Tspot Privacy Policy

Last Update of this Version: April 8, 2022

Effective Date of this Version: April 8, 2022

Tecno Mobile Limited (hereinafter referred to as "Tspot", "we" or "our"), as the provider and operator of Tspot's application software and services, fully respects your right to privacy and will do our utmost to safeguard your personal information security. While furnishing you with products or services (collectively referred to as "these services"), we may collect and apply your personal information with your consent or in accordance with the relevant provisions of applicable laws and regulations. This Privacy Policy (hereinafter referred to as the "Policy") is intended to make clear how we collect, use, disclose, treat and protect the personal information you furnish while enjoying Tspot's products or services, your rights to these personal information as well as how we safeguard your rights. This Policy shall apply to all products and services furnished by Tspot, covering computers, applications of mobile intelligent terminals, applets, web pages, software development kits (SDK) and application programming interfaces (APIs) for third-party websites and applications, or other forms that may appear in the future.

It shall be specially explained that this Policy does not apply to services furnished to you by other third parties. You may receive content or network links furnished by third parties. Please be discreet when choosing whether to access the links, contents, products and services provided by third parties. Please carefully read the privacy protection policies of third parties before submitting personal information to third parties.

To guarantee that you fully comprehend this Privacy Policy and make your own choice, we will do our utmost to explain it to you in clear and understandable terms, clearly mark or highlight the key reading contents (particularly in bold, capitalized and underlined forms, etc.), give you a pop-up prompt when you use our services for the first time, and guide you to focus on the core contents of this Privacy Policy.

Please read this Policy carefully before using our products or services, submitting personal information to us, or giving consent to us collecting your personal information, so as to understand our practices on your personal information. And please make frequent visits for updates to this Policy. If this Privacy Policy is updated, we will post notices on relevant products or websites to keep you informed of our updates. Where you access or enjoy our services after we issue such notice, it shall be considered that you consent to the updated Privacy Policy. You may check the "Update Date" at the top of the Privacy Policy to confirm the latest time of updating the Privacy Policy.

Where you have any doubt, please feel free to contact us by the following means:

Privacy@tecno.com

Or you may contact us by using the FEEDBACK function within these services.

You may also access this Privacy Policy by the following means:

Tspot APP > Me > Settings > About > Privacy Policy

This Privacy Policy will familiarize you with the following:

I. How We Collect and Use Your Personal Information

II. How We Use Cookies and Similar Technologies

III. How We Store and Protect Your Personal information

IV. How We Share, Transfer and Disclose Your Personal Information

V. How Your Personal Information Is Transferred across Borders

VI. Your Rights to Your Personal information

VII. How We Process Personal Information of Children

VIII. Third Party Service Providers and Their Services

IX. Supplementations and Updates to this Policy

X. How to contact us

I. How We Collect and Use Your Personal Information

(I) General Description

Tspot is firmly convinced that the basic right to privacy shall not vary as you live around the world. Thus, we hold that no matter where a natural person lives, Tspot will treat any information about the natural person that has been identified or identifiable, particularly the name, identity information, location data, online identifier or data specific to the physical, physiological, genetic, psychological or associated with the natural person as "personal information".

We will merely collect information required for specific, concrete, explicit and legitimate purposes, and shall warrant that your information will not be further treated in a way contradicting such purposes. If we intend to use your personal information for other purposes that are not described in this Privacy Policy, we will seek your consent again.

We will collect your personal information in the following three ways, covering 1) the information you directly furnish to us (such as the nickname, head portrait, name, telephone number you voluntarily furnish to us when you log in to your account or take part in marketing activities held by us); 2) the information that we collect through automated means during your use of this software (e.g., equipment information, service log information); 3) the information we get from other sources.

You shall be entitled to choose whether to furnish personal information when using Tspot's products or services or at the request of us. You do not have to provide Tspot with personal information, but in some cases, Tspot may become unable to provide you with relevant products or services, or respond to or address your issues if you decide not to provide your personal information. We will collect and use your personal information merely for the purposes stated in this Policy. The following examples are used to your personal information that we collect:

(II) Tspot's primary business functions and scenarios of collection and usage

The primary business function of this software is to furnish you with such services as browsing online contents, publishing contents and recommending personalized contents.

1.Furnishing you with the services of account registration and login.

This software account service function is provided by Palm ID, which will provide you with a consistent user experience and secure authentication. You can log in and use the same Palm ID account for different businesses.

When you register and log in to this software, we will create a Palm ID account for you, and access, collect and bind the personal information collected after your expressly authorized consent via indirect access to associate the relevant account to our products or services. Palm ID authorizes us to obtain your account ID, region/country, and the personal information we ultimately obtain will be based on what Palm ID authorizes. You can better understand how Palm ID collects your information by going to the "My" page and accessing the Palm ID Privacy Policy on the Palm ID page. Please be assured that we will provide appropriate security measures to protect your personal information in accordance with legal requirements and proven industry security standards.

Where you refuse to furnish such information, you will not be able to register an account and make use of related functions, but your normal use of other functions of Tspot will not be influenced as a result. You may still browse and apply the basic business functions of this software in the visitor mode (i. e. without having to become a registered user).

While using this software, you may choose to furnish, fill out and revise your nick name (covering real name), head portrait (covering real portrait), location, email address, date of birth as well as personality signature. However, your experience of registration and login will not be influenced as a result of your refusal to furnish supplementary information. When you set your head portrait, we will get the permissions of camera, file and media of your device. Where you refuse to grant such permissions, we will not be able to revise the head portrait. After you have granted such permissions, you can go to "Phone Settings -> Application Management -> Permissions Management -> Tspot” to stop your grant at any time.

Where you successfully create a Tspot account, we will publicize and present the nick name, head portrait, region as well as your personality signature of your account in Tspot services.

2.Content browsing, likes, bookmarks, comments, personalized recommendation services

Subject to the restrictions imposed in different countries/regions, some services of Tspot may vary. When you log in to these services, we will acquire your country information in a bid to furnish you with appropriate contents.

You may search for contents you may be fond of via these services, and we will store the keywords of your search so that you may view the records of your historical search at any time.

You may bookmark, like, follow the content or author of your favorite, and we will store your collection list and like records, in a bid to help you view your favorite content and users in your account with ease.

When you make use of the comment function, we will store your comment information in the server, which is essential for you to make comments. In the meanwhile, your nick name, head portrait and comments will be publicly presented in our services.

When you browse the contents for the first time, you may, on your initiative, choose the tags that may be of interest to you. We will recommend the contents (graphics or audios/videos) that may be of interest to you in consideration of your selected tags, browsing history, click history, like history and comment content. You may stop our personalized recommendation services by submitting your request via the FEEDBACK function within these services at any time.

3.Content publishing services

You may publish text, pictures, videos and topic contents via Tspot. When you make use of this function, we will upload your pictures or video content by calling the permissions of your camera, files and media. We will store your contents for presentation in Tspot. When publishing content, you may locate your area and publish your location tags, and then we will get your fuzzy location information by calling the permissions of your fuzzy location. If you refuse to grant relevant permission, we will be unable to provide corresponding services to you. You can go to "Phone Settings -> Application Management -> Permissions Management -> Tspot” to stop your grant at any time.

4.Taking part in the in-station activities.

We will launch Tspot’s marketing activities on an irregular basis. When you take part in our activity, we will count the participants in the activities by collecting your click records, browsing records, and GAID identification codes of your device. When you receive a prize or reward via the activity, we may request you to furnish other personal information to grant related rewards to you. For instance, we need you to further furnish your name, contact information, and full address to grant operational prizes to you.

5.Receiving feedback from your users.

When you make use of the function of user feedback, we need to collect your user name as well as your feedback, so as to learn about your opinions and give prompt feedback to our treatment plan. Where you refuse to furnish such information, we may not be able to render these services to you, but your use of other functions of this software will not be influenced as a result.

6.Rendering message push services to you.

We may also push service notifications, activities, winning prizes as well as other messages to you based on your device identifier, the version of operating system, user nickname of current device, network information as well as the information about your use of this app. To unsubscribe from notifications, activities, winning prizes as well as other messages, you may withdraw your consent through Settings > Notification Center > Notification Management. The closing path may vary from version to version.

7.Enhancing our products or services as well as commercial services.

We may collect your system information as well (including ROM version number, Android version number, time zone, system language), network information (network type, mobile operator code), application information (name of application package, account type, user ID), brand and model of mobile phone, browsing records, click records. The above-mentioned data will be used to study and count product usage and help us improve the design and functions of products.

With a view to enhance the security of your use of our services, protect the personal and property safety of you, other users or the public from infringement, prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions as well as other security risks in a better way, and more accurately identify violations of laws and regulations or our relevant agreement rules, we may comprehensively help you receive security risk detection, prevent security risk incidents, and take essential recording, auditing, analysis, and disposal measures in accordance with the law by using or integrating your device information, as well as information about your installed application, running process, overall operation of the application, frequency of using the application, crash data, overall installation and usage, performance data, and sources of the application.

After collecting your personal information, we may study and treat the data prior to commercial use. We may furnish you with personalized business marketing services by use of your fuzzy geographical location information and your GAID, and may share your data after our analysis and treatment with our related parties and third parties mentioned in Section IV. In this case, we will de-mark the data to form a user database strictly in line with the general technical standards of relevant countries, and mine, study and commercialize the user database in compliance with the personal information protection policy without infringing upon your personal privacy.

(III) Other situations where your information may be collected.

As permitted by some laws, we may acquire your personal information from other individuals, commercial entities, public channels or other third parties as instructed by you, other partners as well as other legal channels that furnish our products or services and help us guarantee information security and prevent fraud. We will give an explanation to you at the time of collection and get your consent.

Besides, we may collect other information about you, your device or your use of the services by other means, which will be explained to you to acquire your consent at the time of collection.

With a view to enhance our product layout so as to furnish you with better services, we may launch research, statistical analysis and prediction on the collected information in an anonymous way (such as conducting machine learning or model algorithm training with reference to anonymous data). We will treat the collected personal information by taking technical measures as well as other essential measures, so that the data can neither be re-identified to a specific individual nor recovered. In accordance with applicable laws and regulations, we do not have to inform you and get your consent for the use of such processed data.

II. How We Use Cookies and Similar Technologies

1. What Is Cookies and Similar Technologies

In view of the iterative update of our product functions, to guarantee the normal operation of this software and provide a more relaxed access experience for you, recommend interesting contents or advertisements to you, and the like, we may store small data files named Cookies on your mobile devices in existing or future products and services. The text in Cookies often consists of identifiers, site names, and some numbers and characters. Cookies as well as other similar technologies may be used for our website, online services, interactive applications, e-mail as well as other information services, such as pixel tags and website beacons. As the information collected on the strength of Cookies as well as similar technologies does not contain any personally identifiable information about you, in general cases, we will treat it as non-personal information. However, if the addresses of Internet Protocol (IP) or similar identification marks is treated as personal information in accordance with the laws of relevant countries, we will follow the laws and regulations of relevant countries as well.

2. Why we use Cookies and similar technologies

We as well as our partners will get a better understanding of the usage of mobile software on your device, know how often you make use of the application, the events that happen in the application, the cumulative usage, performance data and where to download the application, and analyze trends, manage websites, track users' behaviors on websites, and collect information on the overall audience characteristics of our user groups on the strength of Cookies as well as similar technologies; For instance, we may present advertisements on our website or manage our advertisements on other websites in collaboration with a third party. Our third-party partners may furnish you with advertisements based on your browsing history and interests on the strength of Cookies as well as technologies of the like;

We will not use such Cookies for any purpose other than those described in the Privacy Policy. You can manage or delete such Cookies according to your preference. You may clear all Cookies stored on your mobile device via the path furnished in the "Settings" option in this software. Alternatively, you may choose not to be tracked, quit advertisements premised on interest preferences or perform other operations by means of deleting Cookies and restoring (clearing) the settings (contents and data) of your mobile terminal, etc.

III. How We Store and Protect Your Personal information

1. How We Store Your Personal Information

We will store the personal information collected with your consent in accordance with the laws and regulations of relevant countries on the protection of personal privacy data. Where not prohibited by local laws and regulations, we may also store the collected personal information in a country or region other than the country where we do business.

Currently, Tspot may store your personal information in India and Ireland. Specifically:

The personal information we collect and generate in our Indian operations will be stored in servers seated in India.

The personal information we collect and generate in our business outside India will be stored in servers in Ireland.

In consideration of the subsequent business, we may introduce servers from other regions or countries, and update this policy at that time as well.

No matter whether the personal information is stored in the country where the business is located or in other countries or regions without violating the laws and regulations, we will keep it in accordance with the relevant laws and regulations on data storage. In the meanwhile, we will implement the essential security measures while taking into account the characteristics, scope, purpose, possible risks in the treatment of personal information, as well as the serious consequences once the damage is caused. For example, we will apply encryption, de-identification, and other means to collect and store personal information. In the meanwhile, we will store the information required for business based on the minimum storage period, unless you consent to prolong the retention period or it is permitted by law. We will delete the data beyond the storage period, or the data you request us to delete, or take other appropriate measures without violating the relevant laws and regulations.

2. How We Protect Your Personal information

Besides, we will protect the security of your personal information by other essential measures, in a bid to prevent the data from being abused, accessed without authorization, revised, disclosed or destroyed without authorization, etc.

We will adopt security measures intended to protect your personal information, and monitor our system for possible vulnerabilities and attacks on a regular basis. Moreover, we will protect your personal information by taking administrative, technical and physical protection measures in consideration of the nature of personal information, treatment methods and security. We constantly endeavor to enhance these protection measures to guarantee the safety of your personal data.

Definitely, you need to be reminded that no matter how perfect measures are taken, there is no absolute guarantee to avoid the occurrence of data storage security incidents. Where there is any security leakage, we will report to the corresponding regulatory authorities in line with the requirements of relevant laws and regulations, and furnish the types of personal data involved in data leakage, the number of data subjects, the possible consequences of data leakage, and the remedial measures we intend to take at the request of regulatory authorities. We will take every possible measure to remedy or mitigate the damage and consequences incurred by data leakage. When permitted or required by laws and regulations, we will inform you of the possible consequences or major damages incurred by data leakage in a prompt manner, so that you may timely take appropriate measures to protect your rights as much as possible.

As no website, Internet transmission, computer system or wireless connection is absolutely secure, besides essential security measures taken by us, users also need to raise their awareness of privacy risks. For instance, when you jump to a third party's websites, links, products or services through our services, for the security of any data information collected by these websites, links, products or services, please be sure to read the agreement terms of these websites, links, products or services in a serious and prudent manner. Otherwise, we will not assume any legal liability for data security problems caused by such third parties. Once you find that some contents, advertisements or functions of our website, products or services may be furnished by a third party, which may endanger your privacy and security, please contact us in a prompt manner, and we will give priority to this problem in accordance with the laws and regulations.

IV. How We Share, Transfer and Disclose Your Personal Information

In sharing, transferring and disclosing your personal information, we will uphold the principles and requirements of minimization, necessity and legal compulsion. In general cases, we will not share, transfer or disclose your personal information, but if applied or permitted by relevant laws and regulations, we may share, transfer or disclose your personal information under the following circumstances:

1. How We Share Your Personal Information

We will not sell any personal information to any third party. In order to provide you with prompt services, your personal information may be shared with affiliates of Tspot. We will merely share your information within the scope of the affiliates of Tspot for lawful and explicit purposes, only limited to the information required to render services, and subject to the purposes stated in this Privacy Policy. If the relevant purpose is not stated in this Policy, we will give an explanation in the Privacy Policy or notice of the corresponding concrete products or services.

We may share essential personal information with authorized third-party partners (covering technical service providers, data storage service providers, after-sales service providers, marketing service providers, third-party SDK service providers, and the like) to perform certain functions or furnish you with better services and user experience. For instance, to enable you to share information, enjoy location services or other abundant and diverse services and functions on third-party platforms, we will embed the software development kit (SDK) of authorized partners or other similar applications in this software (we will make security checks on it with strict standards to protect data security). We will launch such sharing activities on the principle of minimization, necessity and legal permission. Before sharing the information, we will make and enter into a strict confidentiality agreement with authorized partners, requiring them to deal with personal information by means of relevant confidentiality and security measures in accordance with this Policy as well as the applicable laws of your jurisdiction. Apart from that, we will request them to furnish data security functions and information security qualifications (e.g., level protection assessment, information security management system, and the like). When we embed the SDK of authorized partners or other similar applications in this software, we will fulfill the obligation of prudence and request the SDK for acquiring information to protect your data security.

To furnish evaluation, analysis or other business services, we may share your non-personal information with a third party as well. For instance, we may help our partners (such as advertising service providers) learn about the effectiveness, feedback and usage trends of their services with the summarized information.

When it comes to the transfer of personal information during the merger, acquisition, bankruptcy liquidation, asset transfer as well as other related transactions we will require the new companies and organizations holding your personal information to continue to be bound by this Privacy Policy through agreements or other appropriate measures, and require such entities to deal with personal information by confidentiality and security measures no less than those required by this Policy.

2. How We Transfer Your Personal Information

Tspot will not transfer your information to any other party unless under one of the following circumstances:

(1) We have your express consent.

(2) If Tspot relates to the merger, acquisition or sales of all or part of its assets, which may influence your personal information, we will issue an eye-catching notice through email and/or our website or other appropriate methods to inform you of any changes in your ownership and rights of personal information as well as your choice of personal information.

(3) Where it has been stated in this Privacy Policy or notified to you by other means.

3. How We Disclose Your Personal information

Tspot may need to disclose your personal information in line with legal requirements, legal procedures, litigation and/or requirements of government departments and authorities. If disclosure is essential or appropriate for national security, law enforcement or other matters of public importance, we may also disclose the information concerned with you.

Apart from that, we may share your personal information with the following personnel:

(1) When we request them for specialized advice, we may share your personal information with our lawyers, accountants, auditors or similar consultants.

(2) There are actual or potential sales or other company transactions between investors and other related third parties, which are associated with entities in our group.

(3) Other third parties, for instance, disclose concrete information with your authorization.

V. How Your Personal Information Is Transferred across Borders

For the purposes stated in this Privacy Agreement, after observing the applicable laws and regulations in your region and acquiring your authorization consent, we may transfer your personal information to the resources or servers mentioned in Article 3 of this Policy for storage or treatment. Besides, we may transfer your personal information to third-party service providers and business partners, so your data may also be transferred to other countries or regions as well. The privacy laws of these countries may not be exactly the same, and the jurisdictions where these servers are situated may or may not protect personal information based on the same standards as yours. However, we will still do our utmost to protect your personal information in compliance with our Privacy Policy and realize the corresponding cross-border transfer as well as other treatment of personal information in line with the legal requirements of the country or region where the personal information is situated.

In the case that we transfer personal information beyond your jurisdiction to either our affiliated companies or third-party service providers, we will observe the relevant applicable laws. We will take appropriate security and protection measures to guarantee that all such transmissions are all in conformity with the requirements of applicable local data protection laws.

VI. Your Rights to Your Personal information

We fully understand and respect your rights such as confirmation, access, correction, deletion, withdrawal of consent and complaint (hereinafter referred to as "requests") about your personal information as a data subject, and such rights will also be subject to specific exclusions and exceptions in accordance with applicable laws. Moreover, we will take active measures to guarantee that your rights are protected in an effective way. However, please understand and note that we may need to verify your identity before processing your request for security reasons. For your legitimate and reasonable request, we do not charge in principle. However, in terms of repeated requests beyond the reasonable limit, we will charge a certain reasonable fee within the scope permitted by applicable laws based on the actual management expenses as appropriate. We may reject requests that are unprovoked and repeated, which require too many technical means (e.g., to develop new systems or fundamentally change existing practices), pose a risk to the legitimate interests of others or are highly impractical, or requests to violate any mandatory requirement of the law.

1. Confirmation and access rights

We will inform you about how we collect and treat personal information with reference to this Privacy Policy or in the form of Privacy Policy or notice under concrete product and service scenarios. You are entitled to confirm or reject this collection and treatment behavior by checking or other means. However, after you reject it, some functions that may only be used only after your explicit authorization cannot be used as a result of it. For the personal information you have furnished to us, you may directly inquire about it in the interface of our products or services. For cases where you cannot check, you may send an email to Privacy@tecno.com or use the FEEDBACK function within these services to give us feedback and we will deal with it promptly after receiving your information.

2.Right to correct and delete

When there is any change to your personal information, or you find that your personal information we are processing is incorrect or incomplete, you have the right to require us to make corrections or supplementation. You may correct and modify some of your personal information directly on the relevant function page of the product or service. You are entitled to request us to delete your personal information when our collection of your personal information has realized the purpose or it is no longer necessary, or when you find that we have collected and treated your personal information in violation of laws, administrative regulations or this Privacy Policy. For personal information that has not been furnished to you for correction or deletion, you may request for correction or deletion by sending an email to Privacy@tecno.com or using the FEEDBACK function within these services.

However, in some cases, we may not approve your deletion request, for instance, when you request us to delete transaction data and Tspot is legally obliged to keep the record of this transaction to observe applicable local laws. Please also note that if you request to delete your information from our products and services, we may not delete the corresponding information from the backup system forthwith owing to some applicable local laws and technical restrictions, but we will securely store your personal information and prevent it from being treated to a further extent until the backup system is updated, your information may be deleted or your information is anonymized.

3.Withdrawal of Consent Right

To realize the corresponding functions of our different products or services, we will need the essential personal information in accordance with the applicable local laws and regulations. This is explained in "How We Collect and Use Your Personal Information" in this Privacy Policy. You may revoke the consent previously granted to us for a specific purpose, covering the collection, use and/or disclosure of your personal information that we hold or control, by deleting information, turning off the function of the device, or withdrawing the consent request, etc. You may send an email to Privacy@tecno.com or use the FEEDBACK function within these services to contact us for related operations. We will deal with your request within a reasonable time frame from the time when the request was sent by you, and thereafter not collect, use and/or disclose your personal information as per your request.

Where you withdraw your consent, you may not be able to continue to get some and/or all functions of Tspot's products and services. Withdrawing your consent or authorization will not influence the effectiveness of our previous treatment activities with your consent.

4.Right to Complaint

You have the right to file a complaint to us by sending an email to Privacy@tecno.com or using the FEEDBACK function within these services. Upon receipt of your complaint, we will give a reply in a prompt manner. If you are not satisfied with our reply, especially if our personal information processing behavior has damaged your legitimate rights and interests, you can also make complaints or reports to local statutory personal data protection authorities, or file a lawsuit to a court with jurisdiction.

5. Right to manage privacy settings

You are entitled to control your privacy settings, and through these privacy settings, you may restrict our collection, use, disclosure or treatment of your personal information. For instance, you may choose to turn on or off the functions and permissions of "Location Access", "Camera" and "Short Message". Besides, you may get more detailed information concerned with the security status of the device in Settings. Where you have previously agreed to open the corresponding permissions or permit us to use your personal information under the aforementioned business scenarios, you may turn off these permissions through Settings > Application Management > Permission Management or contact us by sending an email toPrivacy@tecno.com or using the FEEDBACK within these services to change your decision.

6. Right to Cancel Service or Account

You can use the cancellation path furnished within these services or contact us by sending an email to Privacy@tecno.com or by using the FEEDBACK function to cancel your account. Please cancel your account in a prudent manner. You know and understand that after you cancel your account, we will stop the products and services furnished by this account as well. Unless otherwise required by the applicable laws in your region, we will delete the corresponding personal data in your account simultaneously. When logging in the services with authorization of a third party account, please apply to such third party for cancelling the account.

7. Rights of Certain Jurisdictions

Please pay special attention that in accordance with the applicable laws in some jurisdictions, you may be provided with the following data subject rights:

(1) Right to Restriction of Processing. You have the right to require us to restrict our processing of your personal information. We will examine the reasons for the requirements about your restriction. If the reasons are in conformity with the applicable data protection laws, we will only treat your personal information in the case where such laws are applicable, and notify you before lifting the treatment restrictions.

(2) Automated decision power. You are entitled to refuse information treatment based on automatic decision-making, covering performance analysis as well as other automatic treatment that may impose legal or similar effects on you.

(3) The right of data portability. You are entitled to apply for the transfer of your personal information to another data controller in a structured and commonly used format.

We shall be entitled to refuse to process your request and to refuse some of your requests in case of exemption or when it is in compliance with applicable laws. For instance, some requests are distinctly unfounded or beyond the limit, or third-party information needs to be disclosed.

VII. How We Process Personal Information of Children

Tspot's products and services will not be furnished to children who are 14 years old or under the equivalent age prescribed by the laws of your jurisdiction (since the standards for determining children's age are not exactly the same in different countries or regions, we will principally define children specifically in accordance with the laws and regulations of the countries or regions where we develop our business). We will neither actively collect children's personal data, nor make use of children's personal information for marketing purposes. If you find that information about a child has been passed to us, please send an email to Privacy@tecno.com or contact us by using the FEEDBACK function within these services, and we will delete the relevant information as soon as possible. If we find that we have collected children's personal information, we will do what we can to delete the relevant content with the least delay possible.

VIII. Third Party Service Providers and Their Services

When you make use of Tspot's products or services (such as life services, online customer services, and the like), you may receive links to websites from third parties other than us or contents and services furnished by third parties, and some third-party products or services may be carried out by SDK as well as other methods. You can choose whether to access or accept the websites, products and services provided by third parties at your sole discretion. Our Privacy Policy does not apply to any products or services offered by a third party. Since we cannot actually control the third party, we will not be held accountable for the third party's collection and processing of your personal information. When you submit any information to the third party, please carefully learn about the Privacy Policy of the third party and attach importance to protecting your personal information.

IX. Supplementations and Updates to this Policy

We reserve the right to update or revise this Policy on an irregular basis along with the changes of our business, technology, applicable laws and operations. If this Policy is revised, we will publish the latest policy here (this page), or notify you by publishing it on the official website (https://spot.tecno.com/global), or separately publishing it to you. Please focus on this page or the notices we send to you on a periodic manner to keep abreast of the update of this Privacy Policy. Despite any change to this Privacy Policy, without your express consent, we will not reduce the rights that you enjoy according to this Privacy Policy.

When we collect other personal information from you or when we use or disclose your personal information for new purposes, we will request to get your explicit consent again in accordance with applicable laws. In the case that you continue to make use of the products and services on the website, mobile devices and/or any other devices, you will be bound by the updated Privacy Policy.

The contents of Tspot's products or services stated herein may vary to some degree along with the change of the product type, system version or the requirements of local laws and regulations.

X. How to contact us

When you come up with any suggestions, questions or concerns around our Privacy Policy or practices associated with personal information protection, please contact us by the following means:

(1)Tspot-FEEDBACK

(2)Privacy@tecno.com

We will review your request for privacy or personal information with the least delay possible and give a reply within 15-30 days upon the verification of your user identity. If your request itself relates to complex or significant issues, we may request you to furnish more information.

In the event that you are not satisfied with our reply, particularly when your legitimate rights and interests are infringed by us, you may seek solutions from the relevant regulatory authorities of data protection in your jurisdiction. If you approach us with the above inquiry, we will provide you with information on how to file a complaint that may be applicable in your case.

Thank you for reading our Privacy Policy in your busy schedule!