FreeMovie Browser Privacy Policy

Effective Date: [May 1, 2023]

This Privacy Policy（“Policy”）sets out how Shenzhen TCL New Technology Co., Ltd. and its affiliates (“we”, “us” or “our”) protect the personal information we process relating to you. This Policy applies if you use FreeMovie Browser app and its related services (hereafter “Product(s)”).

Personal Information We Collect About You

Through the app, we currently collect and process the following information:

• Unique identifiers, including your device ID and advertising identifiers associated with your device, such as Google’s Advertising ID, or ROKU’s Advertising ID;
• Device and product information for service access and management, including IP address, device information such as device model, software version, configuration and setting of your device;
• Feedback information, including the feedback information and your contact information provided by you; and
• Analytics and usage data, including server logs, app logs, error logs, and usage data such as the content you clicked or viewed, your browsing history, favorites and your stay or navigation on our Product.

We may use your advertising identifiers, device and product information to deliver ads on the app. For more information about how we and our ad partners collect and use your personal information, and how can you opt out of ad tracking, see our Personalized Ads Privacy Statement.

We may also collect other information about you or the use of our Products. We will inform you of such use at the time of collection in accordance with applicable laws.

Uses of Personal Data

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

• To provide our services. We process your device ID, advertising ID, device and product information to provide you with our Products or services that you have requested or purchased.
• For our legitimate interests, namely:

to maintain and update our Products. We process your device information, usage data, device related information, software information, and your feedback to maintain and ensure the stability and security of our Products, and to update our Products.

to communicate with you about the Products. We process your personal information to communicate with you in order to solve any product issues, as well as to send you notifications and other important information regarding the Products, such as any material changes to our terms & conditions, and policies.

We may also use your information for non-personalized advertising purposes.

In addition, we may use your personal information to fulfill our contractual obligations to you or comply with a legal obligation to which we are subject. In some cases, we may also obtain your consent and if we do so, you maintain the right to withdraw your consent at any point in time, without effecting the lawfulness of the processing that relied on such consent before your withdrawal.

Who Do We Share Personal Information With

We may share your personal information with the following categories of recipients:

• our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
• affiliates of our company, to carry out regular business activities, and/or with another company or third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including, without limitation, in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, new uses of your personal data, and choices you may have regarding your personal data.

These disclosures are necessary: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to manage and protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Except for the third parties described above, we may also disclose your personal data to other third parties with your consent.

International Transfers

We share your personal data with other entities that are part of our corporate group, some of which are located outside your country, for example in China, to carry out the activities specified in this Policy. We may also subcontract the processing or sharing of your personal data to third parties located outside your country. When you use our Products, we may transfer, store and process your information within and outside of your country of residence, consistent with this Policy. The processing of your personal data may, therefore, also be subject to laws other than those applicable in your country of residence.

We take appropriate steps to ensure that any international transfers of personal data are carried out in accordance with applicable privacy laws and, in particular, that contractual, technical and organizational measures will be in place under our agreements with recipients of the data, including, without limitation, the Standard Contractual Clauses approved by the European Commission. You can obtain a copy of such agreements upon request.

Your Rights Relating to Your Personal Information

In relation to our use of your personal information, applicable law may grant you rights of access, correction, restriction, erasure, and opposition and portability, subject to applicable limitations under the law. You may also have the right to lodge a complaint with a supervisory authority.

If you decide to contact us to exercise your rights, in your request, please make clear what information you would like to have corrected or updated, whether you would like to have your personal data deleted from our database, or otherwise let us know what limitations you would like to put on our use of your personal information. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

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

Additional Privacy Notice for California Residents

In the past 12 months, we may have collected categories of personal data that are described below：

In the preceding 12 months, we have disclosed or sold IP addresses, device IDs, advertising IDs, and device information to our advertising partners for the purposes of delivering advertisements.

For Residents of the State of California in the United States only, in addition to the above-mentioned rights in the “Your Rights” section, commencing January 1, 2020, you will be entitled to the below rights:

• The right to know. You may request information about the categories and specific pieces of personal data we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information and the sale or disclosure for business purposes of your personal data to third parties;
• The right to correct inaccurate personal information. You may request to correct the inaccurate personal data we maintains, taking into account the nature of the personal information and the purpose of the processing of the personal data.
• The right to not be discriminated against for exercising any of the rights mentioned above; and
• Subject to certain legal exceptions, you have the right to request deletion of your personal data.

Once we receive your request, we will verify it by checking whether the email address of the request is the same as the email address that is used to register your account. We may ask for additional information (such as your device serial number) if we need to further verify your identity to promote security or protect against fraud. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your rights and choices on your behalf, please we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise rights on your behalf.

Additionally, 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 below and put “Shine the Light” in the subject line of your request.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section above. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

Security

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your personal information, and provide various security strategies to effectively ensure data security of user devices, including the following:

• We will use SSL and other technical measures to ensure encryption with regards to our services and products. We will regularly examine our practice of information collection, storage, and processing (including physical security measures) to prevent unauthorized system access.
• We will authorize our employees and personnel of third parties to access your personal information on a need-to-know basis in order to help us process your personal data and provide services to you. These employees and external personnel (of third parties authorized by us) are subject to contractual confidentiality obligations.
• We will prudently select business partners and service providers, and implement the requirements for personal information protection to the business contracts between both parties.

Data Retention

We retain personal information only for as long as needed for the purposed to provide the Products and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. For example, your browsing history or favorite will be retained until you remove them from the list within the app or request deletion.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sending a message to the e-mail address specified in your account) or by means of a notification or other notice in the mobile or TV application(s) prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Us

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

The data controller is Shenzhen TCL New Technology Co., Ltd., with its address at ZhongShanYuan road No 1001, Nanshan, Shenzhen, Guangdong, P.R.China. Please contact us by sending an email to freemovie_browser@outlook.com. For residents in California, you can enter the official website to contact us, official website address:https://www.iffalcon.com/global/en, or by sending an email to freemovie_browser@outlook.com.