Statement About Petal Ads and Privacy
Last updated: June, 2023 November, 2023 June, 2023

Petal Ads is an ads platform provided by Huawei Services (Hong Kong) Co., Limited Aspiegel SE, a Huawei subsidiary based in Hong Kong (hereinafter referred to as "we", "us" or "our"), for advertisers to serve ads on HUAWEI and third-partypartner apps.

Aspiegel SE and Petal Ads participate in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Aspiegel's identification number within the framework is 856. Aspiegel also operates a private Consent Management Platform with the identification number 386, which is used by different HMS apps provided by Aspiegel.

This Statement describes:

1. What Data Do We Collect About You?
2. How Do We Use Your Data?
3. How Long Do We Store Your Data?
4. Do We Share Your Data?
5. What Are Your Rights and Options?
6. How to Contact Us?
7. How Do We Update this Statement?
1. What Data Do We Collect About You?

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

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

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

2. How Do We Use Your Data?

We use your personal data for the following purposes on the basis of your consent or the fulfillment of contracts:

2.1 Based on your consent

We access information from your device and use your personal data (see Section 1 for more details about the data) for the following purposes based on your prior consent.

The publisher (the operator of the app where the ad served by Petal Ads is displayed) requests the consent for Petal Ads from you. The publisher signals us your consent status, which indicates, and thus, determines whether we can access data on your device and process your data originating from the publisher app for the purposes listed below.

Use of precise location. If you have consented to location-based ads in accordance with Section 1, we may process your device's precise location to show ads based on areas and locations you have visited and in support of the other purposes explained in this Statement. We never store your precise device location to our Ads platform.

Advertisers' own targeting data. 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.

2.2 Based on our and others' legitimate interests

We use your personal data (see Section 1 for more details about the data) originating from the publisher apps for the following purposes based on our or others' legitimate interests taking into consideration your interests, rights, and expectations.

We use your personal data (see Section 1 for more details about the data) originating from your use of HMS for the following purposes based on our or others' legitimate interests taking into consideration your interests, rights, and expectations.

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 to show ads based on areas and locations you have visited. We never store your precise device location to our Ads platform.

3. How Long Do We Store Your Data?

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:

4. How Do We Share Your Data?

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, Mexico, and Malaysia. Our maintenance and data operations may require us to access your data from Türkiye, Singapore, and Malaysia.

In addition, your data may also be processed by our local customer service centers located, for example, in Egypt, Mexico, Colombia, South Africa, Malaysia, and Thailand, depending on the regions/countries you are currently residing in.

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.

We may carry out cross-border transfer of personal data from the Russian Federation to other regions/countries outside the Russian Federation, such as Türkiye, Singapore, and Malaysia for maintenance and data operations. You hereby give us your consent required under the Russian Federation law for the cross-border transfer of your personal data to regions/countries outside the Russian Federation.

We only share your data:

When transferring and disclosing your data outside the EU/EEA, where the local law may not provide the same level of protection, we shall comply with applicable legal requirements for providing adequate safeguards to such transfers 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.

5. What Are Your Rights and Options?

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

5.1 Access your data

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

5.2 Port your data

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.

5.3 Erase your data

You may at any time:

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.

5.4 Object to processing

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

You can object to the use of your limited HMS data for creating profiles for personalized ads by referring to the following instructions:

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.

In relation to the data we have collected about you based on our or others' legitimate interests for other purposes, you can opt-out from such processing by contacting us.

5.5 Withdraw your consent

In relation to the data we have collected about you based on your consent, you can opt-out to such processing by referring to the following instructions:

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.

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 in the following cases:

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.

5.7 Rectify your data

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.

6. How to Contact Us?

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.

7. How Do We Update this Statement?

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.