TCL GLOBAL PRIVACY NOTICE

This Privacy Notice is effective as of 2023-04-20.

This Privacy Notice sets out how TCL and/or its affiliates and subsidiaries (collectively “TCL”, “we”, “us” or “our”) protect the Personal Data we process relating to you (your “Personal Data”), what types of Personal Data we collect about you, what we do with it, how we disclose it and which rights you have in relation to the processing of Personal Data.

Thank you for choosing TCL!

WHEN DOES THIS PRIVACY NOTICE APPLY?

This Privacy Notice applies when we process your Personal Data as a result of your access and use of “TCL Materials”, including:

TCL website (www.tcl.com);

TCL smart TV products;

SEMP branded devices;

TCL and Alcatel branded devices (including phones, tablets, watches, bracelets, wearable devices, routers);

TCL smart service applications or services (including TCL Account, TCL Channel, TCL Home App, BrowserHere/T-Browser, TCL Live, TV Guard, MagiConnect, ChatNow, Smart Gallery, Reminder, Weather, Game Center, Gesture Control and Remote Diagnosis); and

other TCL devices, websites or applications that may refer to this Privacy Notice.

This Privacy Notice also applies to our processing of the Personal Data of business contacts within our clients, business partners, supplier and other organizations with which TCL has or considers a business relationship.

We may update this Privacy Notice to reflect changes in how we collect and use your Personal Data or changes in applicable laws on a regular basis. Any update to this Privacy Notice will be effective upon its posting on our website at https://www.tcl.com/kz/en/legal/privacy-notice. In addition, we may also notify you to inform you about the changes to this Privacy Notice as required by applicable laws.

BY VISITING OUR WEBSITES, PROVIDING YOUR INFORMATION OR USING TCL MATERIALS, YOU CONFIRM THAT YOUR HAVE READ AND UNDERSTOOD THE PRACTICES DESCRIBED IN THIS PRIVACY NOTICE.

To find out more, please click on any of the sections below.

PERSONAL DATA WE COLLECT ABOUT YOU

Your privacy is important to us so we explain here what Personal Data we collect about you. Please note that, if you do not provide certain Personal Data, TCL may not be able to accomplish some purposes outlined in this Privacy Notice and you may not be able to use or access certain TCL Materials.

We may collect and process the following Personal Data about you:

Information that you provide to us. This includes information about you that you give us by filling in forms, entering information in our website, creating user accounts or by communicating with us, whether face-to-face, by phone, online, by email or otherwise, which are capable of identifying you or to make you identifiable depending on the context. This information includes, without limitation, the following:

o Personal contact information: your name, shipping, billing and/or business address, email address, phone number;

o To comply with our legal obligations required under applicable laws, we may also collect your tax payer number (CPF);

o Log in information: username, password, nickname;

o Demographic information: date of birth, gender;

o Payment information: your debit or credit card information, bank information or other payment and financial information related to your purchase or transactions of our products or services;

o Other information about you such as professional or employment-related information (e.g. when you participate in our survey), language, and health and exercise data, such as your exercise data, including height and weight, body temperature, heartrate, sleep quality data, walk/run/bike tracking data (e.g. when you use related services of TCL wearables);

o Your questions, complaints or feedbacks on our products and services or responses to our questionnaires;

o Information about TCL Materials that you own and use, and proof that you purchased them, when applicable; and

Information we collect or generate about you. We may collect internet, electronic activity, and other information automatically from the devices and browsers that you use. This includes, without limitation, the following:

o Details about your usage of the TCL Materials;

o Location of your device and time zone;

o Details about your usage of the products that we supply to you such as the browsing history, search history and page clicks, browser type, session frequency and your other activities when using our products or services;

o Identifiers, including the IP address, MAC address, Device-ID, Terminal ID, serial number, IMEI number, IMSI number, advertising ID (a unique user ID assigned to your devices for advertising purposes), hardware model and any other device identifiers or device-specific information about your TCL Materials;

o Precise geolocation and approximate geolocation data provided by your device’s GPS signal or communicated through a nearby Wi-Fi access points and cell towers while you use certain services and enable the location feature. You can opt out of our collection of your location data at any time within the settings of the operating system of your products or applications, as applicable;

o Information relating to your health status and details relating to your fitness and exercise information (such as your height and weight, body temperature, heartrate, sleep quality, walking, running and biking tracker information) to the extent that you provide us with such information or otherwise consent to our collecting;

o Error logs, error codes and error descriptions and other information that you provide relating to faults or defect experience with any of your TCL Materials;

o Information collected by certain TCL applications. For example, when you use your TCL Account application on your mobile phone, this application will connect to the Internet, request your system permissions (including permissions for storage, camera, Internet connection and contacts) and collect your email address, account password, account name, gender, country/region, device model, device name, versions of your application and your mobile phone’s operating system;

o The location where you use our TCL Connect or TCL Home application to connect and control your multiple TCL or Alcatel devices (such as your smart devices, watches, bracelets and routers), and also your Wi-Fi or bluetooth information, location, TCL account, device information about your phone and information about the TCL or Alcatel devices to be connected;

o Your emails, phone number, address, fax number, chat history or recordings of phone conversations between you and our Customer Care team when we provide after-sale support to you; and

o Other information according to what we disclosed to you when certain applications are launched by you for the first time.

Information we obtain from other sources. We may collect information about you from third parties, as allowed under the law. This includes, without limitation, the following:

o Information from social media networks;

o Information from data providers and advertising exchange services;

o Information obtained from other providers of products, services, websites and applications;

o Information relating to the repair services from carriers of your mobile devices;

o Other commercially or publicly available source; and

o If you take part in market research programs organized and/or sponsored by/on behalf of TCL we may also collect information from third party websites or social media networks, in accordance with the privacy policies of those respective websites and social media networks.

We may also collect other information about you, your device or the use of TCL Materials in the manner informed at the time of collection and/or with your consent in accordance with applicable laws.

We will not knowingly collect any Personal Data from or about children under the age of 13, or minimum age allowed in your jurisdiction, without making it clear that such information should only be provided with a parent’s or guardian’s consent, if this is required by any applicable laws. TCL will only use Personal Data relating to children as far as it is permitted by applicable laws and if required, only with a parent’s or guardian’s consent and in accordance with children’s best interests. If you believe that your child has provided us with his / her Personal Data without a parent’s or guardian’s consent, please contact us via the email address provided in the Contacting Us section below.

If your child uses our Kids Learning or Kids Mode services, TCL family watch, or other TCL products or services for child, we will provide you with a separate privacy policy (see: https://www.tcl.com/global/en/children-privacy-policy/English) with more details on how we protect children’s Personal Data.

USES OF PERSONAL DATA

Your Personal Data may be collected, stored, processed or otherwise used by us in the following ways and for the following purposes:

· To deliver, activate, verify and manage our products and services purchased by you;

· To provide software updates, maintenance services, technical support and after-sales services for TCL Materials;

· To help you register and manage your TCL account;

· To allow you to download and purchase our products and services such as our applications and related websites and/or to give you access to third-party applications installed on the device;

· To process payments transactions or orders for TCL Materials;

· To send you information or contact you in relation to TCL Materials, for example, in the event that any TCL Materials have changed or present issues;

· To establish, exercise or defend our legal rights or for the purpose of legal proceedings;

· To protect against and prevent fraud and information security risks, as well as to keep TCL Materials secure, such as verifying your accounts and identification, detecting security incidents and combating malicious activities;

· To respond to any complaints or questions that you may raise in connection with TCL Materials, and to defend and exercise our legal rights;

· To personalise TCL Materials at your request;

· To troubleshoot functionality or other issues for the TCL Materials;

· To evaluate and develop new functionalities, technologies and improvements on TCL Materials;

· To administer contests, promotions, events, market research, surveys in relation to TCL Materials;

· To facilitate TCL’s internal purposes such as auditing, data analysis, and research to improve our products, services, user experience and customer communications;

· To comply with all applicable laws, regulations, directives and court decisions as well as decisions from competent authorities;

· To send you information about TCL Materials and to help make that information more relevant to you. We may need your consent for certain marketing activities. We offer you various ways to opt-out of receiving certain communications from us. If you would like to opt out of receiving email marketing communications from us you may click the “Unsubscribe” link found at the bottom of the email and follow the instructions;

· We and our advertising partners may display advertising on some of our products and services. If we and our advertising partners display personalized advertising, we will obtain your prior consent as required by applicable laws; and

· Other purposes with your consent and / or as allowed by applicable laws.

To the extent the Personal Data we collect about you is considered special categories of Personal Data or sensitive Personal Data under applicable laws, we process such data based on your consent, and you may withdraw your consent to such processing at any time with effects to the future. However, you should be aware that if you choose to do so we may be unable to continue to provide certain services to you. If you choose to withdraw your consent, we will tell you more about the possible consequences. If permitted by applicable laws, we may also process special categories of Personal Data that you expressly made public or to establish, exercise or defend legal claims.

The Section “Product Specific Terms” below provides more detailed information about the Personal Data we collect and the purposes for which we use the Personal Data in connection with TCL’s smart TV, MagiConnect, TCL Home application, TCL Channel, TCL Mobile, Tablet and Wearable Device.

If you act as a business contact of your organization to purchase or use TCL Materials on behalf of your organization, we may collect your name, shipping, billing and/or business address, email address, phone number, and use your Personal Data to the extent necessary to carry out ordinary business operations, for associated administrative purposes or for other purposes specified above in the Section “Uses of Personal Data”.

DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We may disclose the information you provide to us, the information we collect or generate about you, or the information we collect from other sources with TCL’s affiliates and subsidiaries for one or more of the business purposes described below:

· To help us provide you with TCL Materials;

· Where we market products and services provided by TCL’s affiliates and/or TCL’s subsidiaries;

· To comply with law enforcement activities when needed; and

· For one of those purposes for which TCL processes your Personal Data under this Privacy Notice.

We may also share any of the Personal Data we collect with our partners in order to achieve the purposes mentioned in the Section “Use of Personal Data” above, including:

· In case of sale of any TCL’s business or assets to another company, merger, or other significant transactions, we may disclose your Personal Data for due diligence purposes and on completion of the transaction;

· We may share your advertising ID (a unique user ID assigned to your devices for advertising purposes) with our advertising partners for them to display advertising;

· If we market third-party products or services to you, we may share your Personal Data with the partners who provide those third-party products or services;

· When you provide your consent to disclose your Personal Data to specific partners;

· To vendors with whom we partner (for example, the providers of our electronic data storage services) that we hire to support us in providing our services and products to you. We will take steps to require such vendors to process your Personal Data in compliance with the provisions set out in this Privacy Notice and under a confidentiality duty;

· To business partners who provide products and / or services that are embedded or served as a component of TCL Materials that we provide to you. These third parties will be responsible for how they use your Personal Data in connection with their services and products as described in a separate privacy notice provided by them, which you are encouraged to verify; and

· To the extent required by law, or if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, establish, exercise or defend our legal rights and/or others.

Besides the disclosures of Personal Data described in this Privacy Notice, we may share your Personal Data with third parties whenever you authorize this sharing.

Please note that if you access third-party services — such as social media services, third-party single-sign on tools, third-party applications, mobile platforms, and telecom carriers of your devices — through our services, these third-party services may be able to collect information about you, including information about your activity on the products and services, and they may notify your connections on the third-party services about your use of the product and services, in accordance with their own privacy policies.

THIRD PARTY LINKS

Our website may contain links to third-party sites and our products may also contain pre-installed applications developed and operated by third parties. We are not responsible for the privacy practices or content of such other sites and applications. This Privacy Notice does not apply to them. You must carefully read the privacy policies related to services of third parties, contacting directly those parties in case of need.

In addition, the carriers of your TCL or Alcatel mobile devices may also collect your Personal Data for service improvement, diagnosis and other purposes. This Privacy Notice does not apply to these carriers and we are not responsible for their privacy practices either. You should contact these carriers if you would like to know the details on how your Personal Data will be collected and processed by them.

INTERNATIONAL TRANSFER OF PERSONAL DATA

TCL shares your Personal Data globally with the companies within its corporate group to carry out the activities specified in this Privacy Notice. TCL may also subcontract the processing or sharing of your Personal Data to third parties located outside your country. When you use TCL Material, we may transfer, storage and process your information within and outside of your country of residence, consistent with this Privacy Notice. The processing of your Personal Data may, therefore, be also subject to laws other than the ones from your country.

TCL takes appropriate steps to ensure that transfer of Personal Data shall be done in accordance with applicable privacy laws and, in particular, that contractual, technical and organizational measures will be in place, such as, with no limitation, the Standard Contractual Clauses approved by the European Commission.

SECURITY OF YOUR PERSONAL DATA

We have adopted organizational, physical and technical security measures that are in line with the industry standards to protect the Personal Data you provide, and to prevent any unauthorised access, disclosure, use, modification, damage or loss of data. We will take reasonable and practical steps to protect your Personal Data, including the following:

· We will use SSL and other technical measures to ensure encryption with regards to our services and products. We will regularly examine our practice of information collection, storage, and processing (including physical security measures) to prevent unauthorised system access.

· We will authorize our employees and personnel of third parties to access your Personal Data on a need-to-know basis in order to help us process your Personal Data and provide the services to you. These employees and external personnel (of third parties authorised by us) are subject to contractual confidentiality obligations.

· The security of your Personal Data is extremely important to us. We will continue our efforts to protect your Personal Data and implement safeguard measures, such as providing encryption protection for information storage and transmission, to prevent your Personal Data from unauthorised access, usage or disclosure.

· We will prudently select business partners and service providers, and implement the requirements for Personal Data protection to the business contracts between both parties.

· We will conduct security and privacy protection training courses, testing and publicity activities to enhance employees' awareness of the importance of protecting Personal Data.

Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. If we become aware of any violation of our security system, we will act in a timely fashion in accordance with any applicable laws.

RETENTION OF PERSONAL DATA

TCL retains your Personal Data only for as long as needed for the purposes described in this Privacy Policy, and it will be deleted after a reasonable time according to the following criteria:

· TCL retains your Personal Data as long as we need for the purposes mentioned in the Section “Use of Personal Data”, which may coincide with the period for which TCL has an ongoing relationship with you; and

· TCL retains your Personal Data as long as we need to comply with a legal obligation to which it is subject or defend claims brought against us.

YOUR RIGHTS

Data protection laws may give you a number of legal rights in relation to the Personal Data that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places. You may refer to the Annexes of this Privacy Notice for more details about your rights in certain specific jurisdictions.

However, we recognise that your Personal Data belongs to you only and that enables you to control how we use it. Consistent with applicable law, your rights may include:

· The right to request access to the Personal Data that we process about you, including the right to obtain information on and copy of such data;

· The right to request that we rectify or correct your Personal Data if it is inaccurate or incomplete;

· The right to request that we erase or delete your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase or delete your Personal Data, but we are legally entitled to retain it;

· If permitted by applicable laws, the right to lodge a complaint with the competent government agency if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting Us” section below.

We may need to go through a data subject request verification before completing your request, and, for example, we may ask you to confirm some data we already have about you. We will only use Personal Data provided in the process of verifying a data subject’s request to verify the requestor’s identity or authority to make the request.

PRODUCT SPECIFIC TERMS

This Privacy Notice applies generally to how we use your Personal Data in relation to our products and services. We may also process additional Personal Data in relation to particular products or services.

SMART TV

We and our third party partners collect Personal Data about your use of our Smart TV products, such as name and duration of videos played, user favourites, pages viewed, and time spent on those pages. This is so that we are able to better understand how our customers use the product and ensure that we can continue to make improvements and tailor our services.

We may collect Personal Data when you use the camera or microphone of your Smart TV products. For example, when you use the camera (either built-in or external camera of your Smart TV products) to conduct video live chats on ChatNow, to provide the video live chat services, we may collect data about your TCL accounts, your video and audio chat history, support data related to trouble shooting and feedbacks related to the use of services.

We may collect additional Personal Data in order to provide remote diagnosis of problems with your Smart TV products. For example, if you have given your consent, we may collect real-time screenshots and information about the data stored on your Smart TV products. This is to ensure that problems with your Smart TV products can be resolved as efficiently as possible.

The Smart TV products capture data of the Amazon Alexa or Google Action voice assistant function on your Smart TV products. This information includes a device description, your voice, Skill Token and Voice command. When you use the voice assistant function, your voice data will be processed by Google or Amazon. Your data will be directly transferred to Google or Amazon. Please refer to Google or Amazon privacy notices for information on further processing of your Personal Data by these companies.

Our third-party advertising partners may use automatic content recognition (ACR) and other technologies to collect your TV viewing and usage information to create profiles of users and determine the personalized advertisements that your devices will receive. You may control whether to allow us to activate the data collection by ACR by following the method provided in the settings page of your Smart TV.

MagiConnect

We and our third party partners will collect details about your usage of the MagiConnect application, including the volume of usage you make of the MagiConnect application (measured through the number of clicks you make) as well as the choice of services you make through the MagiConnect application. We do this so that we understand better your usage of the MagiConnect application and we can tailor the layout of the application to your preferences.

TCL HOME

We and our third party partners will collect details about your usage of the TCL Home application, such as the volume of usage you make of the TCL Home application, the information you provided through live chat and the choices of services you make through the TCL Home application. We do this so that we understand better your usage of the TCL Home application and improve our services and tailor the layout of the application to your preferences.

To provide you with services that allow you to connect and manage multiple TCL devices and other manufacturers’ devices owned by you, we and our third party partners will also collect the following information about you: Wi-Fi or bluetooth information, location, TCL account, device information about your phone and information about the TCL devices to be connected.

TCL CHANNEL

TCL Channel allows users to search content available within TCL Channel by initiating the voice control function in Roku TV. When you use the voice control function, your voice data will be processed by Roku TV directly. Please refer to Roku TV privacy notices for information on further processing of your voice data.

We may collect and process data in relation to Roku TV or TCL device you hold (e.g. its device model, unique device identifier, brand, MAC address, Roku operating system version, region, IP address, application version), and your use of TCL Channel (e.g. your clicks records and browsing history). We may engage third party processors to analyse such data and build profiles on your usage and preference. We do this so that we can understand better how our customers use TCL Channel and make recommendations to you on other content which you may be interested in.

TCL Mobile, Tablet and Wearable Device

We may collect and process special categories of Personal Data such as biometrics data and health data when you use certain applications on TCL mobile, tablet or wearable device. These data are necessary for the health-related functions of these applications. We process your special categories of Personal Data based on your explicit consent, and you may withdraw your consent to such processing at any time with effects to the future. However, you should be aware that if you choose to do so we may be unable to continue to provide certain services to you. If you choose to withdraw your consent, we will tell you more about the possible consequences;

We may collect and process device data and log information including referrer URL, IP addresses and details about your use of our website, cloud services, app store, browsing history, search queries, browser type and session frequency, besides unique device identifiers;

Some TCL mobile devices are under the Alcatel brand but this Privacy Notice also applies to those devices.

USE OF COOKIES

We and our third-party advertising and data analytics partners use “cookies” and similar web technologies including pixel tags or web beacons, (“automated collection tools”) to support certain features of the TCL account, smart TV and other websites and applications operated by us. Automated collection tools are pieces of code deployed on your device. The automated collection tools allow the website to recognize your browser or device during your visit to the TCL website/application or when you return to the TCL website/application. For further details about the cookies we use, please see our Cookies Policy, which can be found here: https://www.tcl.com/kz/en/legal/cookies-policy.

We use two types of automated collection tools: “session cookies” and “persistent cookies”.

A session cookie expires after you close your browser. A session cookie will identify you during your browsing session by assigning a randomly generated unique identification number to your device. We use session cookies:

· To enable us to provide products and services to you and manage transactions. For example, we may deploy a cookie to remember what items you have stored in an online shopping basket; and

· For certain content management and editing purposes.

Persistent cookies do not expire when you close your browser. We use persistent cookies:

· To record whether a visitor is logged in to the TCL account;

· To record when a visitor to the TCL account or other TCL website / application gives consent to our use of cookies, when applicable;

· For performance and design purposes. For example, we might use cookies to track which parts of our websites or applications are popular and to figure out how to improve their functionality;

· To improve user experience and personalise what you see. For example, we might use cookies to record user preferences and to ensure that more relevant website / application content (including advertising content) is delivered to users;

· To enable us and third-party partners that we work with to deliver advertisements or tailor marketing messages that you have consented to receive. For example, we may use cookies to record what products and services you buy or show interest in and use third party services to enable relevant advertisements to be shown on our and other websites / applications based on that information; and

· For certain content management and editing purposes.

How to Manage Automated Collection Tools

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your device. You may also delete cookies as soon as you leave the TCL account or other TCL website / application. Although you are not required to accept cookies when you visit the TCL account, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of the TCL account or other TCL website/application.

For example, the Help portion of the toolbar on most web browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new automated collection tools, and how to entirely disable automated collection tools. With regards to some of the popular browsers you can find more information by clicking on the following relevant links: Google Chrome; Microsoft Edge; Mozilla Firefox; Microsoft Internet Explorer; Opera and Apple Safari.

Where required by applicable laws, we will present you with a cookie banner the first time you visit our website/application that explains what type of automated collection tools we use and which asks your consent for some of the automated collection tools we use.

Personal Data Collected through Automated Collection Tools

We use the Personal Data collected through automated collection tools for the purposes specified above (including in the Section “Uses of Personal Data”). For those cookies where we ask for your consent to deploy them, we also rely on consent as the legal basis for processing Personal Data collected through those cookies.

For U.S. users, the Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit https://www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

At this time, our website does not recognise automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

CONTACTING US

If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed above, please contact us through the specific channels indicated below.

For residents in EEA & UK, please contact our DPO by sending an email at privacy_dpo@tcl.com.

For users in India, our Grievance Officer in India is Mr. Sudhansu Sahu and can be reached at privacyqueryindia@tcl.com.

For users in the United States, TCL subsidiaries are TTE Technology, Inc. and TCT Mobile Inc. whose related addresses and contacts are indicated below:

TTE Technology, Inc. (for TCL TV and service)

189 Technology Drive

Irvine, CA 92618

TCT Mobile, Inc. (for TCL mobile phone/tablet/wearable device and service)

189 Technology Drive

Irvine, CA 92618

For users in Brazil, please contact our DPO by sending an email to privacidade@semptcl.com.br, or by calling +55 (11) 3004-7570.

For more contact information about TCL’s subsidiary, office or representative in your country or region, see our : https://www.tcl.com/choose-country.html.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

TCL GLOBAL PRIVACY NOTICE

DISCOVER THE IDEAL TV FOR YOU