EU DATA ACT User Information on TWS Earphones

This document outlines the types of data TCL products can generate through its integrated services and features, how we use and share that data, and the rights you have in relation to the data. Please note that due to differences in the features provided by our various product models and services, the data generated may vary accordingly. For more detailed information, please contact us using the details provided in the “User Rights” section below.

I. Information about Data

This section relates to the data that the product and the related service can generate and collect.

1. TCL TWS Earphones

The TCL TWS Earphone are smart connected products and can collect data during its usage.

It may collect the following types of data:

2. Related Service

1）TCL Home App

TCL Home APP aims to provide you with device management and software upgrade services. It is provided by Shenzhen TCL New Technology Co., Limited. 

As long as it is made available, you may continue to use the service. You can stop using the service at your discretion and at any time. If you would like to delete the associated account and related data, you can visit TCL Privacy.

a) Purpose of data collection and generation 

The data collected and generated for the purposes stated in the Terms of TCL Home App. In regard to the TWS earphones, no data sharing to third parties.

b) Product Data collected by the Service -  

The TCL Home APP is collecting the following data from the TWS Earphones: 

Hardware and Firmware version; Device model/type; Device ID; MAC address; Serial number; Battery level of earphones and charging case; EQ (Equalizer) audio effect settings; Tap sensitivity settings; Spatial audio settings; Custom tap function configurations; Earphone Ringing Status of Find my Earphone; BLE advertisement data. 

For the estimated volume of product data, when the user operates the earphones, product data is generated at approximately 50–200 bytes per second. When the user does not operate the earphones and only maintains an active BLE connection, approximately 20–30 bytes of data are generated every 20–25 seconds. The actual volume and frequency of data collection depend on the use of the service and the user’s behavior. The actual volume and frequency of data collection depend on the use of the service and the user’s behavior. 

c) Related Service Data to be generated  

Based on the above connected product data collected, the Service will generate the following data: Device binding/unbinding records; OTA firmware upgrade status and progress data; Device version records; User authentication tokens; User preference settings; Upgrade history records; Binding time; Device name and nickname; Location name and ID. 

The estimated volume of service data generated is 0.5-1K per Each time you operate the APP. The actual volume and frequency of data generation depend on the use of the service and user’s behavior. 

d) Data retention and storage

The data collected and generated by the service are stored locally on the user’s mobile device and on the cloud server, with differentiated storage and retention rules based on certain data type.

Real-time status data obtained from the earphones BLE (including but not limited to battery level, EQ, sensitivity, spatial audio, etc.) are not stored. For configuration information stored locally on the mobile device (including device id, MAC address, remote id (iOS BLE identifier), authentication-related tokens, host, country Code and other data used for automatic reconnection), it will be retained until the user unbinds the device or uninstalls the application; For Product Data and Related Service Data synced to the cloud, it will be kept for the duration necessary to provide the services. In line with the principle of storage limitation, such data will be erased upon the expiration of its necessary retention period, or the successful deactivation of the user account, or the unbinding of the device, whichever occurs first.

II．Information about User Rights

This section specifies your rights, how you can exercise the rights and the terms of use of the data and quality of service applicable to you.

1. Right to access and portability under the Data Act

EU Data Act may give you a number of legal rights in relation to the Connected Product data and Related Service data. As such, you have the right to access and to portability of the data generated by the connected product and/or related service you use.

These rights apply to data that is easily accessible and generated by the products and services, whether it qualifies as personal data or non-personal data. Easily accessible data refers to all data generated by the product or related service you use, which we can provide without having to carry out complex operations or disproportionate efforts. This excludes any data protected by specific rights - such as trade secrets, intellectual property - or data that we have reprocessed or enriched.

For more detailed information about data use and access, please refer to the Terms of Use, electronic manuals, or other relevant materials.

You may exercise your rights under the Data Act using the below contact form: 

 Data Act Contact Form on TCL's Official Websites >>

2. Privacy rights under GDPR

If your request concerns personal data, the conditions and limitations set out by the GDPR will apply. Additionally, if your request involves personal data of third-party users, it must be based on valid legal ground, in accordance with Article 6 of the GDPR. To learn more about your personal data, you may visit our dedicated page on TCL Privacy.

3. Right to lodge a complaint

As a user, you have the right to lodge a complaint if you believe that any of your rights under the Data Act have been infringed. This right ensures that your concerns regarding potential violations of data access, sharing, or usage provisions are heard and appropriately addressed by the responsible oversight body. If you wish to exercise this right or require further assistance, please contact the relevant authority in your Member State.