Privacy Notice

A. Categories of Personal Data We Collected

Category Collected	Disclosed for Business Purpose?	Sold or Shared?
Identifiers/biographical information, including name, postal and email address, phone number. Online identifiers, Internet Protocol (“IP”) address, and other similar identifiers.	Yes Service Providers	Yes
Personal Information categories listed in the California Customer Records statute, such as your credit or debit card number.	Yes Payment processing service providers.	No
Characteristics of protected classifications under California or Federal law, including gender, age, marital status, national origin and ancestry.	Yes Service Providers	No
Commercial information, including items purchased, obtained, or considered and other purchasing or consuming histories or tendencies.	Yes Service Providers	Yes
Internet or other electronic network activity information	Yes Service Providers	Yes
Geolocation data (non-precise)	Yes Service Providers	Yes
Audio, electronic, visual, thermal, olfactory, or similar information	Yes Service Providers and Security Providers	No
Professional or employment-related information	Yes Service Providers	No
Inferences, meaning inferences drawn from the above-listed categories of Personal Information to create a consumer profile reflecting consumer preferences or characteristics.	Yes Service Providers	No
Sensitive Personal Information, means Personal Information that reveals social security, driver’s license, state identification card, or passport number, genetic information, biometric information, account log-in, financial account, debit card, or credit card, password, or credentials allowing access to an account, financial information (including account number), precise geolocation, racial or ethnic origin, national origin, trade union membership, religious or philosophical beliefs, status as transgender or non-binary, sexuality, status as a victim of crime, citizenship or immigration status, contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; as well as the processing of biometric information for the purpose of uniquely identifying a consumer, and Personal Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. We do not use or disclose such information for the purpose of inferring characteristics about you or for any purpose other than the limited permissible purposes set forth in the regulations implementing California law. Such purposes include providing our Services and verifying, maintaining the quality of, and improving our Services. To the extent that we use or disclose “sensitive Personal Information” or "sensitive data" as those terms are defined in applicable privacy laws, we limit our use or disclosure of the sensitive Personal Information for permitted business purposes.	Yes. Payment processing service providers	No

 

B. The Business and Commercial Purposes for Which We Use Your Data

S. No.	Purpose	Categories of Personal Data
1	Fulfilling our business obligations: We may need to process your Personal Data to allow us to carry out order management, payment processing, contract management, financial management and website and service administration.	Contact Information Identification Information Demographic Information Financial Information Preferences and Interests Event Specific Information User Account Information Communication Information User Generated Information Usage Information Product or Services Information
2	Managing our contractual obligations and your ongoing relationship with us: We may require your Personal Data to deliver our service or product to you or to provide you with customer support (such as managing your account, billing management, helpdesk support, providing product or safety related notices or such other support as is required in relation to our products or services).	Identification Information Demographic Information Financial Information Preferences and Interests Event Specific Information Contact Information User Account Information Communication Information User Generated Information Usage Information Product or Services Information
3	Data Analytics: We may use your information to analyze and create user group profiles or segment Data and to otherwise create anonymous, aggregated statistics about the use of our products, services and loyalty programs, which we may share with third parties.	Demographic Information Event Specific Information Financial Information User Account Information Communication Information Contact Information Professional Information Usage Information Product or Services Information Health Information (Wearable & Optometric) Preference & Interest Audio & Visual Information User Generated Information Social Media Information
4	Product/Service Improvement: We may use your information to improve and enhance our existing products, services and applications and develop new offerings, recommendations, advertisements and other communications and learn more about customers’ preferences in general.	Contact Information Demographic Information Event Specific Information Product or Services Information Health Information (Wearable & Optometric) Preference & Interests Audio & Visual Information User Generated Information Social Media Information
5	Publish your reviews, comments, and content: Where you have uploaded product reviews, comments, testimonials or content to our websites or application and made them publicly visible, we may link, publish or publicize these materials elsewhere including our own advertisements.	Contact Information Product or Services Information Preference & Interests User Generated Information Social Media Information
6	Tailoring our services to your preferences: We may use your information to provide you with product and service updates, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging and/or text message (SMS), if you have provided your prior consent or we are otherwise permitted to do so under applicable law.	Contact Information Relationship Information Demographic Information Event Specific Informatio User Account Information Health Information (Wearable & Optometric) Communication Information Usage Information Product or Services Information Preference & Interests Audio & Visual Information User Generated Information Social Media Information
7	Maintaining secure and safe services and products: We may need to process your Personal Data to preserve and maintain the security of our websites, networks, systems and premises including protection against fraud and malicious security threats.	Contact Information Demographic Information Financial Information User Account Information Usage Information Audio & Visual Information User Generated Information Social Media Information
8	Compliance with legal obligations: We may need to process your Personal Data for purposes, which are required by the applicable law, or to respond to compulsory legal processes or enforce compliance with the policies governing our business.	Contact Information Identification Information Demographic Information Financial Information Audio & Visual Information
9	Managing our supply chain and business network: To provide our products and services to you, we may need to process your Personal Data in connection with the utilization of our third-party partner business network.	Contact Information User Account Information Audio & Visual Information
10	Corporate activity, including mergers, acquisitions and joint ventures: We may need to process your Personal Data in connection with certain corporate activity, such as a party acquiring all or part of our equity or assets or business operations in the event of a sale, merger, liquidation, dissolution etc.	Contact Information Relationship Information Demographic Information Event Specific Information Financial Information User Account Information Communication Information Professional Information Usage Information Product or Services Information Health Information (Wearable & Optometric) Preference & Interest Audio & Visual Information User Generated Information Social Media Information
11	Job Applications and Recruitment: We may process your Personal Data as part of our recruitment activities, including evaluating your qualifications, assessing your suitability for a role, conducting interviews, and making hiring decisions. This processing may also be necessary in connection with background checks, compliance with legal and regulatory requirements, or for maintaining records of the hiring process.	Contact Information Demographic Information Educational Information Professional Information

 

C. Retention

We will retain your Personal Data for as long as reasonably necessary to provide you with our Services that you request or otherwise where permitted or required in accordance with applicable law. We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and is based on several factors: 

1. Compliance with Laws: We adhere to the retention periods mandated by applicable laws and regulations.
2. Operational Needs/Legitimate Interest: We keep your data for the duration necessary to deliver our services and maintain our business operations effectively.
3. Consent-Based Processing: When processing your data based on consent, we retain the data for as long as we have your consent, and will delete such data within a reasonable time after you withdraw your consent.
4. Legal and Dispute Resolution: In cases of disputes or legal proceedings, we may need to retain your data for longer periods to resolve issues.

2. What Personal Data do we collect?

There are several ways we may obtain Personal Data about you, including through 

1. information you provide to us; 
2. information we automatically collect; 
3. information we receive from other sources; and 
4. combining information from different sources. This includes data that identifies you personally whether directly or indirectly.

A. Information You Provide Directly 

We collect Personal Data from you as listed in the Notice at Collection in the following circumstances: 

1. When you use our services. This includes Personal Data collected when you register or enroll for our event or program such as loyalty program or complete a customer survey. 
2. When you make a purchase with us. We collect information related to your transaction. 
3. When you provide information through social media. Your data collection is also governed by the social media platforms you interact with. 

B. Information We Collect Automatically 

When you visit and interact with our Services, we or our third-party advertising and analytics partners and service providers may use a variety of technologies, such as cookies, tags, SDKs or scripts, to collect certain information regarding your activity.  To learn more about your choices regarding the automatic collection and use of your information as you browse our Services, please see the Your Privacy Choices and Rights section below.

The specific types of information that we and our partners and service providers may automatically collect when you visit and interact with our Services include:

1. Device and Browser Information: This includes your device’s IP address and/or other unique identifiers, browser type, device type, internet service provider, and operating system. 
2. Location Information: When you access our Services from a mobile device, your device’s approximate location (derived from your device’s IP address or other signals) may be collected. 
3. Usage Information: When you interact with our Services, certain information may be collected by us or our third party vendors, including the date and time of your visit, the pages you view immediately before and after you access our Services, the areas or pages of our Services that you visit, the amount of time you spend viewing or using our Services, items placed or left in your shopping cart on the Site or App, keystrokes, mouse movements, form field entries, recordings of chat sessions or your use of and inputs to other AI-supported tools, and other use and overall engagement with our Services.  
4. Marketing Information: If you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our Site). 
5. Third-party analytics technologies: We may use third-party analytics tools to better understand who is using our Services, how people are using them, and how to improve their effectiveness as well as the effectiveness of any related content.
6. Cookies and Other Similar Technologies: “Cookies” are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of our Sites and related content. They can also enable the delivery of relevant and personalized advertisements to you across the Internet.
7. Our use of Google Analytics and Advertising technologies: Our website uses technology provided by Google to facilitate advertising and reporting. We implement Google Analytics cookies to collect Personal Information about you when you visit our website for purposes of remarketing, impression reporting, and demographic and interest reporting. This information may be combined with other data related to you collected through Google’s advertising cookie or other third-party technology.  You can opt-out of the use of this technology through the Google Analytics opt-out browser add on, Google Ad Settings, Ad Settings for mobile apps, and the NAI’s consumer opt-out.

C. Information From Other Sources

We may receive information about you from publicly and commercially available sources (as permitted by law), which we may combine with other information we receive from or about you. We also may receive information about you from third-party social networking services when you choose to connect with those services.

We may collect Personal Data about you from various sources, including but not limited to:

1. Direct interactions with our customers during in-store purchases, platforms, websites and applications.
2. Data collected through customer survey forms and publicly and commercially available sources, including data aggregators.
3. Data collected through automated technologies, such as cookies, call recordings of our call center and CCTV recordings of the cameras in our facilities.
4. Data obtained from our marketing and analytics partners. 
5. Data collected through third party social networking websites and services.

D. Combination of Information 

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Services, as well as information collected offline, across other computers or devices that you may use. Inferences drawn from any of the Personal Data listed above may be used to create a profile or summary about, for example, an individual’s preferences and characteristics.

3. How We Use the Personal Data We Collect?

1. General: TCLNA may use the information collected from you to register you or your device for a Service, to provide a service or feature you request, to provide customized content and make recommendations based on your past activities on our Application.
2. Advertisements: TCLNA may use your information to provide you with product and service updates, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging and/or text message (SMS), if you have provided your prior consent or we are otherwise permitted to do so under applicable law.
3. Statistics and Research analytics: TCLNA may use your information to analyze and create user group profiles or segment data and to otherwise create anonymous, aggregated statistics about the use of our products, services and loyalty programs, which we may share with third parties and/or make available to the public.
4. Product/Services Improvement: TCLNA may use your information to improve and enhance existing TCLNA products, services and Applications and develop new offerings, recommendations, advertisements and other communications and learn more about customers’ preferences in general.
5. Publish your reviews, comments and content: Where you have uploaded product reviews, comments or content to our websites or Application and made them publicly visible, TCLNA may link to, publish or publicize these materials elsewhere including in our own advertisements.

4. How we disclose your Personal Data?

We may disclose each category of Personal Data we collect with the following categories: 

1. Service Providers: We may employ third party entities and individuals to facilitate our Services (e.g., maintenance, analysis, audit, marketing and development). These third parties have limited access to your information only to perform these tasks on our behalf and are obligated to TCLNA not to disclose or use it for other purposes. Your information may also be shared with the developer of our application. 
2. Competent Governmental, Regulatory, and Public Authorities: There may be instances when we disclose your information to other parties to comply with the law or respond to compulsory legal process or to verify or enforce compliance with the policies governing our Services or to protect the rights, property, or safety of TCLNA, or any of our respective affiliates, business partners, or customers.
3. Advertisers and our Advertising Service providers: We will not disclose or share your information with unaffiliated third parties for their own marketing, unless so authorized by you. 
4. Relevant Third Parties as Part of a Corporate Transaction: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
5. Other Third Parties: We may also share your Personal Data with other third parties where:
   1. You request or authorize us to do so
   2. We need to comply with applicable law or respond to valid legal process; or
   3. We need to operate and maintain the security of our website or mobile application, including to prevent or stop an attack on our computer systems or networks. The sharing of your Personal Data will be in line with the processes set out in this Privacy Notice.
6. We may disclose your Personal Data for other reasons that we will describe at the time of information collection or prior to disclosing your information. 

Please note that we may de-identify or aggregate Personal Data so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Notice. 

5. Your Privacy Rights and Choices

A. U.S. State Privacy Rights 

Residents of California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Tennessee, Utah, Virginia, or any other state with an applicable privacy law have certain rights relating to the collection, use, disclosure, and other processing of their Personal Information. The exact scope of these rights may vary by state.

1. Right to Know: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, the categories of Personal Information disclosed to third parties, and the specific pieces of Personal Information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of Personal Information more than twice in any 12-month period.
2. Right to Request Specific List of Third Parties: You may have the right to request a list of the specific third parties to whom we have disclosed your Personal Information. 
3. Right to Request List of Categories of Third Parties: You may have the right to request a list of the categories of third parties to which we have disclosed your Personal Information.
4. Right to Data Portability: You may have the right to access your Personal Information in a portable format. 
5. Right to Delete: You may have the right to request that we delete Personal Information that we have collected from or about you, subject to certain exceptions.
6. Right to Correct: You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
7. Right to Opt Out of Certain Types of Personal Information Uses and Disclosures: We use and disclose to third parties Personal Information for analytics and advertising purposes. Accordingly, you may have the right to opt out of the “sale” or “sharing” of your Personal Information, or the use and disclosure of your Personal Information for “targeted advertising” (as these terms are defined in applicable law).
8. Right to opt out of profiling, targeted advertisement and automated decision making

If you are interested in exercising one or more of the rights outlined above, please click here or you can contact us at dpo@caratlane.us or contactus@caratlane.us or +1844-922-2728. Please put the statement “Your Privacy Rights” in the subject field of your email. Except for your opt out right, we may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. 

• Please note that, where permitted under applicable law, we may decline a request (other than for opt outs) if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the Personal Information we maintain relates to you. 
• Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. You may file an appeal by contacting us as described in this Notice. 
• If an agent would like to make a request on your behalf as permitted under applicable law, the agent may use the submission methods noted in this section. Not all kinds of requests can be made by authorized agents in all states. As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent. In addition, we may require that you verify your identity as described in this section or confirm that you provided the agent permission to submit the request.
• Submitting a privacy request does not require you to create an account with us.
• We will not discriminate against you if you decide to exercise your privacy rights.

B. Notice of Financial Incentive 

We may offer discounts or other benefits to consumers who choose to enroll in our loyalty program. When you sign up for our loyalty program, we ask you to provide Personal Data such as your email address so that we can contact you with promotions and other information that may interest you. Because these promotions involve the collection of Personal Data, they may be interpreted as “financial incentive” programs under California law or “bona fide loyalty programs” under Colorado law. Participation in any financial incentive is optional.

TCLNA does not generally assign monetary or other value to consumers’ Personal Data, and our promotional activities change continually. The Personal Data we collect for the program is approximately equal to the value of the discounts or other benefits provided through the program. These values can change over time. Note that this description does not waive any confidentiality protection, trade secret protection, or other proprietary interest in TCLNA’s business confidential information, and it does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

You may withdraw from the loyalty program at any time by sending an email to dpo@caratlane.us or contactus@caratlane.us

C. Unsubscribing From Marketing and Promotional Emails

From time to time, we may send you marketing and promotional communications, including special offers from us or our partners. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.

6. Children’s Data

We do not direct the Services to, nor do we knowingly collect any Personal Data from, children under the age of 18. If we learn that a minor has provided Personal Data through the Services, we will use reasonable efforts to destroy such information.

7. Security

We restrict access to your Personal Data to employees of ours, our affiliates, and third-party service providers who reasonably need it to support this site. We have implemented physical, administrative, and technical safeguards to protect your Personal Data from unauthorized access. We use security measures to help protect your Personal Data against unauthorized disclosure, misuse, or alteration, and other incident with the disciplinary actions against the offender. As is the case with all computer networks linked to the internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.

8. Changes to this Notice

TCLNA reserves the right to amend this Privacy  Notice at our discretion and at any time. This Privacy Notice is subject to review after a period of every 12 months from the previous update. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website homepage. For additional information on Cookies and technologies engaged by TCLNA, please refer to Cookie Policy

9. Contact Us

If you have any concerns about how we process your data or would like to exercise any of your privacy rights, including those described above, you can reach us at:

• Address: TCL North America Inc., Regus Metropark, 33 S Wood Ave., Suite 740, Iselin, NJ 08830, United States.
• Toll Free Number (only for California residents): +1844-922-2728
• Privacy Webform : Exercise Your Rights
• Email: dpo@caratlane.us

10. Supplemental Privacy Notice for Canada

This Privacy Notice is supplemented by the following additional notices, which may apply based on how and where you interact with us:

• Canada Privacy Addendum