Huawei Cloud Developer Platform (hereinafter referred to as "the Developer Platform") is operated and provided by Sparkoo Technologies Ireland Co., Limited (hereinafter referred to as "Huawei Cloud", "we", "us", or "our"). We understand how important your privacy is to you and fully respect it. Please carefully read this Privacy Statement ("Statement") before you submit your personal data to us. This Statement applies to https://developer.huaweicloud.com/eu/ ("Website"), and use of all our products and services that contain or refer to this Statement (collectively "services").

This Statement describes how we collect, use and disclose your personal data, as well as our legal bases for processing, and the security measures implemented by us to protect your personal data. It also informs you about your rights in connection with your personal data, and other related information you need to know before you provide personal data to us. If Huawei Cloud needs to collect your personal data that is not described in this Statement, or the collection of your personal data is beyond the claimed purposes and a direct or reasonable scope, we will provide a separate explanation through updates to this Statement, prompts on web pages, pop-up windows, internal messages, website bulletins, or other means.

You are not obliged to provide your personal data. However, if you do not provide your personal data, we may only be able to provide you with limited service within our Developer Platform or not answer your enquiries. If the processing of your personal data is necessary for the fulfilment of a contract between you and us and you do not provide the required information, we may discontinue our services. When using a specific service, you are advised to read the service statement or privacy notice in addition to this Statement.

Note: There are many services on the Developer Platform, and the content varies depending on services provided to you. This Statement is a general privacy statement applicable to the Developer Platform. We have the right to release separate privacy policies for specific products or services on the Developer Platform. You shall fully read and agree to the content of the separate privacy policies before using the specific products or services. If this Statement is inconsistent with Applicable Laws and regulations, the stricter requirements shall prevail. 

We have created this Statement to help you understand:

1. How We Collect Your Personal Data

2. How We Process Your Personal Data

3. How We Use Cookies and Similar Technologies

4. How We Share Your Personal Data

5. How We Protect Your Personal Data

6. How Long We Retain Your Personal Data

7. How to Access and Control Your Personal Data

8. How We Handle Personal Data of Children

9. How Your Personal Data Is Transferred

10. How We Update this Statement

11. How to Contact Us

1. How We Collect Your Personal Data

1.1 Personal data means any information relating to identified or identifiable natural person, directly or indirectly, including information that can identify an individual when taken in combination with other information to which we have or are likely to have access.

1.2 We collect your personal data as set out in this Statement. Depending on your use of the Developer Platform, we collect the following personal data:

(a) Personal data provided when you enable our services on the Developer Platform, including your Huawei Cloud account name.

(b) Personal data provided when you perform developer real-name authentication, including your name, email address, country/region, mailing address, ID card number (or passport or driver's license number), and a scanned copy of your ID card, passport, or driver's license.

(c) Personal data provided when you apply for application building and authentication, including your company name, your company contact information (such as name, position, email address or phone number) and your company Certificate issuer information (such as name, position, digital signature).

(d) Personal data provided when you join the Huawei Cloud Developer Program (HCDP), including your name, email address, phone number or your basic information (such as country/region, job information, professional and education information) or your company name and your company contact information (such as name, position, email address, or phone number).

(e) Personal data provided when you join the Huawei Cloud Developer Experts (HCDE), Huawei Cloud Developer Group (HCDG), or Huawei Cloud Student Developers (HCSD), including your name, email address, phone number, photo, certificate information or your basic information (such as country/region, job information, professional and education information) or other information you provide to us.

(f) Personal data provided when you participate in activities or competitions, including your name, phone number, email address, mailing address, your basic information (such as country/region, job information, professional and education information) and your submission for the competition.

(g) Personal data provided when you participate in exams, courses, and exercises in the Developer Institute, including your exam, learning, and exercise information.

(h) Personal data provided when you contact us for support or help from us through the service ticket, including account name, phone number, email address and other information you submitted.

(i) Personal data provided when you participate in community (including forums and blogs) activities, including nickname, avatar, blogs, posts, comments and likes.

(j) Personal data provided when you claim benefits, including the name and email address of your contact person at Huawei Cloud, the Huawei Cloud account ID that will be using the coupons. If you need to use the coupons issued by Huawei Cloud, applicants of coupons shall be entitled to give you coupons to your Huawei Cloud account when you and/or applicants of coupons conclude this Statement with us.

(k) Personal data provided when you participate in the questionnaire survey, including your telephone number, email address, and basic information. (Country and region, job information, professional and educational information).

(l) Personal data obtained and collected automatically by us when you access the developer platform, including your browser history, access date and time, network link information (such as IP address).

2. How We Process Your Personal Data

We process your personal data for the following purposes:

(a) Provide Services: Identifying you as a developer and providing you with developer services, including learning, exchanges with other developers, competitions, and technical support and incentives for application certification and development.

(b) Perform marketing: Sending you notifications or marketing messages related to developer services by phone or email. If you do not wish to receive messages, you can disable them at Developer Center > My Settings > Notifications.

(c) Communicate: Responding to your requests, inquiries, comments or suggestions about us.

(d) Evaluate and improve Services: Evaluating and improving the services through troubleshooting, internal audits, data analysis and research.

(e) Ensure security: Ensuring the security of the services and our customers or users, executing and improving our loss prevention and anti-fraud programs.

(f) Comply with Applicable Law: Complying with and enforcing applicable legal or regulatory requirements, or industry standards.

(g) Obtain consent: Any other purposes which we may separately notify you and obtain your consent for.

We process your personal data on one or more of the following legal bases:

(a) As necessary to enter into a contract with you or a legal entity you represent, or to perform our contractual obligations, e.g. to provide services, to respond to requests from you, or to provide customer support;

(b) Where processing is based on our legitimate interests and those of third parties as described in this Statement;

(c) When necessary to comply with applicable law and relevant legal obligations;

(d) When you have given your consent.

3. How We Use Cookies and Similar Technologies

To ensure our services work correctly, we may at times place cookies and similar technologies (collectively cookies) on your computer or mobile device. Please refer to our Cookie Policies [https://www.huaweicloud.com/eu/declaration/sa_cookies.html] for details on the cookies we use. This Statement applies to how we process your data with the use of cookies.

4. How We Share Your Personal Data

Sharing means providing third parties with personal data, where such third parties would handle the personal data independently of us or on our behalf. We do not share your personal data with third parties without your consent, except in the following circumstances or as described in this Statement:

(a）Third parties under your instruction. We may share your personal data with your consent and/or in accordance with your instructions.

(b) For compliance, fraud prevention and security. We may share your personal data for complying with applicable laws and regulations and enforcing or applying our terms or agreements, for purpose of protecting rights or property of Huawei Cloud, our customers and/or the public. For example, we may share your personal data, when we believe sharing is necessary or appropriate to prevent or defend cyber threat, fraud, physical harm, or financial loss, or when it is in connection with an investigation of suspected or actual illegal activity.

(c) Affiliates. We may share your personal data with our affiliates including Sparkoo Technologies Hungary Limited Liability Company located in Hungary for purposes of services support, delivery and maintenance support, customer service support and technical support or security support. Your personal data will be shared only for reasonable purposes and to the extent required by the services.

(d) Public sharing. In light of the nature of forum services provided by Huawei Cloud Developer Platform, your posts, comments, nickname and avatar will be shared publicly.

5. How We Protect Your Personal Data

We take the security of your personal data seriously. We take appropriate physical, organizational, and technical measures to protect your personal data. For example, we use encryption to ensure data confidentiality; we use protection mechanisms to prevent malicious data attacks; we deploy access control mechanisms to ensure that only authorized personnel can access your personal data; and we raise awareness among employees about the importance of protecting personal data through security and privacy protection training sessions. To this end, we take the following measures:

(a) We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed.

(b) We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data in transmission. We implement protection mechanisms to protect data and data storage servers from attacks.

(c) We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels.

(d) We strictly select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities.

(e) We hold security and privacy protection training courses, tests, and publicity activities to raise employees' personal data protection awareness.

(f) Although we protect your personal data, you are responsible for safekeeping your login data including account name and passwords.

If you find your account name is used by others without your permission, please promptly notify us. You have the right to request us to suspend any unauthorized use of your Account.

In a word, Huawei Cloud is committed to protecting your personal data.

6. How Long We Retain Your Personal Data

We will retain your personal data for no longer than is necessary for the purposes set out in this Statement, unless otherwise required by laws or requested by you. The data storage period may vary depending on the processing purpose and the relevant service.

We will maintain your account information as long as is necessary for us to provide the services to you or to perform our obligations or exercise our rights under agreements related to the services. You can choose to close your Account. After you close your Account, we will stop providing you with the services and delete your relevant personal data within reasonable time (generally lasts for six (6) months), provided that we are not required to continue to process certain of your personal data by law, e.g., for accounting or bookkeeping purposes or to perform our obligations or exercise our rights under agreements related to the services.

7. How to Access and Control Your Personal Data

You should provide us with correct personal data. We are dedicated to maintaining the accuracy and completeness of your personal data and keeping your personal data up-to-date based on the information you provide to us.

According to applicable laws and regulations of some countries and/or regions, data subjects may have rights to make requests (hereinafter referred to as "requests") of in particular accessing, correcting, deleting or erasing the personal data retained by us.

You can easily amend and control the personal data we hold about you as follows:

(a) Account information: If you want to add or update personal data related to your developer identity, please log in to the Developer Center, and go to My Settings > Developer Info.

(b) Cookies: Regarding the management of Cookies, please see our Cookie Policy.

You may have the following rights regarding your personal data under applicable laws:

(a) The right to access the personal data we hold about you and obtain copies thereof;

(b) the right to request us to update or correct your personal data;

(c) the right to request us to erase your personal data;

(d) the right to object to our processing of your personal data;

(e) the right to restrict our processing of your personal data;

(f) the right to obtain the personal data you provided to us in a structured, commonly used and machine-readable format and to have us transfer it to a third party of your choice (data portability); and

(g) the right to lodge a complaint with the competent data protection authority.

Please note that these rights are not absolute and may be restricted in accordance with applicable laws. If you need our assistance to exercise the rights above, please contact us as set out in "11. How to Contact Us" below.

Generally, we will respond to you within 30 days, unless otherwise required by applicable laws. Depending on the complexity of your requests, we may extend the period by a further two months. In this case, we will inform you of the extension and its reasons within one month of receiving your request. Please note that under some circumstances, for example where we cannot verify your identity, we may need to request additional information in order to verify your identity, otherwise we are prohibited by law from giving effect to your request, or your request exceeds your rights under applicable laws, we may refuse your request. In this case, we will inform you that your request is refused together with the reasons for our refusal.

You can withdraw your consent, without affecting the lawfulness of the processing activities based on the consent and prior to such withdrawal. Your right to withdraw consent can be exercised by setting privacy options on your Account or unsubscribing via link sent in an email / SMS / other message. Disabling related services or deleting your Account will be treated as withdrawal of consent, where consent is collected. You may also seek help by contacting us as set out under "11. How to Contact Us ".

You can delete your Account in the account-related services. After you delete your Account, we will stop providing services, and delete your personal data unless otherwise stipulated by law. Your Account cannot be restored after deletion. You need to register a new Account if you want to use related services again.

8. How We Handle Personal Data of Children

Our services are only intended for adults. Minors are not allowed to create their user account.

(a) If Huawei Cloud finds that the personal data of minors is collected without the consent of parents or guardians, Huawei Cloud will attempt to delete such content immediately.

(b) If the Enterprise User is using the Huawei Cloud Service for educational purposes and the End User may be a child, the Enterprise User has been prompted to ensure that the End User has obtained the explicit consent of his/her parents or guardians before using the Service.

9. How Your Personal Data Is Transferred

Our services are deployed at Ireland, and we serve you through our global resources. In order to provide the services to you, your personal data may be re-transferred to countries/regions where Huawei Cloud's affiliates are located. This means your personal data may be transferred to countries or regions outside the places where you are located or where we collect your personal data, and be accessed and stored in those jurisdictions.

These jurisdictions may have different data protection laws, which may impose less stringent data protection requirements. In such cases, we will ensure the transfer is in accordance with applicable laws and regulations (including by ensuring that overseas recipients are subject to confidentiality and data protection obligations where appropriate), as well as this Statement.

10. How We Update this Statement

We may update or modify this Statement from time to time according to changes in our services or data processing. If we update this Statement, we will publish the latest version of the Statement on the Website or by otherwise notifying you. The modified terms will come into effect immediately upon posting or otherwise notified by us. You are encouraged to review this Statement periodically for any changes. We will always indicate the date the last changes were published.

11. How to Contact Us

We have appointed a Data Protection Officer ("DPO"). If you have any questions, comments, or suggestions, please contact us or submitting them to our office at 2nd Floor, Mespil Court, Mespil Road, Ballsbridge, Dublin 4, Dublin, Ireland D04 E516. If you want to exercise your privacy rights, or wish to raise or consult us on any privacy issues please visit our Data Subject Right Portal. You can also contact the DPO by dpoie@huaweicloud.com. You can also raise a concern or lodge a complaint with a data protection authority or other official with jurisdiction.

 

Updated: December 13, 2023