Privacy Policy
This Privacy Policy aims to inform the user (hereinafter referred to as the “User”) of the smart TV device (hereinafter referred to as the “Smart TV”) supplied by Vestel Elektronik San. Ve Tic. A.S. (hereinafter referred to as “Vestel”), whose registered office is in Istanbul province of Turkey, about
- the collection, processing and use of the personal data by Vestel, when the Smart TV is connected to the internet (please see Section 1) by the User,
- and the collection, processing and use of the personal data when certain optional additional offerings and additional services are used by the User. Each of the said additional offerings and additional services (hereinafter referred to as the “Additional Services”, please see Section 2) is subject to separate activation by the User.
The Smart TV will be connected to the internet after this Privacy Policy is accepted by the User, which will enable the User to have access to numerous additional services. In addition to the restricted processing of the personal data during the internet connection that is required to activate the internet based functions of the Smart TV (please see Section 1), the use of the Additional Services also require the collection and processing of other personal data of the User.
The Additional Services are provided based on the personal settings made by the User in the settings menu of the Smart TV, and within the context of this Privacy Policy. Necessary services for the definition and installation of any Additional Service can be obtained through the settings menu at any time. The User will be able to give or withdraw the activation approval for an Additional Service at any time by use of the Switch button.
Vestel, in case the Portal is utilized by the User, is entitled to modify this Privacy Policy at any time by sending a notification through the Vestel settings menu. Any modified version of the Privacy Policy will come into effect when it is notified through the settings menu and approved by the User.
If the User has any questions, complaints or comments regarding this privacy policy or its enforcement, the User may contact via this email: smarttvsecurity@vosshub.com
1. Internet Connection
When it is connected to the internet, the Smart TV will send the following personal data of the User to Vestel: MAC address, country, language, software and firmware versions, Bootloader version, the source and brand of the TV, and connection type (hereinafter referred to as the “Connection Data”). These data will be transferred to a server located in Ireland. Vestel will collect and store such data in order to ensure that the Smart TV operates properly.
2. Additional Services
Via the Smart TV, the User has the opportunity to have access to and use various Additional Services including the services accessible on the Smart TV Portal (hereinafter referred to as the “Portal”) operated by Vestel.
In order to ensure that the Additional Services are performed properly, Vestel, in case the Portal is used, may be required to collect certain additional personal data of the User. Any Additional Service can be used by the User only when prior approval is given by the User through the activation of the Switch button assigned to the related Additional Service (opt-in) (as seen in the Figure below). The Additional Services offered, and the types and scopes of the personal data collected are explained in more detail below. Such explanations can be reviewed at any time in the Privacy Policy that can be seen in the settings menu of the related service. The User will be able to give or withdraw the activation approval for an Additional Service at any time by use of the Switch button.
a) Access to HbbTV by use of the Red Button
If it is available in the activated program, the User will have access to the related HbbTV applications and use them by pressing the HbbTV control button (hereinafter referred to as the “Red Button”). HbbTV applications may have access to the information regarding the user agent of the web browser in order to define the Smart TV (in particular the type and version of the browser, manufacturer and software version) of the User. When the Red Button is pressed, the abovementioned data are transferred to the related HbbTV provider.
b) Use of the Portal and Applications
The Portal is operated by Vestel, which is responsible for the delivery and maintenance of all services regarding the Portal.
The User will be able to gain access to the Portal and use it only after the Portal Membership Agreement is signed / approved with Vestel. The said agreement is separately prepared in the page of the Portal.
During the use of the Portal, the following personal data of the User are collected by Vestel: MAC address, IP address, country, language, software and firmware versions, Bootloader version, and the source and brand of the TV.
The personal data collected during the use of the Portal may be used to have contact with the User, or to improve the users’ experiences regarding the use of the Portal (e.g. to upgrade the existing services or develop new services).
From time to time, Vestel may determine the IP addresses of the User and use it for determining and eliminating/solving the system-based problems of the Portal.
The Portal may include links to other websites or applications. The User is hereby informed and he or she accepts that he or she will be deemed to leave the Portal when such links are used. Vestel bears no responsibility regarding the privacy rules applied by such websites and applications, or their content. For this reason, the User is required to comply with the separate privacy policies applied by such third-party websites or applications.
Vestel will be entitled to anonymize the data of use and operation of the User and utilise the same for Vestel’s and its partners’ statistical surveys, performance evaluations, marketing campaigns, annual reports and other similar instruments. Vestel may also store/keep and process the said date and transfer them to its partners for a period necessary to reach the purposes specified here.
Provided that a separate permission is received from the User, from time to time, Vestel and its partners may directly use the information collected from the users via Portal surveys for marketing purposes.
All personal data collected by Vestel via the Portal will be stored and used by Vestel in order to perform the services related to the Portal.
The User will have access to the applications offered by Vestel or third persons either via the Portal or by pressing the button assigned to the related application on the remote control (if any). When necessary, the applications may have access to the information about the user agent of web browser for defining the User’s device. When approved by the User, Vestel will collect the following data through the applications offered by Vestel: browser type and version, manufacturer and software version.
As an example, certain applications such as Facebook and Twitter direct the users to the related websites. For the use of third-party applications, the privacy policy of the related third party applies.
Operators of websites and applications utilise the Google Analytics services provided by Google Inc. (hereinafter referred to as “Google”). Through the websites and applications, Google Analytics uses cookies that are text files dropped in the devices in order to help analysing the way the websites and applications are used by users. Information collected by way of cookies in relation to the use of a website or application are transferred to Google, and they are stored in the servers located in the United States of America by Google. Vestel does not have access to or control on the said cookies.
The User can receive more detailed information about Google Analytics at https://www.google.com/intl/de/policies/privacy/.
If IP anonymization is activated on a website or application, your IP will be kept secret in the area of the European Union member countries and other parties of the European Economic Area Agreement.
Google will use the abovementioned information in name of the website and application operators in order to evaluate the use of websites and applications, present reports to the said operators about website and application activities and offer other services related to the use of the internet and the effectiveness of websites and applications. The User is able to avoid the use of cookies (reject cookies) with the related setting in his or her browser. However, it should be noted that such setting may prevent full functionality of websites and applications. For more detailed information about the use of cookies, we would advise you to visit the related websites and applications.
c) Recommendation Engine (only for the users located in Turkey at the moment)
The Recommendation Engine will recommend certain broadcasts, programs, videos, etc. to the User, based on the evaluations made on the broadcasts and programs preferred and watched by the User. When the Smart TV is turned off, information about broadcasts, programs, videos, etc. similar to the preferred by the User are stored in the Smart TV via this function (hereinafter referred to as the “Recommendation Engine”).
For the performance of the recommendation service, Vestel will collect certain personal data regarding the types of broadcasts or programs watched by the User, timeframes in which such broadcasts or programs watched by the User, websites visited by the User and the time and duration of such visits, MAC address of the User and the applications used by the User and their duration of use (hereinafter referred to as the “Recommendation Data”).
For the performance of the recommendation service, Vestel will collect and store the Recommendation Data and use the same in the servers located in Ireland.
3. Use of Cookies
Vestel will use cookies in order to ensure that Smart TV services are properly performed, and the user experience is improved. Cookies are small text files stored in the web browser of Smart TV of the User.
In relation to the delivery/offering of Smart TV services, Vestel will use persistent cookies for defining the User in his or her next visit. This type of cookies generally continues to exist in the system even after the browser is closed by the User, which means that they remain stored during the period defined by the cookie, or until being manually deleted by the user.
Vestel will collect and process the following personal data of the User:
- The point which the User left the portal in his or her last visit. In this way, the User can resume his or her next visit from the point he or she left in the previous visit.
- The approval (if any) given by the User for the membership agreement. In this way, Vestel will determine whether the User will be provided with the right to have access to the Portal services and allowed to use the same.
- Location and firmware of the Smart TV. In this way, Vestel will determine the applications that can be offered for the Smart TV of the User.
- The device used by the User (TV or another device). Portal services are displayed when a Smart TV is used by the User.
- Approval, user’s name and password of the User for having access to the User’s Twitter account. In this way, the User will not have to enter his or her user’s name and password every time the Smart TV connects to the Twitter account.
The User will be able to manage the use of cookies and select the “show cookies” or “delete cookies” functions in the settings menu.
When the User decides that he or she no more wants the cookies, he or she can deactivate the related Switch button in the settings menu at any time.
4. Automatic Software Updates
Vestel regularly offers automatic software updates for the Smart TV. Such updates are developed and performed only for improving the level of quality of the Portal and Smart TV and eliminating or preventing failures. In the case of quality improvements, the update software will be automatically downloaded in the Smart TV. Afterwards, a message is displayed to the User in order to receive his or her approval (“Yes” or “No”) for the installation of the software. Before every update, the latest software modifications are presented to the User in an updating file.
In case the automatic software update is not approved by the User, a warning message regarding the risks associated with missing software updates is displayed. The User is recommended to re-evaluate the matter and start updating via the settings menu.