[Effective Feburary 10, 2023]
This Privacy Notice sets out how TCL and/or its affiliates and subsidiaries (collectively “TCL”, “we”, “us” or “our”) protect the Personal Data we process relating to you (your “Personal Data”), what types of Personal Data we collect about you, what we do with it, how we disclose it and which rights you have in relation to the processing of Personal Data.
Thank you for choosing TCL!
WHEN DOES THIS PRIVACY NOTICE APPLY?
This Privacy Notice applies when we process your Personal Data as a result of your access and use of “TCL Materials”, including:
This Privacy Notice also applies to our processing of the Personal Data of business contacts within our clients, business partners, supplier and other organizations with which TCL has or considers a business relationship.
To find out more, please click on any of the sections below:
We may update this Privacy Notice to reflect changes in how we collect and use your Personal Data or changes in applicable laws on a regular basis. Any update to this Privacy Notice will be effective upon its posting on our website at [https://www.tcl.com/us/en/terms-privacy]. In addition, we may also notify you to inform you about the changes to this Privacy Notice as required by applicable laws.
BY VISITING OUR WEBSITES, PROVIDING YOUR INFORMATION OR USING TCL MATERIALS, YOU CONFIRM THAT YOUR HAVE READ AND UNDERSTOOD THE PRACTICES DESCRIBED IN THIS PRIVACY NOTICE.
Your privacy is important to us so we explain here what Personal Data we collect about you. Please note that, if you do not provide certain Personal Data, TCL may not be able to accomplish some purposes outlined in this Privacy Notice and you may not be able to use or access certain TCL Materials.
We may collect and process the following Personal Data about you:
We may also collect other information about you, your device or the use of TCL Materials in the manner informed at the time of collection and/or with your consent in accordance with applicable laws.
We will not knowingly collect any Personal Data from or about children under the age of 13, or minimum age allowed in your jurisdiction, without making it clear that such information should only be provided with a parent’s or guardian’s consent, if this is required by any applicable laws. TCL will only use Personal Data relating to children as far as it is permitted by applicable laws and if required, only with a parent’s or guardian’s consent and in accordance with children’s best interests. If you believe that your child has provided us with his / her Personal Data without a parent’s or guardian’s consent, please contact us via the email address provided in the Contacting Us section below.
Your Personal Data may be collected, stored, processed or otherwise used by us in the following ways and for the following purposes:
To the extent the Personal Data we collect about you is considered special categories of Personal Data or sensitive Personal Data under applicable laws, we process such data based on your consent, and you may withdraw your consent to such processing at any time with effects to the future. However, you should be aware that if you choose to do so we may be unable to continue to provide certain services to you. If you choose to withdraw your consent, we will tell you more about the possible consequences. If permitted by applicable laws, we may also process special categories of Personal Data that you expressly made public or to establish, exercise or defend legal claims.
The Section “Product Specific Terms” below provides more detailed information about the Personal Data we collect and the purposes for which we use the Personal Data in connection with TCL’s smart TV, MagiConnect, TCL Home application, TCL Channel, TCL Mobile, Tablet and Wearable Device.
If you act as a business contact of your organization to purchase or use TCL Materials on behalf of your organization, we may collect your name, shipping, billing and/or business address, email address, phone number, and use your Personal Data to the extent necessary to carry out ordinary business operations, for associated administrative purposes or for other purposes specified above in the Section “Uses of Personal Data”.
We may disclose the information you provide to us, the information we collect or generate about you, or the information we collect from other sources with TCL’s affiliates and subsidiaries for one or more of the business purposes described below:
We may also share any of the Personal Data we collect with our partners in order to achieve the purposes mentioned in the Section “Use of Personal Data” above, including:
Besides the disclosures of Personal Data described in this Privacy Notice, we may share your Personal Data with third parties whenever you authorize this sharing.
Please note that if you access third-party services — such as social media services, third-party single-sign on tools, third-party applications, mobile platforms, and telecom carriers of your devices — through our services, these third-party services may be able to collect information about you, including information about your activity on the products and services, and they may notify your connections on the third-party services about your use of the product and services, in accordance with their own privacy policies.
Our website may contain links to third-party sites and our products may also contain pre-installed applications developed and operated by third parties. We are not responsible for the privacy practices or content of such other sites and applications. This Privacy Notice does not apply to them. You must carefully read the privacy policies related to services of third parties, contacting directly those parties in case of need.
In addition, the carriers of your TCL or Alcatel mobile devices may also collect your Personal Data for service improvement, diagnosis and other purposes. This Privacy Notice does not apply to these carriers and we are not responsible for their privacy practices either. You should contact these carriers if you would like to know the details on how your Personal Data will be collected and processed by them.
TCL shares your Personal Data globally with the companies within its corporate group to carry out the activities specified in this Privacy Notice. TCL may also subcontract the processing or sharing of your Personal Data to third parties located outside your country. When you use TCL Material, we may transfer, storage and process your information within and outside of your country of residence, consistent with this Privacy Notice. The processing of your Personal Data may, therefore, be also subject to laws other than the ones from your country.
TCL takes appropriate steps to ensure that transfer of Personal Data shall be done in accordance with applicable privacy laws and, in particular, that contractual, technical and organizational measures will be in place, such as, with no limitation, the Standard Contractual Clauses approved by the European Commission.
We have adopted organizational, physical and technical security measures that are in line with the industry standards to protect the Personal Data you provide, and to prevent any unauthorized access, disclosure, use, modification, damage or loss of data. We will take reasonable and practical steps to protect your Personal Data, including the following:
Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. If we become aware of any violation of our security system, we will act in a timely fashion in accordance with any applicable laws.
Data protection laws may give you a number of legal rights in relation to the Personal Data that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places. You may refer to the Annexes of this Privacy Notice for more details about your rights in certain specific jurisdictions.
However, we recognize that your Personal Data belongs to you only and that enables you to control how we use it. Consistent with applicable law, your rights may include:
You can exercise your rights by contacting us using the details set out in the “Contacting Us” section below.
We may need to go through a data subject request verification before completing your request, and, for example, we may ask you to confirm some data we already have about you. We will only use Personal Data provided in the process of verifying a data subject’s request to verify the requestor’s identity or authority to make the request.
This Privacy Notice applies generally to how we use your Personal Data in relation to our products and services. We may also process additional Personal Data in relation to particular products or services.
We and our third party partners collect Personal Data about your use of our Smart TV products, such as name and duration of videos played, user favorites, pages viewed, and time spent on those pages. This is so that we are able to better understand how our customers use the product and ensure that we can continue to make improvements and tailor our services.
We may collect Personal Data when you use the camera or microphone of your Smart TV products. For example, when you use the camera (either built-in or external camera of your Smart TV products) to conduct video live chats on ChatNow, to provide the video live chat services, we may collect data about your TCL accounts, your video and audio chat history, support data related to trouble shooting and feedbacks related to the use of services.
We may collect additional Personal Data in order to provide remote diagnosis of problems with your Smart TV products. For example, if you have given your consent, we may collect real-time screenshots and information about the data stored on your Smart TV products. This is to ensure that problems with your Smart TV products can be resolved as efficiently as possible.
The Smart TV products capture data of the Amazon Alexa or Google Action voice assistant function on your Smart TV products. This information includes a device description, your voice, Skill Token and Voice command. When you use the voice assistant function, your voice data will be processed by Google or Amazon. Your data will be directly transferred to Google or Amazon. Please refer to Google or Amazon privacy notices for information on further processing of your Personal Data by these companies.
Our third-party advertising partners may use automatic content recognition (ACR) and other technologies to collect your TV viewing and usage information to create profiles of users and determine the personalized advertisements that your devices will receive. You may control whether to allow us to activate the data collection by ACR by following the method provided in the settings page of your Smart TV.
We and our third-party partners will collect details about your usage of the MagiConnect application, including the volume of usage you make of the MagiConnect application (measured through the number of clicks you make) as well as the choice of services you make through the MagiConnect application. We do this so that we understand better your usage of the MagiConnect application and we can tailor the layout of the application to your preferences.
We and our third party partners will collect details about your usage of the TCL Home application, such as the volume of usage you make of the TCL Home application, the information you provided through live chat and the choices of services you make through the TCL Home application. We do this so that we understand better your usage of the TCL Home application and improve our services and tailor the layout of the application to your preferences.
To provide you with services that allow you to connect and manage multiple TCL devices and other manufacturers’ devices owned by you, we and our thirdparty partners will also collect the following information about you: Wi-Fi or Bluetooth information, location, TCL account, device information about your phone and information about the TCL devices to be connected.
TCL Channel allows users to search content available within TCL Channel by initiating the voice control function in Roku TV. When you use the voice control function, your voice data will be processed by Roku TV directly. Please refer to Roku TV privacy notices for information on further processing of your voice data.
We may collect and process data in relation to Roku TV or TCL device you hold (e.g. its device model, unique device identifier, brand, MAC address, Roku operating system version, region, IP address, application version), and your use of TCL Channel (e.g. your clicks records and browsing history). We may engage third party processors to analyze such data and build profiles on your usage and preference. We do this so that we can understand better how our customers use TCL Channel and make recommendations to you on other content which you may be interested in.
TCL Mobile, Tablet and Wearable Device
We may collect and process special categories of Personal Data such as biometrics data and health data when you use certain applications on TCL mobile, tablet or wearable device. These data are necessary for the health-related functions of these applications. We process your special categories of Personal Data based on your explicit consent, and you may withdraw your consent to such processing at any time with effects to the future. However, you should be aware that if you choose to do so we may be unable to continue to provide certain services to you. If you choose to withdraw your consent, we will tell you more about the possible consequences;
We may collect and process device data and log information including referrer URL, IP addresses and details about your use of our website, cloud services, app store, browsing history, search queries, browser type and session frequency, besides unique device identifiers;
Some TCL mobile devices are under the Alcatel brand but this Privacy Notice also applies to those devices.
We and our third-party advertising and data analytics partners use “cs” and similar web technologies including pixel tags or web beacons, (“automated collection tools”) to support certain features of the TCL account, smart TV and other websites and applications operated by us. Automated collection tools are pieces of code deployed on your device. The automated collection tools allow the website to recognize your browser or device during your visit to the TCL website/application or when you return to the TCL website/application.
We use two types of automated collection tools: “session cookies” and “persistent cookies”.
A session cookie expires after you close your browser. A session cookie will identify you during your browsing session by assigning a randomly generated unique identification number to your device. We use session cookies:
Persistent cookies do not expire when you close your browser. We use persistent cookies:
How to Manage Automated Collection Tools
If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your device. You may also delete cookies as soon as you leave the TCL account or other TCL website / application. Although you are not required to accept cookies when you visit the TCL account, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of the TCL account or other TCL website/application.
For example, the Help portion of the toolbar on most web browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new automated collection tools, and how to entirely disable automated collection tools. With regards to some of the popular browsers you can find more information by clicking on the following relevant links: Google Chrome; Microsoft Edge; Mozilla Firefox; Microsoft Internet Explorer; Opera and Apple Safari.
Where required by applicable laws, we will present you with a cookie banner the first time you visit our website/application that explains what type of automated collection tools we use, and which asks your consent for some of the automated collection tools we use.
Personal Data Collected through Automated Collection Tools
We use the Personal Data collected through automated collection tools for the purposes specified above (including in the Section “Uses of Personal Data”). For those cookies where we ask for your consent to deploy them, we also rely on consent as the legal basis for processing Personal Data collected through those cookies.
For U.S. users, the Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit https://www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.
At this time, our website does not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
This Annex explains how we collect, use, and disclose Personal Data about California residents.
We may collect and process the following Personal Data about you in the preceding 12 months. For the Personal Data collected during that timeframe, we describe below: (a) the categories of Personal Data we collect about you, (b) the categories of sources from which we may have obtained the Personal Data, (c) the categories of third parties with whom we may have shared the Personal Data, (d) the categories of Personal Data we may have sold, and (e) the categories of Personal Data we may have disclosed for a business purpose.
Personal Data We Collect About You
We may collect and process the following Personal Data about you in the preceding 12 months:
Categories of Source
We may collect your Personal Data from the following sources:
How We Use Your Personal Data
We may use the categories of Personal Data listed above for certain business or commercial purposes, as described in this list:
We use or disclose Sensitive Personal Data for the following purposes only: providing the products and services you request, as well as improving those offerings; operating and overseeing our business; protecting rights and interests; short-term transient uses; and for purposes that do not infer characteristics about consumers.
Categories of Third Parties
We may disclose the information you provide to us, information we collect or generate about you, or the information we collect from other sources with the categories of third party below:
Sales & Sharing of Personal Data
Consistent with applicable law, you may opt-out of the sale or the sharing of Personal Data for purposes of cross-context behavioral advertising, by clicking the https://privacyportal-de.onetrust.com/webform/51a2e8fb-ad5e-4969-b97c-5405297554a1/7d87c8c8-ff83-4ec3-b300-b5f7cc0c4c64.
In addition, we honor the opt-out preference signal from the Global Privacy Control. Please note that because the Global Privacy Control is a browser-based mechanism, your opt-out preference will apply only to the browser from which you exercised that choice.
Disclosure for Business Purpose
Other California Privacy Rights
For Residents of California, United States only, in addition to the rights provided under the “Your Rights” section in the TCL Global Privacy Notice, consistent with applicable law, you may be entitled to the rights below:
We will not discriminate against you for exercising your data subject rights, although some of the functionality and features available on the Services may change or no longer be available to you. Any difference in the Services is related to the value provided.
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 IMEI or 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, 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 in the “Contacting us” section above and put “Shine the Light” in the subject line of your request.
You can exercise your rights or raise any questions and concerns you may have 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. 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.
If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed above, please contact us through the specific channels indicated below.
For residents in EEA & UK, please contact our DPO by sending an email at email@example.com.
For users in India, our Grievance Officer in India is Mr. Sudhansu Sahu and can be reached at firstname.lastname@example.org.
For users in the United States, TCL subsidiaries are TTE Technology, Inc. and TCT Mobile Inc. whose related addresses and contacts are indicated below:
TTE Technology, Inc. (for TCL home theatre, appliances, and service)
189 Technology Drive
Irvine, CA 92618
Contact us by sending an email at email@example.com, or by calling our toll-free number +1-877-300-8837
TCT Mobile, Inc. (for TCL mobile phone/tablet/wearable device and service)
189 Technology Drive
Irvine, CA 92618
Contact us by sending an email at firstname.lastname@example.org, or by calling our toll-free number +1-855-368-0829
For users in Brazil, please contact our DPO by sending an email to email@example.com, or by calling +55 (11) 3004-7570.
For more contact information about TCL’s subsidiary, office or representative in your country or region, see our https://www.tcl.com/global/en.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.