(Updated April, 2023)
The GSMA is a global organisation unifying the mobile ecosystem to discover, develop and deliver innovation foundational to positive business environments and societal change. Our vision is to unlock the full power of connectivity so that people, industry, and society thrive. Representing mobile operators and organisations across the mobile ecosystem and adjacent industries, the GSMA delivers for its members across three broad pillars: Connectivity for Good, Industry Services and Solutions, and Outreach. This activity includes advancing policy, tackling today’s biggest societal challenges, underpinning the technology and interoperability that make mobile work, and providing the world’s largest platform to convene the mobile ecosystem at the MWC and M360 series of events. We invite you to find out more at www.gsma.com.
At the GSMA, we take privacy and data protection seriously. The MWC Shanghai Privacy Notice (“Privacy Notice”) describes the GSMA’s policies and practices regarding the collection, use, sharing, and otherwise processing of your personal data, and sets out your privacy rights.
We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant links below to jump to that section.
- When this Privacy Notice applies
- Updates to this Privacy Notice
- Information that you provide voluntarily
- Information that we collect automatically
- Information that we obtain from third party sources
- Sharing of Information
- Legal basis for processing personal information
- Third Party Use of Data
- Transferring Your Information Outside of the European Economic Area (EEA), UK and Switzerland
- Data retention
- Your choices and control
- Contact Us
This Privacy Notice applies to the processing of personal data of participants of MWC Shanghai 2023 (“the Event”), including attendees, exhibitors, sponsors, speakers, partners, third party personnel and other individuals taking part in the event. This includes personal data obtained via the attendee registration system, the partner programme registration system, the exhibitor and partner registration system, and digital and/or printed badge and/or facial recognition scanning (at access points, for sessions or for participation in enclosed meeting spaces) at the Event.
Our Privacy Notice does not apply to services and products offered under other GSMA websites or by other companies and individuals. We are not responsible for the privacy policies and practices of other websites, even if you access them using links from GSMA websites. We strongly recommend that you check the privacy notices of each site you visit, and contact its owner or operator if you have any concerns or questions.
2. Updates to this Privacy Notice
We will update the Privacy Notice when necessary to reflect changes in our products and services. If there are material changes to the Privacy Notice or in how GSMA will use your personal data, we will notify you either by prominently posting a notice of the change(s) before they take effect or by directly sending you a notification, and you will have a choice as to whether or not we use your information in this new manner. We encourage you to periodically review the Privacy Notice to learn how GSMA is protecting your information.
If you have any queries about the Notice, please get in touch with us using the contact details set out at Contact Us link below.
3. Information that you provide voluntarily
3.1 Account Creation and Registration
We collect information you give us when you create an account with us; register for the Event; require a service; and/or download or subscribe to one of our publications or newsletters. The information collected includes (but is not limited to) your name, job title, employer name, address, work email, telephone number, job functions, areas of interest. If you are a speaker, we may collect additional information such as your professional profile.
Due to government registration rules & regulations around real-name registration, all attendees must self-register and enter their identity card/passport details during the registration process.
- For attendees who are Chinese nationals, we will collect your Chinese ID card details and real time ID verification will be completed at the point of registration.
- For international attendees/non-Chinese nationals, we will collect passport details during online registration and ID validation will take place during check-in onsite at the Event venue.
3.2 Automatic ID Validation (Facial Recognition)
Due to mandatory government regulation, we are required to implement facial recognition technology to provide you access to the Event venue. In this regard, we will process your biometric data when you attend the Event, strictly for the limited purposes of verifying your identity and allowing you to access the Event venue.
This facial recognition technology analyses your facial features by taking measurements of data points that make up the face. These data points include the distance between your eyes and the distance from forehead to chin, etc. The technology processes a number of data points to create a real-time map of your face. This is converted into a secure data pattern using a complex algorithm to create your biometric token. For security purposes at venue access, we will automatically match the image taken at the access point against your biometric token (i.e. your facial map).
- For Chinese national attendees, when you access the Event for the first time, the facial recognition gate will scan and read your Chinese ID card details (including ID number, name and photograph) and take a live photo of you (“First Entry Photo”). The facial recognition technology will make a facial comparison between the Chinese ID photo and the First Entry Photo to grant you access to the Event venue. For all further uses of facial recognition technology throughout the duration of the event, the facial recognition technology will make facial comparisons between the First Entry Photo and real time live photos in order to have the most accurate result.
- For international/non-Chinese national attendees, we will use facial recognition technology to automatically match the live image that is taken of you at the registration counter onsite against the photograph in your passport.
3.3 Image, Voice and Other Recordings
We, or authorised third parties attending the Event, may also make and store recordings of your image, voice and likeness in certain instances. These images may be used by GSMA in its promotional materials, including on its website and off-line materials (e.g. brochures, etc.) and broadcast on Mobile World Live or other media channels, including social media channels. Authorised third parties, such as exhibitors and sponsors, may also take images of you via their own on-site crews. Journalists will also be in attendance and appropriately identified. As stated in this Privacy Notice, we will also collect and store recordings of your image for facial recognition purposes to facilitate access to the Event.
Where such images or recordings are taken by an authorised third party, event sponsors, exhibitors, journalists, or the venue (or other security supplier) for security purposes, we require such third parties to provide you with a Privacy Notice relating to same and obtain any necessary consents. We recommend that you check the Privacy Notices of these third parties.
3.4 Badge Scanning
We, or authorised third parties participating in the Event (including exhibitors and sponsors), may collect your personal data by scanning your digital/printed badge. This may occur when you access or exit the venue, enter sessions or other restricted areas at the Event, or enter an enclosed space, meeting room or restaurant. This scanning may occur for the purposes of access control, analytics, event planning, logistics, health and safety, and data sharing with a third party session provider if you have scanned your digital badge or registered to attend that third party’s session.
3.5 Social Media Networks
If you access and become a follower of GSMA’s official social media pages, your personal data will be processed in accordance with this section of the Privacy Notice, alongside the conditions of use, privacy policies and access regulations that belong to the applicable social network, which you would have previously accepted.
You can consult the privacy policies of the main social networks in these links:
- Twitter: https://twitter.com/es/privacy
- LinkedIn: https://es.linkedin.com/legal/…
- Instagram: https://privacycenter.instagram.com/policy/
- WeChat: https://www.wechat.com/en/privacy_policy.html
- Weixin: https://weixin.qq.com/cgi-bin/readtemplate?lang=en_US&t=weixin_agreement&s=privacy&cc=CN
We may process your personal data to properly manage your presence in the social network, inform you of our activities, products or services, or for other purposes that the regulations of social networks allow.
4. Information that we collect automatically
5. Information that we obtain from third party sources
From time to time, GSMA receives personal information about individuals from third parties. This may happen, for instance if your employer is a member of GSMA and signs you up for an event or training or if your employer (or entity by whom you are engaged as a contractor or temporary staff member) provides services to GSMA and you are involved in the provision of these services.
Additionally, this may occur when an authorised third party provides GSMA with access to information obtained from badge scanning. We will check that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
We process your personal information for account administration, to deliver the products and services you require, and, where you provide the applicable consent, to inform you of GSMA-related events, meetings, content, initiatives and other benefits or opportunities associated with GSMA or the industry. We may also use this information to help us understand your needs and interests to better tailor our products and services.
We may contact you by any means of communication that you have authorised, including e-mail, telephone, and post. You can tailor and modify what you receive from us at any time by using our preference centre. You can also unsubscribe at any time via the unsubscribe button present in all of our electronic messages or by using the Contact Us section below.
In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
6. Sharing of Information
We do not sell personal information to anyone, and do not otherwise reveal your personal data to third-parties for their independent use unless:
- you request or authorise it, for instance by registering for a summit or a partner programme;
- you register for (or scan your digital badge to participate in) a speaking session, tour or other event that is sponsored or hosted by a third party in which case GSMA may subsequently share your personal data with the third party, who may contact you in connection with the selected speaking session, tour or other event (as applicable). We may also share your personal data with such parties for direct marketing purposes (with your consent);
- it is required in connection with the delivery of GSMA events;
- it is provided to any competent law enforcement body, regulatory, government agency, court or other third party in order to comply with the law, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others. This includes relevant law enforcement bodies for security purposes. This includes your ID data (Chinese ID card data or passport data) and/or biometric data obtained via online registration and/or facial recognition technologies at the Event (for more information please read the FAQs here);
- it is provided to GSMA affiliated companies, including GSM Association, GSMA 4FYN Event Management S.L., GSMA (Shanghai) Co., Ltd., GSMC Event Project Management S.L., and GSM Conference Services Limited, for processing in accordance with this Privacy Notice;
- it is provided to our agents, vendors or service providers who perform functions on our behalf, including, for example, service providers that provide registration, access control, lead retrieval, security and venue services for the Event or that support the delivery of, provide functionality on, or help to enhance the security of our Website.
6.1 Data Sharing with Government Bodies and Law Enforcement
Due to local Chinese laws and government regulations, we may be required to share personal data with Shanghai government agencies and/or the Shanghai police that are onsite at the Event. The following table outlines the various data sharing scenarios.
|Data Element||Recipients and purposes of data sharing|
|Chinese nationals: ID card details||For real-name and ID verification purposes only, data is matched with Government database via China Pay API. Attendee ID details are not retained in the Government database.|
|Chinese nationals: ID card details and live photograph taken via facial recognition gate||Face++ Database reads ID details and live photograph taken at facial recognition gate and matches the image with the Government database.|
|International/non-Chinese nationals: passport details, live photo taken at registration counter and live photograph taken at facial recognition gates.||Data is shared from GSMA’s online registration system to Face++ Database for the purposes of facial recognition at first time entry. Data is stored in Face++ Database and deleted 4 days after the end of the Event. Data is not transferred to Government database, however may be requested by Chinese officials on demand and GSMA will only comply with such a request in accordance with applicable mandatory legal obligations.|
|All attendees: entry data including ID data, date and time of entry to the Event||Onsite police – GSMA will only provide this information to the onsite police on request, and only in the event of a security issue. Data is not retained by onsite police.|
7. Legal basis for processing personal information
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you on the following bases:
We process your personal information where you have given us your consent. You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
7.2 Performance of a Contract
We process your personal information where we need this to perform a contract with you (e.g. terms of service). If we rely on this legal basis, we will make this clear to you and advise you whether the provision of this information is mandatory (as well as the possible consequences of failing to provide this information).
7.3 Legitimate Interests
We process your information where the processing is in our legitimate interests and this is not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make those legitimate interests clear to you and/or they will be our legitimate interests in organising the Event in compliance with applicable laws and our contractual obligations.
7.4 Legal Obligation
There may be circumstances where we are legally required to process your personal information. In these cases, we will make these requirements clear to you and advise you whether or not the provision of information is mandatory (as well as the possible consequences of failing to provide your information).
For example, we are legally obliged to process your biometric data and passport/ID card data in order to grant you access to the Event. Any failure to provide this information will mean that we cannot register you for the Event and/or permit you to access the venue.
7.5 Public Interest & Protection of Vital Interests
In some cases, we may be required to process your personal information for reasons of public interest. We may also need to collect and use your personal information to protect your vital interests or those of another person, for example, in case of a medical emergency during the Event. If you have any questions or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact us” heading below.
8. Third Party Use of Data
Exhibitors, sponsors, partners or other third parties participating at the Event may wish to scan your physical/digital badge to facilitate networking and business relationships at the Event or to contact you post-Event. You understand that your physical/digital badge holds secure data related to you, including your name, mobile number, email, address, company, job title, job function and areas of interest. If you allow your attendee digital badge to be scanned, you are explicitly consenting to the exhibitor, sponsor, partner or other third party collecting and using your personal data contained in the digital badge. If you wish to withdraw consent or to exercise any data protection rights with regard to how such recipients process and use your personal data, you must do so directly with such recipients.
We recommend that you check the privacy notices and policies of these third parties before providing them with your personal information.
9. Transferring Your Information Outside of the European Economic Area (EEA), UK and Switzerland
GSMA Ltd is based in the US. Therefore, your information may be collected, transferred to, or otherwise processed by us, our affiliated or associated companies, or third parties (disclosed above) who are based in countries outside of the EEA, UK and Switzerland.
As part of the Automatic ID Validation facial recognition process, your biometric data will be disclosed to Face++, which is the supplier approved by the Chinese government who carries out the facial recognition activities for the Event. Face++ is based in China and this means that your biometric data will be accessed in China.
Where we transfer personal data from the EEA, UK and Switzerland to other countries we use a variety of legal mechanisms, including Standard Contractual Clauses adopted by the EU Commission, to ensure your rights and protections travel with your data.
10. Data retention
In general, GSMA retains personal data for the duration of the customer’s or member’s business relationship with the GSMA and where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We remove all personal information 75 days after the Event (during this time, we will keep data for invoicing and fapiao purposes). All ID data, including Chinese ID card details, international ID details, ID images and face photos are deleted from our registration platform, the ID gate vendor and Face++ 4 days after the conclusion of the Event.
For more information on where and how long your personal data is stored, please contact us by using the details set out at the “Contact Us” section below.
11. Your choices and control
Many privacy laws provide individuals with certain rights and enable them to make meaningful choices about the use of their personal information.
If you are located in a European Union member state, or certain other countries, you can exercise the following data subject rights:
- Confirmation of processing – you can ask us to confirm if we are processing your personal information;
- Access – you can ask us to provide a copy of the personal data that we hold about you
- Rectification – you can ask us to rectify the record of your personal data that we maintain;
- Restrict or object to data processing – you can ask us to restrict the processing of your personal data or object to the processing of your personal data, including for marketing purposes and we will deal with such request in accordance with applicable law;
- Deletion – you can ask us to delete some or all of the personal data that we hold about you; we will deal with such requests in accordance with applicable law;
- Portability – in certain circumstances, you can ask GSMA to provide you a copy of your personal data in a structured, electronic format, or to transmit it directly to another data controller, where technically feasible.
We also provide many choices in relation to our marketing communications via our preference centre.
If you wish to exercise any of your rights, please contact us by filling in our data subject request form.
In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how GSMA processes your personal data.
We are committed to protecting the security of your personal information. We have implemented appropriate physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to employees on a need-to-know basis in order to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
Individuals under 16 years of age (“Minors”) are not permitted entry to the Event.
14. Contact Us
We are GSMA Ltd., with registered offices at 165 Ottley Drive, Suite 203. Atlanta, GA 30324, USA. Our Company is registered with the Georgia Secretary of State with the Control Number 0638146.
We are the Data Controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679)).
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, or if you do not wish us to continue using your information as outlined above, you can do so by sending an e-mail to [email protected] or write to Data Privacy – Legal, GSMA Ltd., 1 Angel Lane, London, EC4R 3AB, United Kingdom.