This Privacy Notice is effective as of March 1, 2023.

This Privacy Notice sets out how KingTop(collectively “KingTop” or “we”) protect the personal data we process relating to you (your “Personal Data”), what types of Personal Data we collect about you, what we do with it, how we disclose it and which rights you have in relation to the processing of Personal Data.

Thank you for choosing KingTop!

WHEN DOES THIS PRIVACY NOTICE APPLY?

This Privacy Notice applies when we process your Personal Data as a result of your access and use of KingTop website (www.kingtoptec.com), KingTop smart 5G products, and other KingTop devices, websites or applications that may refer to this Privacy Notice (collectively “KingTop Materials”).

Please refer to [KingTop Privacy Policy] for more specific information about how we process your Personal Data when you access KingTop tablets, pos, worn camera, mobile hotspots, handheld computer and other applications or services provided by KingTop.

This Privacy Notice also applies to our processing of the Personal Data of business contacts within our clients, business partners, supplier and other organizations with which KingTop has or considers a business relationship.

To find out more, please click on any of the sections below:

·PERSONAL DATA WE COLLECT ABOUT YOU

·USES OF YOUR PERSONAL DATA

·DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

·THIRD PARTY LINKS

·INTERNATIONAL TRANSFER OF PERSONAL DATA

·SECURITY OF YOUR PERSONAL DATA

·RETENTION OF YOUR PERSONAL DATA

·YOUR RIGHTS

·PRODUCT SPECIFIC TERMS

·USE OF COOKIES

·CONTACTING US

We may update this Privacy Notice to reflect changes in how we collect and use your Personal Data or changes in applicable laws on a regular basis. Any update to this Privacy Notice will be effective upon its posting on our website at https://www.kingtoptec.com/. In addition, we may also notify you to inform you about the changes to this Privacy Notice as required by applicable laws.

BY VISITING OUR WEBSITES, PROVIDING YOUR INFORMATION OR USING KingTop MATERIALS, YOU CONFIRM THAT YOU HAVE READ AND UNDERSTOOD THE PRACTICES DESCRIBED IN THIS PRIVACY NOTICE.

PERSONAL DATA WE COLLECT ABOUT YOU

Your privacy is important to us so we explain here what Personal Data we collect about you. Please note that, if you do not provide certain Personal Data, KingTop may not be able to accomplish some purposes outlined in this Privacy Notice and you may not be able to use or access certain KingTop Materials.

We may collect and process the following Personal Data about you:

·   Information that you provide to us. This includes information about you that you give us by filling in forms, entering information in our website, creating user accounts or by communicating with us, whether face-to-face, by phone, online, by email or otherwise, which are capable of identifying you or to make you identifiable depending on the context. This information includes, without limitation, the following:

· Personal contact information: your name, shipping, billing address, email address, phone number;

· To comply with our legal obligations required under applicable laws, we may also collect your tax payer number (CPF);

· Log in information: username, password, nickname;

· Demographic information: date of birth, gender;

· Payment information: your debit or credit card details, bank details or other payment and financial information;

· Other information about you such as your occupation (e.g. when you participate in our survey), language, health and exercise data; and

· Information about KingTop Materials that you own and use, and proof that you purchased them, when applicable.

·   Information we collect or generate about you. We collect Internet, electronic activity, and other information automatically from the devices and browsers that you use. This includes, without limitation, the following:

o Details about your usage of the KingTop Materials;

o Location of your device and time zone;

o Details about your usage of the products that we supply to you such as browsing history, search history, page clicks and your activities when using our products or services (e.g. we may collect the app using time when you use KingTop Channel);

o The IP address, MAC address, Device-ID, Terminal ID, serial number, IMEI number, IMSI number, advertising ID (a unique user ID assigned to your devices for advertising purposes), and any other device identifiers or device-specific information about your KingTop Materials; geolocation information provided by your device's GPS signal or communicated through a nearby Wi-Fi access points and cell towers while you use certain services and enable the location feature ;

o Error logs, error codes and error descriptions and other information that you provide relating to faults or defect experience with any of your KingTop Materials; and

o Where we provide after-sales services to you, your emails, phone number, address, fax number, chat history or recordings of phone conversations between you and our support staff.

·   Information we obtain from other sources. We may collect information about you from third parties. This includes, without limitation, the following:

o Information from social media networks;

o Information obtained from other providers of products, services, websites and applications;

o Other commercially or publicly available sources (as allowed under the law); and

o If you take part in market research programs organized and/or sponsored by/on behalf of KingTop we may also collect information from third party websites or social media networks, in accordance with the privacy policies of those respective websites and social media networks.

We may also collect other information about you, your device or the use of KingTop Materials in the manner informed at the time of collection and/or with your consent in accordance with applicable laws.

We will not knowingly collect any Personal Data from or about children under age 13, or minimum age allowed in your jurisdiction, without making it clear that such information should only be provided with a parent's or guardian's consent, if this is required by applicable laws. If you believe that your child has provided us with his/her Personal Data without a parent's or guardian's consent, please contact us via the email address provided in the Contacting Us section below. KingTop will only use Personal Data relating to or from the children as far as it is permitted by applicable laws and if required, only with parent's or guardian's consent. If your child uses our Kids Learning or Kids Mode services, or other KingTop products or services for child, we will provide you a separate privacy notice with more details on how we protect children's Personal Data.

USES OF PERSONAL DATA

Your Personal Data may be collected, stored, processed or otherwise used by us in the following ways and for the following purposes:

· To deliver, activate, verify and manage our products and services purchased by you;

· To provide software updates, maintenance services, technical support and after-sales services for KingTop Materials;

· To help you register and manage your KingTop account;

· To allow you to download and purchase our products and services such as our applications and related websites and/or to give you access to third-party applications installed on the device;

· To process payments transactions or orders for KingTop Materials;

· To contact you in relation to KingTop Materials, for example, in the event that any KingTop Materials have changed or present issues;

· To establish, exercise or defend its legal rights or for the purpose of legal proceedings;

· To protect against and prevent fraud and information security risks, as well as to keep KingTop Materials secure, such as verifying your accounts and identification, detecting security incidents and combating malicious activities;

· To respond to any complaints or questions that you may raise in connection with KingTop Materials, and to defend and exercise our legal rights;

· To personalise KingTop Materials at your request;

· To troubleshoot functionality or other issues for the KingTop Materials;

· To evaluate and develop new functionalities, technologies and improvements on KingTop Materials;

· To administer contests, promotions, events, market research, survey in relation to KingTop Materials;

· To facilitate KingTop ’s internal purposes such as auditing, data analysis, and research to improve our products, services, user experience and customer communications;

· To comply with all applicable laws, regulations, directives and court decisions as well as decisions from competent authorities;

· To send you information about KingTop Materials and help to make that information more relevant to you. We may need your consent for certain marketing activities. We offer you various ways to opt-out of receiving certain communications from us. If you would like to opt out of receiving email marketing communications from us you may click the "Unsubscribe" link found at the bottom of the email and follow the instructions;

· To display personalized advertising of our products and services on KingTop website and display non-personalized advertising on other KingTop Materials. Our advertising partners may also display non-personalized advertising on some of our products or services. If they will display personalized advertising, we will obtain your explicit prior consent as required by applicable laws; and

· Other purposes with your consent.

To the extent the Personal Data we collect about you is considered special categories of Personal Data or sensitive Personal Data under applicable laws, we process such data based on your explicit consent, and you may withdraw your consent to such processing at any time. However, you should be aware that if you choose to do so we may be unable to continue to provide certain services to you. If you choose to withdraw your consent, we will tell you more about the possible consequences. If permitted by applicable laws, we may also process special categories of Personal Data that you expressly made public or to establish, exercise or defend legal claims.

  

If you act as a business contact of your organization to purchase or use KingTop Materials on behalf of your organization, we may collect your name, shipping, billing and/or business address, email address, phone number, and use your Personal Data to the extent necessary to carry out ordinary business operations, for associated administrative purposes or for other purposes specified above in the Section "Uses of Personal Data".

DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We do not sell or otherwise disclose Personal Data you have provided to us, except as described in this Privacy Notice, as disclosed to you at the time of the data collection or as described in any specific privacy notice, as applicable.

We may disclose your Personal Data with KingTop 's affiliates in one or more of the circumstances described below: 

· To help us provide you with KingTop Materials;

· Where we market products and services provided by KingTop 's affiliates; and

· For one of those purposes for which KingTop processes your Personal Data under this Privacy Notice.

We may also share your Personal Data with third-parties in order to achieve the purposes mentioned in the Section "Use of Personal Data" above, including:

· In case of sale of any KingTop 's business or assets with another company, merger, or other significant transactions, we may disclose your Personal Data for due diligence purposes and on completion of the transaction;

· We may share your advertising ID (a unique user ID assigned to your devices for advertising purposes) with our advertising partners for them to display non-personalized advertising;

· If we market third-party products or services to you, we may share your Personal Data with those third parties;

· When you provide your consent to disclose your Personal Data to specific and identified third party or category of third parties;

· To third-party agents or contractors (for example, the providers of our electronic data storage services) that we hire to support us in providing our services and products to you. We will take steps to require such third-parties to process your Personal Data in compliance with the provisions set out in this Privacy Notice and under a confidentiality duty;

· To business partners who provide products and / or services that are embedded or serve as a component of KingTop Materials that we provide to you. These third parties will be responsible for how they use your Personal Data in connection with their services and products as described in a separate privacy notice provided by them, which you are encouraged to verify; and

· To the extent required by law, or if we are under a duty to disclose your Personal Data in order to comply with any legal obligation, establish, exercise or defend our legal rights and/or of third parties.

Besides the disclosures of Personal Data informed in this Privacy Notice we may share your Personal Data with third parties whenever you authorize the sharing.

Please note that if you access third-party services — such as social media services, third-party single-sign on tools, third-party applications, mobile platforms, and telecom carriers of your devices — through our services, these third-party services may be able to collect information about you, including information about your activity on the products and services, and they may notify your connections on the third-party services about your use of the product and services, in accordance with their own privacy policies.

THIRD PARTY LINKS

Our website may contain links to third-party sites. We are not responsible for the privacy practices or content of such other sites and this Privacy Notice does not apply to them. You must carefully read the privacy policies related to services of third parties, contacting directly those parties in case of need.

INTERNATIONAL TRANSFER OF PERSONAL DATA

When you use KingTop Material, we may transfer, storage and process your information within and outside of your country of residence, consistent with this Privacy Notice. The processing of your Personal Data may, therefore, be also subject to laws other than the ones from your country.

KingTop takes appropriate steps to ensure that transfer of Personal Data shall be done in accordance with applicable privacy laws and, in particular, that contractual, technical and organizational measures will be in place, such as, with no limitation, the Standard Contractual Clauses approved by the European Commission. 

SECURITY OF YOUR PERSONAL DATA

We have adopted organizational, physical and technical security measures that are in line with the industry standards to protect the Personal Data you provide, and to prevent any unauthorised access, disclosure, use, modification, damage or loss of data. We will take reasonable and practical steps to protect your Personal Data, including the following:

· We will use SSL and other technical measures to ensure encryption with regards to our services and products. We will regularly examine our practice of information collection, storage, and processing (including physical security measures) to prevent unauthorised system access.

· We will authorize our employees and personnel of third parties to access your personal data on a need-to-know basis in order to help us process your Personal Data and provide the services to you. These employees and external personnel (of third parties authorised by us) are subject to contractual confidentiality obligations.

· The security of your Personal Data is extremely important to us. We will continue our efforts to protect your Personal Data and implement safeguard measures, such as providing encryption protection for information storage and transmission, to prevent your Personal Data from unauthorized access, usage or disclosure.

· We will prudently select business partners and service providers, and implement the requirements for Personal Data protection to the business contracts between both parties.

· We will conduct security and privacy protection training courses, testing and publicity activities to enhance employees' awareness of the importance of protecting Personal Data.

Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. If we become aware of any violation of our security system, we will act in a timely fashion in accordance with any applicable laws.

RETENTION OF PERSONAL DATA

KingTop retains your Personal Data only for as long as needed for the purposes described in this Privacy Policy, and it will be deleted after a reasonable time according to the following criteria:

· KingTop retains your Personal Data as long as it needs it for the purposes mentioned in the Section "Use of Personal Data", which may coincide with the period for which KingTop has an ongoing relationship with you; and

· KingTop retains your Personal Data as long as it needs to comply with a legal obligation to which it is subject or defend claims brought against us.

YOUR RIGHTS

Data protection laws may give you a number of legal rights in relation to the Personal Data that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places. You may refer to the Annexes of this Privacy Notice for more details about your rights in certain specific jurisdictions.

However, we recognise that your Personal Data belongs to you only and that enables you to control how we use it. Your rights may include:

· The right to request access to the Personal Data that we process about you, including the right to obtain information on and copy of such data;

· The right to request that we rectify or correct your Personal Data if it is inaccurate or incomplete;

· The right to request that we erase or delete your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase or delete your Personal Data, but we are legally entitled to retain it;

· If permitted by applicable laws, the right to lodge a complaint with the competent government agency if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the "Contacting Us" section below.

We may need to confirm your verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

USE OF COOKIES

We and our third-party advertising and data analytics partners use "cookies" and similar web technologies including pixel tags or web beacons, ("automated collection tools") to support certain features of the KingTop account, smart TV and other websites and applications operated by us. Automated collection tools are pieces of code deployed on your device. The automated collection tools allow the website to recognize your browser or device during your visit to the KingTop website/application or when you return to the KingTop website/application. For further details about the cookies we use, please see our Cookies Policy, which can be found here: https://www.kingtoptec.com/privacy-policy.

We use two types of automated collection tools: "session cookies" and "persistent cookies".

A session cookie expires after you close your browser. A session cookie will identify you during your browsing session by assigning a randomly generated unique identification number to your device. We use session cookies:

· To enable us to provide products and services to you and manage transactions. For example, we may deploy a cookie to remember what items you have stored in an online shopping basket; and

· For certain content management and editing purposes.

Persistent cookies do not expire when you close your browser. We use persistent cookies:

· To record whether a visitor is logged in to the KingTop account;

· To record when a visitor to the KingTop account or other KingTop website / application gives consent to our use of cookies, when applicable;

· For performance and design purposes. For example, we might use cookies to track which parts of our websites or applications are popular and to figure out how to improve their functionality;

· To improve user experience and personalize what you see. For example, we might use cookies to record user preferences and to ensure that more relevant website / application content (including advertising content) is delivered to users;

· To enable us and third-party partners that we work with to deliver advertisements or tailor marketing messages that you have consented to receive. For example we may use cookies to record what products and services you buy or show interest in and use third party services to enable relevant advertisements to be shown on our and other websites / applications based on that information; and

· For certain content management and editing purposes.

How to Manage Automated Collection Tools

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your device. You may also delete cookies as soon as you leave the KingTop account or other KingTop website / application. Although you are not required to accept cookies when you visit the KingTop account, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of the KingTop account or other KingTop website/application.

For example, the Help portion of the toolbar on most web browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new automated collection tools, and how to entirely disable automated collection tools. With regards to some of the popular browsers you can find more information by clicking on the following relevant links:Google Chrome; Microsoft Edge; Mozilla Firefox; Microsoft Internet Explorer; Opera and Apple Safari.

Where required by applicable laws, we will present you with a cookie banner the first time you visit our website/application that explains what type of automated collection tools we use and which asks your consent for some of the automated collection tools we use.

Personal Data Collected through Automated Collection Tools

We use the Personal Data collected through automated collection tools for the purposes specified above (including in the Section “Uses of Personal Data”). For those cookies where we ask for your consent to deploy them, we also rely on consent as the legal basis for processing Personal Data collected through those cookies.

At this time, our website does not recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

CONTACTING US

If you would like further information on the collection, use, disclosure, transfer or processing of your Personal Data or the exercise of any of the rights listed above, please contact us through the specific channels indicated below.

For users in China and other regions of the world, the data controller is Shenzhen Jintaiyi Electronic Co., Ltd. , with its address at 12-A, Building E4, KingTop International E-City, Zhongshanyuan Rd, Nanshan, Shenzhen, Guangdong Province, China.

Legal Bases for Processing Personal Data

The processing of Personal Data may be conducted in accordance with one of the following main legal bases:
(i) compliance with a legal or regulatory obligation of KingTop ;
(ii) contract necessity;
(iii) exercise of legal rights in judicial, administrative or arbitration proceedings;
(iv) protection of life and health;
(v) legitimate interest of KingTop or third parties;
(vi) credit protection.

Undertaking

When you visit our sites, provide your Personal Data or use KingTop Materials, you declare your knowledge as to the collection, use, transmission, transfer, classification, access, storage, modification, communication, disclosure, elimination or any other processing activity in relation to your Personal Data as described in the Privacy Notice.

Confidentiality of Personal Data and your Responsibilities

KingTop applies it best efforts to protect your Personal Data. You are responsible for all the activities under your login and password related to KingTop Materials. If, by any chance, you believe that your account information is unauthorized known, please contact us as described in the “Contacting us” section.

Your Rights

The applicable rules and legislation grants you the following rights:
(i) right to confirm the existence of processing activities related to your Personal Data;
(ii) right of access;
(iii) right to correct incorrect, incomplete or outdated Personal Data;
(iv) right of anonymization, blockage or exclusion of unnecessary or excessive Personal Data, or of Personal Data processed in violation of the applicable legislation;
(v) right of portability;
(vi) right to exclude Personal Data which is no longer necessary for the purposes for which collected, but for cases in which retention of the Personal Data is necessary and allowed under the law;
(vii) right to obtain information on the private and public entities to whom your Personal Data was shared;
(viii) information on the consequences of refusing consent;
(ix) right to withdraw consent;

Automated decision and Profiling

Automated decision are decisions based on the use of algorithms and computer programs without human intervention.

On the other hand, profiling involves analyses of certain personal aspects, such as your interests, preferences, behaviour, location, through an automated processing of Personal Data with statistical processes. As result of this processing, we may send you targeted communication, present more relevant information on our platforms that we believe might be of your interest.

You have the right to request the review of a decision carried out in an automated processing of information.

Controller

The data controller is Shenzhen Jintaiyi Electronic Co., Ltd. , with its address at 12-A, Building E4, KingTop International E-City, Zhongshanyuan Rd, Nanshan, Shenzhen, Guangdong Province, China, unless otherwise informed in a specific privacy statement.

To contact KingTop 's headquarters, please send an email to info@kingtoptec.com or by calling our hot-line at +86 158-1736-7432

Use of Personal Data

Your Personal Data may be collected, stored, processed or otherwise used by us in the following ways and for the following purposes and legal basis:

1. To perform a contract with you and to provide you with KingTop Materials;

· To deliver, activate, verify and manage our products and services purchased by you;

· To provide software updates, maintenance services, technical support and after-sale services for KingTop Materials;

· To help you register and manage your KingTop account;

· To allow you to download and purchase our products and services such as our applications and related websites and/or to give you access to third-party applications installed on the device;

· To process payments transactions or orders for KingTop Materials;

· To contact you in relation to KingTop Materials, for example, in the event that any KingTop Materials have changed or present issues;

2. To comply with a legal obligation to which we are subject;

· To comply with all applicable laws, regulations, directives and court decisions as well as decisions from competent authorities;

· To protect against and prevent fraud and information security risks, as well as to keep KingTop Materials secure, such as verifying your accounts and identification, detecting security incidents and combating malicious activities;

3. KingTop has legitimate interest in collecting and processing your Personal Data;

· To establish, exercise or defend its legal rights or for the purpose of legal proceedings;

· To respond to any complaints or questions that you may raise in connection with KingTop Materials, and to defend and exercise legal rights;

· To personalise KingTop Materials at your request;

· To troubleshoot functionality or other issues for the KingTop Materials;

· To evaluate and develop new functionalities, technologies, and improvements on KingTop Materials;

· To administer contests, promotions, events, market research, survey in relation to KingTop Materials;

· To facilitate KingTop 's internal purposes such as auditing, data analysis, and research to improve our products, services, user experience and customer communications;

· To develop our training processes and systems;

· To conduct business planning, reports and establish predictions;

· To comply with contractual obligations owed to third parties;

· To send you information about KingTop Materials and help to make that information more relevant to you. We may need your consent for certain marketing activities. We offer you various ways to opt-out of receiving certain communications from us. If you would like to opt out of receiving email marketing communications from us you may click the "Unsubscribe" link found at the bottom of the email and follow the instructions; and

· To display non-personalized advertising.

4. Other purposes with your informed consent.

KingTop may use your Personal Data for purposes compatible with purposes mentioned above. When assessing whether a purpose is compatible, we will take into account the criteria set out in applicable laws, including your reasonable expectations. In other words, Personal Data may be used for non-conflicting and/or excessive secondary purposes in relation to the purposes mentioned above.

Minors

If you are between 13 and 16 years old, you live in the EEA or UK, and we ask for your consent, make sure that under your country's data protection laws you are able to provide valid consent without authorization of your parents or guardian. We will verify your age and may ask for parental/guardian consent.

Transfer of Personal Data

When we transfer your Personal Data outside the EEA or UK, we will ensure that it is protected in a manner that is consistent with how your Personal Data will be protected by us in the EEA or UK and an adequate level of protection will be ensured, through one of the following mechanisms:

· As applicable, KingTop may also share the data in accordance with derogations for specific situations set out under applicable laws, such as to provide services requested by you, to conclude or perform a contract in your interest, with your explicit consent, as necessary for important reasons of public interest, and if necessary to establish, exercise or defend legal claims. 

You may request additional details about how your Personal Data is protected by us in case of transfer outside an EEA country or UK (including a copy of the Standard contractual clauses entered into with importers in the third country) by contacting us as described in the "Contacting us" section.