Privacy Policy of TCL Technology Official Website

Introduction

Welcome to the official website of TCL Technology. TCL Technology official website is a platform operated by TCL Technology Group Corporation (hereinafter referred to as “we”) to provide users with information services related to TCL Technology Group Corporation.

We are fully aware of the importance of personal data to you. The Privacy Policy of TCL Technology Official Website (hereinafter referred to as the “Policy”) covers how we collect and process your personal data when you use our website services globally except in mainland China. This Policy is drafted in accordance with the General Data Protection Regulation (hereinafter referred to as the “GDPR”), the California Consumer Protection Act (hereinafter referred to as the “CCPA”) and other applicable laws and regulations (hereinafter collectively referred to as “applicable laws and regulations”). This Policy describes the purposes, methods, collection scope and information security protection measures of our collecting, using, storing, entrusted processing, sharing, transferring and public disclosure of your personal data in the process of the provision of TCL Technology Official Website products and/or services, as well as the methods we provide to enable your control over your personal data, such as accessing, correcting and deleting your personal data. Please read this Policy together with our User Service Agreement of TCL Technology Official Website.

Please read carefully and fully understand this Policy to make choices that you deem appropriate before using TCL Technology Official Website. Please be reminded that this Policy only applies to the data we collect outside of Chinese mainland. If you are Chinese mainland user, please read our Chinese version of Privacy Policy. If you do not agree with this Policy, please voluntarily stop using this website.

This Policy will help you to understand the following:

Content

• I. How Do We Collect and Use Your Personal Data
• II. Collection and Use of Minors' information
• III. How Do We Use Cookies and Similar Technologies
• IV. How Do We Entrust, Share, Transfer and Publicly Disclose Your Personal Data
• V. How Do We Protect Your Personal Data
• VI. How Do We Store Your Personal Data
• VII. International Transfer of Your Personal Data
• VIII. Your Rights
• IX. Our Protection of Personal Data of Deceased Users
• X. How Do We Update This Policy
• XI. How to Contact Us
• XII. Applicable Law
• XIII. Relevant Terms and Definitions

I. How Do We Collect and Use Your Personal data

When you use the services provided by TCL Technology Official Website, to better serve your purposes, we may collect and use your personal data based on the principles of legality, fairness, necessity and transparency and based on purposes described in this Policy. If we use your personal data for purposes other than the scope described in this Policy, or collect your personal data for other special purposes, we will notify you in a reasonable manner and obtain your consent again before collecting or using such information.

1. Personal Data Proactively Collected by Us During Your Use of the Services

Subject to applicable laws and regulations, to better provide you with high-quality services, we will collect and use the following information generated by you in the course of using TCL Technology official website:

For information collected from your different devices, we may correlate them so that we can provide you with consistent and coherent services across these devices.

2. Exceptions Where Consent is not Required

In accordance with the relevant laws and regulations, the collection and use of your personal data do not require your consent in the following cases:

• （1）processing that is necessary to perform a contract to which the data subject is a party or to satisfy the prerequisites of the personal data subject for entering into a contract;
• （2）processing that is necessary to fulfill the legal obligations assumed by the data controller;
• （3）Processing necessary in order to protect the significant interests of data subjects or other natural persons;
• （4）Processing necessary in the public interest or in order to execute the official authority vested in the data controller;
• （5）Where any processing is required due to the legitimate interests of the data controller or of a third party; However, if the rights and interests, basic rights and freedom of the data subject are more important than the aforementioned legitimate rights and interests, especially when the personal data subject is a minor, then the personal data shall be protected, i.e., the aforementioned exception under which no prior consent is required for processing personal data does not apply.

II. Collection and Use of Minors’ information

The TCL Technology official website does not provide services to minors defined by applicable laws and regulations in your jurisdiction. If we accidentally collect personal data from minors, we will delete it as soon as possible.

III. How Do We Use Cookies and Similar Technologies

1.How do we use cookies and similar technologies

Cookies help you personalize your online experience. You can accept or reject cookies. Most web browsers automatically accept cookies, but you can usually modify your browser's settings to reject cookies if you want. Cookies don’t track personal data.

When you use TCL Technology Official Website, it will also use cookies. In this case, TCL Technology Official Website will collect and store the client identification, timestamp, operation settings, language settings. Cookies from TCL Technology Official Website can only be read by TCL Technology Official Website. If your browser is set to reject cookies, you can still access most pages of TCL Technology Official Website.

2. How do we manage cookies

You can choose to enable or disable cookies in your Internet browser. Most Internet browsers allow you to choose whether you want to disable all cookies or only third-party cookies. By default, most Internet browsers automatically accept cookies, but you can usually modify the settings of your Internet browser to reject cookies according to your needs. For more information, please see the Help Menu in your Internet browser or the documentation that came with your device.

The following links provide instructions on how to control cookies in the relevant browser:

• （1）Google Chrome：https://policies.google.cn/technologies/cookies?hl=zh-cn#managing-cookies
• （2）IE：https://support.microsoft.com/zh-cn/topic/cookie-%E7%9A%84%E8%AF%B4%E6%98%8E-ad01aa7e-66c9-8ab2-7898-6652c100999d
• （3）Safari（Desktop）：https://support.apple.com/kb/PH5042?locale=en_US
• （4）Safari（Mobile）：https://support.apple.com/zh-cn/105082
• （5）Firefox:： https://support.mozilla.org/zh-CN/kb/Cookies?redirectlocale=en-US&redirectslug=Cookies
• （6）Opera：https://help.opera.com/en/latest/web-preferences/#cookies；https://help.opera.com/en/mobileios/settings/

If you use other browsers, please refer to the documentation provided by the browser manufacturer.

Please note that if you refuse to use, or clear existing cookies, you may need to change your user settings personally for each visit, and we may not be able to provide a better and quality experience to you or parts of our services may not function correctly.

IV. How Do We Entrust, Share, Transfer and Publicly Disclose Your Personal Data

1. Entrusted Processing

In order to provide you with better and high-quality services, certain functions may be provided by our technical service partners, and we may entrust our partners to process some of your personal data. We will enter into strict confidentiality agreements with the companies, organizations and individuals to whom we entrust to process your personal data, in order to specify the responsibilities of both parties, the matters, period, nature and purpose of the processing and require them to process the personal data only in accordance with our instructions, this Policy and any other relevant confidentiality and security measures. If you refuse to allow our technology partners to collect the personal data necessary for the provision of the service, you may be unable to use the products and/or services on the TCL Technology official website to take advantage of the services provided by such partners. Our partners include:

1.1. Website Development, Operation and Maintenance Service Provider:

We need to entrust a third party, Guangdong TCL Juxiang Technology Co., Ltd. to carry out the overall website development and operation and maintenance services, and we need to provide them with your device information and log information. If you refuse to do so, you will not be able to use the products and/or services on the TCL Technology official website.

2. Sharing

Respecting users' personal privacy is one of the fundamental principles of TCL Technology Official Website. We will not share your personal data with any third party unless required by laws and regulations or mandated by government authorities.

3. Transfer

We will not transfer your personal data to any company, organization or individual, except for the following circumstances:

• （1）Transfer with express consent: we may transfer your personal data to other parties after obtaining your express consent;
• （2）To satisfy a law or regulation, legal process or mandatory governmental request or judicial ruling;
• （3）In the event of mergers, acquisitions or bankruptcy and liquidation, in case of transfer of personal data is involved, we will require the new company or organization holding your personal data to continue to be bound by this Policy. Otherwise, we will require such company or organization to obtain your consent again.

4. Public Disclosure

We will only publicly disclose your personal data under the following circumstances:

• （1）After obtaining your express consent;
• （2）Disclosure based on laws: we may publicly disclose your personal data as compulsorily required by laws, legal proceedings, litigation or governmental authorities.

V. How Do We Protect Your Personal Data

We attach great importance to the security of your personal data. We have adopted multi-level protection measures such as technical safety measures conforming to industry standards and supporting organization structure and management system, to prevent your personal data from disclosure, destruction, misuse, unauthorized access, unauthorized disclosure or alteration to the greatest extent possible. In particular, the measures include the following:

1. Technical Measures for Data Security

（1）For the data transmission security, we adopt the cryptographic technology such as transport layer security protocol and deploy Https and other ways to prevent the transmission links from being eavesdropped, intercepted, and to establish a safe and private data environment and ensure the confidentiality and completeness of data. We also take additional safety measures to protect your information such as encrypted storage.

（2）With regard to the security control of data access and use, we have implemented a strict data authorization control mechanism, adopted multiple identity authentication technology, and monitored the processing of your personal data to prevent illegal access and unauthorized use of data. We also monitor the entire lifecycle of data to protect your personal data from unauthorized access, public disclosure, use, modification, and intentional or accidental damage or loss, etc.

2. Organization and Management Measures for Data Security

We have established a special TCL Technology Data Compliance Project Team pursuant to the requirements of laws and regulations to oversee the company’s cybersecurity, personal data protection and data security. In addition, we have established a series of systems concerning data security production, and actively provided relevant special training sessions for our employees to raise their awareness of personal data protection and professional competence in this regard.

3. Security Incidents Handling

• （1）We will formulate contingency plans for cybersecurity incidents and promptly dispose of security risks such as system vulnerabilities, computer viruses, network attacks, network intrusion, etc. In the event of an incident that jeopardizes network security, we will immediately activate the contingency plan, take corresponding remedial measures, and report the incident to the relevant competent authorities in accordance with the regulations.
• （2）After the unfortunate occurrence of a personal data security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the following: the basic situation of the security incident and its possible impact, the disposal measures we have taken or will take, the suggestions you can independently take to prevent and reduce the risk, and the remedial measures to be taken against you. We will promptly inform you of the situation related to the incident by email, letter, phone call, push notification, etc. When it is difficult to inform the personal data subject one by one, we will take a reasonable and effective way to make a public announcement.
• （3）Meanwhile, we will also proactively report the handling of personal data security incidents as required by regulatory authorities.

VI. How Do We Store Your Personal Data

We will store personal data collected within the territory of Chinese mainland. If, due to business or other needs, we have to transfer or store personal data outside of China, we will obtain your prior consent and strictly perform relevant obligations of the personal data cross-border transfer in accordance with relevant laws and regulations. We warrant that, unless otherwise stipulated by laws and regulations, we will store your personal data for the minimum period of time necessary to achieve the purposes for which you authorized.

Under the following circumstances, we may change the storage time of personal data due to the need to comply with legal requirements:

• （1）To comply with the application of laws and regulations and other relevant provisions;
• （2）To comply with the provisions of a court judgment, ruling, or other legal process;
• （3）To comply with the requirements of relevant governmental authorities or legally authorized organizations;
• （4）To protect our personal property and that of our customers, users or employees;
• （5）Reasonably necessary for other legitimate interests.

If the storage period of your personal data expires or the TCL Technology official website ceases to operate, unless otherwise stipulated by laws and regulations, we will delete your personal data or anonymize it in a timely manner; if the deletion/anonymization is technically difficult to achieve, we will discontinue processing measures other than storing it and adopting the necessary safety protection measures. For countries with localized storage requirements, we will actively communicate with your country or region to achieve localized storage together.

VII. International Transfer of Your Personal Data

TCL Technology is based in Mainland China and the personal data we collect from you will be transferred and stored in Mainland China. By agreeing to this Policy and using our products, you allow us to process such international transfer. We have deployed strict measures to safeguard your personal data, if you have any question regarding your personal data’s security and/or our international transfer manners or would like to withdraw your consent to the international transfer, you may contact us according to contact information specified in Chapter XI.

VIII. Your Rights

Whenever you use TCL Technology official website, we will try our best ensuring that you can access your personal data. If we provide you with incorrect information, we will endeavor to provide any means to allow you to update or delete your personal data (unless we have to retain such information, whether by law or regulation). To provide you with the adequate ability to protect your privacy and security, you are entitled, in accordance with law and common practice, to:

1. Access to Your Personal Data

You have the right to access your personal data at any time, except as provided by laws and regulations. Please refer to the List of Personal data Collected by TCL Technology Official Website for information on the collection of personal data by TCL Technologies Official Website. If you are unable to access it by the above means, you may contact us at any time by the means described in Chapter XI of this Policy, and we will respond to your request within 15 working days after verifying your user identity.

2. Correct Your Personal Data

If you find that the personal data you have provided or processed by us is incorrect, you have the right to correct the information through contacting us in the manner described in Chapter XI of this Policy, and we will respond to your request within 15 working days of verifying your user identity.

3. Delete Your Personal Data

Unless stipulated by laws and regulations, you have the right to delete your information through contacting us via the contact information described in Chapter XI of this Policy. You can make a request to us to delete personal data under the following circumstances:

• （1）If we collect, use, share or transfer your personal data with others in violation of laws and regulations or our agreement with you;
• （2）If we publicly disclose your personal data in violation of laws and regulations or our agreement with you, you have the right to request us to immediately stop the public disclosure and issue a notice requesting the relevant recipient to delete the corresponding information;
• （3）We collect or use your personal data without your prior consent;
• （4）The purpose of processing personal data has been achieved, cannot be achieved, or is no longer necessary to achieve the purpose of processing.
• （5）We no longer provide you with services;

You hereby agree that once the deletion request is responded, your personal data will be deleted and any information you have provided and the record of actions you have taken will not be retrievable. The relevant information may not be deleted from our backup system immediately but will be deleted when the backup system is updated.

4. Change the Scope of Your Authorized Consent or Withdraw Your Consent

When you need to change the scope of your authorization for us to continue to collect personal data or withdraw your other authorizations, you may contact us as described in Chapter XI of this Policy.

Please understand that certain business functions and services will require your information in order to be completed, and when you withdraw your consent or authorization, we will not be able to continue to provide you with the services for which you have withdrawn your consent or authorization and will no longer process your corresponding personal data. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out on the basis of your consent or authorization.

5. Your Right to Portability and Explanation

Where permitted by law, you may make copies of your personal data and request that your personal data be transferred to a designated processor of personal data, and you may ask us to explain the rules governing the processing of your personal data. You can exercise these rights by contacting us via the contact details published in Chapter XI of this Policy.

6. Your Right to Restrict Processing

You can restrict our processing of your personal data in the following circumstances:

• （1）you contest the accuracy of the personal data and you allow us to verify the accuracy of the personal data within a certain period of time;
• （2）the processing is unlawful and you object to the erasure of the personal data and request a restriction on the use of the personal data;
• （3）the personal data is no longer necessary for the purposes of the processing, but you need the personal data for the establishment, exercise or defense of legal rights.
• （4）you have objected to the data processing and are waiting to verify whether the legitimate interest is more important than the data subject's interest.

7. Your Right to Object

You have the right to object to the processing of your personal data if it is necessary for us to pursue our legitimate interests, or if it is carried out in the public interest or for the performance of a task on the basis of official authority, or if there are grounds relating to your particular situation. You can exercise your right by by contacting us via the contact details published in Chapter XI of this Policy.

8. Additional Rights of California Residents

We recognize and protect your legal rights under the CCPA and other California laws. You may exercise your rights at any time with Chapter VIII of this Policy. In addition, you have:

（1）The right to know about participating in data sharing in exchange for financial incentives

If we will offer financial incentives before collecting your personal data, we will ask for your consent in advance.

（2）The right to choose not to sell personal data to third parties

You have the right to choose not to sell your personal data to any third party. Please be aware that this right does not apply to the sharing of personal data with our service providers. The service provider is a party entrusted by us to perform functions on our behalf and is contractually obliged to use the personal data only within the scope of its functions as agreed in the contract.

（3）Right to non-discrimination

You may exercise all of your rights at any time, and China Knowledge will not discriminate against you for exercising your rights under the CCPA.

（4）California Shine the Light Law (CSPA)

California residents have the right to request information about companies that have disclosed certain types of personal data to third parties in the previous year for the latter's direct marketing purposes. If you are a California resident and would like us to stop such disclosure of personal data, you may contact us via the contact details published in Chapter XI of this Policy.

9. Respond to Your Above Request

For security purposes, you may be required to provide written requests or otherwise to prove your identity. We may ask you to verify your identity before processing your request. In principle, we do not charge a fee for your reasonable requests, but for requests that are repeated several times and go beyond the reasonable limits, we will charge a fee for certain costs, depending on the circumstances.

We will respond to your above request within 15 working days after receiving your request and verifying your user identity. If you are not satisfied, you may also contact us by sending an e-mail to tcl-ds@tcl.com. Requests that are unnecessarily repetitive, require excessive technical means (e.g., require the development of a new system or a fundamental change in current practices), pose a risk to the legal rights of others, or are highly impractical may be denied.

According to the requirements of the laws and regulations, we will not be able to respond to your requests in the following circumstances:

• （1）Related to the fulfillment of our obligations under laws and regulations.
• （2）Directly related to national security or national defense security.
• （3）Directly related to public security, public health or material public interests.
• （4）Directly related to criminal investigation, prosecution, trial, execution of judgment, etc.
• （5）Where there is sufficient evidence proving that you have malice or abused your rights.
• （6）For the purpose of safeguarding the life, property and other significant legitimate rights and interests of you or other individuals, but it is difficult to obtain my authorized consent.
• （7）Responding to your request will cause serious damages to your legitimate rights and interests or those of any other individual or organization.
• （8）Where trade secrets are involved.

IX. Our Protection of Personal Data of Deceased Users

TCL Technology Official website strengthens the protection of the personal data of the deceased in accordance with applicable laws and regulations. After the death of a user of the TCL Technology official website (natural persons only), his or her next of kin, for his or her own lawful and legitimate interests, may contact us through the contact information published in Chapter XI of this Policy to exercise the rights of access, copy, correction, deletion, etc., in respect of the personal data of the deceased user, unless otherwise arranged by the deceased user before his or her death.

X. How Do We Update This Policy

We may update or change this Policy from time to time and such changes are part of this Policy. However, we will not impair any of your rights under this Policy without your express consent.

Please read the amended Policy carefully. If you don't agree to this Policy, or any amendment or update to this Policy, you may choose to stop using the TCL Technology official website. However, please be aware that this Policy will still govern your activities before you stop using the TCL Technology official website.

We will post on this page or otherwise notify you of any changes to this Policy, and with respect to material changes, we will also provide more conspicuous notification, such as conspicuous position notices, pop-up boxes and other means. In such cases, by choosing to continue to use our services, you agree to be bound by this Policy, as amended.

Material changes referred to in this Policy include, but are not limited to:

• （1）Our service model has changed substantially. For example, the purpose of processing personal data, type of personal data processed and method of using personal data, etc.;
• （2）A change in the primary recipients of personal data that is shared, transferred, or publicly disclosed;
• （3）Your rights to participate in the processing of personal data and the method of exercising them have changed substantially;
• （4）Other changes that may have a significant impact on your rights and interests in personal data;
• （5）When there is a change in the circumstances under which the personal data is exported.

We will also keep an older version of this Policy on file for your review. You may obtain a copy of an older version of this Policy by contacting us as described in Chapter XI of this Policy.

XI. How to Contact Us

If you have any questions, comments or suggestions regarding this Policy, you may contact us by sending an e-mail to tcl-ds@tcl.com.

Under normal circumstances, we will complete the verification and processing within 15 working days after verifying your user identity. If it takes longer to respond to your request or we are unable to respond to your request, we will send you a notice explaining the reason within the maximum time limit required by law.

If you are not satisfied with our response, in particular if you believe that our personal data processing behavior has harmed your legitimate rights and interests, you can file a complaint and report to the relevant regulatory agencies.

XII. Applicable Law

This Privacy Policy of TCL Technology Official Website and User Service Agreement of TCL Technology Official Website together constitute the basic agreement document for your use of TCL Technology Official Website. This Policy applies to the current laws and regulations of the People's Republic of China.

Any dispute related to this Policy should be resolved by consensus between the two parties; if the two parties are unable to resolve the dispute through negotiation, you agree to submit the dispute to the people’s court with jurisdiction over the location of the actual operator of TCL Technology official website.

XIII. Relevant Terms and Definitions

1. 1. Personal data: means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. 2. Data controller: A data controller determines the purposes for which and the means by which personal data is processed, for purpose of this Policy, data controller refers to TCL Technology Group Corporation.
3. 3. Process：means any operation or set of operations which is performed on personal data or on sets of 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.
4. 4. Collection: refers to the behavior of gaining control over personal data, including voluntary provision by the data subject, automatic collection by interaction with the data subject or recording the behavior of the data subject, and indirect acquisition by sharing, transferring and collecting public information.
5. 5. Deletion: refers to the behavior of removing personal data from the system involved in the implementation of daily business functions, so that it cannot be retrieved and accessed.
6. 6. Public disclosure: refers to all information recorded electronically or otherwise, which, independently or in combination with other information, can identify the specific natural persons or reflect the activities of specific natural persons.
7. 7. Transfer: refers to the process of transferring personal data control from one data controller to another.
8. 8. Sharing: refers to the process of data controller providing personal data to other data controllers, and both sides have independent control over personal data.
9. 9. Anonymization: means the process of making the personal data subject unrecognizable through the technical processing of personal data, and the processed information cannot be recovered.
10. 10. Minor: this term is defined in accordance with your jurisdiction, e.g., it refers to an individual who is under the age of 18 pursuant to the Digital World Act of U.S.A.