Privacy Policy for Huawei’s Social Media Fan Pages

a) Data Controller

This Huawei Social Media Fan Page (also known as a page or brand page) within the online social networking service / platform that you have accessed it through has been created and is managed by [Huawei Technologies Norway A / S, with its registered office at Rolfsbuktveien 4C, 1364 Fornebu, Norway] (hereinafter referred to as "Huawei", “we”, “us” and “our”).

With regard to certain categories of personal data collected through this Huawei Social Media Fan Page (as described in more detail below) Huawei acts as a data controller, jointly with the provider of a specific Social Media Platform [Facebook / Twitter / Instagram / YouTube / LinkedIn] (hereinafter referred to as “Social Media Platform”). We have therefore entered into a dedicated agreement with the Social Media Platform to comply with the applicable data protection laws.

By using the Social Media Platform you acknowledge that the processing of personal data is governed by the respective Terms and Conditions and privacy policy of the Social Media Platform. We encourage you to use the relevant option made available by the provider of the Social Media Platform to access this documentation. Usually this documentation can be accessed by options available at the bottom of webpages within Social Media Platform, or in your account settings.

Please note that this Privacy Policy for Huawei’s Social Media Fan Pages (hereinafter referred to as the “Privacy Policy”) applies to the data processing executed by Huawei with respect to this Huawei Social Media Fan Page only.

b) Purposes of Personal Data Processing
Your Personal Data will be processed by Huawei for the following purposes:

Managing the fan page as far as it is in Huawei’s capacity;
Establishing or improving business relations;
Providing you with the content of the Huawei Social Media Fan Page as well as ensuring the high quality of your user experience, including but not limited to its suitability and attractiveness, to the extent in Huawei’s capacity;
Answering your queries, requests and messages submitted via direct message function of the Platform and / or the feature to leave a comment under a specific post publicised by Huawei;

c) Legal Basis for Personal Data Processing

The legal basis for collecting and processing your personal data via Huawei Social Media Fan Pages is our legitimate interest to promote Huawei’s activities and products, enhance the image of the firm as well as to enhance, modify, personalise and improve our services and communications for the benefit of the users of Huawei Social Media Fan Pages. In this case, the fundamental interests, rights and freedoms of the data subjects do not prevail over the legitimate interests of Huawei.

d) Categories of data concerned

i) Non-personally identifiable usage and performance statistics

As part of this fan page we are able to access statistical data of different categories from the Social Media Platform. This involves data about registered and unregistered users. We only receive anonymous data about you via the Social Media Platform, but the Platform does also process personal data separately.

We are able to access the following statistical data: [total number of page views, “Like” information, page activities, post interactions, video views, scope of the posts, comments, shared content, responses, proportion of men and women, origin by country and city, language, views and clicks in shops, clicks on route planners and clicks on phone numbers].

ii) Personal data

We also process your personal data where you interact with us directly, for example, post on our wall or send us a private message regarding a query or issue. The personal data we will process will depend on your particular interaction or query, but may include:

Information about you, such as your name, username / ID, email, age, country, job title, education background, profile picture and other publicly available information, provided that you have published all this information on your social media profile or posted it on Huawei Social Media Fan Page. To modify visibility of certain information, please refer to account settings of the Social Media Platform;
Information you may provide us with when you interact with Huawei, including your comments and / or likes to our posts and pictures or direct messages you send to us via Huawei Social Media Fan Page.
Details of your Huawei device you have an issue / query about;

Huawei may process comments, questions and other postings you make on Huawei Social Media Fan Page so we can respond to them. We may also monitor such postings in order to protect employees and other individuals against illegal activities or behaviour by users visiting and interacting with Huawei Social Media Fan Page which could be damaging or distressing to others as well as to protect Huawei's reputation and confidentiality of information.

We will collect and use your personal data only for the purposes stated in this Privacy Policy.

For more information about the data collected and processed by the Social Media Platform and its provider, please use the relevant option made available by the provider of the Social Media Platform to access relevant privacy documentation.

e) Duration of data storage

[We will retain your personal data for [6 months]. After the retention period expires, we will delete or anonymize your personal data, unless otherwise required by laws and regulations.]

[The personal data and contributions posted on Huawei’s fan pages available of the Social Media Platform will remain published until Huawei will close or delete its fan pages.]

The deletion of the comments and other interactions you leave on the Social Media Platform is governed by the privacy and legal framework of the Social Media Platform provider, as mentioned above. As a general rule, if you have provided a comment to any of our posts, such comments will be deleted at the time when the post in question is deleted or when you choose to delete your own comment. We may, however, choose to delete specific comments at an earlier point in time.

f) Transfer and disclosure of personal data

We process your personal data within the EU / EEA.

We may share your personal data with our partners, contractors or authorities acting as controllers, when there are legal grounds to do so. We may also outsource some of our customer service operations to third-party suppliers acting on our behalf. The processing of personal in relation to our suppliers is always commissioned by us and the parties will act only on our behalf as data processors. Such processing is always protected with contractual arrangements to ensure that your personal data is processed in accordance with the laws and good data processing practices. Huawei and its data processors shall establish technological, physical, administrative and procedural safeguards all in line with the industry accepted standards in order to ensure the confidentiality, integrity and accessibility of the personal data processed.

The use of the Social Media Platform may also involve data processing operations of the Social Media Platform providers in the USA. The data protection guidelines of these providers may apply in this scenario.

In addition, due to the nature of the Internet, your personal data and contributions published by you on this or other pages of the Social Media Platform are available worldwide. You understand and acknowledge that these personal data and contributions, once posted on the Social Media Platform may be taken and distributed in the online environment outside the control of Huawei, who is not responsible for such distributions or subsequent downloads by others.

g) Rights of the data subjects

As a Data Subject, you have the following legal rights in relation to your Personal Data. These rights may be subject to certain conditions, limitations and legal exceptions.

Right of Access	You have the right to obtain from Huawei confirmation as to whether or not personal data concerning you is being processed, access to a copy of the personal data and specific information about how Huawei processes the personal data.
Right of Rectification (Correction)	You have the right to obtain from Huawei the correction of inaccurate personal data concerning you and also the right to have incomplete personal data completed.
Right of Erasure (Deletion)	You have the right to obtain from Huawei the erasure (deletion) of your personal data in particular circumstances.
Right of Restriction	You have the right to obtain from Huawei restriction of processing in particular circumstances.
Right of Objection	You have the right to object to the processing of your personal data in particular circumstances.
Right to Data Portability	You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller, in certain circumstances.

You also have the right to lodge a complaint to the relevant EU Supervisory Authority. A list and contact details of such authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

If you have any questions, comments, or suggestions on the processing of your personal data by Huawei, or if you want to exercise your rights mentioned above, or to contact our Data Protection Officer, please contact us via dedicated web form available at https://consumer.huawei.com/no/legal/privacy-questions/.

Last updated: [29^th of March, 2021]

Privacy Notice for Huawei’s Social Media Marketing Campaigns

a) Data Controller

From time to time, Huawei [Huawei Technologies Norway A / S, with its registered office at Rolfsbuktveien 4C, 1364 Fornebu, Norway] (hereinafter referred to as "we" or "Huawei") may organize Social Media marketing campaigns, such as raffles, lotteries, lucky draws, competitions and other similar marketing events (hereinafter referred to as the “Campaigns”) on Huawei Social Media Fan Page available on the Social Media Platforms [Facebook / Twitter / Instagram / YouTube / LinkedIn] (hereinafter referred to as “Social Media Platforms”). If you decide to access and interact with such Campaign as a participant, we will process your personal data in the capacity of data controller.

b) Processing purpose and legal basis

The personal data of the Campaign’s participants is processed for the purpose of fulfilling Huawei’s legitimate interests (Article 6 (1) (f) of the GDPR), respectively organizing Campaigns and other similar marketing events, in order to promote Huawei's business and products, as well as to increase the brand notoriety and, implicitly, the Huawei fan community. In this case, the fundamental interests, rights and freedoms of the data subjects do not prevail over the legitimate interests of Huawei.

Where documents produced within the framework of organising contests and other marketing and promotional events may serve the purpose of ensuring that applicable tax and accountancy-related obligations are fulfilled, Huawei may process selected personal data based on applicable laws. Where this is the case, Huawei will include such information in Terms and Conditions of the respective Campaign.

For more information regarding the Campaign to which you are participating, please also read the Terms and Conditions of the respective Campaign.

c) Categories of personal data concerned

Within the Campaigns we only process the personal data you provide to us for the Campaigns or that is necessary for the procedure of the Campaigns. This may concern in particular:

Social Media Platform ID / username and profile picture to identify the participants and determine the winners;
Your content or activity necessary to participate in the Campaigns (e.g., comment, like, photo, drawing, post, transfer of a link);
Contact details and other information of the winners to validate them and deliver the prizes (e.g. name and surname, delivery address, e-mail address / telephone number, age, citizenship, tax identification number, national identification card number);
Any additional information relevant to the Campaign (e.g., exclusions, previous participations).

Please consider that the privacy policy and Terms and Conditions of the Social Media Platform additionally applies here for the separate data processing of the Platform. We encourage you to use the relevant option made available by the provider of the Social Media Platform to access this documentation. Usually this documentation can be accessed by options available at the bottom of webpages within Social Media Platform, or in your account settings.

There is no legal or statutory obligation to provide this personal data; however, failure to provide this information will result in us being unable to consider you as a participant and / or winner when awarding prizes.

d) Duration of data storage

The personal data of the Campaign participants will be retained for [6 months] from the closing date of the Campaign and will then be deleted unless there is a legal obligation to store them.

The personal data of the Campaign winners will be retained for [12 months] from the closing date of the Campaign and will then be deleted unless there is a legal obligation to store them.

[The personal data and contributions posted on Huawei’s fan pages available of the Social Media Platform will remain published until Huawei will close or delete its fan pages.]

The deletion of the comments and other interactions you leave on the Social Media Platform is governed by the Privacy Policies of the Social Media Platform provider, as mentioned above. As a general rule, if you have provided a comment to any of our posts, such comments will be deleted at the time when the post in question is deleted or when you choose to delete your own comment. We may, however, choose to delete specific comments at an earlier point in time.

e) Transfer and disclosure of personal data

We process your personal data within the EU / EEA.

We may share your personal data in some cases to service providers who are directly involved in the Campaign as a partner (e.g., another company, co-organizer of the Campaign) or who are processing the data on our behalf (e.g., marketing agency). The processing of personal in relation to our service providers is always commissioned by us and the parties will act only on our behalf as data processors. Such processing is always protected with contractual arrangements to ensure that your personal data is processed in accordance with the laws and good data processing practices. Huawei and its data processors shall establish technological, physical, administrative and procedural safeguards all in line with the industry accepted standards in order to ensure the confidentiality, integrity and accessibility of the personal data processed.

Depending on the local requirements of your country, the announcement of the winners may be made public by revealing your full name, Social Media Platform ID / username and the prize and value thereof within the Social Media Platform.

In addition, due to the nature of the Internet, your personal data and contributions published by you on this or other pages of the Social Media Platform are available worldwide. You understand that these personal data and contributions, once posted on the Social Media Platform may be taken and distributed in the online environment outside the control of Huawei, who is not responsible for such distributions or subsequent downloads by others.

f) Rights of the data subjects

As a Data Subject, you have the following legal rights in relation to your Personal Data. These rights may be subject to certain conditions, limitations and legal exceptions.

Right of Access	You have the right to obtain from Huawei confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to a copy of the personal data and specific information about how Huawei processes the personal data.
Right of Rectification (Correction)	You have the right to obtain from Huawei the correction of inaccurate personal data concerning you and also the right to have incomplete personal data completed.
Right of Erasure (Deletion)	You have the right to obtain from Huawei the erasure (deletion) of your personal data in particular circumstances.
Right of Restriction	You have the right to obtain from Huawei restriction of processing in particular circumstances.
Right of Objection	You have the right to object to the processing of your personal data in particular circumstances.
Right to Data Portability	You have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit those data to another controller, in certain circumstances.

Last updated: [29^th of March, 2021]