding suspected illegal activities, fraud or potential threats, or to exercise legal rights or defend against claims, when we believe that doing so may protect your safety or the safety of Huawei, or others, or as otherwise permitted or required by law. We may disclose your information in the event that we are ordered to do so through a valid court order, subpoena or official request from a law enforcement agency or court.

The Sites may provide you with social plug-ins from various social networks such as Facebook, Twitter, Instagram, YouTube, Pinterest, LinkedIn and Google+. If you choose to interact through social media, your activity on the Sites may also be available to these social networks. If you are logged-in to one of these social networks when you visit the Sites, the social network might add some information about the Sites, Products or Services to your respective profile and/or your use thereof. If you are interacting with one of the social plug-ins on our Sites, this information will be transferred to the social network. Please read the privacy policies of these social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.

Additionally, we may take personally identifiable information and de-identify it and share it in a de-identified or aggregated form with third parties, advertisers and/or business partners to analyze the Sites’ usage or demographics, or improve our products or services, improve our user experience, or for similar purposes. We will not re-identify such data and we will ask our contracting parties to agree to keep the data in its de-identified form.

## 8. How We Respond to "Do Not Track" Signals

Huawei does not alter the practices detailed herein based upon your selection of the "Do Not Track" setting or other "opt out" setting or feature that may be offered by your browser; however, Huawei reserves the right to do so in the future without notice to you.

## 9. Request to Update Your Information

Please note that you are responsible for keeping your information current and up-to-date. Upon request, Huawei will provide you with information about whether we hold any of your personal information. You may update your information by contacting us. For Huawei products contact us at SUPPORTUSA@HUAWEI.COM. For Honor products contact us at support.us@hihonor.com. We will use reasonable efforts to process any change you request; provided, however, that requests to delete information are subject to Huawei's internal reporting, processing and retention policies and all applicable legal obligations. When we can process change requests, we will do so for free, except where it would require a disproportionate effort and or if a fee is allowed under applicable law. We will respond to your requests within a reasonable timeframe.

## 10. Children

The Sites, Products and Services are not directed toward children under 13 years, nor do we knowingly collect personally identifiable information from children without requiring that the child seek prior parental consent, as required by applicable law. If you are under 13 years of age, you are not permitted to submit any personally identifiable information to Huawei. If we accidently collect data of children under 13 years of age, we will delete the data as soon as possible after you make us aware of same by emailing us. For Huawei products contact us at SUPPORTUSA@HUAWEI.COM. For Honor products contact us at support.us@hihonor.com We encourage parents and guardians to take an active role in their children’s online and mobile activities and interests.

## 11. Links

You may have the opportunity to follow links on the Sites to other sites that may be of interest to you. Huawei endeavors to only link to reputable organizations. Because other sites may not be hosted or controlled by Huawei, we are not responsible for the privacy practices of those sites or the content provided thereon. If you submit personal information to any of these websites, your information will be governed by their privacy policies. We encourage you to review the privacy policies of each other site. This Policy only applies to information collected and maintained by Huawei.

## 12. Security

We are committed to protecting your personally identifiable information and have taken reasonable technical and organizational measures to protect your information against any loss, alteration, access or misuse. No transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Huawei to intercept or access transmissions or private communications unlawfully. While we strive to protect personally identifiable information, neither Huawei nor our service providers can ensure or warrant the security of any information you transmit to us over the internet. Any such transmission is at your own risk. Personally identifiable information collected by Huawei may be stored and processed in the United States, Germany or any other country in which Huawei or its affiliates or service providers maintain facilities.

By using the Sites, Products or Services, you expressly consent to any such transfer of information outside of the United States. Although we take your privacy duly in account, we advise you to make sure your device has been reset and all data has been wiped in the event that you are sending your Product back for repairs or return.

Huawei will retain your personally identifiable information in accordance with its internal reporting, processing and retention policies and applicable law. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

## 13. Changes To This Policy

This Policy may be revised from time to time in order to keep pace with new developments and opportunities relating to the Internet and to stay in line with current laws, among other reasons. Should the Policy be revised, Huawei will post the changes on the Sites and the new Policy will be effective immediately upon posting. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. You can determine when the Policy was last revised by referring to the "Last Revised" legend at the top of this page.

## 14. Questions and Contact

If you have any questions or concerns about our Sites, Products or Services, our use of your information or this Policy, please contact us. For Huawei products contact us at SUPPORTUSA@HUAWEI.COM or by calling 1-888-548-2934. For Honor products contact us at support.us@hihonor.com or by calling 1-844-524-6667.

Copyright © 2017 Huawei Device USA, Inc. All rights reserved