Hello, and thank you for taking the time to read this policy. Our company is called TCL. We make services and devices for kids to enjoy and to help them learn new and interesting stuff. We have offices all over the world, including in Europe and the United Kingdom (“UK”).

 

If you are a kid who lives in Europe or the UK, this policy is for you. Where you live, there are rules to help keep “personal data” safe. Those rules are important to us, and we do our best to obey them so that you trust us with your data. In this policy, we explain how we use your data and what we do to keep it safe.

 

If you have any questions, you or your parent (or guardian) can contact us at privacy_dpo@tcl.com. You can also write us at one of our addresses listed at the end of this policy. If you are an adult, or would like to read more details about how we handle personal data, please refer to the Children Privacy Protection Notice for adults here. 

 

To find out more, read on below, or skip to one of these sections:

• WHAT IS PERSONAL DATA? 
• WHAT KINDS OF DATA DOES TCL COLLECT ABOUT ME? 
• WHAT DOES TCL DO WITH MY DATA?  
• WHAT ARE TCL’S “GOOD REASONS” TO USE MY DATA? 
• WHO DOES TCL SHARE MY DATA WITH?
• HOW LONG DOES TCL KEEP MY DATA?
• DOES TCL SEND MY DATA TO OTHER PLACES?
• WHAT ARE MY RIGHTS?
• WHERE CAN I FIND OUT MORE?
• UPDATES

 

WHAT IS “PERSONAL DATA”?  

 

You might ask: what is “personal data”? That is a good question. Personal data is a big idea. Basically, it means any data about you or that can be related to you. It means your name, age, and address, but it can be lots of other stuff, too.

 

For example, it can be data about the services you like to play and how long you play them. It can be data about your hobbies or stuff you find interesting. It can be data about where you are from or where you are right now, or data about how you relate to your family and friends. It can be data about how tall you are or how much you weigh. It can also be data about your computer, tablet, or phone, and how you use it when you are on the Internet.

 

Just remember, lots of information can be personal data, if it is about you or can be connected to you.    

What kinds of data does TCL collect about me?

        For Kids watch

 

When you use one of our devices (like smartwatch), we need to collect some data about you.

 

First, if your parent pays for a device, we have to keep a record of it. If your parent has a TCL Connect account and want to bind your device with this account, they need to let us know your name and your parent’s name and email address. We need to use an account or device ID to help your parent set this up.

 

Once you your device is bound, there is lots of cool stuff you can do with it. You or your parent can make a user profile (with a nickname and avatar) and set up a game profile or kid workout profile. You can also create a list of friends who you can call or chat with, if your parent approves. Then, when you play our games, we help you keep track of how many points you score, your best games and top scores, total score, ranking, and number of “likes” or “thumbs up.”

 

The profiles on our devices include lots of extra features. Some of them are designed to help your parent watch out for you and keep you safe. For example, a kid workout profile might ask about how tall you are and how much you weigh, to let your parent track the exercise level of you. Your parent can also set up features that allow them to:

• keep track of how long you are playing a game, and set time limits;
• know where you are and set the parent as your emergency contact (and set up a “safe zone”);
• send you reminders.

There are also features that let you do stuff like check the weather where you are. If you have any questions about these features, talk to your parent and make sure you understand how they work, and which ones your parent has decided to activate.  

 

To be able to do all the things described above, we receive data about your activity on our devices. For example, this might include the type of device, the IP address, and other technical details.

 

We want to remind you to be careful about the data you share, especially if you use a device with other people online. Even if you are sharing only with your approved friends, remember that it is best to keep some information private. This helps keep you safe.

 

        For TCL Kids

 

When you enjoy TCL Kids app, we need to collect some data about you.

 

First, if your parent pays for a content, we have to keep a record of it. If your parent want to let you enjoy the content, they need to let us know your name, your parent’s name and email address, birthday (month and year), gender and content preferences. We need to use your parents’ TCL account to help your parent set this up.

 

Once it is done, there is lots of cool stuff you can do with it. You or your parent can make a user profile (with a nickname and avatar). If you watch a learning program or other content, we keep track of how much time you spend watching it and what you learn.

 

The profiles in our App include lots of extra features. Some of them are designed to help your parent watch out for you and keep you safe. Your parent can also set up features that allow them to:

• keep track of how long you are enjoying the app, and set time limits;
• restrict your enjoy some content; 

 

To be able to do all the things described above, we receive data about your activity in our App. For example, this might include the type of device, the IP address, and other technical details.

 

We want to remind you to be careful about the data you share, especially if you enjoy the App with other people online. Even if you are sharing only with your friends, remember that it is best to keep some information private. This helps keep you safe.

 

What does TCL do with my data?  

 

The main thing we use your data for is to let you use our services and devices, so that you can enjoy them and learn new and interesting stuff.

 

Like we said above, if the service or device costs money, we keep a record of payment. We also need to check who wants to set up an account and make sure they are old enough (or ask a parent to help). We also use data to provide the features mentioned above. This includes optional features to let your parent watch out for your and keep you safe. We also use your data to update our device and services to keep them secure, make them better, and provide new features.

 

We may use data to send messages about our services and devices that you or your parent need to know. We may also send messages about special offers, contests, and promotions, but you or your parent do not have to see these messages if you do not want to. Just hit the “unsubscribe” button on any email from us or turn off notifications, and you will not get those messages any more.

 

Lastly, we may use your data if we need it for legal reasons or to obey certain rules, including to protect you and others. This includes keeping our services secure, keeping bad people off our services, and responding to law requests if the rules say we need to. We also may need to share your data if we sell our company or do some other kind of business deal. 

 

What are TCL’s “good reasons” to use my data?

 

Where you live, the rules require us to have a “legal basis” to use personal data. That means we need to have a good reason to collect and use your data. We cannot do anything we want to do with your data for any reason at all. 

• One of our good reasons is called “legitimate interests”. This means we use your data for our benefit in a way that does not unfairly affect or harm you. There are lots of things we do based on this good reason – like providing our services, making them better, and keeping them safe and secure. We may also use this good reason to: answer your questions, prevent fraud or cheating, to protect our rights and interests, or in case we ever sell our company or do some other kind of business deal.
• Another good reason we have to use your data is to obey the rules that apply to us. For example, like we said before, some services cost money to play them. If you (or your parent) buy a device or service, the rules say we have to keep a record of it. There are also rules about keeping our services secure, helping keep you and others safe, and responding to law requests. 
• In some cases, our good reason is to enter into a contract with you (or with your parent or guardian, if you are not old enough), and do what we say we will do. For example, our services and devices include rules called the “Terms of Use”, and if people obey these rules, then we agree to provide the service. We use this good reason only if you are old enough for this kind of agreement, or your parent agrees for you. 
• The last good reason we rely on is called “consent”. This means special permission to do something with someone’s data. To give consent, you have to be at least 13 years old in the UK. The age of consent may be different if you live somewhere else in Europe. If you are not the right age yet, your parent has to give consent for you. We may use consent to send you certain types of information. If we use consent, it will be very clear when we do so. You or your parent or guardian will have to do something, like tick a box, to show we have this special permission. If you or your parent or guardian give us this special permission, it can be taken back at any time. 

 

Who does TCL share my data with?

 

We share your data only for good reasons with certain groups.

• We share your data with other TCL companies to provide our services. This includes making our stuff better, keeping it secure, and to do business. It also includes marketing and for the other reasons described above.
• We also share your data with other companies who help us provide our services, make them better, keep them secure, and to do business. Some of this companies store data for us or help us in other ways, like to prevent cheating or fraud, or to check our business records. We have agreements in place to make sure they protect your data. 
• In some cases, we might need to share your data for legal purposes or to obey certain rules, such as to keep you or others safe, or keep bad people off our services. We also may need to share your data with another company if we sell our company or do some other kind of business deal.
• Lastly, we may share your data with others if you are your parent give us special permission to do so.

 

How long does TCL keep my data?

 

We keep your data only for as long as we need it to do the things we explain above. This is usually for as long as you and/or your parent are our customer, or to obey certain rules, or for other legal reasons.

 

Does TCL send my data to other places?

 

Yes, we may send your data to places other than the UK or Europe. If we send your data to other places, we will make sure we obey the rules when we do. This may include signing a special agreement to protect your data, and you can ask for a copy of this agreement.

 

What are my rights?

 

You have special rights over your data. You can contact us to about your rights, or have your parent contact us for you. These rights include access to your data. This means you can see the data we keep about you, and get a copy of it. You can also ask us to correct your data. This means we will fix any mistakes, like if we spelled your name wrong by accident, or have the wrong month and year of birth. You can also ask us to delete your data, or let us know if you disagree with how we use it. You may also limit how we use it. You can also ask us to send a copy of your data somewhere else, or stop certain kinds of decisions.

 

We respect your rights, but in some cases there are limits or exceptions. We will always explain to you (or to your parent) if there is a reason why we cannot or will not do something you ask us to do. You or your parent can complain to the privacy supervisor in your country (like the ICO) if you do not agree with how we are using your data.    

 

Where can I find out more? 

 

If you have any questions or want to take action about your rights, you or your parent or guardian can contact us at privacy_dpo@tcl.com or write us:

• For kids residing in Europe, our representative in the EU is TCT Mobile Europe, which has its offices at Le Capitole, 55 rue des Champs-Pierreux, 92000 Nanterre, France.
• For kids residing in the UK, our representative in the United Kingdom is TCT Mobile UK Limited, which has its offices at 10 Finsbury Square, London EC2A 1AF, England.

 

UPDATES

 

Thanks a lot for reading this important information about your privacy. We take it seriously, and we do our best to help keep your data safe. We may update this policy from time to time with new information and to mention important changes. We will let you and/or your parent know about any major changes. Check back from time to time, and see the “last updated” date at the top.