Enhanced Viewing Service Privacy Notice

(Effective Date: June 10, 2022)

This Enhanced Viewing Service Privacy Notice (“Privacy Notice”) applies to the information Hisense International Co., Ltd., (“we”, “us” or “our”) collects through the Enhanced Viewing Service (the “EV Service”).

In this Privacy Notice, we describe the types of information used to provide the EV Service, how we use the information, with whom we share the information, and the choices available to you regarding your use of the information. We also describe the measures we take to safeguard your personal information and tell you how to contact us about our data protection practices.

1.     What is EV Service?

The EV Service is an optional service designed to provide you with useful, interactive features and interested-based advertisements offered by us and third parties across various devices connected to the same IP Address as your smart TV. When activated, the EV Service also can improve your sound and video quality based on what you are watching in real-time. The service can be activated during the initial setup of your smart TV or anytime after within the smart TV’s settings.

If you have opted-in to enabling the EV Service on your smart TV, the EV Service will continuously analyze audio from any onscreen content accessed or displayed on your smart TV at that moment, including content from any set-top-boxes, media players, gaming consoles, over the air broadcast, or other audiovisual sources playing through your smart TV.

Subject to your opt-in to enabling the EV Service, the automatic content recognition (“ACR”) service included in this device will irreversibly encode the analyzed audio signals, and may also irreversibly encode video signals, from onscreen Content into hashed digital signatures (“Digital-print”), which are transferred from this device to the ACR service for further processing, such as to identify a match in a database of known hashed commercial programing signatures.  This ACR process will associate the data with the public (WAN) IP Address used by this device, which identifies the general location where this device is connected to the Internet, but otherwise does not collect, store, or transfer any directly identifiable personal information, audio, or video from this device. The ACR service also generates a random number to associate with this device, called a “SmartTV Identifier”.  The Digital-print, your IP Address and SmartTV Identifier are referred to collectively as “SmartTV Viewing Data”. 

The ACR service analyzes SmartTV Viewing Data in combination with other data or information from the ACR service, or third-party services, and produces aggregate, de-identified analytics (including user profiles, statistics, metrics, abstractions and other analyses) that the ACR service uses to deliver more relevant advertising on other devices that share the IP address of this device, and to automatically adjust the picture mode and sound mode so as to match with the then current content displayed on this device.  The Smart Viewing Data may also be used to create aggregated, anonymized reports used to help third parties understand general TV viewing trends.  Any data or information exchanged between this device and the ACR service provider(s) in this process is governed by this Privacy Notice, and our current ACR service provider, Tremor Video’s, privacy policy that is available at https://www.tremorvideo.com/privacy-policy/). 

2.     Information We Obtain

Through the EV Service, we may obtain information about your smart TV, including:

·         Device information, such as your device model, operating system version, IP address, SmartTV Identifier, device configurations and settings and other device identifiers;

·         Device usage and log information about how, when and for how long you use your devices, including your interactions with the EV Service and our and third-party apps and services on the devices;

·         Your smart TV viewing history, including information about the networks, channels, and programs viewed on your smart TV and the amount of time spent viewing them, to produce aggregate, de-identified analytics (user profiles, statistics, metrics, abstractions and other analyses) that cannot be used to identify you (“Analytics”). The Analytics will be used by us and our authorized ACR service provider(s) and select third party content providers to automatically adjust the picture mode and sound mode to match with the then current content displayed on this device, deliver more relevant advertising on other devices that share the IP Address of this device. We obtain this information only if you have opted-in to enable EV Service on your smart TV;

·         Behavioral and demographic information about you or your devices, such as your generalized location.

We also may collect other information about you, your devices and apps in ways that we describe to you at the time of collection or otherwise with your consent.

3.     How We Use the Information We Obtain

We, and our authorized ACR partner may use the information we obtain through the EV Service to:

·         provide you with relevant advertising on other devices that share the IP address of you smart TV that is personalized based on your viewing history.

·         provide you with the EV Service on your smart TV and across your devices;

·         optimize sound and video quality based on the content you are currently watching on your smart TV;

·         improve and customize your experience with the EV Service;

·         respond to your requests and enquires;

·         operate, evaluate and improve our business (including developing new products, enhancing and improving our products and services; managing our communications; analyzing our products, customer base and services; conducting market research; performing data analytics and performing accounting, auditing and other internal functions);

·         protect against identify, and prevent fraud and other criminal activity, claims and other liabilities; and

·         comply with and enforce applicable legal requirements, relevant industry standards and our policies, including this Privacy Notice and our Data Protection Policy.

We may combine information about your online activities over time and across other our and third-party devices, apps, websites and online services. We also may use the information we obtain in other ways for which we provide specific notice at the time of collection or otherwise with your consent.

4.     Information Sharing.

We do not share personal information collected about you through the EV Service except as described in this Privacy Notice and our Data Protection Policy. We may share your personal information with our subsidiaries, affiliates, service providers, contractors, agents, advisors and business partners for the purpose of providing the EV Service. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf and to comply with legal requirements.  We may disclose personal information and geographic information as described above with third party advertising partners, who may provide you with relevant advertising.

We and our third-party service providers may also disclose information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response or requests by government agencies, such as law enforcement authorities; (3) to establish, exercise, or defend our legal rights; (4) when we believe disclosure is necessary to appropriate to prevent physical or other harm; (5) in connection with an investigation of suspected or actual illegal activity; (6) in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, reorganization, dissolution or liquidation); or (7) otherwise with your consent.

5.     Right to Opt-out of Sale for California Residents. 

You have a right to direct us not to sell your Personal Information. In the preceding twelve months we have not sold your personal information, as that term is generally understood, but we recognize that California law defines “personal information” in such a way that making available identifiers linked to you for a benefit, or viewing/browsing history, may be considered a “sale.”  If you are a California resident and would like to exercise that right, please select the “Do Not Sell My Personal Information” link within the “Settings” menu of your smart TV.  Alternatively, you may direct us to not to sell your Personal Information as provided in the Contact Us section below.

6.     Your Choices.

We offer you certain choices in connection with the personal information we obtain about you through the EV Service. You can revoke your consent for processing EV Service by turning off this feature anytime through your smart TV “Settings”. If you reset the SmartTV Identifier on your smart TV, any data collected and associated with your previous SmartTV Identifier will no longer be used to deliver more relevant advertising.  Please note that if you reset your SmartTV Identifier, it may take some time for our systems to update your information due to technical reasons. Please also note that resetting your SmartTV Identifier will not stop relevant advertising to you, and will continue to automatically adjust the picture mode and sound mode so as to match with the then current content displayed on this device. To disable automatically adjust the picture mode and sound mode, please adjust the setting on your device, as described above.

7.     How We Protect Personal Information.

We maintain physical, administrative, technical and organizational safeguards designed to maintain the confidentiality and security of the personal information we obtain through the EV Service against accidental, unlawful or unauthorized destruction, interference, loss, alteration, access, disclosure or use. Unfortunately, the transmission of information via the Internet is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through use of the smart TV or our operating system.

8.     Updates to Our Privacy Notice.

This Privacy Notice may be updated periodically to reflect changes in our personal information practices with respect to the EV Service, or changes in applicable law.  We will indicate at the top of this Privacy Notice when it was most recently updated.

9.     How to Contact Us.

To ask us questions about this Privacy Notice, please contact us by sending an email to  product.tv.info@gmail.com or by mailing us at:

Hisense International Co., Ltd.

No. 218, Qianwangang Road, Economic and Technique Development Zone, Qingdao, P. R. China.

If you are based in EEA or EEA residents, you may also contact our EU representative:

     VERDATA Datenschutz GmbH & Co. KG        

       Roemerstr. 12        

       D – 40476 Duesseldorf        

       Email: hisense.representative@verdata.de