Publish Date: 21 July 2023

Effective Date: 21 July 2023

Last updated: 8 May 2024

This policy applies to New H3C Group and its subsidiaries and branches (hereinafter referred to as "H3C", “New H3C” or "H3C Group").

H3C Group and its affiliates respect and protect your privacy. When you use any services provided by H3C Group, we may collect and use your personal information. We hereby would like to explain our principles and rules guiding our collection and use of your personal information to you in the "New H3C Group Privacy Policy" (hereinafter referred to as "this Policy") with the aim to better safeguard your rights and interests.

This Policy applies to all products and services we provide, such as websites, services, applications, products, and solutions (collectively referred to as “H3C products”). We may have supplementary privacy policies or terms for specific H3C products. The supplementary policies or terms shall prevail in the event of any conflict with this Policy when it comes to specific H3C product.

Before using H3C products, please be sure to carefully read and thoroughly understand this Policy. You should only start using the products after confirming that you fully understand and agree with this Policy.

This Policy includes:

1. How H3C Collects & Uses Your Personal information

2. How H3C Shares & Discloses Personal information

3. How H3C Uses Cookies & Similar Technologies

4. Third-Party Services

5. How H3C Store & Protects Your Personal information

6. How H3C Protect the Minor’s Personal information

7. How to Access & Control Your Personal information

8. International Transfers of Your Personal information

9. Updates to This Policy

10. How To Contact H3C

11. EU GDPR Representative

1. How H3C Collects & Uses Your Personal information

Personal information refers to any type of information recorded electronically or otherwise relating to an identified or identifiable natural person. We collect your personal information with the primary purpose of making it easier and more satisfying for you and other users to use H3C products, providing personalized experiences, and maintaining a good relationship between you and New H3C.

1. We will collect and obtain your personal information through the following channels.

（1） You directly provide us with such data when you use our websites, products, or services, register a New H3C ID, contact us for support or other means of interaction with us.

（2） We may also obtain data by recording how you interact with our websites, products, or services. For example, we may use technologies such as cookies or receive digital activity information from products.

（3） As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our services or information from publicly available sources.

2. We will collect and use the following types of personal information for the following purposes:

The type of personal information we collect depends on how you interact with New H3C, including the website you visit or the type of H3C product you choose to use. Please refer to the specific H3C product you actually use. In addition, we may launch new services or business functions, and may therefore need to collect new personal information or change the use purpose or method of personal information. If we want to use your personal information for other purposes not stated in this Policy or collect other personal information that is not mentioned, we will obtain your consent through page prompts, interactive processes, website announcements, or other means in accordance with the laws.

Creating an account.

To facilitate our provision of continuous and stable services to you and ensure the security of your use of H3C products, we need you to provide basic registration or login information, including name, email, phone, company/organization, city, and country. In some services, if you only need to use basic functions such as browsing and searching, you do not need to register an account or provide the above information.

Communicating with you

When you contact our customer service or use other user response functions (such as after-sales applications, customer complaints, and requests), we may need you to provide necessary personal information to match and verify your user identity to ensure the security of your account and system. According to business needs, we will also save your contact information (the contact information you use to contact us or other contact information you actively provide to us), communications/call recordings and contents between you and us, as well as other necessary information related to your needs, in order to contact you or help you solve problems, or record the processing solutions and results of related issues.

Managing our good relationship with you

Based on the information you provide to us, the information we record, and the information we collect from legitimate third parties (such as your browsing and search records, device and location information, contact addresses, emails, and phone numbers that you submit when registering and updating your account), we may maintain a good relationship with you based on one of the above information or combination and analysis of such information:

(1) Provide you with personalized user experience and personalized content, provide page displays that are more fit for your needs, and recommend personalized H3C Products.

(2) Send you important notifications, such as operating system or application updates and installation notifications.

(3) Authenticate and manage suppliers and business partners, communicate with suppliers and business partners or conduct business with them.

(4) Provide you with interactive and publishing services. When you upload and/or release information and participate in related interactions when using H3C Products, we will collect the information you upload, release, or form, and use your nickname, avatar, and published content for display.

(5) Send you marketing information, user surveys, contest invitations to help us improve H3C products, and provide or promote our/third-party’s goods and services through email, SMS, or other means. You can refuse subsequent marketing information through SMS or email unsubscribe.

(6) conduct anti-corruption/global trade or similar due diligence on third parties and conducting required investigations, in compliance with applicable laws

(7) Protect H3C brand by conducting investigations into H3C product and service-related fraud, compliance, grey marketing, theft and/or counterfeit

Assisting you in completing transactions or orders

(1) When you order H3C products, we will generate purchasing guidance information for you via the system. During the submission of the purchase intention, you need to provide at least the personal identity information, name, email, phone number, company, and city of the recipient. If you refuse to provide such information, we will not be able to complete the pertinent delivery. If you are ordering H3C products or services for someone else, you need to provide the aforementioned information of the actual purchaser. Before providing us with the aforementioned information of the actual purchaser, you need to ensure that you have obtained their authorized consent;

(2) In order to display transaction information to you and ensure transaction security, we will collect information generated during the ordering process (such as the H3C products you purchased, project number, order number, order creation time, transaction amount) for you to browse and manage your order;

(3) In order to complete orders, deliver products, confirm transaction status, and provide after-sales and dispute resolution services for you, we will collect your account, order, transaction, payment, and logistics information related to the transaction progress from the transaction parties, payment institution, logistics company or share your transaction information with the aforementioned service providers.

Provide and improve H3C products and support

(1) Conduct internal audits, data analysis, and research based on relevant data to improve our products and services anonymously.

(2) Protect the security of our products, services, and customer or user transaction processes.

(3) Address and resolve enquiries and complaints, such as detecting, preventing, and investigating misconduct by H3C staff, customers, partners, and suppliers.

Exceptions to obtaining authorized consent:

According to relevant laws and regulations, we do not need to obtain your consent to collect your information in the following situations:

(1) it is necessary for the performance of a contract to which the you are a party or in order to take steps at the request of the you prior to entering into a contract;

(2) it is necessary for compliance with our legal obligation;

(3) it is necessary in order to protect the vital interests of the you or of another natural person;

(4) necessary for the protection of your or other individuals' significant legitimate rights and interests, but difficult to obtain your consent.

2. How New H3C Shares & Discloses Personal information

1. Sharing

Sharing refers to the process in which New H3C provides personal information to other personal information controllers, and both parties have independent control over the personal information.

We value the protection of your personal information. Except as described below, we will not share your personal information with any third parties outside of New H3C:

(1) New H3C has obtained your or your guardian's explicit authorization or consent;

(2) Necessary sharing with our affiliates. Due to the natural affiliation of the business system, the personal information we collect may be shared with our affiliates or actually processed by them. We will only share the necessary personal information, and such sharing is limited to the purpose of this Policy.

(3) Sharing with our service providers or third parties to perform the agreements between you and New H3C or to realize specific services that you use;

(4) To achieve other purposes described in the first section “How We Collect &Use Your Personal information” of this Policy;

(5) Within the scope permitted by laws and regulations, in order to comply with laws, protect us and our affiliates or partners, you or other users or public interests, property, or safety from damage, such as to prevent fraudulent and illegal activities and reduce credit risks, we may exchange information with other companies and organizations;

(6) Comply with law, regulation, subpoena, or court order or respond to duly authorized information requests of governmental authorities

We promise to only share your personal information with third parties in a lawful, legitimate, necessary, specific, and clear purpose, and only share the personal information necessary to achieve the relevant purposes. At the same time, we will also manage third parties, requiring them to handle information not less than the requirements under the confidentiality and security measures of this policy.

In addition, according to the aforementioned regulations, if personal information is processed and deidentified in a way that the recipient cannot recover and re-identify the data subject, we do not need to notify you separately or re-obtain your consent.

2. Transfer

New H3C may merge, acquire, sell, or otherwise restructure certain businesses with the business growth and strategies change. Your information may be transferred as part of such transactions. We will require the new organization to continue to be bound by this Policy, otherwise we will ask the organization to re-obtain your consent.

3. How H3C Uses Cookies & Similar Technologies

We will only disclose your personal information in the following cases:

1. After obtaining your explicit consent;

2. Based on legal grounds: in case of mandatory requirements such as laws, legal procedures, litigation, or government authorities, or to protect New H3C or public safety and property from infringement, we may disclose personal information related to your illegal or default behavior.

4. Exceptions to obtaining consent for sharing, transferring, and disclosing personal information:

In accordance with applicable laws, regulations, and national standards, we may share, transfer, and disclose your personal information without your consent in the following situations:

(1) related to our obligations under laws and regulations;

(2) directly related to national security;

(3) directly related to public safety, public health, or major public interests;

(4) directly related to criminal investigations, prosecutions, trials, and judgment enforcement;

(5) necessary for the protection of your or other individuals' significant legitimate rights and interests, but difficult to obtain your consent;

(6) personal information voluntarily disclosed by you to the public;

(7) personal information collected from legally publicized sources, such as legal news reports and government information disclosures.

In addition, according to the aforementioned regulations, if personal information is processed and deidentified in a way that the recipient cannot recover and re-identify the data subject, we do not need to notify you separately or re-obtain your consent.

3. How H3C Uses Cookies & Similar Technologies

1. Cookie

A cookie is a small piece of data that are stored on your computer via the internet. The content of a cookie can be retrieved or read only by the server that creates the cookie. Cookies are unique to the browsers or mobile applications you use. The text in a cookie often consists of identifiers, site names, and some numbers and characters. When you browse our website or websites containing our advertisements, make purchases, request information, personalize information, or register for certain services, New H3C or its service providers will send cookies to your computer. If you accept cookies used by our website, websites "providing technical support" on behalf of New H3C or websites containing our ads, we can access your browsing information, which may be used to personalize your experience.

New H3C will not use cookies for any purposes not sated in this Policy. You can manage or delete cookies based on your own preferences.

2. Web Beacon

Some New H3C web pages, third-party web pages, applications, and HTML-formatted emails may only use web beacons or combine web beacons with cookies to compile information about your use of the website and your interactions with emails, and to assess the performance of New H3C's web pages, applications, and websites on behalf of New H3C that "provides technical support" by other companies. A web beacon is an electronic image known as a single pixel (1x1) or a transparent GIF. Web beacons can identify certain types of information on the computer, such as cookies, the time and date of browsing the page, and a description of the page on which the web beacon is located. Depending on the specific situation, web beacons may also reference content on third-party servers, and service providers may use them to send you relevant advertisements.

You can disable web beacons by not downloading images in the email (this feature will vary depending on the email software you use on your computer). However, this may not necessarily disable web beacons or other automatic data collection tools in the email as different email software may function differently. For more information on this issue, please refer to the information provided by your email software or service provider.

If you choose to accept New H3C's marketing emails or newsletters, New H3C may automatically collect your personal information. For example, through web beacons and personalized URLs embedded in these emails or newsletters, New H3C can track whether you have opened these emails and whether you have clicked on the links contained in them. For more information on embedded web links, please read the description below.

3. Embedded Web Links

Emails sent by New H3C, keyboard keys pre-set by New H3C, and promotional icons pre-installed on your computer usually have pre-designed links that will redirect you to relevant areas on the internet after passing through New H3C servers. The redirect system allows New H3C to modify the URL of these links when necessary and evaluate the effectiveness of our marketing campaigns.

Such web links in emails can also let New H3C know if you have clicked on a link in the email, and we may associate this interaction data with your personal identity.

4. H3C advertisements placed on third-party websites

New H3C has signed contracts with service providers to advertise on third-party websites. In addition, some websites may have service providers offering technical support to provide H3C Products on behalf of New H3C. Service providers may send cookies via third-party websites and New H3C web pages, and use web beacons on these sites. These cookies and web beacons allow New H3C to collect information about your page browsing and link-clicking activities.

4. Third-Party Services

To provide a good user experience, you may receive content or web links from third parties other than New H3C and its partners ("Third Parties"). New H3C does not have the right to control such third parties, but you can choose whether to use the links, view the content and/or access the products or services provided by third parties.

New H3C cannot control the privacy practices and data protection policies of third parties that are not subject to this Policy. When you submit personal information to such a third party, please read and refer to the privacy protection policy of the third party.

To ensure the stable operation and functionality of our application and provide you with more services and features, we embed our partners' SDK or similar applications in our application (such as Baidu Analytics, Google Analytics, and Gridsum Analytics). When you use these products or services, your information may also be collected. Therefore, we strongly recommend that you take the time to read the privacy policies of these third parties.

Below are examples of the third-party terms and privacy policies that will apply when you use the specific products or services mentioned:

Baidu Analytics: https://tongji.baidu.com/web/welcome/login

Google Analytics Privacy Policy: https://policies.google.com/privacy?gl=PH&hl=zh-CN

Gridsum Analytics Privacy Policy: https://gridsum.com/policy.html

5. How H3C Stores & Protects Your Personal information

New H3C attaches great importance to the security of personal information. We store the personal information within the territory of China. We are in compliance with applicable laws and regulations concerning your personal information, including EU/UK GDPR and China PIPL. We adopt appropriate physical, managerial, and technical measures to protect your personal information and require data recipients to implement protection measures that are no less than the current security level to protect your personal information.

H3C has obtained certifications in information security-related qualifications such as ISO27001, ISO22301, and classified protection.

We have adopted security measures that meet industry standards, including establishing sound regulations and security technologies to prevent unauthorized access, use, or modification of your personal information, and to prevent data damage or loss. For example, we use encryption technology to protect data confidentiality, and deploy protection mechanisms to prevent data from malicious attacks. We deploy access control mechanisms to ensure that only authorized personnel can access personal information.

We only store data for legal business purposes and in accordance with local legal requirements or permits. Unless legally required or permitted to extend the retention period, we will retain your personal information for the period necessary to achieve the purposes described in this policy. We set reasonable and different data storage periods based on different scenarios, products, and services to ensure the provision of service to you, meeting contractual obligations, agreements, and legal requirements.

While we have taken reasonable and effective measures and complied with relevant legal requirements, we cannot guarantee the security of your personal information if you communicate through an insecure channel due to the open nature of the network environment. As such, we highly recommend that you take active measures to protect your personal information, such as setting complex passwords, regularly changing account passwords, not disclosing personal information such as account passwords to others, and using information-sharing or sharing functions with caution.

In the event of any data security incident, we will promptly inform you of the basic information about the security incident and its possible impact, measures that we have taken or will take, suggestions about active defense and risk mitigation, and remedial measures pursuant to local legal requirements. The notification may take the form of an email, letter, telephone, push notification, etc. If it is difficult to inform data subjects individually, we will take appropriate and effective measures to release a security notice. We will also report the handling status of data security incidents as required by supervisory authorities.

6. How H3C Protects Children's Personal information

Our products, websites, and services are primarily intended for adults. Any minors who participate in online activities should obtain prior consent from their parents or other guardians. We will protect the relevant information of minors in accordance with relevant laws and regulations. We do not actively distinguish minor information. If you are a minor under the age of 14, please notify your parents and guardians to read and accept this policy together and seek their consent and guidance before submitting personal information.

7. How to Access & Control Your Personal information

It is your responsibility to ensure that all personal information submitted by you to New H3C is correct. H3C is dedicated to maintaining the accuracy and completeness of personal information and keeping the data up-to-date.

To the extent required by our agreement and applicable laws you may (i) have the right to access certain personal information we maintain about you, (ii) request that we update your personal information, (iii) ask us to delete your personal information, and (iv) restrict our use of your personal information

Access, Update, Deletion, and Cancellation

New H3C provides individuals with reasonable access to their personal information submitted to New H3C, and reasonable permissions to view, modify such information or perform other operations such as anonymity, blocking or deletion. To protect your privacy and security, we will take appropriate steps to verify your identity before granting access to your information, such as requesting a password and user account.

We encourage you to update and modify your personal information to make it more accurate and effective. We will use appropriate technical means or provide contact channels for you to submit an application. You can send your request to [email protected] to update or modify your personal information. We will make every effort to ensure that you can access, update, and correct your personal information or other information provided when using H3C products.

After you cancel your account, we will stop providing all or part of the services to you, and delete your personal information or anonymize it upon your request, except as otherwise required by law or regulations.

Unless otherwise required by laws or regulations, when you modify or delete your personal information or apply to cancel your account, we may not immediately correct or delete the corresponding information from the backup system, but will do so when the backup is updated.

Changing the Authorized Scope

You have the right to choose whether or not to disclose personal information to us. Some personal information is necessary for the use of H3C products, while the provision of other information is up to you. You can change the scope of information we are authorized to collect by deleting information, disabling device functions, canceling your account, or withdrawing your authorization.

If you no longer wish to receive marketing information provided by us, you can unsubscribe via SMS or email.

After you withdraw your authorization, we will no longer be able to provide you with the services corresponding to the withdrawn authorization, and we will no longer process your corresponding information. However, your decision to withdraw authorization will not affect the information processing carried out based on your authorization before.

Making Complaints

If you feel that your personal information rights or interests are infringed by us or because of us, you may lodge a complaint against us with the supervisory authorities according to applicable laws.

8. International Transfers of Your Personal information

As a global company, the personal information collected by New H3C may be processed or accessed in countries or regions where you use our products and services, or other countries regions where we or our affiliates, subsidiaries, service providers, or business partners are located. These jurisdictions may have different data protection laws. In such cases, H3C will take measures to ensure that data is processed as required by this Policy and applicable laws.

If the international transfer of your personal information is subject to EU GDPR, your personal information is protected by EU SCC Addendum.

9. Updates to This Policy

In order to provide you with better services, we may timely modify the terms of this Policy according to the updates of H3C products, services and relevant legal requirements. Such modifications will form part of this Policy. We will publish any changes made to this Policy on this page. For significant changes, we will also provide more prominent notices (including website announcements, push notifications, pop-up prompts or other means).

We may timely modify the terms of this Policy based on the updates of H3C products and legal requirements, and then update the policy on this page. For significant changes, we will also notify you by other means such as sending an email or posting the notice on our official website and/or social media pages, before the changes take effect.

If you do not agree with these changes, you may choose to stop using H3C products. If you continue to use H3C products, it indicates that you have fully read, understood, and agreed to be bound by the revised terms of this Policy.

10. How to contact H3C.

We are committed to protect your personal information in accordance with this Policy. If you have any privacy questions, comments or suggestions, please contact us via the following channels:

Email: [email protected]

H3C Compliance Hotline: 400-826-0732

You can also send a letter to:

Compliance Department, New H3C Group, 466 Changhe Road, Binjiang District, Hangzhou, Zhejiang Province, China, 310052.

11. EU GDPR Representative.

Pursuant to Article 27 of the EU GDPR, H3C is considered a data controller and has therefore appointed a GDPR representative in the EU.

If you are in the EU/EEA, please feel free to contact us via our GDPR Representative, DataRep, who can be reached using these points of contact:

DataRep Group

Sending an email to DataRep : [email protected]

Mailing your inquiry to: DataRep at the following address:

DataRep, Calle de Manzanares 4, Madrid, 28005, Spain