This Statement describes:

We shall collect and use the following personal data for the purposes of Petal Ads:

• Account information, such as, age, gender and account identifier, if you have logged in with your HUAWEI ID account.

• Device information, such as Huawei device's advertising identifier (if your device has Huawei Mobile Services, hereinafter "HMS"), Google advertising identifier (if your device has Google Mobile Services, hereinafter "GMS"), device identifier, device brand, device model and type, operating system version, carrier information, precise location, screen resolution, language settings, processor, memory, and storage information, and device usage time.

• Network information, such as IP address, network type, Wi-Fi name, MAC addresses of Wi-Fi and Bluetooth hotspots, and Internet access information. We use the IP address to obtain the approximate location (city/country or region level).

• Service usage information, such as in-app purchases (no additional details are collected, e.g. about what was purchased and where), ad event data (e.g. clicks and click positions on the screen) from Huawei and third-party apps serving you ads using the Petal Ads platform, information about the clicked content (e.g. which brand, price, and industry), information about apps (name and category) you have installed from HUAWEI AppGallery and used during the last 30 and 180 days, and videos you have watched in HUAWEI Video. the following information about your use of HMS and your interactions with ads served by Petal Ads.

If you have Petal Ads personalization enabled on your device, the personal data may be used for serving you more relevant ads on Huawei Mobile Services and third-party apps by the Petal Ads platform. You can at any time object to such ads personalization in accordance with Section 5.4. If you have disabled ads personalization, general factors such as the content you are viewing, approximate location (based on the IP address), device language settings, and device model will be used for serving you contextual ads. In addition, Petal Ads will recognize which apps are installed on your device without saving such information to any server or linking it to you. In this way, you can be shown appropriate app ads (e.g. the ads will not encourage you to install apps you have installed on your device).

We use data about your use of HMS to serve you personalize ads as follows:

• Based on your HUAWEI AppGallery activities we create segments such as games, music, sports, videos, TV, communication, housekeeping, weather and calendars, maps, navigation, transportation, cars, screen locks, wallpapers, well-being, photography, e-books, news, audiobooks, magazines, humor, travel, and recruitment based on the apps you have installed. The segment is created based on the nature of the installed app(s). The data about app installations can also be used together with other data mentioned in this Section to create segments.

  In addition, Petal Ads will recognize which apps you have installed on your device to show appropriate app ads (e.g. the ads will not encourage you to install apps you have already installed on your device), and to enable measurement and reporting of app downloads for Petal Ads advertisers as a campaign metric.

• Based on your HUAWEI Video activities we create segments for advertisers such as cartoon, crime, interview, music, food, fashion, cars, fantasy, education, literature, technology, family and sport based on the videos you have watched. The segment is created based on the nature of the watched video(s). The data about watched videos can also be used together with other data mentioned in this Section to create segments.

• HUAWEI ID account information is used for creating age and gender segments. If you do not have a HUAWEI ID account, we may infer your age and gender using data mentioned in this Section.

• HUAWEI IAP information is used for creating segments about payment status (paying user or non-paying user) based on whether you have made in-app payments with HUAWEI IAP or not.

  In addition, EMUI operating systems operated by Huawei Device Co., Ltd. will inform the Petal Ads platform about the fact that payments have been made on your device (no additional details are collected, e.g. about what was purchased and where).

We use data from apps serving you ads via the Petal Ads platform as follows:

• When any app you are using is serving ads from the Petal Ads platform, that app will act as a source of data for Petal Ads for ads personalization purposes and shares information about the app you are using (e.g. app name, version, and app usage times and frequency), contextual information (e.g. what type of video you are watching at the time the ad is served), your device's advertising identifier, advertisement/campaign identifier, IP address, device information (e.g. brand and model), and app installation information, operating system information, network type, carrier information, location data (if you have authorized use of location data). We may also receive a consent string that indicates your consent and objection preferences and will process your data accordingly. We will receive the data every time the third-party app makes an ads request to Petal Ads. Also, data about how you interact with ads from Petal Ads (ad clicks, downloads, views, plays, etc.) is collected. This data allows us to create segments based on for example the nature of the apps you are using and frequency of such use as well as the nature of the content you are viewing, and can be used alone or together with other data mentioned in this Section to create segments. Such information is also used for other purposes, including performance measurement, fraud prevention, and reporting as detailed in Section 2 of this Statement.

We use your device location information for location-based ads as follows:

• If you have enabled ads personalization and consented to location-based ads on HMS devices, we may process your GPS information together with your Huawei device's advertising identifier to derive location categories of locations you have visited during the past 30 days, such as business district, residential area, business building, industrial park, university, airport, train station, bus station, subway, library, and museum.If you have consented to location-based ads on HMS devices, we may process your precise location (via GPS/GNSS and network information) together with your Huawei device's advertising identifier. In addition to identifying your visits to different countries and cities, precise location allows us to identify other location categories you have visited such as business district, residential area, business building, industrial park, university, airport, train station, bus station, subway, library, and museum. In addition, we may use Wi-Fi names to assess the categories of locations you have visited (e.g. airport, when the Wi-Fi name includes "airport").

• If you have enabled location permission for the app serving ads by the Petal Ads platform, we may also use your device's location to show ads based on areas and locations you have visited.

• We may obtain your location either directly from your device using its GNSS locating capabilities (whereby the device obtains the location from the satellites) or via the HMS Core Location service, which calculates your location based on network information (such as Wi-Fi/Bluetooth hotspots and cell tower locations). This is done by approximating your location by comparing the network information (such as the Wi-Fi networks, specific types of Bluetooth devices and cell towers sending signals to your device) surrounding your current location to the HMS Core Location service's location database. For more information about the Huawei Location service, go to Settings > Privacy > Location services on your device (please note that the place of settings may vary depending on your operating system version).

• We may use federated learning on your device for serving you more relevant ads. If smart ads are enabled, we will use local, on-device processing to select ads for the crowd, rather than individual persons. We will use data stored on your device, such as installed apps, app usage, device, location, and app information. You can at any time disable smart ads in accordance with Section 5.4.

We use your personal data for the following purposes with your consent based on legitimate interests pursued by us:

• For understanding users' preferences to enable targeted advertisement to suit their interests. The processing also enables advertisers using the Petal Ads platform to focus their advertising to right people at the right time.

  We use users' data to create different segments based on similar characteristics shared by users. The abovementioned data is used to determine which segments you are assigned to. Advertisers can use these segments to create specific target groups for their ads. You can find more information about how to access and control such segments from Section 5. We never enable or allow advertisers to target users based on sensitive data such as data relating to health, sexuality, religious beliefs, or political affiliations. In order to protect children from any potential harm caused by advertising, we do not knowingly serve personalized ads to children and aim to filter and limit ads which may not be suitable for children. If an ads request from any app indicates that the user is a child, we will only serve contextual ads and not store or use any data for profiling. Also, personalized ads will be disabled by default on HMS devices for users logged in with a HUAWEI ID child account or if the HMS device has been set specifically for a child user.

  We do not share or make visible to advertisers or any other third parties any segment information which could be associated or linked to you as a specific user. We make sure that no ads are delivered if there are less than 5,000 users in any specific target group created by the advertiser.

• Advertisers can use their own user information to create marketing audiences and to target specific users via Petal Ads based on their device and other advertising identifiers. Advertisers are required to obtain consent from their users to conduct such targeting. There needs to be at least 5,000 users in such target group. Advertisers can also target similar users based on the initial audience created by them. Advertisers are prohibited under Petal Ads policies from targeting users based on their sensitive characteristics, such as health, sexuality, religious beliefs, or political affiliations.

• For collecting statistical data about your ad clicks and actions, such as open, download or play different ad content in HUAWEI and partner apps as well as about HUAWEI AppGallery app installations and activations. This data is used for handling our business relationship with advertisers and for reporting and measuring their ads performance. We share aggregated reports with the advertisers. This serves our commercial interests, because we get paid by advertisers for ads placement and performance.

• In addition to sharing aggregated reports with advertisers, the Petal Ads platform makes available to given advertisers the following information regarding how you interact with their ads: device's advertising identifiers with information about the app that is showing you the ad (e.g. app name, version, language, and country/region), device information (e.g. brand, model, screen resolution, and operating system information), network information (e.g. IP address, carrier information, and network type), advertisement/campaign identifier, and ads events (e.g. ads views, clicks, plays, and downloads). Advertisers process the data in accordance with their privacy policies and may use it for attribution analysis, conversion tracking, anti-cheating, and effect evaluation purposes. The processing serves our and our advertisers' commercial interests as it allows advertisers to analyze how users interact with their ads and the effectiveness of such ads. Advertisers may also use the data for their remarketing activities on Petal Ads or other ads platforms (e.g. target you, or similar users, based on the fact that you have visited their app or webpage), if you have given consent to the advertisers for such processing. Advertisers are prohibited under the Petal Ads policies from using the data for creating or supplementing their user profiles or creating target groups based on sensitive data such as data relating to health, sexuality, religious beliefs, or political affiliations.

• For analytics and development purposes in order to understand our users' needs as customers and to improve the quality and user experience of our current and future services and offerings.

• For detecting fraud (e.g. an attacker using automatic software to click systematically on an advertisement) and safeguarding advertisers from being unfairly charged. For example, we may analyze how users interact with the touchscreen (e.g. how the screen and which screen position is touched) and how the device is moving (based on the device's sensor data) to detect and prevent fraudulent ad clicks.

• For data security purposes to provide you with secure and reliable services.

Third-party apps serving you ads from Petal Ads are required to obtain your prior consent for accessing your device's advertising identifier and allowing sharing and use of your data for personalizing ads as provided by this Privacy Statement. We will process your data in accordance with any consent string transmitted to us by the app indicating your preferences as to consents and objections for specific processing purposes. If you have not given your consent for ads personalization for the app, you may still receive contextual ads from Petal Ads based on general factors such as the content you are viewing, approximate location (based on the IP address), device language settings, and device model.

If you have consented to location-based ads in accordance with Section 1, we may process your GPS and Wi-Fi information device's precise location to show ads based on areas and locations you have visited. We never store your precise device location to our Ads platform.

The personal data used for ads personalization is retained for one (1) years from the time of collection. Once the retention period expires, we will delete or anonymize your personal data, unless otherwise required by laws and regulations. Any data processed for serving contextual ads is erased in seven (7) days from collection. In addition, we shall retain:

• Personal data processed for customer relationship management such as complaints, data subject requests, consent records, and contract management purposes up to five (5) years.

• Personal data that is used for analytical and development purposes up to twelve (12) months from the collection, unless you have objected to such processing.

• Backups and app logs, which are processed for ensuring the security of your data and services, for up to 6 months from the date they were created.

We store your data in the data centers located in Hong Kong (China) and Singapore the data centers located in the European Union (EU)/European Economic Area (EEA) the data centers of our supplier located in the Russian Federation operating under contract and acting on behalf of us as a data processor.

Our business operations may require us to access your data from the United Arab Emirates, South Africa, Nigeria, Malaysia, Philippines, and Kenya and our maintenance operations may require us to access your data from India.

In addition, your data may also be processed by our local customer service centers located, for example, in Egypt, Mexico, India, South Korea, and Pakistan, if you are currently residing in any of these countries/regions.

Our business operations such as marketing, surveys, sales promotion, business development, and customer support may require processing of your personal data by our suppliers operating under contract and acting on behalf of us as a data processor located in the Russian Federation and/or in the EU/EEA.

We may carry out cross-border transfers of personal data from the Russian Federation to other countries such as Ireland and Finland and other regions/countries outside the EU/EEA and Russian Federation. You hereby give us your consent required under the Russian Federation law for the cross-border transfer of your personal data to the countries outside the Russian Federation.

We only share your data:

• Our third-party vendors, who provide us with IT (including cloud-based) and business support as well as customer care services, may need to process your information. All such third parties are operating under contract and acting on behalf of us and located in the EU/EEA.

• When required in response to a legal process or request from a competent authority according to applicable laws or in connection with legal proceeding or process.

• 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 other company.

• In addition to sharing aggregated reports with advertisers, the Petal Ads platform makes available to given advertisers the following information regarding how you interact with their ads: device's advertising identifiers with information about the app that is showing you the ad (e.g. app name, version, language, and country/region), device information (e.g. brand, model, screen resolution, and operating system information), network information (e.g. IP address, carrier information, and network type), advertisement/campaign identifier, and ads events (e.g. ads views, clicks, plays, and downloads). Advertisers process the data in accordance with their privacy policies and may use it for attribution analysis, conversion tracking, anti-fraud, and effect evaluation purposes. The processing serves our and our advertisers' commercial interests as it allows advertisers to analyze how users interact with their ads and the effectiveness of such ads. Advertisers may also use the data for remarketing purposes (e.g. target you based on the fact that you have visited their app or website) and other advertising personalization, if you have given consent to the advertisers for such processing.

You have the following data subject rights and choices regarding your personal data.

The Petal Ads platform creates user segments for advertisers based on users' HUAWEI ID account information and other interactions with HMS and third-party apps.

If you are using an HMS device, you can see segments which you have been included in (based on your HMS device's advertising identifier) and which are available to Petal Ads advertisers by going to Settings > Privacy > Ads and privacy > More information > Ad information, or Settings > HMS Core > Ads > More information > Ad information, or Settings > Privacy > HMS Core > Ads > More information > Ad information, or Settings > Security & privacy > More settings > Device identifier > More information > Ad information on your device depending on your operating system version. To safeguard this information against misuse, the segments will only be visible on the Ad information page if you are logged in to your HUAWEI ID account. You may also log in to your HUAWEI ID account and go to device Settings > Account center > Privacy center > Configure Your Privacy Settings > Ads personalization to access the segments.

You can also access these Privacy center settings from the HUAWEI ID web portal.

If you do not have a HUAWEI ID account and want to access such segments, including segments created based on your GMS device's advertising identifier, or have other requests about accessing your data, please contact us.

You can request your personal data, which you have provided to us, to be ported to you in a commonly used machine readable format by contacting us.

You may at any time:

• Object to the processing of your data, as detailed in Section 5.4. If your objection is valid, and we no longer have legal basis to continue processing your data, we will erase or anonymize the relevant data within your effective objection. You can also choose to reset your device's advertising identifier by referring to the following instructions:

  • If you are using an HMS device, go to Settings > Privacy > Ads and privacy, or Settings > HMS Core > Ads, or Settings > Privacy > HMS Core > Ads, or Settings > Security & privacy > More settings > Device identifier depending on your operating system version. On your smart TV, go to Settings > System > HMS Core > Ads. In this case your device will generate a new random identifier, and the data associated with your previous advertising identifier will not be linked to the new identifier.

  • If you are using a GMS device that does not have the above mentioned HMS device settings, please use Google's advertising settings from Settings > Google > Ads > Reset advertising ID on the device.

• Contact us if you think the processing of your personal data is unlawful and your data should be erased.

We shall erase or anonymize your personal data without undue delay in accordance with the retention periods detailed in Section 3. When you disable personalized ads, it may take us up to 7 days to fully erase or anonymize your data from our ads personalization systems. If you object to the processing for analytical and development purposes, it may take up to 14 days to fully erase all data processed for such purposes.

You can at any time opt-out from processing of your personal data for personalized ads by referring to the following instructions:

• If you are using an HMS device, select Disable personalized ads from Settings > Privacy > Ads and privacy, or Settings > HMS Core > Ads, or Settings > Privacy > HMS Core > Ads, or Settings > Security & privacy > More settings > Device identifier depending on your operating system version. On your smart TV, go to Settings > System > HMS Core > Ads. If you object to ads personalization, your Huawei device's advertising identifier will be replaced with a non-unique value of all zeroes to prevent targeted ads being served to you.

• If you are using a GMS device that does not have the above mentioned HMS device settings, please use Google's advertising settings from device Settings > Google > Ads > Opt-out of Ads Personalization or Delete advertising ID depending on your operating system version.

If you have disabled ads personalization, the ads will be delivered based on general factors such as the content you are viewing, device language settings and device model, or as smart ads.

You can at any time select Disable smart ads from Settings > Privacy > Ads and privacy > More information, or Settings > HMS Core > Ads > More information, or Settings > Privacy > HMS Core > Ads > More information, or Settings > Security & privacy > More settings > Device identifier > More information, depending on your operating system version.

If you want to object to the processing of your data for analytical and development purposes, please contact us.

You can also choose to reset your device's advertising identifier as instructed in Section 5.3. In this case your device will generate a new random identifier, and the data associated with your previous advertising identifier will not be linked to the new identifier.

If you have consented to a third-party app for sharing your data with Petal Ads for purposes mentioned in this Privacy Statement, you need to withdraw your consent from that app to indicate you no longer want that app to share data with us.

If you have given your consent on an HMS device for the processing of your location data for serving location-based ads, you can withdraw your consent by going to Settings > Privacy > Location > System services on the device.

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 in the following cases:

• 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.

• You have contested the accuracy of your personal data and the accuracy of your data is pending our verification.

• Your request for objection is pending our verification.

When submitting the request, please specify the scope and the basis of the request. We will contact you to verify your identity in order to proceed with your request.

You can access and modify the segments you are included in based on your HMS device's advertising identifier and which are available to Petal Ads advertisers by going to Settings > Account center > Privacy center > Configure Your Privacy Settings > Ads personalization. By touching any segment, you can disable it (e.g. if you think the segment is not accurately depicting your interest or demographic information is not accurate) and it will no longer be associated with your device. You can also modify HUAWEI ID account information based segments by updating your account information by going to Settings > Account center > Personal info.

You can also access these Privacy center settings from the HUAWEI ID web portal.

If you do not have a HUAWEI ID account and want to access and rectify such segment data, including segments created based on your GMS device's advertising identifier, or have other requests about rectifying your data, please contact us. When submitting the request, please specify which data you think is inaccurate or incomplete.

You can find guidance on how to exercise your data subject's rights in Section 5. If you have any questions 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: Huawei Services (Hong Kong) Co., Limited, Room 03, 9/F, Tower 6, the Gateway, No. 9 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong. Registration number 1451551. Aspiegel SE, 3rd floor, Mespil Court, Mespil Road, Ballsbridge, Dublin 4, D04 E516, Ireland. Registration number 561134.

If you are using the service with a device that does not support the above hyperlink (such as with a Huawei smart TV), please contact us via https://consumer.huawei.com/en/legal/privacy-questions/ using another device, such as a PC.

If you believe 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 the data protection authority in your country/region, or the Privacy Commissioner for Personal Data in Hong Kong (China) 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.