We, and our subsidiaries and affiliates committed to providing quality services and a safe environment to users. This Privacy Policy is meant to help consumers (“you”) understand what information we collect, why it is collected and how the information is used and shared.

Where it is reasonable and practicable to do so, we will collect your personal information only from yourself. However, in some circumstances, we might be provided with information by third parties. This Privacy Policy does not cover actions of third parties. For more information about their practices, please consult their privacy policies. We are not responsible for it.

Definition

1.You: means the natural person whose Personal Data is collected and processed by us.

2.Consumer ID: Consumer Identifier; newly assigned during virgin installation; recreated after reinstallation.

3.Personal Information: 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 a 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 (art. 4(1) GDPR).

4. Serial Number: Serial Number as identified from TV panel. In the event of return of a device, it is refurbished. All of the other parameters can undergo a change, but Serial Number remains the same. So, this is stored to identify the device hardware.

5. URL: means uniform resource locator. This is the web address of a site, which is inserted in the navigation bar of the browser of your Device.

6. App: Means a website or application owned, developed, hosted, operated and maintained by a content partner. We have no control over the app or over the Personal Data that the content partner or other companies collect through your use of the app.

7. Content partner: Means the party that owns, develops, hosts, operates and maintains an app.

8. Cookie: A cookie is a small file containing a string of text that is sent from a server that you visited on the internet to your device and that can be read again by this server at a later time.

9. Device: means any Internet connected product, which is capable to access the Portal and has been certified by us.

10. Device-ID: Unique identifier for Device; remains constant throughout lifetime of use by the Consumer. Server identifies a device through its Device-ID.

11. IP Address: Every device that is connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.

12. Ethernet MAC address: MAC address or wired connection. Used to override server configuration for a single TV under test.

13. Device Portal: A Device authentication server, used to authenticate and identify Devices.

14. Installed country and country of geo location: Installed country is the selected country from the smart TV menu by the consumer. Country of geo location is obtained via IP address of the smart TV.

15. EUI64: EUI64, formed from Ethernet MAC address.

16. Profile ID: Concatenation of : CTN_Component ID_Software version.

17. Model Name : Consumer Type Number as consumer knows it.

18. Firmware ID: Platform ID.

19. Component ID: Platform ID.

20. Software version: TV firmware version number.

21. BCN: Bitmask indicating broadcast network type(s) to which the Device is connected (for which it has channel lists installed).

22. Ufversion: Human readable dotted version number.

23. Status of TOU Acceptance: Individual flags store the status of acceptance by the user.

Why we Collect Information

To enable building of better services and improvement of our services, third parties and our party need to collect your personal information. Personal information collected by us is used for the following purposes:

1. Support and maintenance: to provide you with quality and maintenance services, and to handle and meet your requirements. For example, your search history or browsing history. To deliver the basic Smart device services to you, we are working with several internal and external suppliers.

2. Improve our products and services: we use your information to make improvements in our products and services, for example, your smart TV will store data on hardware/software related to failures and send the above information to our servers for the purpose of problem solving and use of experiences for future improvements of our products.

3. Develop new services: we use the information we collect in existing services to help us develop new ones.

4. Service communications and customer cares: we may use information we collect, e.g. your email address to send you service information, for example, we may inform you of upcoming changes or improvements in our services, or respond to your comments and questions and provide customer services.

5. Protect users, the public and us: we use collected information to help improving safety and reliability of our services. This includes protecting, detecting and deterring fraudulent, unauthorized, infringing or illegal activities that could harm us, our users or the public.

6. To help you or your device register for our Services.

7. To provide customised content and personalised services based on your past activities on our Services. For example, to provide you with Recommendation Service

8. To comply with the law and legal processes

We Want You to Understand Types of Information We Collect as You Use Our Services

We collect information to provide better services to all our users. What information we collect and how that information is used depends on how you use our services and how you manage your privacy controls. A large sum of personal information is collected by us, as described below.

1. Information you create or provide us

When you sign up for an account, you will provide us your personal information that contains your name, telephone number, email address, country of residence, company information, brand information, etc. During sign-up process, we will also request you to provide a password. Your personal data will be linked to combination of username all the time (e-mail address) and password of your own account. When you sign up for an account, a verification e-mail may be sent to you to confirm that we have actually received your e-mail address.

2. Information We Collect as You Use our Services

2.1 Browsing and Device Information

In order to provide you with basic Smart device services, we may collect browsing and device information when you use our services. Information we collect contains Smart device IP address, MAC-Address, browser histories and settings, device type and settings, device-ID, Wi-Fi network name and connection data, country and language configured on your Smart device, time and date of server accessing, error logs, crash reports, software version numbers and which apps you have downloaded.

2.2 Third-party APPs

When you use a third-party App, the third-party may receive your information including device-ID, IP address, login details and language and country configured on your device. To better understand how this information is used and how long it takes to be stored, please check privacy policies of the third party that provides the app. If we need third-party applications to share your information with us, we will seek your prior consent. But we is not responsible for these providers’ privacy or security practices. You should exercise caution and review the privacy statements applicable to the third party websites and services you use.

2.3 Your Location

We will collect your location information when you use our services so that we can provide you some convenient and practical services, such as weather forecast service, etc. We will determine your location either by your IP address. Whether we can collect your location information depends on your authorization.

What do We do with Information We Collect?

1. Authentication

We use combination of your username (e-mail address) ,password or unique identification of equipment to authenticate you.

2. Improve Our Services

For example, we use the application information and IP logs of WebServer to improve user experience through using the smart TV and to further develop it.

3.Share Your Information

We will not share your personal information with companies, organizations or individuals outside of us except in the following cases：

4.With your consent

We’ll share your personal information with third parties when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information.

5.For Legal Reasons

We will share your personal information outside of us if we have a good-faith belief that accesses, uses, preservation or disclosures of such information are reasonably necessary to:

Meet any applicable law, regulation, legal process or enforceable governmental request. Enforce applicable terms of services, including investigations of potential violations. Detect, prevent or otherwise address frauds, security or technical issues. Protect against harms to rights, properties or safety of us, our users or the public as required or permitted by law.

For External Processing

We provide personal information to our affiliates and other trusted businesses or persons to process it for us based on our instructions and in compliance with our Privacy Policy as well as any other appropriate confidentiality or security measure. For example, we use service providers to help us with customer supports. We use and combine the information we collect about you from our Services, devices, or other sources to provide you with a better experience. You have choices about your information.Check out the WHAT ARE YOUR RIGHTS section to learn more.

[For European Economic Area (EEA) Residents only]

We processes personal information for the purposes described above. Our legal basis to process personal information includes processing:
(i) So that we can keep our promises to you, such as providing you with a Service
(ii) To promote our business interests (for example, to manage our relationship with you and improve your customer service experience), including communications on our website, third party websites, and online platforms.
(iii) To comply with the law and legal processes.
(iv) With your consent. If you give consent, you can always revoke by contacting us as specified in the CONTACT US section of this Privacy Policy.

[For California Residents only]

The CCPA requires us to provide our consumers who reside in California with the additional notice below. In the prior 12 months before the date of this Privacy Policy, we may have collected and disclosed for a business purpose the following categories of personal information: the Smart Device IP-address, Serial Number, Ethernet MAC address, Device ID, Consumer ID, and the country and language configured on your Smart Device. If you are a resident of California, you have the right to make the following requests, up to twice every 12 months:
(i)The right to request a copy of the personal information that we have collected about you in the prior 12 months.
(ii) The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.
(iii) The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
(iv) The right to opt-out of sale of your personal information. We do not sell your personal data under the definition of the California Consumer Privacy Act. The CCPA prohibits discrimination against California consumers for exercising their rights under it and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided in the Contact Us area below and provide“My California Information Privacy Rights” in the subject line of your request.

Transfer of your Personal Information

You should also know that your Personal Information may be transferred from your home country to other companies that belong to us or to our service providers around the world. If you are an EU resident, please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country. When we transfer this data, we will do so only when we have put in place appropriate and legal contracts and safeguards to protect your Personal Data.

Information Sharing

We may share your personal information with our subsidiaries and affiliates and with service providers who perform services for us. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. In addition, we may share your personal information with our business partners, such as wireless carriers, as well as third parties who operate apps and services that connect with certain of the Services. We may share personal information we collect through the Services if you ask us to do so or otherwise with your consent. We also may disclose information about you in other circumstances, including
(1) if we are required to do so by law or legal process,
(2) to law enforcement authorities or other government officials,
(3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, and
(4) in the event we may or do sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

How Secure is Your Personal Information?

We uses industry-standard methods to secure its electronic databases of personal information. However, you should know that no company, including us, can fully eliminate security risks associated with personal information. To help protecting yourself, please use a strong password, do not use passwords that are the same as those of other accounts or services to access your account, and protect your user names and passwords to help preventing others from accessing your accounts and services. All products are built with strong security features that continuously protect your information. Insights we gain from maintenance of our services help us detect and automatically block security threats from ever reaching you. what’s more, if we do detect something risky that we think you should know about, we’ll notify you and help guiding you through steps to be better protected. We work hard to protect you and us through unauthorized accesses, alterations, disclosures or destruction of information we hold, including: We use encryption to keep your data private in transit; We review our information collections, storage and processing practices to prevent unauthorized accesses to our systems; We restrict accesses to personal information of our employees, service providers and vendors who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet those obligations. However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system, or wireless connection is completely secure.

How Long do We Store Personal Information?

We won’t keep your personal information for longer than is necessary for the purpose for which it was collected. This means that information will be destroyed or erased from our systems when it’s no longer required. We take appropriate steps to ensure that we process and retain information about you based on the following logic:
1. At least the duration for which the information is used to provide you with a service
2.As required under law, a contract, or with regard to our statutory obligations
3. Only for as long as is necessary for the purpose for which it was collected, is processed, or longer if required under any contract, by applicable law, or for statistical purposes, subject to appropriate safeguards. We generally store personal data as long as it is needed to provide services to you, unless we publish elsewhere in this policy that we store it for a shorter or longer period. We may store (aggregated) data longer if it is needed for taxes or auditing issues.

Information Transfers

We maintain servers in some different countries and your information may be processed on servers located out of the country where you live. Data protection laws vary among countries, of which some provide more protections than others. You consent to transfer of information to countries out of your country of residence, which may have different data protection rules compared with those in your country. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks related to transfers of data.

You Are in Control

Your personal information belongs to you. You can ask us to provide details about what we’ve collected, and you can ask us to delete it or correct any inaccuracies. You have the right to request accesses to your personal information that we process. You also have rights to:
(a) Rectify incorrect personal data or erase it in certain circumstances.
(b) Restrict or object to processing of your personal data.
(c) Right to erase and “right to be forgotten”.
(d) Receive your data so that you can use it elsewhere (data portability).

Cookies

WHAT ARE COOKIES?

Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors. Cookies are used to recognize visitors, enhance your user experience, personalize users' experience if you return to the Site, deliver and tailor marketing and advertising, and generally to improve the Sites and the services provided.

WHAT TYPE OF COOKIES DOES WE USE?

Strictly necessary cookies:

Our Site uses first party cookies (i.e. cookies set directly by Us to your device) that are strictly necessary. These are essential cookies that let you move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, certain services you have asked for cannot be provided. You cannot object to these cookies as otherwise the service cannot be provided.

Cookies to improve your user experience

Our Site uses first party cookies as well as cookies served by third parties and can be used to recognize your computer or mobile device when it visits other websites. Third party cookies are most commonly used for website analytics or advertising purposes. Some of the cookies the Site uses only remain on your device while your browser is open (these cookies are known as 'session cookies'), while others remain for longer periods (these are known as 'permanent cookies').

HOW ARE WE USING COOKIES?

Category of Use	Description
Authentication	We use cookies to verify your account and personalize your experience (e.g. these cookies can help Us keep you logged in as you navigate between webpages).
Security	We use cookies to enable Our security features and to help Us detect activities that violate Our policies (e.g. these cookies can help Us prevent spam).
Site Preferences, Features and Provision of Services	We use cookies to provide you with the features and intended user experience of the Site (e.g. these cookies can help Us with user language preferences, video watch markers, video player setting and preferences, and payment).
Advertising and Remarketing	We and Our advertising partners may collect information using cookies to help make the advertising you see on the Site and elsewhere on the internet more relevant to you, and to measure the effectiveness of the advertising on the Site (e.g. these cookies can help Us and Our advertising partners show you useful and relevant ads more effectively).
Social Media	We use cookies that are set by a range of social media services that We have added to Our Site to enable you to share Our content with your friends and networks. They are capable of tracking your browser across other sites. This may impact the content and messages you see on other websites you visit (e.g. these cookies can help the social media services build a profile of your interests).
Performance, Analytics and Research	We use cookies to collect information on how the Site is used and to report on the Site usage statistics for the improvement of Our services (e.g. these cookies can help Us count visits, page views, traffic sources, and better understand how you and other users use Our Site, and identify features that could be improved).

DO WE RESPOND TO 'DO NOT TRACK' SIGNALS?

We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

WHAT TO DO IF YOU DO NOT WANT COOKIES TO BE SET OR WANT THEM TO BE REMOVED?

If you do not want the Site to collect information through the use of cookies, you can set your web browser to reject cookies from the Site. Each browser is different, so you should check your browser or device's "Help" menu to learn how to change your cookie preferences. You should note that if you reject or block cookies from the Site, the Site may not function as intended. For example, We may not be able to store your preferences or login information or customize the content to your viewing habits.

CHANGES TO THIS COOKIES POLICY

From time to time, We may update this Cookies Policy in order to reflect changes, such as changes to the cookies We use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookies Policy regularly to stay informed about Our use of cookies and related technologies.

Children’s Personal Information

Unless otherwise specified, the Services are designed for a general audience and are not directed to children. In connection with the Services, we do not knowingly solicit or collect personal information from children under the age of 16 without parental consent. If we learn that we have collected personal information from a child under age 16 without parental consent, we will either seek parental consent or promptly delete that information. If you believe that a child under age 16 may have provided us with personal information without parental consent, please contact us as specified in the Contact Us section of this Privacy Policy.

Updates

This Privacy Notice may be updated periodically to reflect changes in our personal information practices with respect to our Service or changes in the applicable law. We will post a notice on our website to notify you of any significant changes to our Privacy Notice, and indicate at the top of the notice when it was most recently updated.The English language version of this Policy will control and translations, if any, are non-binding and for reference only.

Contact Us

If you have any questions, please contact us through the Customer Service.

[For European Economic Area (EEA) Residents Only]

You can also contact us at:
European Data Protection Officer
Raymond,
Marten Meesweg 8,3068 AV Rotterdam