With this update we will be providing you with an improved user experience and better controls over your data to enjoy HUAWEI In-App Purchases. The main changes in this version are as follows:
•Provided more clarifications on the marketing purpose we seek, especially added more information about our purpose of processing of your data for targeted marketing on third-party marketing platforms. You can read more on this specific change in Sections 2, 4, and 5.
•Changed the company’s title, as your data controller Aspiegel has transformed from an Irish Limited Liability Company to a Societas Europaea (SE) known as Aspiegel SE. Such transformation has no impact on you and does not affect your relationship with us or rights.
HUAWEI In-App Purchases (hereinafter referred to as "HUAWEI IAP") is a service provided by Aspiegel SE, a subsidiary of Huawei incorporated in Ireland (hereinafter referred to as "we", "us", or "our") that provides you with in-app and web-based payment capabilities and manages your various payment methods.
This Statement describes:
As part of the HUAWEI IAP service, 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.
We shall collect and process the following data:
•HUAWEI ID account information: such as account identifier, user service token, child account status to prompt the HUAWEI ID parent account to authorize the payment, and user agreement sign-up record.
•Device information: such as device ID (e.g. MEID, UDID or IMEI, depending on your system version), open advertising identifier (OAID), device type, and operating system version.
•Network information: such as IP address, network type, mobile network code (MNC), and mobile country code (MCC).
•Payment information: such as bank card number, bank cardholder's name, bank card expiry date, bank card security code (CVV2), bank card brand, bank card sub brand, issuer country code, mobile phone number, text message (SMS) verification code, carrier ID for mobile payment, order ID, payment method information, PayPal account information (pseudonymized PayPal email address and hashed account ID), purchase history, payment token ID, payment token expiry date, payment results, bank name (data returned from your bank) transaction password, transaction password protection answers, product name, price, currency unit, merchant name, invoice information (first and last name, address, and email address), fingerprint ID, payment certificate, stored credentials information (such as first payment and transaction ID), device fingerprint (device technical information), device fingerprint token (provided by your bank), HUAWEI Gift Card redemption code, HUAWEI Gift Card ID, HUAWEI Points balance, and coupon information (coupon ID, coupon code, activity type and list).
If you use the web-based payment service, we shall collect and process the following data:
•HUAWEI ID account information: such as account identifier, user service token, and sign-up record of user agreement.
•Browser information: such as cookies.
•Payment information: such as bank card number, bank cardholder's name, bank card expiry date, bank card security code (CVV2), bank card brand, bank card sub brand, issuer country code, mobile phone number, text message (SMS) verification code, purchase history, payment token ID, payment token expiry date, payment results, transaction password, transaction password protection answers, product name, price, currency unit, merchant name, invoice information (first and last name, address, and email address).
To provide you with this service, HUAWEI IAP requires your permissions to access your device to obtain the necessary information. You can manage the permissions in the settings screen on your device.
To provide you with the HUAWEI IAP service and fulfill our contractual obligations, we will use and process your personal data. The data is processed so that you can make payments within apps and on webpages, complete transactions, and manage your bank cards and other payment methods. We also use your data for settlement, identification, customer relationship management, support and communication, software and system updates, billing, refund, agreement management as well as for diagnostics and repair purposes.
In addition, we use your personal data for the following purposes based on legitimate interest pursued by us:
•Communicating about our offerings, sales promotion and marketing purposes, including awards and loyalty programs, as well as for creating aggregated target groups for marketing. Knowing customers' preferences enables us to target our offers and offer products and services that better meet the needs and desires of our customers. Our digital marketing activities also utilize different third-party advertising services and networks, which allow us to reach you on different platforms (e.g. on social media). When those services provide a custom audience feature, you may be targeted with specific campaigns on third-party platforms based on your HUAWEI ID account information, your purchase behavior (e.g. based on whether you have ever made a payment using IAP or never). The account information is used to associate you with the platforms data to enable us to reach you or exclude you from our marketing campaigns (e.g. a hashed email address or phone number is uploaded to the platform). Your data may be used for creating lookalike audiences as well. You can object to such data processing as described in Section 5.5 below.
•Analytical and development purposes. This also enables us to understand our users' needs and improve the quality and user experience of our current and future services and offers. You can object to such processing as described in Section 5.5 below.
•To assess the performance of personalized ads shown in specific apps, we will share your OAID and paying status (whether you are a paying or non-paying user) without any other details about your payment information to HUAWEI Ads so it can create aggregated reports showing the number of users who have seen the ads and the number of paying users within that group. The outcome of such processing is aggregated without any personal data that can be linked back to you as a user, and HUAWEI Ads does not use your data for any other purposes. You can object to such data processing as described in Section 5.5 below.
•Information security and fraud prevention purposes, including detecting or preventing various types of misuse of services and payment fraud in order to provide you with secure and reliable services. For the fraud prevention purposes, in addition to processing your data, we receive a blocklist of anonymized IP addresses from a third-party risk assessment company, which we use to assess payment risks and ensure that your payment is safe. We also receive and process your PayPal account email address from PayPal to conduct fraud prevention processing and ensure that such transactions are not fraudulent. We also process your account identifier, as well as device and network information, to ensure that the device is not rooted and safe to make payments. For more information on such processing, you can check the Statement About HMS Core and Privacy.
We also process your payment and network information for tax and accounting purposes as required by laws and regulations applicable to us.
We will retain your personal data for no longer than is necessary for the purposes defined in this Statement.
We will process and retain your data for the duration of the customer relationship. When you delete your HUAWEI ID account, personal data related to your account and associated services, such as the HUAWEI IAP service will be erased. However, we shall retain:
•Your payment and network information for seven (7) years from the date the transaction was made.
•Your subscription information for up to thirty (30) days from the end of your subscription.
•Personal data processed for customer relationship management such as data subject requests, complaints, and customer interaction records for up to six (6) years from the last interaction.
•Personal data processed for contract management purposes for up to three (3) years after your HUAWEI ID has been deleted.
•Your payment certificate of authentication for five (5) years, from the date it was generated.
•Personal data used for analytical and development purposes for up to twelve (12) months from the date of collection, unless you have objected to such processing.
•Your email address received from PayPal and processed for payment fraud prevention purposes if you make a payment with your PayPal account for up to twelve (12) months from the date the payment using this account was made.
•Data backups and app logs processed to ensure the security of your data and services for up to six (6) months from the date they were created.
•Personal data processed for payment security and fraud prevention purposes for up to six (6) months from the date the payment was made.
Once the retention period expires, we will delete or anonymize your personal data, unless otherwise required by applicable laws and regulations.
We store your data in the data centers located in the European Union (EU)/European Economic Area (EEA).
Our third-party vendors, who provide us with IT (including cloud-based) services, business support, and customer care services, may need to process your information. All such third parties are operating under contract and acting on behalf of us and are located in the EU/EEA, unless you are using the service in the following countries:
•Canada, in which case we may share your personal data to customer service centers located in Mexico and operated by our supplier operating under contract and acting on behalf of us.
•Australia or New Zealand, in which case we may share your personal data to customer support services located in Malaysia and Singapore, as well as to business support entities located in United Kingdom, Malaysia, and Singapore, all operating under contract and acting on behalf of us.
In order for us to comply with applicable tax and accounting laws and regulations, your order information, including order ID, subscription information (if applicable), product name, purchase amount, currency unit, merchant name, available HUAWEI Points balance, coupon information, and country code will be processed by a Huawei group company operating under contract and acting on behalf of us within the People's Republic of China.
In order to complete the transactions, your payment method information (such as bank card information), order information, device identifier, IP address, HUAWEI ID account identifier, and email address will be processed by a payment service provider operating under contract and acting on behalf of us within the EU. The transaction related processing may require the access to your data by our payment service provider's subsidiaries in the UK, USA, China, Mexico, Brazil, Singapore, and Australia.
When our digital marketing activities utilize different third-party advertising platforms' custom audience features, we may target you by uploading your HUAWEI ID account information (e.g. a hashed email address or phone number) to such platform. We may also use third-party tracking platforms, which collect data about how users interact with our ads for ads attribution analysis and effect evaluation purposes. Such third parties are operating under contract and acting on behalf of us and include data transfers to partners located in the US.
We will only share your data under the following circumstances:
•When you make payment with your bank card, your payment information will be disclosed to your bank (card issuer) to complete the transaction.
•When you make a payment through a third-party app using any payment method including coupons, your order information, including the order ID and subscription information (if applicable), will be disclosed to the third-party app, whose server may be located outside of EU/EEA, to complete the purchase (including recurring purchase, if applicable) and allow the settlement between us and the third-party app.
•When you make a payment with your bank card, we will disclose your bank card information, stored credentials information, device identifier, and email address to WORLDPAY (UK) LIMITED, WORLDPAY LIMITED, and WORLDPAY AP LTD ("WORLDPAY"), our payment service providers in the United Kingdom, in order to verify your bank card information with the card issuer (your bank) and prevent fraud.
•When you link your phone number and/or make a mobile payment through your available mobile balance, we will disclose your phone number, country code, carrier ID, and order information (including order number, merchant name, product name, price, and currency unit) to your carrier in order to complete the purchase. If the transaction is made through our billing partner, BOKU PAYMENTS INC (hereinafter referred to as "BOKU") in the United States, the preceding information will also be disclosed accordingly.
•When you make a payment with your PayPal account, we will disclose your order information (order ID, amount, purchased product, currency) to PayPal S.A.R.L. in Luxembourg to complete the purchase. All transaction-related information will be subject to the Privacy Statement for PayPal services.
•When you make a payment by bank transfer, we will disclose your order information (order ID, amount, and vendor), IP address, and hashed HUAWEI ID account identifier to your bank transfer service provider in your country, such as PayU in Poland, Giropay in Germany, Sofort in Germany, Switzerland, and Austria, and iDeal in Netherlands.
•When required in response to a legal process or request from a competent authority according to applicable laws or in connection with a legal proceeding or process. In the case of the users in Canada, this means that the personal data transferred, processed and stored outside of Canada may be available to government authorities under lawful orders and laws applicable there.
•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 another company.
When transferring and disclosing your IAP data outside the EU/EEA, where the local law may not provide the same level of protection as in the EU/EEA, we shall comply with applicable legal requirements for providing adequate safeguards to such transfer 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.
You have the following rights and options:
5.1 Access your data
You can request information and a copy of personal data that we have collected and stored about you in relation to HUAWEI IAP by going to Settings > HUAWEI ID > Privacy center > Request your data on your device.
For additional access requests, please contact us.
5.2 Rectify your data
In order to keep your data up-to-date and accurate, you can access and modify your data by going to Settings > HUAWEI ID > Payment and purchases on your device.
5.3 Port your data
You can port the personal data that you have provided to us in relation to HUAWEI IAP in a commonly-used, machine-readable format by going to Settings > HUAWEI ID > Privacy center > Request your data on your device.
5.4 Erase your data
You may at any time:
•Remove your bank cards, mobile payment phone number, unlink your PayPal account, and delete your purchase history by going to Settings > HUAWEI ID > Payment and purchases on your device.
•Delete your HUAWEI ID. This will erase your personal data associated with your HUAWEI ID, including your personal data in relation to HUAWEI IAP.
•Object to the processing of your personal data, as described in Section 5.5. If your objection is valid, and we no longer have legal basis to continue the processing, we will erase the data in scope of a valid objection.
• Contact us if you think the processing of your personal data is unlawful and your data should be erased.
We will erase or anonymize your personal data without undue delay when necessary based on your aforementioned actions and in accordance with the retention periods as described in Section 3.
5.5 Object to processing
If you do not want your OAID to be shared by HUAWEI IAP to HUAWEI Ads, you can stop the sharing by going to Settings > Privacy > Ads > Disable personalized ads.
If you want to object to other processing of your data for analytics and marketing purposes, please contact us.
When making the request, please specify the scope of the request and provide us with your email address or phone number that you used to log in to your HUAWEI ID.
We will contact you to verify your identity in order to proceed with your request.
5.6 Restrict processing
If you want to restrict the processing of your personal data, please contact us. You have the right to restrict the processing of your data under the following circumstances:
•Your data is unlawfully processed but you do not want to erase it.
•You have a legal claim that you need to establish, exercise and 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 have contested the accuracy of your personal data and the accuracy of your data is pending our verification.
When making the request, please specify the scope and the grounds for the request and provide us with your email address or phone number that you used to log in to your HUAWEI ID.
We will contact you to verify your identity in order to proceed with your request.
You can find guidance on how to exercise your data subject's rights in Section 5. 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, 1F, Simmonscourt House, Ballsbridge, Dublin, D04 W9H6, Ireland. Registration number 561134.
If you believe that we do not process your personal data in accordance with this Statement or the applicable data protection laws, you can lodge a complaint with the data protection authority in your country/region, or the Data Protection Commissioner in Ireland.
We encourage you to regularly check for the latest version of this Statement from the app settings as we may change it from time to time. If we make material changes to this Statement, we will notify you using an appropriate method, such as through a notification dialog box, notification message on your device, email, etc., depending on the nature of the change.