Privacy Policy

The data controllers of this Platform (hereinafter, referred to as "the Platform") are Huawei Services (Hong Kong) Co., Limited (Company registration number: 1451551), a company incorporated under the laws of Hong Kong and having its registered address at Room 03, 9 / F, Tower 6, the Gateway, No. 9 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong ("Huawei"), and TWIRELESS INC., a company incorporated in Philippines and having its registered office at 1506A West Tower, PSE Centre, Exchange Road, Ortigas Center, Pasig City, Philippines ("TWIRELESS", collectively, Huawei and TWIRELESS will be referred to as "we" or "us").

We understand the importance of your privacy, and pledge to take all appropriate security measures to protect it in accordance with the industry's well-established safety standards.

The Platform is not intended for use by a Minor without the legal representative’s prior consent. Minor refers to an individual who is under the age of eighteen (18). If you are an incompetent/incapacitated or quasi-incompetent, please obtain the prior consent from your custodian or curator who has the power to act on your behalf before use of the Platform.

1. What data do we collect about you?

We will collect and use the following personal data only for the purposes stated in this Statement. Personal data means any information that enables us to identify you as a user.

- Device information: browser information.

- Network information: IP address, location information.

- Account information: personal data disclosed by Huawei Services (Hong Kong) Co., Limited, about your HUAWEI ID, including profile picture and nick name, UID, date of birth, country, gender, your email address and / or phone number.

- Order information: contact information (including name, phone number, post code, shipping name and address, email address, billing address, billing name), TIN, invoice number and based on which, we will generate an order number for you.

- Payment information: if you choose to pay by credit card or debit card, card holder’s name, card number, expire date, card verification value, SMS verification code; We will generate a payment number for you.

- Delivery information: shipment number generated by system and tracking number obtained from the delivery company.

- Customer service information: the name, phone number and email address you entered, and the email content, recordings, chat records.

- Product review and FAQ information: including any of your comments on our products, inquires, ratings and likes.

- Service usage information: browsing and clicking records.

- Information for return: your name, phone number and pick up address.

- Community participation information: Personal post, comments, reviews with a "like", shared content, private messages,votes in our Huawei Community forum, and other activity-related data, as well as your Community Nickname and profile photo or photos uploaded from your device gallery.

2. How do we use your data?

2.1 Your personal data are necessary for us to provide you with the following services as requested by you and / or to fulfill our contractual obligations towards you. Unless otherwise stated in this Statement, you will no longer be able to enjoy the relevant service(s) if you refuse the collection and processing of your personal data for these services:

Log-in: If you choose to log in with your HUAWEI ID as a Member of the Platform, your account information is required for us to provide you with the membership services. As a Member of the Platform, you can maintain the contact information for frequent use, manage your reviews, to check the in-site messages and the membership rights and interests. Without the account information, you can still access the Platform or purchase as a visitor.

Notify Me: In case some product is out of stock, you can leave us your email address so that we can promptly notify you when the product is available for purchase.

Online purchase: Your order information and payment information is needed to process payment, issue invoices, fulfill purchase orders, deliver purchases to the designated address, and to update you of your order progress. If you start the return process, we need to collect the information for return.

Verification: To make sure your order has been fulfilled, to verify and inspect the devices you send back to us for return, we record your device identifier, delivery information and order number before the goods are shipped out for further alignment.

2.2 We use your personal data based on our legitimate interests as follows:

Handling customer inquiries: If you contact us through our customer service to make inquiries such as price consultation, fulfilment of order, promotions, rights and interests, your order number is usually needed to locate the concerned order. We will collect the customer service information so as to inform you about the result or progress. Other than that, information further required is dependent on your inquiries. We will have no choice but to cease such services if you object to our processing of such information.

Handling the disputed payment: We will transfer your UID, order information, payment number and delivery tracking number to the payment service provider to facilitate the issuer banks in resolving disputed payment.

Service maintenance and business analysis: For the purposes of business development, we use your personal information to conduct trouble shooting, to monitor and analyze our services or stock, and to settle with our suppliers on a necessary basis.

Warranty and repair service: To check and confirm the warranty status of your device, we will process your device identifier and order number. You can also provide your device identifier to check the price of spare part. We also process your account information, contact information, device information and customer service information for you to request, book and track repairs through the website or through our authorized customer service services, as well as collect and deliver devices from your home or selected collection point.

Find Service centers / stores nearby: When you search for nearby Huawei Customer Service Centers, we will use your location information. The preceding information is only used to provide store locations, and your personal information will not be retained on our servers after use.

Product reviews and FAQ: You can leave and share your product reviews and questions on our Platform. Log-in is required for us to identify commentators. We will process your account information and Product review and FAQ information.

Data analysis: we will process your personal data for statistics and product improvement purposes, including creating aggregated groups based on your service usage information. This enables us to understand our users’ needs, improve the quality and user experience of our current and future services and offerings and send commercial communications based on the aggregated groups.

Community: we will process your community participation information and other activity-related data for the purpose of your use of Huawei Community and community environment maintenance. This includes review of entries and promotional campaign information to ensure reliability of the activity and fairness its results.

Notification: notify you with information about products, services, promotions, and marketing you might be interested, you can opt out at any time.

Cookies: For more information on how we use cookies, see the cookie notice.

2.3 On the basis of your consent, we process the following data for the associated purposes:

Commercial communications: We will process your email address and device information, and use the aggregated group information which we create based on your service usage information to send you commercial communications by email or by third-party tools.

You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before your withdrawal. Additionally we will process your personal data as necessary to comply with legal obligations, including tax and accounting requirements, and to establish or defend our legal rights.

3. How long do we store your data?

We retain your personal data for no longer than is necessary for the purposes defined in this Statement unless otherwise required by laws and regulations. In particular:

We retain order information and payment number for 10 years from the date the transaction for the purposes of after-sales services, and legal compliance to tax, and financial-related laws or regulations. We do not retain your payment information with sensitive nature, such as CVV. If you deactivate an account or voluntarily delete an order during the data retention period, we reserves the right to retain these transaction records in the background until the end of the above retention period.
The retention periods for personal data in connection with the provision of Huawei online services are set out below:

Contact information and Online service information: name , email address , address, phone number and your device details ,chat record, email content and hotline record will be retained for 24 months from the date of your contact with us. Huawei Community comments and other activity-related information shall be retained for 7 days only.
We retain your HUAWEI ID account information, your frequently used information of recipient and your rights and interests as a member until you deregister your HUAWEI ID.
Product reviews that you post on our product pages are presented pseudonymously on our website not attributed to you and remain posted for as long as such function is still accessible.
Inquiries you submit through the product page will be posted online pseudonymously, to guide other users for as long as such function is still accessible.
Your personal data used for data analysis will be retained for 2 years.

After the retention period expires, we will erase or anonymize your personal data, unless otherwise required by laws and regulations.

4. Do we share your data?

(1) Disclosure, transfer and storage of your personal data outside of Philippines:

Your personal data generated during your visit to our Platform will be transferred to, processed and stored in Singapore by Huawei’s affiliate on behalf of us and under our instruction.

Disclosure with our suppliers

To conduct verification and conduct business analysis, the order information, device information and delivery information will be transferred to, processed and stored in China by Huawei’s affiliate on behalf of us and under our instruction and the protection of data processing agreement. Your data relating to your community activities will be transferred to HK for forum environment maintenance purpose.

To conduct service maintenance and business analysis, the necessary personal information will be transferred to, processed and stored by Huawei’s affiliate in Malaysia on our behalf under our instruction and the protection of data processing agreement.

Our payment service suppliers provide you with payment related services. Your personal data will be processed and stored by them in Singapore.
EDM email for User survey or Marketing, Your personal data will be processed and stored by them in European Union.

To respond to the customer inquiries and deal with order related services, your personal information will be transferred to, processed and stored by our suppliers located in Germany (Chat contact) and USA (E-mail) and Singapore (Hotline) on behalf of us and under our instructions and the protection of data processing agreement.

When processing your payment, the payment information you submitted will be shared between the payment service provider and the issuer banks. We will not store any of your payment information except the first six (6) digits and the last four (4) digits of your payment card number which are anonymized. To handle the disputed payment and in accordance with our contract with the payment service provider, we will disclose your UID, order information, payment number and delivery information to such payment service provider to facilitate the payment institutions.

Disclosure with Huawei’s affiliates:

To conduct business analysis and service maintenance, the necessary personal data will be processed in Malaysia by Huawei’s affiliates as instructed by us and under the protection of data processing agreement.

To conduct invoicing to customer, the necessary personal data will be processed in Singapore by Huawei’s affiliates as instructed by us and under the protection of data processing agreement.

To have Huawei’s affiliates conduct verification, warranty confirmation and accounting, the order number, shipping number, delivery tracking number and order number will be transferred to China We comply with applicable legal requirements for providing adequate safeguards to such transfer. You can visit "Privacy Inquiries" to obtain a copy of the data transfer agreement.

(2) Disclosure of your personal data within the Philippines:

Disclosure with our suppliers

We procure suppliers to help with the invoicing, warehousing and logistics services. Your personal data will be processed by them on behalf of us and under the protection of data processing agreement.

In addition to the information and parties mentioned in this Privacy Policy, we may disclose information about you to third parties with your consent or at your request.

(3) Disclosures related to legal requirements

We may share your data 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.

Your data may also be disclosed as part of merger, acquisition, sale of assets (such as service agreements) or transition of service to a Huawei group or other company.

5. What are your rights and choices?

You have the following rights and choices:

Your right	Description	How to exercise your rights?
Right of access	You can receive information and a copy of personal data we have collected and stored about you.	(1) Please log in, go to My Account / Account page then click your profile picture or nickname to User Center to access your account information. You can access your order information, address information, subscription information, and forum information on My Account / Account page. You can click the shopping cart icon to access your shopping cart. (2) You can exercise your data subject rights through "Privacy Inquiries".
Right of portability	You can receive certain data that you have provided to us in a machine-readable format.	If you need to obtain a digital copy of your personal data, you can exercise your data subject rights through "Privacy Inquiries".
Erase data	You can have your data erased under certain conditions.	(1) Please log in, delete order information and the information of recipient for frequent use on My Account / Account page. (2) You can exercise your data subject rights through "Privacy Inquiries".
Rectify data	You can have your inaccurate data corrected and incomplete data completed.	(1) Please log in, you can click Profile on My Account / Account page to edit your account information. You can click Addresses on My Account / Account page to change the information of recipient. (2) You can exercise your data subject rights through "Privacy Inquiries".
Manage your consents	You can withdraw consents to the processing of personal data based on your consents.	(1) If you want to unsubscribe from the electronic communications, in the email you receive, please click the link for un-subscription. You can also go to My Account / Account page then click Subscriptions for un-subscription. (2) For notification of WEB / WAP, please go to browser setting page to withdraw your consent in the respective browser; For notification of APP, please go to Account page to withdraw your consent.
Object processing	You can object to processing of your data to certain purposes such as direct marketing.	(1) If you want to object to the processing of your data for statistical, product improvement or sales and marketing purposes, please contact us. When making the request, please specify the scope of the request and provide us with device information if you don’t log in the Platform and your email address or phone number if you log in with your HUAWEI ID. (2) You can exercise your right of objection through "Privacy Inquiries".
Restrict processing	You can restrict processing of your personal data under certain conditions.	You have the right to request for restriction of processing of your data through our "Privacy Inquiries" under the following scenarios: • The accuracy of your data is contested by you, and we need a period to verify the accuracy of your data. • 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. • Your request for objection is pending our verification.

You can contact us via Privacy Inquiries If you think that we are not processing your personal data in accordance with this Statement or the applicable data protection laws, you are entitled to lodge a complaint with National Privacy Commission in Philippines.

6. How to contact us?

If you want to exercise your privacy rights, or have any privacy issues for which you need to lodge a privacy complaint with our Data Protection Officer (DPO), or want to consult our DPO regarding general data protection, please visit our Data Subject Right Portal.

Our address: Room 03, 9 / F, Tower 6, the Gateway, No. 9 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong. 1506A West Tower, PSE Centre, Exchange Road, Ortigas Center, Pasig City, Philippines.

If you think that we are not processing 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 [Personal Information Protection Commission].

7. How do we update this notice?

If Huawei changes the way your personal data is processed, it will inform you about relevant changes in advance, through appropriate methods, such as push email, publication on the website, etc., so you are aware of these changes in due time.

Latest update: [2020-09-01]

IMPORTANT: This privacy statement is a privacy commitment of website application. If you want to learn more please read Huawei Consumer Business Privacy Statement.