SMART TV PRIVACY POLICY

 

This Privacy Policy describes how Arçelik A.Ş., Karaağaç Cad. No: 2-6, Sütlüce-34445 Istanbul, Turkey ("Company"“we”, or “us”) uses, shares, protects and otherwise processes the Personal Data (as defined below) we may collect relating to you through your use of the Smart TV device (“Device”), the software installed by us on the Device (the “Software”) and all the related services provided by us, which are Smart TV Online FW Update, Smart TV 3rd Party Application Portal, Smart TV In House Application Portal, TV Usage Statistics, Built-in Voice Service on Smart TV and Voice Control on Smart TV by external voice asistant device (“Services”). It also explains how we share your Personal Data with our affiliates and subsidiaries, including Grundig Intermedia GmbH.

 

This Privacy Policy has been drafted to ensure compliance with the EU’s General Data Protection Regulation ("GDPR"). We are committed to follow the GDPR in all data processing operations in the European Economic Area (“EEA”) and where it otherwise applies.

 

This Privacy Policy is an integral part of the Smart TV Service Conditions. All terms not defined in this Privacy Policy shall be deemed to have been defined in the Smart TV Service Conditions. Smart TV Service Conditions shall apply to all matters not covered in this Privacy Policy.

 

This Privacy Policy does not apply to the Personal Data processed by third parties’ softwares installed on the Device, applications and software run by third-party application portals installed in the Device and/or by other third-party applications and software run on the application portal. The providers of such third-party applications and softwares may process your Personal Data in accordance with their own privacy policies. We do not have control over these policies and urge you to read the third-party privacy statements before providing any Personal Data to such third parties.

 

    1. What Personal Data We May Collect and for What Purposes

 

“Personal Data” refers to any information that may be used, alone or in combination with other information, to identify you. For the purposes of this Privacy Policy, we consider all the below information that is linked to your Device as Personal Data.

 

One ore more features described in this Privacy Policy may not be available to you depending on the country settings selected by you, on the model or launch date of the Device.

 

To the extent permitted by applicable law, when you use the Device, the Software and the Services, we collect the following Personal Data for the following purposes and based on the following legal grounds :

 

Smart TV Online FW Update: We process the following data:

 

  • Product Serial Number

  • Chassis Serial Number

  • MAC address

  • Public IP address

  • Current FW version

  • Current Boot FW version

  • Current Acoustic binary version

  • Country setting

  • Language setting

  • Project-Platform name

  • Online Update status (such as Success, Failed etc.)

    •  

    We process the data to provide an online firmware (FW) and we track the results of online updates to your Device to identify and fix any problems during the FW update process. 

    The processing of this data is necessary for us to perform a service you have asked for under a contract, i.e., the Smart TV Service Conditions.

     

    We also process the data for statistical purposes which is necessary for our legitimate interests to manage and improve products and services and manage business risk.

     

    You may opt out from Online FW Update at any time via TV Settings/Data Collection item. When you select this item, the features performing the data processing are listed. You can select Smart TV Online FW update and you can disable this feature. Please note that SW updates are necessary for the functionality of your Device. By disabling this feature, you will no longer get SW updates to your Device, which might affect the functionality of your Device; after disabling the Online FW Update, we will no longer colect the data mentioned above under this feature.

     

    Smart TV In House Application Portal: We process the following data to provide Smart TV In-House Application Portal service to you:

     

  • TV brand information

  • Current FW version

  • Country setting

  • Language setting

  • Project-Platform name

  • Connection type (wired, wireless)

  • Public IP address

    •  

    The processing of this data is necessary for us to perform a service you have asked for under a contract, i.e., the Smart TV Service Conditions.

     

    TV Usage Statistics: We process the following data to carry out analytics, create reports and keep records regarding software updates, technical service operations and other similar transactions and to improve our products and services:

     

  • Channel usage data (Input source type (DTV/ATV), DTV source type (DVBT/C/S), Triple ID (tsid, onid, sid), channel name, channel frequency, start time of channel watch, stop time of channel watch)

  • Application usage data (Start time of application launch, stop time of application launch, application unique ID', portal type (Arçelik or third party)

  • Menu usage count for all menu and sub-menu on your Device ( number of your entries, all menu items such as TV Settings menu, TV Source Menu, EPG menu; other data related in these menu items such as Network connection type (cable/wireless), the name of multimedia source being watched (USB Video, USB Music, USB Picture, DLNA), actions taken while viewing (recording start; pause; stop and restart details; reminder/record setup start details), the name of the peripherals (such as CAM, Bluetooth or CEC device) connected to the Device).

    •  

    The processing of the above data is necessary for our legitimate interests to manage and improve our products and services.

     

    You may opt out, at any time, from TV Usage Statistics by accessing via TV Settings/Data Collection item. When you select this item, the features performing the data processing are listed. You can select TV Usage Statistics and you can disable this feature. While this feature is disabled, we suspend the collection of data listed under TV Usage Statistics

     

    Location of your Device based on the Device’s broadband IP address: We identify your Device’s location by using your Public IP address with geo-location services. We use this location data (country, region and city) on our Weather application to provide the weather information according to your location. We also use this location data on “TV Usage Statistics” activity defined above to extract statistical data based on regions. Third party applications and web pages can also identify your location based on your Public IP address.

     

    This location data shall be used by the Company to provide the relevant service and to improve location-based products and services.

     

    You may opt-out from Location based services at any time via the TV Settings menu/Data Collection item. When you select this item, the processes performing the data processing are listed. In order for us not collect your location data based on the Device’s broad band IP address, you would need to disable both features: Weather Service and TV Usage Statistics. Please note that once disabled, we will not be able to provide with the Weather Service.

     

    Built-in Voice Service on Smart TV: If you enable the voice recognition function, you can control your Device with your voice. You can use this feature by giving voice commands to your Device by using a microphone embedded device (for example a remote controller). We process the following data and share this data with third-party voice service providers - currently, Amazon.com, Inc., to provide the voice control feature on your Device:

     

  • Your voice data

  • Randomly generated unique ID for Alexa feature

    •  

    The Software formats this voice data and sends the voice data together with the unique ID data to the third-party voice service provider. Amazon processes your voice data and provides Alexa service to your Device. We do not store any voice data, including any of the text, and only use it to provide the voice recognition functionality. Please refer to third-party privacy policies of Amazon for their usage of your Personal Data.

     

    We process the above data because it is necessary for us to perform a service you have asked for under a contract, i.e., the Smart TV Service Conditions.

    You may disable the Built-in Voice Service at any time by visiting the TV Settings menu/Data Collection item. When you select this item, the features performing the data processing are listed. You can select Built-in Voice Service and you can disable this feature. Disabling the Built-in Voice Service would prevent you from using this service.

     

    Please note that this feature may not be available on all models of the Device.

     

    Voice Control on Smart TV by external voice assistant device: You can control your Device with your voice by the help of skills running on an external voice assistant device (currently, Amazon Echo devices) . You can use this feature by giving voice commands to the external voice assistant device and external voice assistant device processes your voice data. To do this, you would first have to register on our website https://connect.arsmarttv.com , where we process the following data in order to provide the voice control feature on your Smart TV with the external voice assistant device:

     

  • User name or alias

  • Email adress

  • Your chosen name for the TV (e.g., "living room TV”, “kitchen TV”, or any other information inserted by you for naming your TV)

  • The external voice assistant device that you have paired your Device with

  • Randomly generated unique ID

    •  

    The Software processes the mentioned data and shares the following information with a third-party voice service provider (currently Amazon.com, Inc) : TV brand information, current FW version, country and language settings of the TV , your chosen name of the TV, the external voice assistant device that you have paired your Device with. Please refer to third-party privacy policies of Amazon for their usage of your Personal Data.

     

    We process the above data because it is necessary for us to perform a service you have asked for under a contract, i.e., the Smart TV Service Conditions.

     

    You may disable the Voice Control by external voice asistant device at any time by visiting the TV Settings menu /Data Collection item. When you select this item, the processes performing the data processing are listed. You can select Voice Control external voice assistant and you can disable this feature. Disabling this feature, would prevent you from using the Voice Control features.

     

    Please note that this feature may not be available on all models of the Devices.

     

    Smart TV 3rd Party Application Portal: We receive third-party application usage statistics relating to your use of such applications from third-party application providers. We process such data on the basis of our legitimate interests to improve our products and services. For any other data collected by third-party application portals (currently Netrange) that we do not control, please refer to the section below on “Data Processed by Third Party Applications, Software or Services”.

     

    In addition to the above purposes, we may need to process any of the Personal Data we have described above based on our legitimate interests to protect our business and manage our risk in order to enforce the Smart TV Service Conditions and this Privacy Policy, including the investigation of potential violations, identification, prevention or handling of technical issues, fraudulent operations or security issues (including but not limited to filtering undesired emails). We will also rely on our legitimate interests in managing our business to communicate to you important notices, such as information about changes to the Smart TV Service Conditions, this Privacy Policy and service updates.

     

      1. Cookies

     

    The Software and the Services, including the Company’s Smart TV online services and applications, may use cookies. A cookie is a small file that is downloaded on your Device when you access a webpage via the Smart TV In House Application Portal, or on any of the devices (e.g. smartphone, tablet, laptop, computer) you use for registering on our website https://connect.arsmarttv.com for the Voice Control on Smart TV by external voice assistant device Service. The cookie contains information about you and your visit to the websites. Cookies are widely used to make websites work, to distinguish unique users, and learn how users interact with the websites. We only use necessary cookies that are essential for the websites to function, for example, to secure the websites or to provide a service you requested. These are “session cookies” (cookies that expire at the end of each user session) and “persistent cookies” (cookies that stay on your device after your session).

     

    The table below provides an overview of the cookies we use and why we use them.

     

    Cookie name

    Service

    Purpose

    Duration

    CloudFront-Key-Pair-Id

    Smart TV In House Application Portal

    A resource identifier that will be used to access the directory where our Smart TV applications are hosted

    It expires at the end of browser session

    CloudFront-Policy

    Smart TV In House Application Portal

    An encoded set of statements describing the access rights to the directory where our Smart TV applications are hosted

    It expires at the end of browser session

    CloudFront-Signature

    Smart TV In House Application Portal

    A randomly generated signature to verify the integrity of keypair and policy which are used to access the directory where our Smart TV applications are hosted

    It expires at the end of browser session

    authorize

    Voice Control on Smart TV by external voice assistant device

    Encoded session identifier to store the login information on https://connect.arsmarttv.com to provide user authorization and authentication

    1 year

     

    We do not share the information collected via cookies with third parties other than the ones that operate with us to offer the Services to you.

     

      1. Retention of Your Personal Data

     

    The Company will not keep your Personal Data for a period longer than necessary for the purposes set out above. Unless we are required to keep your Personal Data for the purposes of satisfying any business, legal, regulatory, accounting or reporting requirements, we will delete your Personal Data when you no longer use the Device and the Services.

     

      1. Data Processed by Third Party Applications, Software or Services

     

    You may choose to use several applications, software and services offered by various third parties, including, mainly, third-party application portals when using the Services or the Device (the Company may also be considered as a third party for services offered by the Company outside the Smart TV Service Conditions or this Privacy Policy). The providers of such third-party applications, software and services may collect and process your Personal Data and such processing is subject to the terms of use and privacy policies of those third-party providers for which the Company does not assume any responsibility.

     

    If you choose to use such third-party applications, software and services, the providers of the third-party applications, software and services will have access to a minimum amount of Personal Data about you that is necessary to connect the Services or your Device to that third-party application, software or service. For example, if you want to use Smart TV 3rd Party Application Portal on your Device (currently, Netrange), we will provide your Device’s Serial number, Current SW version, Country setting on Device, Language setting on Device and Platform name.

     

    Moreover, if you use third-party applications or visit third-party websites using the Device’s internet browser, such third-party applications and websites may temporarily install cookies on your Device. We do not control and are not responsible for the collection of your data by means of these third-party cookies.

     

      1. Sharing Your Personal Data with Third Parties

     

    We may share with or disclose your Personal Data to third parties in the following cases:

     

    Other Arçelik group companies. We may share your Personal Data (e.g., TV and application usage statistics) with other companies belonging to the Arçelik group, including our subsidiaries, who may use your Personal Data for purposes consistent with those purposes set out in this Privacy Policy.

     

    Service providers. We may disclose your Personal Data to companies that provide services to us, such as companies that operate cloud computing services. The service providers are required to keep your Personal Data confidential and are not permitted to use your Personal Data for any other purpose than to carry out the services they are performing for us.

     

    Third parties where required by law. We may disclose your Personal Data to a third party if it is necessary to comply with a legal obligation or the decision of a judicial authority, a public authority or a government body, or if disclosure is necessary for national security, law enforcement (e.g., to track a stolen TV) or other issues of public importance.

     

    Business partners. We may disclose your Personal Data to our business partners if it is necessary for providing products and services to you, such as sharing your voice data with third-party voice service. For further information, see the section above on Data Processed by Third Party Applications, Software or Services.

     

    Third parties in connection with a business sale. If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer, we may transfer your Personal Data to one or more third parties as part of that transaction.

     

    Other third parties with your consent. We may also share your Personal Data with other third parties when you consent to such sharing.

     

    We will also provide anonymized data to third parties for marketing purposes (e.g., the number of Devices that are connected to the internet in specific countries).

     

    We will not give third parties your Personal Data for any purpose other than the ones set out in this Privacy Policy and we will not sell your Personal Data to third parties.

     

      1. International Transfers of Your Personal Data

     

    Your Personal Data will be processed by Arçelik A.S. in Turkey and may be shared with other third parties (as described in the section above on Sharing Your Personal Data With Third Parties). Therefore, your Personal Data may be transferred outside of your country of residence. The level of protection for Personal Data is not the same in all countries, however, we will take reasonable steps and implement security measures as described in this Privacy Policy in order to keep your Personal Data secure.

     

    Specifically, before we transfer your Personal Data outside the European Economic Area (“EEA”) and the UK, we will take steps to ensure that your data will be afforded the same level of protection as under applicable data protection laws within the EEA and the UK. For data transfers outside of the EEA and the UK, we use applicable safeguards, including the standard contractual clauses adopted by the European Commission and will make available a copy to you upon request made using the contact details listed below in section on “How to Contact Us”.

     

      1. Security Measures for Personal Data

     

    The Company takes certain administrative, technical, organizational and physical measures to secure and protect your Personal Data against loss, theft, abuse and unauthorized access, disclosure, modification or destruction.

     

    Among other measures, we ensure the security of your Personal Data by means of encryption, password protection and by otherwise restricting the access to your Personal Data.

     

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to us using unsecured means; any transmission is at your own risk.

     

    You should also continue to take measures to keep your Personal Data safe and secure, such as avoiding the use of apparent or predictable user IDs or passwords, changing your passwords with regular intervals and making sure that you have not disclosed your password(s) to anyone else and that you have not given consent to a third party to have access to your user account and Personal Data.

     

      1. Links to External Content Sources

     

    Third-parties, whose sites or content you may visit after clicking on a link from the Services, may have different and less stringent privacy policies. We do not have control over these policies and are not responsible for the processing of your Personal Data by such third parties. We urge you to read their privacy statements before providing any personally identifiable information to such third parties.

     

      1. Your Rights for Your Personal Data

     

    You have the following rights with respect to your Personal Data that we process, subject to conditions set out in applicable law:

     

  • to learn whether your Personal Data is processed by us and to request a copy of your Personal Data and information relating to the processing of your Personal Data, including the purposes of processing your Personal Data, and the third parties to whom your Personal Data is disclosed;

  • to request the correction of any inaccurate or incomplete Personal Data;

  • to request the erasure of your Personal Data or the restriction of the processing of your Personal Data in accordance with applicable law;

  • to object to our processing of your Personal Data;

  • to withdraw any consent you have given;

  • under certain circumstances to demand data portability;

  • to lodge a complaint with the applicable data protection supervisory authority; and

  • to contest certain automated decisions, we make about you that have legal or otherwise similarly-significant consequences. We do not typically carry out such automated decision making but, if we do, we will make it clear where such decisions are being made.

    •  

    To exercise your rights, please contact us using the contact details listed below in the section on “How to Contact Us”.

     

      1. How to Contact Us

     

    If you want to obtain more information about how we process your Personal Data and our commitment to this Privacy Policy, you can contact us by email at smarttv@arcelik.com. You can also write to us:

     

    ARÇELİK A.Ş.

    Compliance & Ethics Department

    Karaağaç Cad. No: 2-6, Sütlüce-34445 Istanbul, Turkey

     

      1. Changes to This Privacy Policy

     

    The Company may change and update this Privacy Policy from time to time. The Company shall notify you about material changes or additions to this Privacy Policy and you will be notified of such material changes via on-screen notifications on your Device.

     

      1. Access to the Privacy Policy

     

    You can access a copy of the latest “Smart TV Privacy Policy” on your Device by going to “About” section on TV Settings Menu.

     

     

     

    This Privacy Policy was last updated on 23-09-2019.