Huawei Cloud KooPhone App ("KooPhone App", "KooPhone Service", or "Service") is provided and operated by Huawei Cloud ("we", "us", or "our"). We understand and fully respect how important your privacy is to you. Please read this Privacy Statement ("Statement") carefully before you submit your personal data to us.

This Statement describes how we collect, use, and disclose your personal data, as well as our legal bases for processing, and the security measures we implement to protect your personal data. It also lists your rights in connection with your personal data, and other related details you need to know before you provide personal data to us. We may inform you of product- or service-specific data collection that is not reflected in this Statement through supplementary policies or notices provided before the corresponding collection of your personal data.

By interacting with us, using our Website, submitting information to us, or signing up for our Services, you agree and consent to Huawei Cloud (including its affiliates), as well as our third-party service providers, representatives and/or agents, collecting, using, and disclosing your personal data in the manner set forth in this Statement.

We have created this Statement to help you understand:

1. How Huawei Cloud KooPhone App Collects Your Personal Data
2. How Huawei Cloud KooPhone App Processes Your Personal Data
3. How Huawei Cloud KooPhone App Shares Your Personal Data
4. How Huawei Cloud KooPhone App Protects Your Personal Data
5. How Long Huawei Cloud KooPhone App Retains Your Personal Data For
6. How to Access and Control Your Personal Data
7. How Huawei Cloud KooPhone App Handles Personal Data of Minors
8. How Your Personal Data Is Transferred Across Country Borders
9. How This Statement Is Updated
10. How to Contact Huawei Cloud
11. Additional Information for Certain Jurisdictions

 

1. How Huawei Cloud KooPhone App Collects Your Personal Data

Personal data means any information (whether true or not) relating to an identified or identifiable natural person, including information that can identify an individual when taken in combination with other information to which we have or are likely to have access. We collect personal data from you in the course of your interaction with us for various purposes, such as providing you with the best possible service from KooPhone Service and its Apps. Your interaction with us may include: logging in to the App, accessing KooPhone Service, and using Apps installed in KooPhone Service.

If you provide us with any personal data relating to a third party (e.g. information of your employees and/or end users), by submitting such information to us, you represent and warrant to us that you have notified such third parties of the terms of this Statement, and that such third parties have consented to you disclosing his/her personal data to us for the collection, use, and disclosure of their personal data by us as described in this Statement.

Depending on your use of the Services, we collect the following personal data:

a) Personal data provided when your account administrator registers a KooPhone account for you, including account information (such as account name, accout ID, password);

b) Personal data provided when you use the Phone App or Messaging App in KooPhone Service, including phone number;

c) Personal data provided when you encounter faults in KooPhone App, including fault log information (such as app system error log, os logcat, brand, manufacturer, model, os version);

d) Location permission when you use location data in KooPhone Service or any App installed in KooPhone Service;

e) Media and file permission when you use KooPhone App. KooPhone App will read/modify/delete some files in your SD card;

f) Camera permission when you use the camera in KooPhone Service or any App installed in KooPhone Service;

g) Microphone permission when you use the microphone in KooPhone Service or any App installed in KooPhone Service;

h) Contacts permission when you use the Phone App in KooPhone Service;

i) Clipboard permission when you use copy and paste functions in KooPhone Service;

j) Sensor data (gravity, gyroscope, orientation, magnetic field, rotation vector, linear acceleration) when you use Apps in KooPhone Service;

k) Music and audio permission when you change audio in KooPhone Service;

l) Shortcut permission when you create app shortcuts from KooPhone Service to phone desktop;

m) Phone call permission when you use the Phone App in KooPhone Service;

n) SMS send permission when you use the Messaging App in KooPhone Service;

o) Call log operate permission when you use the Phone App in KooPhone Service.

Many of the Services require personal data to operate. If you choose not to provide the data required, you may not be able to use those Services. For example, if you do not log in with account name and password, you cannot use KooPhone App and Service; if you do not give permissions (such as location, camera, microphone, etc), Apps installed in cloud phone may not work well.

 

2. How Huawei Cloud KooPhone App Processes Your Personal Data

We process your personal data for the following purposes:

a) Account login, authentication and authorization: Provide account login, and authentication and authorization to protect account information and service security when you have given your consent;

b) Usage calculation: Calculate device manufacturer, brand, and model percentages when you have given your consent;

c) For compliance with and enforcement of applicable laws, service reliability and optimization of products and services, we will use personal data to:

(1) Handle system errors when you submit app error information to the platform.

(2) Protect Service, product, and user/customers by fraud detection.

(3) Perform internal calculation and data analysis to optimize products and services.

(4) Comply with and enforce applicable laws.

 

3. How Huawei Cloud KooPhone App Shares Your Personal Data

Sharing means providing third parties with personal data, where such third parties 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 the purposes of complying with applicable laws and regulations and enforcing or applying our terms or agreements, protecting the rights or property of Huawei Cloud, and protecting 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 against cyber threat, fraud, physical harm, or financial loss, or when it is in connection with an investigation of suspected illegal activity.

When we share your personal data with third parties, their responsibilities and obligations will be governed by contracts and we will require them to take appropriate measures to ensure the security of the personal data shared and/or processed.

 

4. How Huawei Cloud KooPhone App Protects 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 trusted 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. While we take the utmost care to protect your personal data, please note that no security measures are completely infallible. You can find more details on our security measures at Huawei Cloud Security. To this end, Huawei Cloud:

a) Sets up a privacy protection organization to identify and manage personal data protection risks;

b) Adopts strict data security and personal data protection policies in accordance with the risk of the categories of data processed. Such policies include security breach response and data breach process to reduce privacy and security risks brought by personal data breaches and guide relevant departments to handle personal data in compliance with laws and regulations;

c) Holds security and privacy protection training courses, tests, and publicity activities to raise employee personal data protection awareness;

d) Takes reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to the purposes for which they are processed;

e) Takes a range of measures such as an entrance and exit control, entrance guard systems, and CCTV surveillance to ensure the physical security of the data centers to prevent unauthorized persons from gaining access to data processing systems with which personal data is processed or used;

f) Deploys access control and hierarchical permissions management tailored to service requirements and personnel levels to ensure that only authorized personnel can access personal data;

g) Clearly defines and assigns cyber-security roles and responsibilities, and implements separation of duties (SOD) based on a risk assessment to reduce risks to prevent data processing systems from being used by unauthorized persons;

h) Encryption and pseudonymization of personal data using recommended industry standard protocols as appropriate to prevent data breach and unauthorized access;

i) Degausses the discarded storage media before returning it to the warehouse to ensure that they are overwritten prior to disposal. In cases where this is not possible (CD, DVD, etc.), physical destruction shall be performed;

j) Implements appropriate O&M security management and technical measures, including identity authentication and access control, change and event management, vulnerability management, configuration management, event logging, and continuously monitors cyber-security events and threats, detects exceptions promptly, and proactively takes measures to deal with them to ensure that personal data cannot be read, copied, altered or removed by unauthorized persons;

k) Implements mechanisms such as DDoS protection to protect networks from attacks, develops vulnerability management policies, evaluation standards, and management processes to manage security vulnerabilities throughout the lifecycle. This includes regular vulnerability scanning to detect potential security vulnerabilities and take prompt countermeasures; and

l) Strictly selects business partners and service providers and incorporates personal data protection requirements into commercial contracts, audits, and appraisal activities.

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

If you find that your account ID is being 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 summary, Huawei Cloud KooPhone App is committed to protecting your personal data. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure.

Huawei Cloud has developed several mechanisms and control measures, clear rating standards of security incidents and vulnerabilities, and corresponding processing procedures for possible risks, such as personal data breach, damage, and loss. The Huawei Cloud emergency response team implements security planning, loss reduction, analysis, locating, and remediation, and performs tracking operations with related departments in line with security incident response regulations and requirements.

 

5. How Long Huawei Cloud KooPhone App Retains Your Personal Data For

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 depends 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 which we will stop providing you with the Services and delete your relevant personal data within reasonable time unless we are required by law to continue to process certain of your personal data, e.g. for accounting or bookkeeping purposes or to perform our obligations, or exercise our rights under agreements related to the Services.

 

6. How to Access and Control Your Personal Data

It is your responsibility to ensure that all personal data submitted to us is valid. 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 us.

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

You can easily amend and control the personal data relating to you, which we hold, as follows:

Account information: To add or update personal data related to your Account, access the Website and log in to your Account via Log in > My Account. For modification of information provided through Huawei ID, please refer to Statement About HUAWEI ID and Privacy.

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

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

b) Right to request us to update or correct your personal data;

c) Right to request us to erase your personal data;

d) Right to object to our processing of your personal data;

e) Right to restrict our processing of your personal data;

f) Right to obtain your personal data and have us transfer it to a third party of your choice (data portability); and

g) Right to lodge a complaint with the relevant 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 Section 10 "How to Contact Huawei Cloud" below.

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

You can change the authorized personal data collection scope or 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, disabling related Services, or deleting your Account. You may also seek help by contacting us as set out under Section 10 "How to Contact Huawei Cloud".

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 required by law. Your Account cannot be restored after deletion. You will need to register a new Account if you want to use related Services again.

 

7. How Huawei Cloud KooPhone App Handles Personal Data of Minors

Our Services are only intended for adults. Minors are not allowed to create their own user Account. If you are a minor, you may use our Services only with the permission of a parent or guardian.

 

8. How Your Personal Data Is Transferred Across Borders

Your personal data is stored on a server located in Singapore, and we serve you through our global resources. In order to provide the Services to you, your personal data may be transferred to or accessed by countries/regions where Huawei Cloud, Huawei Cloud's affiliates, Huawei Cloud's partners are located. 

These countries/regions 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 international recipients are subject to confidentiality and data protection obligations where appropriate), as well as this Statement.

 

9. How This Statement Is Updated

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 notification. You are advised to review this Statement periodically for any changes.

 

10. How to Contact Huawei Cloud

Country/Region in Which You Are Registered	Data Controller (Entity You Are Contracted With)	Address
South Africa	Sparkoo Technologies South Africa (Pty) LTD.	Building 17 - Huawei Office Park, 124 Western Service Road, Woodmead - Johannesburg, Gauteng, 2191
Chile	Sparkoo Technologies Chile SpA	ROSARIO NORTE 530 OF 1101 LAS CONDES
Peru	Sparkoo Technologies PERU S.A.C.	Calle Las Begonias 415, Int. 2301, San Isidro, Lima 27, Perú
Brazil	Sparkoo Technologies Do Brasil Ltda.	Avenida Doutor Chucri Zaidan, S/N, conjunto 252, Edifício EZ Towers, Vila São Francisco, São Paulo/SP, CEP 04711-130
Thailand	Sparkoo Technologies (Thailand) Co., Ltd.	No. 9, G Tower Grand Rama 9, Room No. GN01-04, 35th Floor, Rama 9 Road, Huaykwang Sub-district, Huaykwang District, Bangkok Metropolis
Hong Kong	Sparkoo Technologies Hong Kong Co., Limited	7/F., Tower 6, The Gateway, No. 9 Canton Road, Tsimshatsui,Kowloon
Saudi Arabia	Sparkoo Technologies Arabia Co., Ltd.	C-Center, Prince Mohammed Road, PO Box 295320, Riyadh, the Kingdom of Saudi Arabia
Others	Sparkoo Technologies Singapore Pte. Ltd.	1 Changi Business Park Ave 1 #05-01/06 Singapore 486058

Data controller: If there are any conflicts between the table and the contracting party displayed in the Account Center, the information set out in the Account Center shall prevail.

We have set up a dedicated personal data protection department (or data protection officer). If you have any questions, comments, or suggestions, please contact us or submit them to our global offices. 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: https://www.huaweicloud.com/intl/en-us/personal-data-request.html. You can also contact us by email [dposg@huaweicloud.com]. You can also raise a concern or lodge a complaint with a data protection authority or other official with jurisdiction.

Customers from Malaysia please refer to our Privacy Statement in Malay at: https://www.huaweicloud.com/intl/en-us/declaration/sa_prp_ms.html.

 

11. Additional Information for Certain Jurisdictions

We provide additional information about our controllers and data protection officers (as applicable), the privacy, collection, and use of personal information of prospective and current customers of Huawei Cloud Offerings located in certain jurisdictions.

Türkiye

You may have the following rights regarding your personal data under the Turkish law:

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

b) Right to request us to update or correct your personal data;

c) Right to request us to erase your personal data;

d) Right to object to our processing of your personal data;

e) Right to restrict our processing of your personal data;

f) Right to obtain your personal data and have us transfer it to a third party of your choice (data portability);

g) Right to learn whether your personal data is processed or not;

h) Right to demand for information as to if your personal data has been processed;

i) Right to learn the purpose of the processing of your personal data and whether your personal data is used in compliance with the stated purpose;

j) Right to know the third parties to whom your personal data is transferred in country or abroad;

k) Right to request reporting of the operations carried out related to erasure of your personal data to third parties to whom your personal data has been transferred;

l) Right to object to the occurrence of a result against you by analyzing the data processed solely through automated systems; and

m) Right to lodge a complaint with the competent data protection authority.

 

Last Updated: April 3, 2024