Effective as of December 1, 2019           

TCT Mobile Inc. (“TCT”) is committed to protecting the privacy of children who use our devices, applications and websites. The Children’s Privacy Policy explains how we collect, process, disclose personal information related to children under the age 13 (“child” or “children”) as well as the parental consent practices with reference to the processing of such information. 

This Children’s Privacy Policy is intended to supplement the TCL global Privacy policy and all terms and conditions set forth in the latter apply. In case of conflict between terms, this Children’s Privacy Policy prevails. This policy is in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”) for the protection of children’s personal information in United States. For more information about COPPA please visit the FTC website here.

This Children’s Privacy Policy does not apply to the practices of any third-party applications, actions or websites that your child may use. You should review the applicable terms and policies for such third-party applications, actions and sites to determine their appropriateness for your child, including their data collection and use practices.

1. INFORMATION WE COLLECT FROM YOU AND YOUR CHILD

As part of the account creation process, we may ask for personal information like first and last name, e-mail address, gender and birthdate. We collect the content your child provides, such as your online contact information which is necessary for us to provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity requested or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law.

Verifiable parent consent: In the event TCL wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by e-mail. In the email we will explain what information we are collecting, how we plan to use it, how the parent or guardian can provide and/or revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent or guardian contact information and any other information collected from the child in connection with that activity.

In no event TCL will collect personal information from a child without obtaining the prior consent of the parent or guardian, as mentioned above. In the event, we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

Collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian e-mail address before we collect any personal information from the child. If you believe your child is participating in an activity that implies collection of personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at privacy.na@tcl.com. We will not use parent e-mails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.

2. INFORMATION WE GET FROM YOUR CHILD’S USE OF OUR DEVICES OR SERVICES

We may automatically collect certain information about the devices and services that your child uses and how your child uses them. This information may include:

• “Your child’s apps, browsers and devices”, including browser type and setting, operating system, mobile network information, IP address.

• “Your child’s activity” including search items, chrome browsing history, voice and audio information.

• “Your child’s location information” when the child uses our devices and/or services, unless disabled by parent/guardian.

We use various technologies to collect and store your child’s information including cookies, pixel tag, local storage, such a browser web storage or application data caches, data bases, server logs.

3. HOW DO WE USE YOUR CHILD’ S PERSONAL INFORMATION

In general, we use your child’s personal information to:

• Register your child with the device or service.
• Provide information to parent and /or guardians.
• Provide, maintain, and improve our services and devices. 
• Measure performance and understand how our services and devices are used. 
• Help improve the safety and reliability of our services.

We use different technologies to process your child’s information for the purposes above.

4. PUSH NOTIFICATIONS

Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed applications that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.

5. ADVERTISING (OPT IN & OPT OUT)

We will not send any advertising or marketing communication to your child under 13 years of age without securing parent/guardian consent. We will not send any advertising or marketing communication to your child of age between 13 and 16 without securing the child consent. If the child is above 16 years of age, we will stop sending advertising or marketing communications in case the child opts out. 

6. WHEN WE SHARE WITH OTHERS THE INFORMATION COLLECTED FROM A CHILD 

We also may share or disclose personal information collected from your child in a limited number of instances, including the following:

• We may share information with our service providers if that is necessary for them to perform a business, professional, or technology support function for us.

• We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from your child in the following situations:  (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

7. PARENTAL ACCESS AND CONTROL ON THEIR CHILD’S PERSONAL INFORMATION

If you create a new account for your child, you can select the “Kid mode” and then access, remove, and export your child’s information or change the “Kid mode” setting. Parents may refuse anytime to permit us to collect further personal information from their children in association with a particular account, and they may request that we delete from our records the personal information we may have collected in connection with that account. Please be aware that a request to delete records may lead to a termination of an account, membership or other service.

8. CONTACT US

If you have any questions about your TCL child’s account, or you want to access or delete your child’s personal information you may contact us at the mailing address or email below with questions about the operators’ privacy policies and collection and use practices:

TCT Mobile Inc
25 Edelman street
Irvine, CA 92618
United States of America
Email: privacy.na@tcl.com

In any correspondence such as e-mail or mail, please include the child’s username and the parent’s email address and telephone number. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal information.