3rd Party Survey Privacy Notice (Western Europe Region)

3rd Party Survey Privacy Notice (Western Europe Region)

What is this the purpose of this Privacy Notice?

This Privacy Notice gives you information about the personal data we collect about you and how and why we use that personal data.

This Notice also contains a summary of your rights in relation to your personal data.

There is a section at the end of the Notice (called the Glossary) which explains some of the terms used in this Notice.

The identity and contact details of the Controllers

Huawei Technologies Dusseldorf GmbH (our West Europe Region headquarter)

Contact: Huawei DPO office. dpo@huawei.com

Registered address: Hansaallee 205, 40549, Dusseldorf, Germany

Huawei Technologies Co. Ltd. our Chinese parent company)

Address: Huawei Base, Bantian, Longgang District, Shenzhen, China

Huawei Local Subsidiaries (limited to the subsidiary where the data subject located)

1) Name: Huawei Technologies Deutschland GmbH

Registered address:Hansaallee 205, 40549 Düsseldorf, Germany Registered Office: Düsseldorf, Register Court Düsseldorf, HRB 72992

2) Name: Huawei Technologies France SASU

Registered address:18 Quai du point du jour, 92100 Boulogne Billancourt

3) Name:Huawei Technologies Italia S.R.L.

Registered address: Via Lorenteggio 257, Torre B, 20152 Milan, Italy

4) Name: Huawei Technologies Espana SL

Registered address: C/ Federico Mompou 5, Edificio 1 planta 5, Madrid Espa?a.

5) Name: Huawei Technologies (Belgium) NV.

Registered address: Woluwelaan 2, 1150 Sint-Pieter-Woluwe Belgium

6) Name: Huawei Techologies Netherlands B.V.

Registered address: Herikerbergweg 36, 1101CM, Amsterdam Zuid-Oost, The Netherlands

7) Name: Huawei Technologies Switzerland AG

Registered address:Waldeggstrasse 38, CH-3097 Liebefeld / Switzerland

8) Name : Huawei Tech. Portugal – Tecnologias de Informa??o, Lda.

Registered address: Avenida D. Jo?o II, lote 1.18, Edifício ART’s Business & Hotel Centre, Bloco B, 11o A, Parque das Na??es, Lisboa (Portugal)

Personal contact information

The personal data

  • Name
  • Email address
  • Department/Job/JOB_TITLE

The source of the personal data

Business card/email exchange

Why we process the personal data

We process your contact data in order to:

  • Conduct 3rd party satisfaction survey on Huawei product and service satisfaction.
  • The legal basis or bases we rely on to process the personal data

    Huawei processes your contact Data on the following legal bases:

  • Legitimate Interest: Customer satisfaction survey performed to listen to the voice of customers, make improvements accordingly and better serve such customers.
  • Recipients of the personal data

    Huawei local/region/HQ employees who are involved in the survey process.

    Third party survey provider:

    GfK Custom Research (Beijing) Co., Ltd.

    Address: Room 1807A, Floor 18, Building 1,China Life Tower,No.16, Chaowai Avenue, Chaoyang District, Beijing, 100020 China

    CFI Consulting (Shanghai) Limited

    Address: Unit 808, Jing An New Century Plaza 881 West Nanjing Road Shanghai,200041 China

    Above 2 companies are engaged by Huawei to conduct the 3rd party survey on Huawei product and service satisfaction.

    How long we retain the Personal Data

    The data processing will take place for the duration of 1 year after Aug 31st 2018

    Data sharing within the Huawei Group of Companies

    Huawei is a world-wide group of companies, which operates not necessarily along the borders of legal entities and countries, but according to functions which may exist across various group companies and countries. Like most global organizations, Huawei has centralized data management systems in place which involve personal data being accessible by Huawei group companies outside of the European Economic Area.

    This Satisfaction Survey is co-managed by our parent company (Huawei Technologies Co. Ltd.) in China. This means that all Personal Data which are accessible by employees of Huawei Technologies Co. Ltd in charge of customer relationship management.

    We have put in place appropriate safeguards for the transfer of personal data to a third country by adopting the standard data protection clauses adopted by the Commission in accordance with the Committee procedure set out in Article 87(2).

    Data sharing with third parties

    Your data will be processed by with the above-mentioned third party service providers. . . We require such third parties to respect the security of such personal data and to treat it in accordance with the law.

    All our third-party service providers are required to:

    • process data strictly in accordance our instruction, as detailed in a Data Processing Agreement,
    • Process the data only for the purpose of this Survey,
    • To take appropriate security measures to protect your data.

      • Your rights as a data subject

        As a data subject, you have the following legal rights in relation to your Personal Data. Further details about how to exercise your rights as a data subject are contained in Huawei’s Data Subject Rights Policy. For any question, demand, please contact us: dpo@huawei.com

        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 of Portability

        In certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

        Right to Withdraw Consent

        Where the legal basis of processing personal data is based on consent, you have the right to withdraw your consent at any time.

        Right to Complain

        You have the right to lodge a complaint to the national Supervisory Authority



        A Controller is an organization who (alone or jointly with others) determines the purposes and means of the processing of personal data.

        Data Transfer Agreement

        An agreement containing standard data protection clauses adopted by the European Union Commission as referred to in Article 46(2)(c) of the GDPR.

        Data Subject

        The identified or identifiable natural person to whom the Personal Data relates.


        The European Union General Data Protection Regulation (2016/679).

        Legal Basis

        Processing of Personal Data is only lawful if and to the extent that at least one legal basis specified in the GDPR applies. The available legal bases which are applicable in the employment context are summarized as:

        • consent of the data subject
        • processing necessary to enter into or perform a contract
        • necessary for compliance with a legal obligation
        • processing necessary in order to protect the vital interests of the Data Subject or another natural person
        • processing necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of Personal Data (Legitimate Interests).

        Personal Data

        Any information relating to an identified or identifiable natural person (Data Subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more

        factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.


        Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise

        making available, alignment or combination, restriction, erasure or destruction.

        Special Category Personal Data

        Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.