DATA PROTECTION POLICY

 (Effective Date: July 29, 2025)

The Data Protection Policy set forth below (the “Data Protection Policy”) applies to your use of the Device, Application(s), Site, and any Smart Services (collectively, including the Device, Applications, and Smart Services, the “Services”) accessible through the Device. This Data Protection Policy is provided by Hisense International Co., Ltd (hereinafter referred to as “we”, “us” or “ours”).

The entity responsible for processing your personal data pursuant to this Data Protection Policy is:

Hisense International Co., Ltd.

No. 218, Qianwangang Road, Economic and Technique Development Zone, Qingdao, China

E-mail: product.tv.info@gmail.com

EU representative for EEA residents:

 VERDATA Datenschutz GmbH & Co. KG

 Roemerstr. 12

 D – 40476 Duesseldorf

 Email: hisense.representative@verdata.eu

By using our Services, you understand and acknowledge that the collection and use of your Personal Data will be made in accordance with the Data Protection Policy. If you do not feel comfortable with any part of this Data Protection Policy, please discontinue the use of the Services or engage with us immediately.

Introduction

We are committed to protecting the privacy of all our users. The purpose of this Data Protection Policy is to inform you about the types of information we gather about you, how we may use that information, how we disclose it to third parties, and the rights and controls you have with respect to your personal information.

This Data Protection Policy applies to information about you that is collected by us as set forth herein.

This Data Protection Policy does not apply to information that you provide directly to, or is collected by, unaffiliated third parties whose Smart Services you access via the Device, which are controlled by such third parties and whose use may be governed by a separate privacy policy and/or terms of use (for example, a channel or Application operator that is unaffiliated to us). You should review the applicable privacy policy and/or terms of use of any third-party service providers whose Smart Services you access via the Services.

1.     IMPORTANT DEFINITIONS

“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

“Application(s)” means an embeddable, downloadable, and/or executable software application owned by us or a third party and made available on the Device.

“Content” means all audio and visual elements and ideas offered by us or third parties, including but not limited to, data, movies, videos, photographs, software, games, designs, likenesses, artwork, images, music, sound, information, and other materials, tangible and intangible, including derivative works, on all media and formats, existing or in future.

“Controller” means the entity that decides how and why Personal Data are Processed.

“Data Protection Authority” or “Supervisory Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

“Device” means this Smart TV.

“EEA” means the European Economic Area.

“Materials” collectively means any Content, Submitted Content (where applicable and as further defined herein), messaging, blogging, chatting, social networking, information, advertising, and/or Internet links, etc., accessible or delivered through the Device.

“Personal Data” (used interchangeably with the term “Personal Information”) may refer to any information that identifies or makes an individual identifiable or, depending on as defined by the law applicable in your location. In the UK and EEA, Personal data shall mean any information relating to an identified or identifiable natural person. Only the definition that applies to your physical location will apply to you under this Data Protection Policy. 

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Sensitive Personal Data” means personal data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law. Other non-EU jurisdictions, such as Mexico, may define sensitive personal data more generally to include the following: photographs, national origins, or payment records (e.g., credit card numbers, expiration dates, and records of checks.)

“Site” means any website operated, or maintained, by us or on our behalf.

“Smart Services” means the access, procurement, disposal, sale, purchase, subscription, lease, rental, consultation, or other use of Materials, and all other types of services or functions typically available from the Internet, offered by us or by third parties, through Application(s).

“Submitted Content” means any Content submitted, uploaded, or posted by you, on behalf of you, or by other users, on or through your Device or the Smart Services.

2.     WHAT DATA DO WE COLLECT

We collect Personal Data when you interact with our Services.

The types of Personal Data that we may collect about you include but are not limited to: information you provide to us, information collected automatically about your use of our Services, and information from third parties. 

Information You Voluntarily Provide to Us: The Personal Data we collect on or through our Services may include:

(1)    Data you provide: We may obtain your name, email address, mailing address, or other contact details when you provide it to us (e.g., where you contact customer service via email or telephone, register an account, submit a form through our Site, your Device, or newsletter signup).

(2)    Relationship data: We may collect or obtain information in the ordinary course of our relationship with you (e.g., your contact information for technical support or fulfillment purposes, or if you purchase a product or service from us, including any Smart Service).

(3)    Data you make public: We may collect or obtain your Personal Data that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).

(4)    Application data: We may collect or obtain your Personal Data when you download or use any Applications, including your user name, device ID, or other technical identifiers.

(5)    Submitted Content: We may collect or obtain your Personal Data when you provide any Submitted Content.

(6)    Site data: We may collect or obtain your Personal Data (including non-directly identifiable information, such as IP address, cookie IDs, and login information) when you visit any of our Sites or use any features or resources available on or through a Site.

(7)    Registration details: We may collect or obtain your Personal Data when you use, or register to use, any Applications or Smart Services.

(8)    Content and advertising information: If you choose to interact with any third-party Content or advertising in any Applications or Smart Services, we may receive Personal Data about you either directly or from the relevant third party providing that Application or Smart Service.

(9)    Promotions and feedback: We may collect or obtain your Personal Data relating to your voluntary participation in a promotion or survey that we may ask you to complete for research purposes.

(10) Payment information: We, or service providers on our behalf, may collect payment card, transaction or financial account information, if you make a purchase online or sign up via order forms.

(11) Device permissions: We may collect information relating to your use of features on our Services that may ask you to grant us access to location information, photos, microphone, video camera, or media on your computer, mobile device, or other Device.

(12) Third-party information: We may collect information that you provide to us about others, such as the name or contact information of individuals with whom you would like to share one of our webpages or promotions. Please only share such information with us if you have obtained the permission of the other person to do so.

Information Collected Automatically: As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

(1)   Activity and Usage Data: when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.

(2)   Mobile Device Information: if you access the Services through a mobile device (e.g., a smart phone or a tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, and mobile network information.

(3)   Performance Data: information about your preferences to make your use of the Services more productive, via the use of cookies or similar tracking technologies.

Information from Third Parties: When you interact with our Services or accounts on a social media platform, we may collect the Personal Data that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service.

The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such Personal Data that we are permitted to collect by those social media platforms. When you access our Services through social media channels or when you connect our Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Data Protection Policy.

3.     COOKIES AND OTHER TRACKING TECHNOLOGIES

Where applicable, we and our third-party service providers and partners may use cookies, embedded scripts, and other similar technologies (collectively, “Tracking Technologies”) to collect additional Personal Data automatically as you interact with the Services and to personalize your experience with our Services. |

Cookies. 

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes:

• to make our Services function properly;

• to improve our Services;

• to make login to our Services easier (such as by remembering your user ID);

• to recognize you when you return to our Services and to remember the information you have already provided;

• to track your interaction with the Services;

• to collect information about your activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests;

• and to provide a secure browsing experience during your use of our Services.

We may place cookies from third-party service providers and partners who may use information about your visits to other websites to target advertisements for products and services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies. The following types of cookies are used on our Site:

• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site as you reasonably expect. For example, strictly necessary cookies allow you to access secure areas on our Site and provided necessary security functions. Without these cookies, some Site features cannot be provided. This category of cookies is essential for our Site to work and so they cannot be disabled.

• Functional or Preference Cookies. We use functional cookies to remember your choices so that we may tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. While these cookies can be disabled, this may result in less functionality during your use of our Site.

• Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. You can disable these cookies.

• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They may perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting ads that are based on your inferred interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant ads on other sites. You may disable the use of these cookies as noted below.

Your Choices.

Your web browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.

• First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable, or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies, other parts of the Site may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.

• Third-Party Cookies. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.

Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/.

To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

• Google Chrome: https://support.google.com/chrome/answer/95647

• Internet Explorer: https://support.microsoft.com/en-us/topic/description-of-cookies-ad01aa7e-66c9-8ab2-7898-6652c100999d

• Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

• Safari (Desktop): https://support.apple.com/en-us/guide/safari/sfri11471/mac

• Safari (Mobile): https://support.apple.com/en-us/HT201265

• Android Browser: https://support.google.com/nexus/answer/54068?visit_id=638035184398113524-4063500978&hl=en&rd=1

• Opera: https://www.opera.com/en-us/help

• Opera Mobile: https://help.opera.com/en/mobile/android/#privacy

Other Tracking Technologies.

To see how our Site is performing, we sometimes use conversion beacons, tags, scripts and pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We also use these tracking technologies to analyze usage patterns of our Services. The use of these technologies allows us to record that a particular device, browser, or application has visited a particular webpage.

Cross-Device Use. 

We and our third-party service providers may use the information that we collect about you (whether directly from our Site, from our mobile applications, through your device(s), from a third party, or via your use of Services through your Device, such as Enhanced Viewing Service) to help us and our third party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers may also use the cross-device use and other information we learn about you to serve targeted advertising on your devices and send you emails. To opt-out of cross-device advertising, you may disable or opt-out of personalized advertising at any time via opting out of advertising cookies on our website or by disabling personalized advertising via your Device. Please note that your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.

Do Not Track.

Because uniform standards for “Do Not Track” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

4.     HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data as described in this Data Protection Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your Personal Data include:

(1)    Provision of Services to you: providing Sites, Applications and Smart Services to you; registering your account on your Device; providing you with other products and services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those products and services; operating and managing Sites, Applications and Smart Services; providing Content to you; displaying advertising and other information to you; communicating and interacting with you via Sites, Applications and Smart Services; and notifying you of changes to any Sites, Applications and Smart Services.

(2)    Operation of the Device: providing and maintaining services in connection with the Device; administering the Device (including Processing any searches or requests for certain Materials, recommending Materials, providing blogs, open forums, discussion pages or personalized features).

(3)    Maintain legal and regulatory compliance: our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to fulfill our business obligations, to manage risk as required under applicable laws and regulations, or to respond to requests by judicial process or governmental agency.

(4)    Enforce compliance with our terms, agreements and policies (“Terms”): when you access or use our Services, you are bound to our terms, including our End User License Agreement. We may process your personal information for compliance purposes, such as carrying out our obligations and enforcing our Terms or other legal rights, including those arising from any contracts entered into between you and us, including for billing and collection.

(5)    Detect and prevent fraud and security risks: we may process your personal information to help monitor, prevent and detect fraud and abusive use of our Service, monitor and verify your identity so that unauthorized users do not gain access to your information, enhance system security, and combat spam, malware, malicious activities, or other security risks, operation of IT security systems, and conducting IT security audits.

(6)    Provide support or respond to you: we collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of our services.

(7)    Provide you with service-related communications: we may send you administrative or account-related information to keep you updated about your account and our services. Such communications may include information about Data Protection Policy updates, confirmations of your account actions or transactions, security updates, or other relevant transaction-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise, you may miss important developments relating to your account or our services.

(8)    Provide other communications to you: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.

(9)    Financial management: sales; finance; corporate audit; and vendor management.

(10) Surveys and polls: engaging with you for the purposes of obtaining your views on our products and services, including for research purposes.

(11) Investigations: detecting, investigating and preventing breaches of policy and criminal offences in accordance with applicable law.

(12) Improving our Sites, Applications and Smart Services: identifying issues with Sites, Applications, and Smart Services; planning improvements to Sites, Applications, and Smart Services; and creating new Sites, Applications, and Smart Services.

(13) Personalize your experience: saving your user account, registration and profile data or other Personal Data (so you do not have to re-enter it each time you visit or use the Device or Services); tracking your return visits to and use of the Services; tailoring your experience on the Services; using information about your viewing history or purchase history to make contextual inferences while using our Services; and/or otherwise customizing what you see when you visit and use the Services;

(14) With your consent: for any other purpose disclosed to you before you provide us with your Personal Data or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.

5.     HOW WE SHARE AND DISCLOSE DATA

There are times where we may share the information described in this Data Protection Policy, and this section describes how we may share such information. Generally speaking, we will only disclose your Personal Data to the extent that such disclosure is necessary: (i) to provide you with Smart Services you have requested; (ii) for compliance with applicable law; (iii) to establish, exercise or defend our legal rights; or (iv) to the extent necessary in connection with the sale or reorganization of any relevant portion of our business. Such sharing applies to all of the categories of Personal Data that we collect.

We may share or disclose your personal information in the following circumstances:

(1)    Within Our Corporate Organization. We may share your Personal Data with our subsidiaries and affiliates in order to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis.

(2)    Service Providers. We may employ other companies and individuals to facilitate our Services, provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Services are used. These service providers provide us support services such as credit card processing, payment gateways, subscription processing, website hosting, online store platforms, customer relationship management, order fulfillment, email and postal delivery, analytics, surveys, digital rewards, and marketing services. The service providers have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

(3)    To Facilitate Corporate Acquisitions, Mergers and Transactions. We may disclose Personal Data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Services users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your Personal Data.

(4)    As Required by Law and to Protect Lawful Interests. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us investigate or prevent crimes (including fraud) or protect the rights, property, or safety of us or our customers. We may also share your information with our data protection officers, legal counsels, and other professional advisors , for the management of our business and for legal compliance purposes.

(5)    With Business Partners. We may provide Personal Data to unaffiliated third-party business partners, such as personalized advertising partners where it is available on your Device. You may opt out of such sharing at any time by contacting us or by disabling the use of services that enable such sharing, such as Enhanced Viewing Service within a Device.

(6)    With Your Consent. We may disclose your personal information for any purpose with your consent.

Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.

6.     ENHANCED VIEWING SERVICE AND AUTOMATED CONTENT RECOGNITION

Where available, we offer an Enhanced Viewing Service (“EV Service”) that, where available and when activated, adjusts your sound and video quality based on what you are watching in real time and provides you with useful, interactive features, content recommendations, and personalized advertisements. This is an optional service that you must opt-in to via your Device during the initial setup or any time after within the Device’s “Settings” menu. From the Settings menu, you may also choose to enable all, some, or none of Enhanced Viewing Service’s features. Please be noted that the EV service is not available in all regions worldwide nor in all models of Device. It may not currently be available on your Device.

The EV Service uses Automated Content Recognition (“ACR”) technology, which works by analyzing and matching onscreen audio sounds that come from your Device (such as a TV show’s dialogue or a movie streaming from an app or music playing during a commercial) against an extensive database of programming content. When the content is recognized, we can use this ACR data for content recommendations, advertising, and where available, to automatically optimize your picture quality based on the type of content you are watching (e.g., optimizing the picture mode to watch sports versus a movie).

Through the EV service and ACR technology, we may collect and use data from your Device, including: device and usage information; log data about your use of Applications and services; user ID or other identifiers; your Device’s IP address; product registration data; geolocation or information that can be used to derive geolocation; your Device viewing history; behavioral and demographic information; and your general device location (together, “Viewing Data”). If you opt-in to the EV Service, we may collect and use your Viewing Data even if the EV Service is not currently available on your Device.

Viewing Data will be used to help our advertising partner Nexxen Inc. and its partners select, deliver, and measure personalized ads shown to you on your Smart TV or other linked devices sharing the same IP address, based on audience segmentation created from your viewing habits. By giving your consent to personalized ad targeting, you therefore also allow Nexxen Inc. to use your household IP address to identify other devices linked to you or your household for such advertising purposes. If you do not consent to personalized ads, you will still see ads, but they may not be as interesting to you.

For more information, including regarding how Nexxen Inc. may share your data with its partners for such purposes, please review Nexxen ’s privacy policy (available at: https://nexxen.com/services-privacy-policy/). You can also see each partner and how they may use data about you and your household at https://nexxen.com/acr-data-partners/ .

We use and may share this information for the purpose of delivering to you the EV Service, device-specific viewing recommendations, and serving relevant advertising. You may opt-in or opt-out of EV Service at any time through the Device’s “Settings” menu.

For more information, including details on the technical aspects of the EV Service and ACR data, please see our Enhanced Viewing Service Privacy Notice.

7.     SECURITY OF THE INFORMATION WE COLLECT

We maintain physical, administrative, technical, and organizational safeguards designed to maintain the confidentiality and security of your Personal Data. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through use of any Device or Smart Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures for the Device or the Smart Services. The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Services, please keep your account and password safe. Please do not share your password with anyone.

8.     RETENTION

We store your Personal Data within the period of your valid consent or the period under the contract between you and us, unless there are other different requirements according to applicable laws. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data or the information you provided to us to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will retain your marketing contact information until you unsubscribe from our marketing communications. We will also retain Site, Applications, and Device usage data for internal analysis purposes.

9.     COLLECTION OF CHILDREN PERSONAL DATA IS NOT PERMITTED

We are committed to protecting the Personal Data of children, and recognize that parents or legal guardians may purchase the Device for family use, including by minors. As such, Smart Services accessed through the Device are not intended for use by individuals under the local adult legal age minimum, and we will not knowingly collect Personal Data from individuals under such age for any purpose, nor will we accept registration from such individuals. In some cases, particularly where information is collected electronically, we may not be able to determine whether information was collected from children under local legal age, and we treat such information as though it were provided by an adult. If we learn that a child under the local legal age has provided any Personal Data, we will use commercially reasonable efforts to delete such information immediately.

WE EXPRESSLY DISCLAIM ANY RESPONSIBILITY OR LIABILITY FOR THE USE OR MISUSE OF SUCH FEATURES IN OUR SERVICES BY CHILDREN IN VIOLATION OF THIS DATA PROTECTION POLICY.

10.  ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA

You have the ability to access, correct, and delete your Personal Data that you shared with us on our Services or through other written or oral means. We are committed so that your Personal Data is kept accurate and up to date. However, it is up to you to update it with any changes. In most cases, you can review and submit changes to your Personal Data by logging into your account and visiting your account profile page. You may also notify us via the information in the “Contact Us” section below to request access to, or to correct any Personal Data that you have provided to us. We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you no longer wish to have your Personal Data processed, you may request to delete your account (username and password), subject to certain limitations, by contacting us as described in “Contact Us” section below.

Please note that if you would like to deactivate the Smart Services or withdraw your consent, this does not automatically delete all of your Personal Data collected by us or on our behalf. However, you can delete all of the account-related Personal Data you have provided us by deleting your account or by contacting us with your request as described below.

11.  COMMUNICATION PREFERENCES

In order to provide service to you, we may send you communications related to your transactions, security, or the administration of our Services. From time to time, we may also send you other messages or updates about us, our website, our operating systems, Device, or our other products and offerings. If you do not wish to receive non-transaction communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us as specified in the “Contact Us” section below.

Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process, and apply, during which time your information shall remain subject to the prior privacy settings.

By downloading and using our mobile applications, you may receive messages, reminders, offers, news, and information from us within the mobile application itself. These “in app” messages are part of our mobile application’s functionality but can be adjusted using your device or app settings.

12.  SENSITIVE PERSONAL DATA

We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. We ask that you not provide us with any Sensitive Personal Data. In some jurisdictions, the uploading of photos to a user account or the storage of payment card information, for instance, may constitute collection of Sensitive Personal Data, and we comply with applicable law in relation to residents of those locations. Although we generally do not collect or Process Sensitive Personal Data, in situations where applicable law requires it, we rely on one of the following legal bases:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law;

• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);

• Establishment, exercise or defense of legal rights: We may process your Sensitive Personal Data where the processing is necessary for the establishment, exercise, or defense of legal rights; or

• Explicit Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your Sensitive Personal Data (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

13.  NOTICE TO EEA, U.K, AND SWISS RESIDENTS

This section provides general information about how we collect, store, use, transfer and otherwise process personal data in or from certain countries in the European Economic Area, the United Kingdom, and Switzerland, in accordance with the General Data Protection Regulation (“GDPR”) and its local implementations.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. If any terms in this section conflict with other terms contained in this Data Protection Policy, the terms in this section shall apply to respective individuals.

a.     Legal Bases for Processing Your Personal Data

Our legal bases for processing your Personal Data under the GDPR will depend on the Personal Data at issue, the specific context in which the Personal Data is collected and the purposes for which it is used. Below is how we use and share your Personal Data, as described above in Section 4 and Section 5 with the corresponding legal bases for processing.

1.     Based on our legal obligations. Article 6(1) lit.(c) GDPR:

Section 4(3) Maintain legal and regulatory compliance.

Section 4(5) Detect and prevent fraud and security risks.

Section 5(4) As Required by Law and to Protect Lawful Interests.

2.     Based on our contract with you or to take steps at your request prior to entering a contract. Article 6(1) lit.(b) GDPR:

Section 4(1) Provision of Services to you.

Section 4(2) Operation of the Devices.

Section 4(4) Enforce compliance with our Terms, Agreements and Policies.

Section 4(6) Provide support or respond to you.

Section 4(7) Provide you with service-related communications.

Section 4(9) Financial management.

Section 4(10) Surveys and polls.

Section 4(11) Investigations.

Section 5(1) Within Our Corporate Organization.

Section 5(2) Our Service Providers.

3.     Based on our legitimate interest to operate our business and not overridden by your data protection interests or fundamental rights and freedom. Article 6(1) lit.(f) GDPR:

Section 4(8) Provide other communications to you.

Section 4(12) Improving our Sites, Applications and Smart Services.

Section 4(13) To personalize your experience.

Section 5(3) To Facilitate Corporate Acquisitions, Mergers, and Transactions.

4.     Based on your consent. Article 6(1) lit.(a) GDPR:

Section 4(14) With your consent.

Section 5(6) With Your Consent.

b.     Data Subject Rights.

Your rights in relation to our processing of Personal Data concerning you are set out below. Please note that not all such rights apply in all circumstances.

If you would like to exercise your rights under applicable laws, please contact us via the identified at the beginning of this policy. In your request, please make clear which right you would like to exercise. Upon receiving your rights request, we may seek to verify your identity to ensure the security of your Personal Data. If you assert any of these rights, we will make reasonable efforts to do so within one (1) month or, to the extent permitted by applicable law, as soon as reasonably practicable.

●      Right to access. You have the right to obtain to access the Personal Data that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your Personal Data. You are also entitled to copies of the Personal Data you have provided to us that we process, unless there are reasons why we cannot provide these, for instance, if by doing so we will adversely affect the rights and freedoms of others in relation to Personal Data concerning them.

●      Right to rectification. You have the right to correct any incorrect Personal Data in our files.

●      Right to erasure. Under certain circumstances, you may have the right to the erasure of the Personal Data that we hold about you. This right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your Personal Data.

●      Right to restrict processing. You have the right to request that we restrict our processing of your Personal Data in certain circumstances. For instance, this right may be available if you contest the accuracy of the Personal Data.

●      Right to object to processing. You may have the right to object to our processing of your Personal Data at any time and as permitted under applicable law if we process your Personal Data on the legal bases of consent or legitimate interests. However, we may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted under applicable laws.

●      Right to portability. Under certain circumstances, you may have the right to receive Personal Data we hold about you in a structured, commonly used, and machine-readable format so that you can provide that Personal Data to another controller.

●      Right to lodge a complaint. Without prejudice to any other administrative or judicial remedy, you may have the right to lodge a complaint with a supervisory authority if you consider that the processing of Personal Data relating to you infringes applicable laws. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

●      Automated Decision-Making. You have the right to not have automated decision making made about you. We do not make any decisions based solely on algorithms or other automated processing that produces legal effects or similarly significantly affects you.

You also have the right, for reasons arising out of your particular situation, at any time to withdraw your consent for the processing of the data concerned. In this case, we will no longer process the data concerning you, unless we can prove compelling reasons of protection for the processing that outweigh your interests, rights and freedoms, or processing is for the purpose of asserting, exercising, or defending legal claims.

c.      Retention.

As a general rule, we keep your Personal Data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal, regulatory, accounting or other obligations. For more information, please see Section 8 above.

14.  NOTICE TO RESIDENTS OF CERTAIN STATES IN THE UNITED STATES

This section advises residents of the United States who reside in states that have a comprehensive consumer privacy law currently in effect. This section describes how residents of such states, including California, Colorado, Connecticut, Oregon, Texas, Utah and Virginia, may exercise rights under the consumer privacy laws applicable to their state of residence (“U.S. State Privacy Laws”).

The definition of “personal information” depends on the applicable law in your U.S. State Privacy Law state. For purposes of this section, “personal information” is any data that identifies or makes an individual identifiable.  Personal information does not include information that is publicly available, deidentified or aggregated, or otherwise excluded from the scope of applicable U.S. State Privacy Laws.

Privacy rights include the following:

(a)     Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.

(b)     Right to Correct. You may have the right to correct any of your personal information in our records and systems that is inaccurate.

(c)     Right to Delete. Under certain circumstances, you may have the right to request that we delete the personal information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal information or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable laws and their exceptions.

(d)     Right to Portability. You may have the right to receive a copy of the personal information we have collected about you in a structured, commonly used and machine-readable format.

(e)     Right to Opt-Out Sale / Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt-out of: (i) the sale of your personal information to third parties; and (ii) the sharing of your personal information for targeted advertising. While we do not sell your personal information for money, we use cookies, pixels, software development kits, advanced programming interfaces, third-party integrations within our Device operating systems, and similar technology, and we make available certain information, such as your IP address or device identifiers, to certain third-party advertising partners in order to improve your user experience and to optimize our marketing activities. Under some state privacy laws’ broad definition of “sell”, this could be considered a sale, and it could be considered “sharing” of your personal information for targeted, cross-context behavioral advertising purposes. 

You have the right to direct us not to sell your personal information to third parties, and to direct us not to share or use your personal information for targeted advertising purposes. To exercise your right to opt-out, please submit a request by clicking on the “Do Not Sell/Share My Personal Information” link within the settings menu of your Device or Service, or by emailing us as described in the “Contact Us” section below. Please note that you may still receive generalized ads after opting out of targeted advertising.

(f)      Right to Limit Use and Disclosure of Sensitive Personal Information. If you are a California resident, to the extent your sensitive personal information, as that term is defined under California privacy law, is used to infer characteristics about you, you have the right to object to our processing of your sensitive personal information.  We do not use sensitive personal information to infer characteristics about you.

(g)     Right to Opt-Out of Automated Decision-making or Profiling.  You may have the right not to be subject to a decision which significantly impacts your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.

(h)     Right Against Discrimination. You may have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your rights.

(i)      Right to Appeal. In certain jurisdictions, you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.

(j)      Shine the Light. If you are a California resident, you have the right to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes.

(k)     Right to Withdraw Consent. In certain jurisdictions, to the extent the processing of your information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing before your withdrawal.

(l)      Marketing Communications.  You may choose to provide us with your email address to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. If you sign up to receive text messages from us that contain promotional information, you can opt-out of receiving future messages by replying “STOP.”

Please note that “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process, and apply, during which time your information shall remain subject to this Section. Additionally, you should be aware that any information provided to third-parties prior to your election to unsubscribe will not be retrieved or rescinded, unless required by applicable law.

As mentioned above, depending on where you reside, you may be able to assert certain rights with respect to your personal information. To determine which rights you have, please refer to the table below that references the rights as described above in the “Consumer Privacy Rights” section. Any places that are not listed either do not have a law providing such rights, or their law does not apply to our operations.

Submitting a Request to Exercise Your Rights.  In addition to the methods specified above, you may exercise these rights by sending your request via mail to the address provided in the “Contact Us” section.

Before fulfilling your request, we may be required by law to have you to verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

You may use an authorized agent to submit a rights request on your behalf.  If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.

Special Notice to California Residents

This section applies solely to individuals who reside in the State of California. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information, about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act of 2018, as amended (“CCPA”).

In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:

·          Identifiers

·          Personal information categories listed in the CCPA

·          Commercial information

·          Internet or similar network activity

·          Inferences drawn

The sources of this personal information are outlined in Section 2 above (“How We Collect Your Personal Data”); the purposes of information collection are outlined in section 4 (“How We Use Your Personal Data”); and the sharing of this personal information is described in section 5 (“How We Share and Disclose Data”).

We will promptly take steps to respond to your right request within forty five (45) days of receiving a verifiable request form you, when this time period is to be extended by an additional forty five (45) days wherein reasonably necessary, we will provide you notice of extension within the first 45-day period.

15.  SPECIAL INFO FOR CANADIAN CITIZENS

Consent

We will obtain your consent to collect, use or disclose personal data except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal data without your knowledge or consent where: the information is publicly available, as defined by statute or regulation; we are obtaining legal advice; or we reasonably expect that obtaining consent would compromise an investigation or proceeding.

Other exceptions may apply.

Your consent can be express, implied, or given through an authorized representative. Consent may be provided orally, in writing, electronically, through inaction (such as when you do not notify us that you do not wish your personal data collected/used/disclosed for various purposes after you have received notice of those purposes), or otherwise.

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of your withdrawal of consent. If you notify us that you withdraw consent, we will inform you of the likely consequences of that withdrawal, which may include our inability to provide certain services for which that information is necessary.

Limits on Collection of Personal Data

We will not collect personal data indiscriminately but will limit collection of personal data to that which is reasonable and necessary. We will also collect personal data as authorized by law.

Limits for Using, Disclosing, and Retaining Personal Data 

Your personal data will only be used or disclosed for the purposes set out above and as authorized by law.

We will keep your personal data for as long as necessary in connection with the purposes identified above or as permitted or required by law. You must notify us if you no longer want us to retain your information.

Location of Service Providers, Hosting, and Servers

Our service providers may be located outside of the country in which you are located, and our servers are currently located in the United States of America. You therefore acknowledge that your personal data may be processed and stored in foreign jurisdictions and that governments, courts, law enforcement or government or regulatory agencies in the USA, Canada, and elsewhere may be able to access or obtain disclosure of your personal data under a lawful order or otherwise through the laws of the applicable jurisdiction, irrespective of the safeguards we have put in place for the protection of your personal information.

Access to my Personal Data 

You may modify personal data that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Site or Application for a period of time.

In some situations, we may not be able to provide access to certain personal data. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation, or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm our competitive position. We may also be prevented by law from providing access to certain personal data. When an access request is refused, we will notify you in writing, document the reasons for refusal, and outline further steps which are available to you.

Amendment to my Personal Data

Requests to modify any information that exists in Provider notes may be submitted to product.tv.info@gmail.com. Please allow up to thirty (30) days for us to process and respond to your request.

Limitations on Deletion of Data

You may request deletion of your personal data by us. However, we may be required (by law or otherwise) to keep this information and not to delete it. When we delete personal data, it will be deleted from the Services’ active database, but your personal data may remain in our archives. If we disclose some of your personal data to third parties, we may no longer have access to that personal data and cannot force the deletion or modification of any such information by those third parties. After we delete personal data, we may retain de-identified information, and will continue to use the information as permitted under this Privacy Policy.

What choices do I have regarding the use of my personal data?

We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

You may also withdraw your consent to our collections, uses and disclosures of your information at any time, subject to legal, contractual, and other restrictions and technical limitations, provided that you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.

16.  YOUR MEXICO PRIVACY RIGHTS

You have the right to (i) access your Personal Data; (ii) rectify your Personal Data, if they are inaccurate or incomplete; (iii) cancel your Personal Data; and (iv) oppose the use of your Personal Data for specific purposes (jointly, the "ARCO Rights"). In case you wish to exercise any of the ARCO Rights, please send an email to the account at product.tv.info@gmail.com, which must contain, at least, the following information:

Full name and email address or address, in order to communicate the response to your request.

The documents that prove your identity, or if applicable, that of your legal representative.

A clear description of the Personal Data with respect to which you seek to exercise any of the ARCO Rights.

Any other element or document that facilitates the location of Personal Data.

If required, we may request additional information.

The response to your request will be communicated to you within the following 15 (fifteen) business days and, if it is appropriate, it will be implemented within a maximum period of 20 (twenty) business days.

How can you revoke your consent to the use of your personal data?

You can revoke the consent that, in your case, you have given us for the processing of your personal data. However, it is important that you bear in mind that not in all cases we will be able to respond to your request or terminate the use immediately, since it is possible that due to some legal obligation, we will need to continue processing your personal data. Likewise, you should consider that for certain purposes, the revocation of your consent will imply that we cannot continue to provide the service you requested, or the conclusion of your relationship with us.

To revoke your consent, or to inquire as to the procedure and requirements for doing so, you must submit your request at product.tv.info@gmail.com.

How can you limit the use or disclosure of your personal data?

In order for you to limit the use and disclosure of your personal data, we offer you the following means:

Your registration in the Public Registry to Avoid Advertising (Registro Público para Evitar Publicidad), which is in charge of the Federal Consumer Prosecutor's Office (Procuraduría Federal del Consumidor), so that your personal data is not used to receive advertising or promotions from goods or services companies. For more information about this registry, you can consult the PROFECO Internet portal, or you can contact it directly.

Your registration is in our exclusion list, so that your personal data is not processed for marketing, advertising, or commercial prospecting purposes by us. For more information, you can contact us at product.tv.info@gmail.com.

Non-conformity or complaint to the INAI

If you consider that your right to the protection of Personal Data has been damaged by any conduct or omission on the part of the Data Controller, or you presume any violation of the provisions set forth in the Law, its Regulations, and other applicable regulations, you may file your disagreement or complaint before the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI). For more information, we suggest you visit their official website: www.inai.org.mx.

17.  THIRD PARTY MATERIALS, APPLICATIONS, AND ADVERTISEMENTS

Third parties who offer Applications or Materials on a Device may collect Personal Data when you access their Application(s) and Materials. We are not responsible for the data collection and privacy practices employed by such third parties or their services, and they may be collecting data about you and may be sharing it with us and/or others. These third parties and their services may also track you across sites and time, serve you their own advertisements (including interest-based advertisements) and may or may not have their own published privacy policies.

In addition, when you are using the Device you may be directed to other services that are operated and controlled by third parties that we do not control. For example, if you browse the Internet and “click” on a link on a website, the link may take you to a different website. We encourage you to review the privacy policies of all third-party locations when you access a new website or Application and exercise caution in connection with them. We are not responsible for the availability, completeness, or accuracy of such third parties’ policies or notices.

18.  BULLETIN BOARDS AND OTHER PUBLIC AREAS

We may offer bulletin boards or other public functions on the Device and/or Smart Services, and any posting by you in these areas is considered public information that is available to other users. We do not control, and are not responsible for, the actions of other users of the Device and/or Smart Services with respect to any information you post in public areas. In addition, information that you submit to public areas may be collected and used by others to send you unsolicited messages and for other purposes. Any posting in bulletin boards and public areas on the Device are governed by the EULA for the Device or the terms and conditions of the applicable third parties web sites. Portions of your user profile may also be available to other users, and you should take care to not use Personal Data in your user name or other information that might be publicly available to other users.

19.  INTERNATIONAL TRANSFER OF INFORMATION

Our business operates on a global scale. When you access or submit information to us, your Personal Data may be transferred to, processed, maintained, and used on computers, servers, and systems located where the data protection laws may not be as protective as those in your jurisdiction. If you choose to provide information to us in connection with your use of the Device or Services, please note that we may transfer your Personal Data to servers located in the United States of America, and our processor or affiliates located elsewhere. We will take appropriate contractual or other steps to protect the relevant personal information in accordance with applicable laws.

We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of Personal Data collected in the EEA, to the extent the recipients of the European Personal Data are located in a country that the EEA consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.

We are responsible for the processing of Personal Data we collect and subsequently transfer to a third party acting on our behalf. Before we share your information with any third party, we will enter into a written agreement requiring that the third party provide at least the same level of protection for the personal information as required under applicable data protection laws.

20.  DATA PROTECTION POLICY VERSIONS AND CHANGES

We reserve the right to change this Data Protection Policy at any time or for any reason, and will post any changes to this Data Protection Policy within a reasonable period after they go into effect. This Data Protection Policy will remain in full force and effect as long as you are a user of the Service, even if your use of or participation in any particular service, feature, function, or promotional activity terminates, expires, ceases, is suspended or deactivated for any reason.

21.  CONTACT US

Please direct any questions you may have regarding your data protection or requests to exercise applicable rights described in this Data Protection Policy to our email at product.tv.info@gmail.com.

If you are based in EEA or EEA residents, please contact us at product.tv.info@gmail.com. You may also contact our EU representative:

 VERDATA Datenschutz GmbH & Co. KG

 Roemerstr. 12

 D – 40476 Duesseldorf

 Email: hisense.representative@verdata.eu

For Australian residents, we will review your complaint and endeavor to respond to you as soon as possible. If you are unhappy with our response to your complaint, you have the right to make a complaint to the OAIC. Details of how to contact the OAIC are provided on its website at www.oaic.gov.au.