1. Which type of personal data do we process?

When you consent to this Privacy Policy for the “_BRAND_ TV” skill application (“Privacy Policy”), you give your consent that Vestel Elektronik Sanayi ve Ticaret A.S who is sole manufacturer and operator of _BRAND_ Smart TV and _BRAND_ TV skill with an operating address of Organize Sanayi Bölgesi 45030 Manisa/Turkey (“Vestel”, “we”, “our” or “us”), acting as a data controller may collect and consolidate various information about you and/or this application as more specifically explained below.

This Privacy Policy explains the following items:

i. How you can link your _BRAND_ Smart TV with Alexa compatible device

ii. How we collect, use and/or store information related to your “_BRAND_ TV” skill application.

iii. How you can contact us.

In order to provide you the service, firstly, you should download _BRAND_ Smart Center application from the platforms Google Playstore or Apple Appstore and log into your active Alexa Amazon account. Subsequently, you should pair your _BRAND_ Smart Center application with _BRAND_ Smart TV and create your TV friendly name. When the foregoing process is successfully completed, we will collect and store the following information and share with Amazon service in order to provide you the service.

Amazon ID, TV Version, TV unique ID, TV friendly name, TV model name, TV description, TV unique connection name

Enable process of _BRAND_ TV Skill and use of access token

In order to complete the process and link your Alexa compatible device with _BRAND_ Smart TV, you should access to your Amazon Alexa account via Amazon Alexa application or Alexa web app. This application will enable you to link your Alexa compatible device with _BRAND_ Smart TV. Please read this Privacy Policy and indicate whether you give consent to its terms by selecting the button or checkbox describing your consent or refusal. If you accept this privacy policy and enable this application, Amazon service shall generate the access token and share with us in order to complete the linking process of your Alexa compatible device with _BRAND_ Smart TV.

2. How do we use your information?

(i) To provide you service

We may collect and/or analyze the information referred to in Section 1 in order to link your Alexa compatible device and _BRAND_ Smart TV so that we could provide you service of this application.

(ii) To improve and develop products and services

We may collect and/or analyze the information referred to in Section 1 in order to generally improve our products and services and to develop new ones, for example, by helping us understand the way you use this application, so that we can generally provide improved user experiences for the current and/or future products and services.

(iii) To protect _BRAND_ and its users

We may collect and/or analyze the information referred to in Section 1 in order to identify potential security threats and to protect _BRAND_, its users and _BRAND_ Group Companies.

3. Who else has access to your information?

Your information that is communicated to and stored by us may be made available to other _BRAND_ Group Companies and our third party contractors as follows:

_BRAND_ Group Companies and Vestel

Your information may be shared with other _BRAND_ group companies and/or us or the purposes of pursuing the activities outlined in Sections 1 and 2 above on _BRAND_’s behalf, acting as processors of _BRAND_.

Business transfer

In the event that we sell or transfer a portion or all of our business, your information may be transferred by us to the purchasing or acquiring entity as part of the transaction. In the event we sell or transfer your information to a purchasing or acquiring entity you will be duly informed.

Compliance and enforcement

We may retain, use and/or disclose any of your information as required or permitted by law, regulation or order, including to the police or other appropriate authorities, to investigate complaints made by or against you, or to protect or defend ourselves, or others, against illegal, criminal or harmful activities.

4. Data Retention, Managing Your Information

We will retain the information described in Section 1 for 24 months after your last access to this application and the “TV control Setup with Amazon Alexa” application. Please note that we may be required to retain certain information by law.

In some jurisdictions (e.g. if you reside in the EU), you have a right to request from us access to your information, rectification of inaccurate information, or erasure of your information in certain circumstances. In addition, where provided for under applicable local law, you may also have a right to restrict the processing of your information, a right to object to the processing of your information, as well as a right to lodge a complaint with the local data protection supervisory authority.

5. Transfer of your information internationally

Your information will be processed, stored and transferred for the purposes outlined in Sections 1 and 2 to various countries outside the European Economic Area (EEA) and/or your country of residence, including Turkey. Your information will be processed by staff operating outside the EEA and/or your country of residence who work for us or for one of our service providers and may be seen by such staff in those countries. In particular, you are hereby informed and consent that your information may be transferred to us, which is not a country that is regarded as providing an adequate level of protection, and you are informed that Vestel has implemented appropriate safeguards to ensure these data transfers are made in compliance with applicable local laws.

6. Security

We undertake reasonable security measures designed to protect against the loss, misuse or alteration of your information. Although we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to us through this application or that we store on our systems or that is stored on our third party contractors’ systems.

7. Our Policy Regarding Children

We are committed to complying with all applicable laws and regulations regarding the collection, storage and use of personal information concerning children, applicable local legislation in other countries. If you are a parent or guardian and are concerned that your child has provided us with personal information without your consent, you should contact us at the address set forth indicated below.

8. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify or request your consent (whenever necessary under the applicable law) for any changes to our Privacy Policy.

You are advised to consult the posted Privacy Policy regularly for any changes.

9. Contact Information

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any legal right you may have in respect of your personal information, please contact us at the address as indicated below.

Contact number: +90 212 456 20 00

Contact registered address: Levent 199, Buyukdere Cad. No: 199 34394 Istanbul/TURKEY

Contact email: smarttvsecurity@vosshub.com

Last Updated and Effective Date: 5/25/2018