Grundig TV Smart Remote APPLICATION PRIVACY POLICY

This Privacy Policy describes how Arçelik A.Ş., its affiliates and subsidiaries (hereinafter referred to as the "Company") collect, process, share and protect your personal data through the Grundig TV Smart Remote Application (hereinafter referred to as the “Application”) Grundig Intermedia GmbH is a subsidiary of Arçelik A.Ş. The Company’s Privacy Policy shall also be valid for all services provided by the Company or its affiliates and subsidiaries in the scope of the Application (hereinafter referred to as the "Services"). The Company may process the personal information in accordance with this Privacy Policy.

This Privacy Policy is an integral part of the service conditions of the Grundig TV Smart Remote Application. All terms not defined herein shall be deemed to have been defined in the sense set out in the Service Conditions document of the Grundig TV Smart Remote Application. Service Conditions of the Grundig TV Smart Remote Application shall apply to all matters not included in this Privacy Policy.

1.Which personal information of yours are collected by us and how do we collect them?

Your information such as your identity and contact details, as well as the responses that your Smart TV appliance (hereinafter referred to as the “Appliance”) gives to the commands transmitted from the Application with the Appliance number, which allows your Smart TV to pair with the Application, can be collected and processed through the Application and when you are using it.

We call all personal information that we collect about you as “Personal Data” as well. Personal data mean such information and data that may be used to verify your identity.

2.Local Legislation

Provisions of this Privacy Policy shall be applicable for all our users. Notwithstanding the foregoing, there may be different legislations in some other countries for the protection of personal data. For instance, directives and policies adopted by the European Union countries may introduce different standards for the protection of personal data.

Users agree and represent that they are aware of the fact that the Company, its affiliates and subsidiaries may be based outside the European Union and that thus they give their consent to the collection, use and transfer of their personal data and information under this Privacy Policy. Notwithstanding the foregoing, the Company, its affiliates and subsidiaries agree and undertake to provide for such mandatory protection as set out in the European Union Directive.

This undertaking by the Company, its affiliates and subsidiaries do not release you of your obligation to act in line with the applicable legislation in your country.

Special provisions of this Privacy Policy remain reserved.

3.How do we use your Personal Data?

We may use your personal data and information for the following purposes in particular provided that such use is allowed by the applicable law.

i.To register you and to allow you to use our Services,

ii.To get sufficient efficiency and benefits from the Application

iii.To inform you by various methods such as sending you notices about the latest products and services offered by the Company via e-mail, SMS and other similar electronic communication methods, and displaying notices, ads and images through the Device and the Application,

iv.To improve our products, Services, contents and ads,

v.To offer you recommendations about our content, channels and other products,

vi.To keep records regarding software updates and other operations,

vii.To fulfil any and all governmental requests that are in line with the applicable law,

viii.To apply the Grundig TV Smart Remote Application Service Conditions and this Privacy Policy, including the investigation of potential violations,

ix.To identify, prevent or handle otherwise technical issues or fraudulent operations or security issues (including but not limited to filtering the undesired e-mails).

To the extent permitted by the applicable law, we may combine your personal data that we gather through our Services or web site or other channels with such information that you submit us by other means, and we can keep such information in a combined database or in separate databases.

The Company shall not keep your personal data and information for a period not longer that necessary. Unless we are forced to keep your personal information due to justified legal reasons and to the extent we do not have to keep them, we will immediately delete your personal data if you notify us that you no longer use our services. If the deletion of your personal data is only possible through an unreasonable amount of effort, we will anonymize your personal data instead of deleting them, and where even this is not possible, we will block them. We will not collect highly private personal data or any information that is not related to the purpose of collecting such information.

4.Marketing Activities

We can use your personal data for marketing purposes, mainly to offer you ads and promotional products and to update you about our new products, award drawings, contests with prize and other information that according to our opinion may appeal to your interest. Provided that at all times the said use shall be in line with the applicable law, this shall depend on your use of our services and applications.

In case you prefer to receive such ads, marketing or promotional products by means of e-mail and/or regular mail or other communication means, we will send messages to you. Based on your jurisdiction and in accordance with the applicable law therein, before sending you any marketing or promotional materials or any product or service introduction, we may ask you to give your express consent for the said use.

You may change your opinion about your preferences / options regarding direct marketing at anytime by using the “unsubscription” information in every such mail, updating your user profile or account details or contacting us. In case you act so, we will not delete your personal data from our database to the extent that we need such data under the provisions hereof or we keep providing you with our services.

5.Location Based Services

The Company may collect, use, store, transmit and share your appliance’s, smart phone’s or tablet’s location data in order to provide location based services about its products. These location data shall be collected anonymously to prevent the detection of your identity, and shall be used by the Company to offer and improve location based products and services. All of the said data and information shall be collected in line with the provisions of this Privacy Policy.

6.Application Use Data

The Application exchanges data with Amazon Echo and with the Appliance. The Appliance will get your full name and e-mail address during registration. In addition to this, the Application receives from your Appliance the Appliance number that you need to define to be able to use the Application together with the Appliance. The Appliance does not record or save your voice; Amazon Echo gets your voice record and with the help of the Application, it turns this record to a command. This command is sent to the Appliance with the help of the Application and a Success/Fail message about the command’s correct acquisition is send to the Application.

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

You may use several applications, software and services offered by various third parties, including, mainly, third party application portals during the Service provision or the use of the Application (the Company shall also be considered as a third party for services offered by the Company outside the Grundig TV Smart Remote Application Service Conditions or this Privacy Policy). Such applications, software and services may process your personal data. Said applications, software and services are subject to their own terms of use an privacy policies. Therefore the Company shall be under no responsibility for their operations.

8.Sharing Your Personal Data with Third Parties

In principle, we do not share your personal data nor shall we disclose them to third parties. Notwithstanding the foregoing, the Company may need to share or use your personal data in the following circumstances:

i.If it is necessary for providing the services,

ii.Where it is mandatory to comply with our legal processes,

iii.Where it is necessary to disclose your personal data and information to comply with a legal obligation or a resolution by a judicial, public or official authority, or where there is an obligation connection with the national security, enforcement of the law or any other material public issues,

iv.Where it is necessary to share personal data with third parties such as outsourced cloud computing providers pursuant to the outsourced services,

v.Where we are permitted to do so under the applicable law.

Disclosure or share of your personal data and information may include disclosure or share with Company affiliates, subsidiaries or third parties based outside the European Union ("EU") or the European Economic Area ("EEA"). If you are resident in an EU or EEA state, data protection laws outside the EU/ EEA may not provide the same level of protection as the ones in force in your own country. Notwithstanding the foregoing, before the transfer of personal data or information of a person based in an EU/ EEA member state, we will take measures to make sure that said data shall be subject to the same protection level offered by such data protection laws applicable in the EU/ EEA.

We will not give third parties your personal information and data for any purpose other than the ones set out in this Privacy Policy nor shall sell your personal information and data to third parties.

9.Security Measures for Personal Data

The Company shall take certain administrative, technical, organizational and physical measures to secure and protect your personal data and information against loss, theft, abuse or unauthorized access, disclosure, modification or destruction.

Even if we comply those obligatory and mandatory standards pursuant to applicable law, we do not guarantee that your personal data are safe when they are submitted by unsecure means or sent otherwise.

We ensure the protection of your personal data and information by means of encryption, password protection and by restricting the access to your personal data and information.

Even if we take such measures, you shall be liable at all times to keep and maintain your personal data and information safe and secure, to avoid using apparent or predictable user IDs or passwords, to change your passwords with regular intervals and moreover to make sure that you have not disclosed your password(s) or that you have not given consent to a third party to have access to your user account, personal data and information.

10.Links to External Content Sources

Our Services may contain some services and links that direct you to other web sites, services or external content sources beyond our control. We are not responsible for such directions as well as the protection and privacy of your personal data and information that you share at other web sites. We do not accept any liability or responsibility for such situations.

11.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 get a copy of the amended version via your e-mail, or any other appropriate means to keep you aware of the changes to this Privacy Policy.

12.Access to the Privacy Policy

If you wish to access the “Grundig TV Smart Remote Application Privacy Policy”, which you have accepted, you can view it on the Application. You can review the policy again on the Application.

13.Your Rights About Your Personal Data

You are entitled to the following rights about your Personal Data:

a)To query whether your personal data are processed,

b)If they are processed, to ask about information in that respect,

c)To query the purpose of processing your personal data and whether such data is used for the intended purpose,

d)To know about third parties to which your personal data are transferred within country or abroad,

e)To ask for the correction of your personal data in case it is not processed completely or correctly,

f)To demand, subject to conditions set out in the applicable law, the deletion or destruction of your personal data,

g)To demand that the operations performed under subparagraphs (e) and (f) be notified to third parties to which your personal data were transferred,

h)To object a result to your detriment as a result of the exclusive analysis of your processed data via automatic systems,

i)To ask for the indemnification of your losses in case you suffer a loss upon unlawfully processing of your personal data.

You can use the following contact details to exercise such rights [ARÇELİK A.Ş. – Elektronik İşletesi, Cumhuriyet Mahallesi E5 Yan Yol No:1 Beylikdüzü, 34520, İstanbul, Turkey] [ , smarttv@arcelik.com, www.arcelik.com.tr].

14.Contacting Us About Your Personal Information and Data

If you want to obtain more information about the Privacy and our commitment to this Privacy Policy please do not hesitate to contact us.