Privacy Policy


Introduction

TCT Mobile International Limited (“We”) attach great importance to the protection of privacy and personal data of our users (“You”). When you use our product (Push SDK) and/or service, we may collect and use certain information about you. This Privacy Policy applies to the Push SDK product and service we provide you, and it’ll explain to you how we collect, use, protect, keep and dispose of information generated from you or provided by you, for the purpose of making available, maintaining and improving our service, and optimizing or updating the functions in our product and service. Please read this Policy carefully and fully comprehend its contents. Your usage of our product and service (or continuance to use them after we update this Policy) will be deemed as your consent to this Privacy Policy (including its updates), and the consent to allow us collect, use and handle information about you. If you do not agree with these items and conditions, you are not allowed to download, use this product, or you should remove this product. If you have any question or advice on this Policy, you’re welcome to contact us by sending email to mie-alcatel.support@tcl.com.


The personal information we collect

We will collect and use your information only for the following purposes and in the following manners.

1.  Information you submit to us

1)   When submitting a complaint or suggestion, the user needs to provide email address so that we can provide feedback by sending you relevant emails.

2)    We may request you to submit certain other information when we provide new functions and features which needs such information, or when we're required to keep such information pursuant to new laws, regulations and policies. In such cases, you'll be informed of such request by the updated Privacy Policy and/or relevant notifications and explanations we provide you.


2.  Information we get from your use of our product and services

We collect information about the product and services that you use and how you use them in order to properly provide the core or important features of the product and/or services, or to improve our product or services, or to provide additional features to our product (such as push message function, value-added service, promotion, etc.). Some of the reasons that we collect Personal Information include (in case of any contents or statements herein which provide otherwise, please refer to the relevant details accordingly):

  •  Provide our product and services, including our app and related website (if any), and improve them over time;

  •  Allow you to download  products and services;

  •  Personalize and manage our relationship with you, including introducing you to products or services that may be of interest to you or to provide customer support;

  •  Investigate, respond to, and manage inquiries or events;

  •  Work with and respond to law enforcement and regulators; and

  •  Research matters relating to our prod and business, such as security threats and vulnerabilities, or conducting internal audit, data analysis, and research.

If you do not provide some of the information mentioned below, you may not be able to continue using the product and/or services that we provide, and if you do not agree that the information to be collected after your installation or use of the product, you may stop using or uninstall our product and/or services, or contact with us for advice; for the other types of information, your refusal to provide or opt-out option may cause you unable to access certain specific features or get the best experience.

1)    Device and/or SIM card information

We collect device-specific information (such as your hardware model, MAC address, Android version, device manufacturer details and model name, unique device identifiers, and mobile network information including phone number). (A unique device identifier (sometimes called a universally unique ID or UUID) is a string of characters that is incorporated into a device by its manufacturer and can be used to uniquely identify that device (for example an IMEI-number of a mobile phone). Different device identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed. A given device may have several different unique device identifiers. Unique device identifiers can be used for various purposes, including security and fraud detection, syncing services such as a user’s email inbox, remembering the user’s preferences and providing relevant advertising.)

2)    Log information

When you use our services or view the content provided by us, we automatically collect and store certain information in server logs. This includes:

Details of how you used our service, such as your search queries.

Telephony log information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.

Internet protocol address.

Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.

Our collection of aforesaid information is for analyzing our product functions and improving our product’s user experience.

3)    Location information
When you use product to check for weather information, we need to collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points and cell towers. The collection and use of location information is for providing accurate weather information at your location, and if you refuse to or stop providing it, we cannot guarantee such accuracy or this product may not able to be used at all. For more details on location information, you can also find out in the following section of "Permissions on your device".


3.  Permissions on you device

1)    In providing our product’s functions and services, we may need you to allow certain “permissions” on your device, which will enable to information collection and usage relevant to those functions. These include the permissions described in the list below (please take note that we may revise and update this list from time to time, for the reasons such as update or revision of our product, technology upgrading such as changes in your phone’s operating system, or legal and policy requirements. Such changes will be posted in our updated Privacy Policy):

Permission

Related functions

Purpose of permission

Push sdk user will be asked about permission

Push sdk user can deny permission

Push

Network request

Allow request network data

Yes

Yes (depending on the device network)

Push

Monitor network changes

Allows programs to access information about the GSM network and to allow programs to access information about the WI-FI network

Yes

Yes (depending on the device network)

Push

Open the window

Allows a program to open windows that appear on top of all other programs

Yes

Yes (depending on the device network)

Push

Get job information

Get job information

Yes

Yes (depending on the device network)


2)    You can check if such permissions are allowed or not for our product and service, which can be done by checking “Settings-Apps- (related applications)-Permissions” on your device , and thereby decide whether each permission will continue to be allowed or will be denied. The specific way to review the status of such permissions and deny them may vary in different devices, and please refer to the notes or instructions provided by relevant device OEMs and OS developers. In case that you’re unable to carry out relevant steps and adjust the settings in your currently-used X product or device, please contact us or the OEM of you device. 

3)    Please note that allowing these permissions will be deemed as your consent to allow us collect and use relevant information to realize relevant functions; when you deny or disable the permissions in whole or in part, it means you have refused to provide related information to us, therefore also making us unable to provide you those functions relevant to such permissions. Your decision to deny a certain permission on your device does not affect our handling of your relevant information which has been based on your prior consent to allow such permission.


4.  We will not need to, or will be effectively unable to, get your prior consent on collecting and/or using your information in the following circumstances:

1)    When the collection and usage is related to national secure or national defense;

2)    When the collection and usage is related to public safety, public health or significant public interests;

3)    When the collection and usage is related to investigation, prosecution, trial or judgment enforcement of criminal acts;

4)    For the sake of life, property or other major legitimate interests of you or others, while in such incidents we have difficulty to reach you to confirm your consent;

5)    When the information we collect has been voluntarily disclosed by yourself;

6)    When we collect your information from sources that have made legitimate and public relevant disclosures of such information, such as legitimate news reports, or governmental information disclosure;

7)    When relevant collection or usage is necessary for ensuring the safe, stable and legitimate operations of our product and/or service, such as when we need to diagnose or deal with failure or defects in the product and/or service.

8)    When the collection or usage is required for legitimate news reports;

9)    When the collection or usage is necessary for academic or research institutes to make statistical or academy research for public interests, and when such results of research are being disclosed, the personal information contained has been made to be “de-identified”.

When the collection or usage of your information is permitted by applicable laws and regulations for other reasons.


Our principles in using your information

1.  For the information that we have collected according to the conditions and situations set forth in this Privacy Policy, we’ll be using them for providing the relevant functions in our product and/or service, or for other legitimate purposes and use them in a reasonable and necessary principle.

2.  Please note that, for all the information you’ve consented to provide us while using our product or service, you’re deemed to have granted us authorization to continuously use such information throughout the period you use our product or service- unless you have deleted such information (either by yourself or by informing us, pursuant to this Privacy Policy) or, by effective settings or notice, refused our continued usage of the information. When you cancel your user account and/or completely uninstall our product (or stop using our service), we will, pursuant to applicable laws and according to this Policy, stop using and delete such information of you.

3.  We may use certain technology to anonymize some of your information, so that the information which has been processed will not be used to identify specific data subject. Please understand and also consent, that in such cases we’re allowed to make use of the anonymized information; we have the right to make user database analysis and use it for relevant commercialization as long as we don’t disclose information of personal identities.

4.   We may build up product/service usage statistics, which could be shared with to the public or with third parties, so as to illustrate the trends in using our product and/or service, provided that such statistics does not include information of personal identities. 

5.  You hereby grant us the right to send you as you use our product and/or service, and agrees to accept, commercial information that we may send you via notifications in our product or on our device, or sent to your email, mobile phone, address etc., including but not limited to product introduction and promotional messages of our own or third-party products. We may provide these message and recommendations using the information we collected based on the sections above (including device information). If you choose not to accept the above information we provide, you may refuse to continue receiving such information by making the setting or operations according to relevant instructions we provide, such as canceling subscription. In case you find problems in making such settings by yourself or you continue to receive other commercial information, please contact us for further advice. Besides, when necessary (e.g., certain service is suspended due to system maintenance), we may send to you announcements related to the services. You may not be able to cancel the announcements related to the services that are not promotional in nature.

If we’re going to use your information for purposes other than those stated in this Policy, or we have collected certain information for designated purposes but will use it for some different purpose, we’ll have your prior consent accordingly.


Cookies and Other Technologies

1.  We or our third party partners may collect and use your information via tracking technology such as Cookies, which information may be stored as log information.

2.  We use such technologies to provide more tailored services and user experiences, and for purposes such as remembering your account identity or analyzing your account’s security; analyzing your usage of our product and service; advertisement optimization (helping us to provide you with more targeted advertisements instead of general advertisements based on your information). We may also process and summarize the non-personal information collected via tracking technology and provide the same to advertisers or other partners to be used to analyze how users use our services and for advertisement purpose.

3.  There may be tracking technology placed by advertisers or other partners in our products and service. Such tracking technology may collect the non-person information related to you for the purpose of analyzing how users use the services and sending to you the advertisements you might find interest in, or evaluating the effects of the advertisements. Collection and use of such information via third party tracking technology will not be subject to this Privacy Policy, but will be subject to third-party privacy policies applicable to the users, and we will not be liable for the third-party Cookies or web beacon.

4.  You may use browser and personal device settings to refuse or manage tracking technology. However, for technical reasons beyond our control, this cannot be guaranteed. For example, if you reset your browser, delete your cookies or access to our website or applications from another browser or device, your cookie settings may be lost.

You shall be aware that when ceasing to use Cookie or other tracking technology, you may not be able to enjoy the best service experiences, or parts of our product or service may no longer function correctly (please contact us in case of any such problems). Furthermore, you mays still receive the same amount of commercial information such as advertisements which will have lower relevancy to you.


Do We Share the Information?

We do not share personal information with companies, organizations and individuals outside of TCT unless one of the following circumstances applies.

We may share personal information with your consent.    

We may disclose personal information to our affiliates when necessary to perform services on our or on your behalf.

We cooperate with companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes.

 

We will share personal information with organizations or individuals outside our organization if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:

• meet any applicable law, regulation, legal process or enforceable governmental request.

• detect, prevent or otherwise address fraud, security or technical issues.

• protect against harm to the rights, property or safety of our users or the public, as required or permitted by law.


Security and Transparency

1.  We will endeavor to take all reasonable physical, technical and organizational measures and procedures to safeguard and secure the personal information we collect through our products and our website.

2.  We put access restrictions on all the user information we’ve collected. Only those relevant personnel may access and handle the information for the purpose of providing the product and service;

3.  We work hard to protect our company, reputation and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of personal information that we hold. In particular:

  1)  We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems;

  2)  We use encryption where appropriate;

  3)   We use password protection where appropriate; and

  4)   We restrict access to personal information to our employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract may be terminated if they fail to meet these obligations.

4.   However, these measures do not release you from taking appropriate steps to keep your personal information safe and secure, in particular by avoiding obvious user ID's or passwords, by ensuring that you do not disclose your password(s) or grant any other person access to your user account and your personal information, and any other protective measures applicable.


If you share your personal information through one of our websites or devices with a third party account, such as Facebook, Google + or Twitter, please note that the privacy of your personal information will be managed respectively by one of those third parties. We are not responsible for any damages due to any data loss, damage or infringement that may occur on your third party profiles over which we have no control.


Changes

Our Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

 

The current version will be updated on March 08, 2018.

Retention of Personal Information

We keep your personal information for a limited duration necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law and only for the purposes defined above. Once the purpose is achieved, all personal information is deleted in a safe and secure mode.


Your rights: Access, Review and Edit

You can access, review and edit your personal information at any time by using the Push sdk product. Should you require us to edit or delete your personal information, we may ask you to provide us with evidence of your identity before we can act on your request.

 

You can also have your data deleted or blocked, as appropriate, should you believe that your data is inaccurate.

 

For all and any requests as defined above, you may send your request to the following email address: mie-alcatel.support@tcl.com

 

Under certain jurisdictions and data protection laws, you may have the right to request details of your personal information, which we hold, about you or to request the correction or deletion of your personal information.

 

Please help us to ensure that we hold about you is accurate and up to date. If you think that any we have stored about you is incorrect or incomplete, please contact us at  mie-alcatel.support@tcl.com or write to our customer services department.  


Privacy Questions

If you have any questions or concerns about our Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us at mie-alcatel.support@tcl.com

All communications are examined and replies are issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues, which may be applicable to your circumstances.