LG Smart Media Product Privacy Policy (February 2024)

# LG Privacy Policy (Smart Media Product) This Privacy Policy is designed to inform you how LG Electronics Inc. (“LGE” or “we” or “our”) collects, uses, and shares information that we obtain as a result of your use of your Smart Media Product (including but not limited to Smart TV, monitors, or any other internet-based Media Products), as well as any add-on features and function(s) (together, the “Smart Media Product Services”) that we provide. Depending on the country where you are based and the model of Smart Media Product that you own, some of the Smart Media Product Services may not be available (Information collected may vary based on the availability of specific Smart Media Product). LG Privacy Policy 1. Introduction 2. What information does LGE obtain? 3. How LGE uses the information it obtains 4. How LGE shares your information 5. Your rights 6. Overseas Transfers 7. Additional disclosures for California consumers 8. How long will LGE keep my personal information? 9. Security 10. Children and LGE Smart Media Products 11. Consenting for others 12. Additional information for features and add-on services 13. Changes to LGE’s Privacy Policy 14. Contacting LGE about this Privacy Policy 1. Introduction This Privacy Policy describes how we collect, use, and share information that we obtain as a result of your use of the Smart Media Product and, in particular, sets out: • What information LGE may obtain from you as a result of your use of your Smart Media Product; • How LGE uses the information that it obtains; • When LGE shares information with service providers or third parties; • How you may control LGE’s use and sharing of your information; and • The rights you may have. In addition to this Privacy Policy, we provide supplemental terms and information about our privacy practices related to particular add-on features and services in the applicable Additional User Agreements for each of the add-on features and services. You should review such information before enabling these features and services. LGE’s Smart Media Product enables access to apps and may provide links to other services owned and operated by third parties (“Third Party Apps”). If you choose to activate and access an App, that App’s provider may collect, receive or use information about you or your Smart Media Product in order to provide their service. These Third Party Apps are controlled by thirdparties and are outside the scope of this Privacy Policy, so we encourage you to read their privacy policies to learn more about their collection, use, and sharing of information. LGE is not responsible or liable for the privacy or security practices of Third Party Apps or any acts or omissions of the third-parties that provide and operate such Third Party Apps. 2. What information does LGE obtain? During the set-up and authentication process, we receive certain information, including Device Information (as described below). This information is necessary for the basic functioning of the Smart Media Product and is not contingent upon your agreement with this Privacy Policy. In order for you to access the full range of Smart Media Product Services, however, you will need to agree to this Privacy Policy and certain additional User Agreements (“Additional User Agreements”) that permit the use of your information in a manner that facilitates a greater exchange of information between your Smart Media Product, LGE, and in some cases, certain outside entities. Please see the relevant sections below for more details on how we use and share the information we obtain from your Smart Media Product. The information that we may receive when you use your Smart Media Product falls into the categories of information described below. If you do not opt-in to any of the Additional User Agreements for add-on features and services, LGE will not collect all of the categories of information described below; however, LGE will still receive some information from your Smart Media Product, including Device Information, Basic Usage Information, and Information in Connection with the LG Channels feature. • Device Information. This is information about your Smart Media Product and any external devices that you might connect to it, such as your set-top box, video game console, remote control, and DVD or Blu-ray player. Examples of Device Information include the following: information to authenticate your Smart Media Product with LGE’s servers, the country code and zip code or postcode of the region where your Smart Media Product is being set up, your IP Address, device type (e.g., set-top box, DVD player, etc.), device ID, AD ID, input method (e.g., RF, Component, HDMI, Network), MAC address (or in some circumstances, a truncated MAC address), model number, software version, chipset, language, and screen resolution. Other features which you may use, such as controlling other internet-connected devices (e.g. light switches) in your home via your Smart Media Product, will require collection of data regarding those devices. • Basic Usage Information. This is information about your interactions within the Smart Media Product, such as the menu items you click on, the apps you access (but not your activity within Third Party Apps), and what channels are available to you. • Information in Connection with LG Channels. This is information about your interactions with the LG Channels feature. LG Channels is a streaming service that allows you to access live and on-demand premium TV channels alongside internet channels (IP channels). The information collected when you use LG Channels includes device information and viewing information such as the name of the LG Channels or program watched, requests to view LG Channels content, details of actions taken while viewing LG Channels (e.g., play, stop, pause, click, etc.), and the duration of LG Channels content watched. • Other information you share with us. In addition to Device Information, Basic Usage Information and Information in Connection with LG Channels, you may choose to share further information with us through your Smart Media Product, such as by entering information on the user registration page. Such information may include your name and basic contact details, or preferences (such as your favorite sports and/or teams). As explained above, you will have the opportunity to review and separately agree to Additional User Agreements. You can always access these agreements on the “User Agreement” page within your Settings menu to agree to them, review their terms, or withdraw consent (by unchecking the checkbox next to the appropriate agreement and clicking the “Agree” button). If you agree to these Additional User Agreements, LGE may also receive the following categories of information from your Smart Media Product: • Viewing Information: This is information about your interactions with program content, including live TV content, cable, satellite or set-top box content, streaming content, movies, and video on demand. Viewing Information may include the name of the channel or program watched, requests to view content, details of actions taken while viewing (e.g., play, stop, pause, click, etc.), the duration that content was watched, and input method (e.g., RF, Component or HDMI, Network). Viewing information may be collected using Automatic Content Recognition (“ACR”) software to identify the content you watch or listen to on your device, regardless of the source of the information (e.g., from any set-top-boxes, gaming consoles, media players, over the air broadcast, or other audiovisual sources connected to your device). The ACR software identifies content by continuously analyzing audio signals it receives directly from the soundboard integrated with your Smart Media Product’s speakers; it does not receive any information directly from the microphone on your Smart Media Product or your remote(s). Some categories of Viewing Information may only be collected through certain features or addon services. You will need to agree to the Viewing Information Agreement or Additional User Agreements (which requires Viewing Information) before LGE can collect and use Viewing Information. If at any time you opt out of the Viewing information Agreement or Additional User Agreements, we will discard such Viewing Information we may have collected from you based on past consent, if applicable. • Voice Information: Smart Media Products can be operated with a voice capable remote control or other input devices that enable you to control aspects of your Smart Media Product with voice commands. Voice Information refers to these voice commands and associated data (such as information about the input device that records your voice) used to recognize and act upon the command (e.g., Magic Remote or built-in microphone), operating system information, Smart Media Product model information, content provider, channel information and service results. You will need to agree to the Voice Information Agreement before you can activate voice command functions, and before we can collect and use your Voice Information. If you consent to the Voice Information Agreement, we will still only collect Voice Information if you activate the voice command function. If the voice command function is activated while your Smart Media Product is on, it will notify you on the screen. If the voice command function is activated while your Smart Media Product is off, it will notify you by blinking the light on the Smart Media Product. However, if you use a third-party App or Service that offers voice functionality, the provider’s collection, use and sharing of your voice information will be governed by the provider’s privacy policy. Please note that LGE may collect some of the above information by using cookies and beacons, which are small data files that contain information on how you interact with certain advertisements and pages. A cookie also often includes a unique device identifier that is stored on your Smart Media Product. See below for more information on how we use cookies and beacons. In addition to receiving the information above directly from your Smart Media Product, LGE may receive further information that you choose to provide (including your preferences and interests) in order to access certain services, or that you may provide to LGE in other contexts (e.g., through use of other LGE devices or through a LG Account). Such information will be processed in accordance with the privacy policy associated with that service. 3. How LGE uses the information it obtains We use information we obtain from your Smart Media Product to provide you with Smart Media Product Services, to improve our products and services, provide you with future products and services, and other purposes described below. We use each of the categories described above for a variety of purposes, including: • providing you with Smart Media Product Services • providing you with relevant advertisements • providing you with a user-friendly navigation experience • analyzing, reviewing, and improving Smart Media Product Services and products, as well as developing new products and services • understanding how Smart Media Products are used • complying with our legal obligations, exercising our rights, and defending or bringing any existing or potential legal claims; and • internal record keeping • preventing, detecting and investigating illegal activities, such as breaching our Terms of Use and fraud How We Use Information in Connection with LG Channels Anytime you request to view content through LG Channels, we will collect the types of information described above in the “Information in Connection with LG Channels” section above (e.g., about the content you select). This information is necessary to fulfill your request on LG Channels (i.e. IP channel streaming, to provide the content you request, etc.). LG Channels is a streaming service that allows you to access live and on-demand premium TV channels alongside internet channels (IP channels). LGE partners with a number of third party entities to provide the LG Channels services. Depending where you live and which model Smart Media Product you own, the LG Channels service may not be able to you. In order to provide LG Channels content, including video on-demand services, live digital channels, and advertisements, your Device Information and the information described in the “Information in Connection with LG Channels” section must be shared with LGE’s third-party partners who provide the LG Channels streaming content and services. When you use LG Channels, these types of information will automatically be sent from your Smart Media Product to LGE’s third-party partners for the following purposes: (i) to provide, maintain, and improve Smart Media Product Services and interactive services including LG Channels; (ii) to contribute to aggregate statistics regarding the popularity of particular content; and (iii) to generate reports and analysis about Smart Media Product viewing trends, ad effectiveness, and understanding of audiences. LGE’s third-party partners, and the entities with whom they share information, may enrich, aggregate, and commercialize the information they receive through your devices. How We Use Viewing Information If you agree to the Viewing Information Agreement or Additional User Agreements (which requires Viewing Information), which can be found in your Settings menu, we will use Viewing Information (as described above) for several purposes, including: • providing you with recommendations of content that may be of interest to you • providing music recognition features • enhancing the viewing experience on your Smart Media Product and other devices • understanding and analyzing how our services are being used and making improvements to them accordingly • for analytics purposes (e.g., to understand the popularity of certain content) • providing you with advertisements, including advertising that may be targeted to you based on your Viewing Information (If you have agreed to the Interest-Based and Cross-Device Advertising Agreement) • creating aggregate reports and analysis about Smart Media Product viewing, audience trends, and ad effectiveness • sharing your Viewing Information with third party partners and service providers, for example, our service partner Alphonso for other purposes such as analytics and selling advertisements We may use and combine information collected under this Agreement with information collected and associated with your use of other LG services, such as LG SmartHome services including but not limited to our ThinQ App and LGE Website. For more information, please refer to the LGE Service Privacy Policy from App settings menu in the ThinQ App or LG Account menu in the LGE Website (collectively "other services). If you use more than one of our services, including Services described in this Privacy Policy and other service, we will combine the personal information we collect from you in connection with each of those services and use it for the purposes set out below or as described in the privacy policy applicable to the services you use For more information, please refer to the Viewing Information Agreement or the Additional User Agreements. As described in the “How LGE Shares Your Information” section below, we may also share Viewing Information with other third parties, depending on which features of the Smart Media Product you use and which of the Additional User Agreements you have agreed to. For example, when you use the Live Plus services described in the Viewing Information Agreement, we share your Viewing Information (and Device Information) with our service partner, Alphonso, to enable the services described above and for Alphonso’s processing purposes (such as analytics and selling advertisements.) If you have agreed to the Interest-Based and Cross-Device Advertising Agreement, we may share your Viewing Information with other third parties so that we and they may provide targeted advertising to you. How We Use Voice Information Please note that you must consent to the Voice Information Agreement before we can collect and use your Voice Information, and before you can activate voice command functions. The Voice Information Agreement can be found in your Settings menu. We use Voice Information to respond to your commands or to return your search results (such as a recommendation for a comedy movie). With the assistance of our service partner, we use your Voice Information to improve and develop new Smart Media Product functions. For more information about our use of Voice Information, please refer to the Voice Information Agreement in the Settings menu. However, if you use a third-party App or Service that offers voice functionality, the third-party provider’s collection, use and sharing of your voice information will be governed by the provider’s privacy policy. How We Use Cookies and Beacons As mentioned above, the information we collect may be collected using cookies and beacons. We may use cookie data to count how many times you may have seen a particular advertisement to try to make sure that you do not see it too many times, and beacon data to understand how you interact with particular advertisements. How We Use Deidentified Data We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by use or another party, and we may use or share this deidentified data for any purpose. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data. 4. How LGE shares your information For Our Business Purposes LGE may share all of the categories of information we collect within our corporate umbrella (e.g., with our corporate parent, subsidiaries, affiliates or joint partnerships) or with outside entities for our own business purposes. We share this information to provide or otherwise enable your use of features and functions on the Smart Media Product, and for various internal purposes, such as providing customer service, safeguarding the security of our products, and analyzing the data we collect. More information on our sharing practices can be found below. To Power Add-On Features When you activate certain add-on Smart Media Product features and agree to the appropriate Additional User Agreement, you are directing LGE to intentionally disclose personal information, such as Viewing Information, Device Information, Basic Usage Information, and cookies and beacons to outside service partners that provide add-on services. As described in further detail above and in the Additional User Agreements, these service partners use the information to provide certain services alongside LGE. Besides sharing with partners in connection with LG Channels (as described above), before we share your information with the service partners powering other add-on features, including those involving Voice Information, Viewing Information collected via ACR technology (and related information, as described above), and Interest-Based and Cross-Device Advertising, among others, we will ask for your consent by asking you to agree to the respective Additional User Agreements. We will not share information for the purposes described in each Additional User Agreement without first obtaining your consent to the appropriate Additional User Agreement. For more information on the specific service partners we use, as well as the practices of these partners, please consult the relevant Additional User Agreement. To Provide You with More Relevant Advertisements A. Interest-Based and Cross-Device Advertising Please note that you must consent to the Interest-Based & Cross-Device Advertising Agreement before we can provide you with Interest-Based and Cross Device advertisements. The Interest- Based & Cross-Device Advertising Agreement can be found in your Settings menu. Interest-Based advertisements are advertisements that are tailored to your interests based on personal information collected about you from your Smart Media Product, including Viewing Information, keywords you may have searched for, or other information you may have shared with us through your Smart Media Product (e.g., LG Account information, preferences, etc.). This information is used to display advertisements across devices – on your Smart Media Product or on other digital devices that share the same IP address as your Smart Media Product, such as your laptop, mobile phone or tablet (“Other Devices”) – in what is known as Cross-Device Advertising. Interest-Based advertisements may also be displayed across different platforms including thirdparty websites and social media. To display Interest-Based advertisements on your Smart Media Product, we may share Viewing Information (if you have agreed to the Viewing Information Agreement), Device Information, Basic Usage Information, and information collected via cookies and beacons with third-party advertising partners. These advertising partners use the information they receive from us to help us do the following: • Deliver Interest-Based and Cross-Device advertisements; and • Enhance viewing experience through content recommendation and interactive services Under the laws of some U.S. states, such sharing may be considered a “Sale” even if no money is exchanged. Please see below for more information about the rights you may have to opt out of such sales. In addition, these advertising partners may also enrich, repackage (e.g., aggregate, de-identify, anonymize, etc.) and commercialize information they receive from us. As described in more detail in the “Your Rights” section below, you may opt-out of receiving Interest-Based and Cross-Device advertisements at any time by navigating to the Interest-Based & Cross-Device Advertising Agreement on the ”User Agreements ” page of the Settings menu, or you can prevent the use of information collected from your Smart Media Product for advertising by selecting the “Limit Ad Tracking ” option on the ”Advertisement ” page of the Settings menu. B. Contextual Ads Contextual ads are non-personalized advertisements displayed on your Smart Media Product. Even if you do not consent to our Interest-Based & Cross-Device Advertising Agreement, your Smart Media Product may still display contextual ads in connection with the provision of certain Smart Media Product Services. To display contextual ads, we share certain information, such as the region where your Smart Media Product is located and the content that your Smart Media Product is displaying, with third-party advertising partners. For Other Reasons Related to Smart Media Product Services In addition to the above, LGE may share your personal information for business purposes with the following categories of service partners: • Payment processors • Customer service providers • Security and quality assurance vendors • Data analytics providers These entities may receive your Device Information, Basic Usage Information, and other basic identifying information, such as your name and contact details. Depending upon the nature of the service they provide, they may also receive your payment information, Viewing Information, or other details relating to your use of the Smart Media Product(such as crash reports). For Legal Reasons We may also share personal information collected from and about you with third-parties if we are legally required to do so, or if we have a good-faith belief that access, use, preservation or disclosure of the personal information is reasonably necessary to: • comply with any applicable federal, state, or local law, regulation, civil, criminal or regulatory inquiry, investigation, legal process or enforceable governmental request; • respond to legal process (such as a search warrant, subpoena, summons or court order); • enforce our Terms of Use (or other terms of service for our website), including investigation of potential violations; • cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law; or • exercise or defend legal claims, protect against harm to our rights, property or safety, or the rights, property or safety of third-parties, our consumers, or the public as required or permitted by law. In this context, we may share your Device Information, Basic Usage Information, Information in Connection with LG Channels, Viewing Information, Voice Information, basic identifiers and contact details, and/or other information relating to your use of the Smart Media Product. In Connection with a Sale or Merger If we directly or indirectly undergo a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part of our assets, we may disclose or transfer personal information collected from and about you (including your personal information), to the successor or potential successor organization, and their professional advisers during the transition. We will make reasonable efforts to let you know if your personal information has been disclosed or transferred in connection with a business transition. In this context, we may share your Device Information, Basic Usage Information, Information in Connection with LG Channels, Viewing Information, Voice Information, basic identifiers and contact details, and/or other information relating to your use of the Smart Media Product. With Third Parties in Other Contexts In some circumstances, we may also sell or otherwise share your personal information with third-party entities. The information that we share in this context may include your Viewing Information, Information in Connection with LG Channels, Device Information, Basic Usage Information, Voice Information, information collected via cookies or beacons, and other identifiers or identifying information you choose to send us. You can opt out of such sharing of your personal information with third parties by turning on the Do Not Sell My Personal Information (“Do Not Sell”) toggle, which can be found in your Settings menu. Your activation of the Do Not Sell toggle will not disrupt your use of the services or features available on the Smart Media Product. As mentioned below, our service is not intended for minors under 16, and as such we will not knowingly collect or sell the personal information of minors under 16. 5. Your rights Depending where you reside and whether these rights are relevant to LGE’s processing of personal information, you may have the following rights with respect to your personal information, where applicable under local law: • Right to Access. You may be entitled to request that we disclose to you the specific pieces of your personal information that we have collected about you in a portable and, to the extent technically feasible, readily usable format. • Right to Know. You may have the right to confirm that we have collected personal information about you and know what personal information we have collected about you, including, as applicable, the categories of personal information we have collected, the sources from which we collected that personal information, the business or commercial purposes for which we collected, sold, and shared that personal information, the categories of personal information that we sold, shared, or disclosed to third parties for business purposes and the categories of third parties to whom we sold, shared or disclosed personal information. • Right to Deletion. You may be entitled to request that we delete the personal information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law. You may also delete certain data on your own, for example, by deleting any saved preferences or user accounts on the Smart Media Product. • Right to Limit the Use of Sensitive Information. California residents may be entitled to request limiting the processing of sensitive information to specific purposes, to the extent applicable. (Please note that LGE only uses sensitive account information for identification and authentication purposes when registering for or logging into your LGE Account, and therefore LGE does not provide an option to limit the use of sensitive information.) • Right to Correct. You may be entitled to request that we correct or update personal information that we hold about you. • Right to Opt Out of Sales of Personal Information. You may be entitled to opt out of “sales” of personal information to third parties. To opt out of “sales”, you should activate the “Do Not Sell My Personal Information” toggle in the Settings menu, as described below. • Right to Opt Out of Targeted Advertising. You may be entitled to opt out of targeted advertising. (Under California law, this is referred to as “sharing” of personal information for cross-context behavioral advertising.) To opt out of targeted advertising (and “sharing”), you should revoke your consent to the Interest-Based and Cross-Device Advertisements agreement as described below. You may also prevent the use of information collected from your Smart Media Product for advertising by selecting the “Limit Ad Tracking” option as described below. • Right to Opt Out of Profiling. You may be entitled to opt out of profiling in furtherance of certain decisions that produce legal or similarly significant effects that concern you as a consumer. Please note that LGE does not engage in profiling that produces legal or similarly significant effects, and therefore LGE does not offer an option to opt out of such profiling. • Right to Non-Discrimination. You have the right not to receive discriminatory treatment if you exercise the rights conferred to you by applicable privacy laws. If you would like to exercise one of your rights, or if you are an authorized agent exercising rights on behalf of someone else, please contact us at https://privacy.us.lg.com/policies or 800-243- 0000. To process your requests to Access, Know, Delete, or Correct personal information (as described above), we must be able to verify your identity. To verify your identity, we may ask you to provide certain contact information and additional identifiers (e.g., LG Account information, MAC address of your Smart Media Product). You may also appoint an authorized agent to exercise your rights on your behalf. In order for us to honor a request made by your authorized agent, the agent (or you) must submit proof of your written authorization of the agent. As described above in this section, you may have the right to opt out of “sales” of personal information to third parties. The “Do Not Sell My Personal Information” toggle (“Do Not Sell” toggle) located in the Settings menu helps you do this. When you manually activate the Do Not Sell toggle, LGE will cease “sales” of your personal information to third parties. Even when the Do Not Sell toggle is activated, you may still continue to receive Interest-Based and Cross-Device advertisements from LGE (if you have consented to receive such advertisements), unless you revoke your consent to the Interest-Based and Cross-Device Advertising Agreement. You may opt out of receiving Interest-Based and Cross-Device advertising at any time by navigating to the Interest-Based & Cross-Device Advertising Agreement on the “User Agreements” page of the Settings menu. You may also prevent the use of information collected from your Smart Media Product for advertising by selecting the “Limit Ad Tracking” option on the “Advertisement” page of the Settings menu. To reset your Advertising Identifier (and to prevent advertisements from being targeted based on personal information that was associated with that Advertising Identifier), you can press the “Reset Ad ID” button in the Settings menu. Please note that if you activate the Do Not Sell toggle, you may still continue to see advertisements that are contextual or not targeted by individual device or personal information about you. Please also note that activating the Do Not Sell toggle will prevent us from selling your personal information until you either manually deactivate the Do Not Sell toggle or reset your Smart Media Product. If you reset your Smart Media Product and wish to opt out of sales, please activate the Do Not Sell toggle again. Smart Media Products are household devices. Please be aware that if more than one person uses the Smart Media Product, LGE does not have a way to match the personal information we obtain through the Smart Media Product to any specific individual. As such, we may only be able to verify your identity if you use an LG Account associated with your Smart Media Product. You may also contact us using the contact details above to appeal any decision we make relating to your request to exercise your rights. 6. Overseas Transfers As a global organization, we, our affiliates, subsidiaries, and suppliers may need to transfer your information (including your personal information) outside the country where your Smart Media Product is located, for example to our headquarters in South Korea. We may transfer your personal information in this manner in order to provide you with our Smart Media Product and for any other purposes outlined in this Privacy Policy, consistent with this Privacy Policy and any applicable laws. You should also bear in mind that the data protection laws in many of these countries may not offer the same level of protection as those in your home country. However, before transferring we will take steps to ensure that safeguards are put in place aimed at ensuring the same level of protection as required by applicable data protection laws in the country where your Smart Media Product is located. For further information on how we handle and protect your personal information, please contact us at https://privacy.us.lg.com/policies, usprivacy@lge.com or 800-243-0000. 7. Additional disclosures for California consumers The disclosures in this section describe how LGE collects, uses, processes, and discloses personal information of California consumers. These disclosures are intended to supplement the disclosures in this Privacy Policy with additional information as may be required by the California Consumer Privacy Act. We may collect the following categories of personal information: • Identifiers (e.g., IP address, MAC address) • Internet and other network activity information (e.g., Device Information, Basic Usage Information, Information in Connection with LG Channels, and Viewing Information, as described above) • Commercial activity (e.g., the services you consent to use, your preferences) • Geolocation data (e.g., your approximate location based on your IP address) • Inferences (e.g., an understanding of your preferences and interests based on the other information we collect from you) • Audio information (e.g., Voice Information, as described above) • Sensitive information (e.g., account credentials such as LG Account username and password) We may “sell” or “share” (as those terms are defined under California law) the following categories of personal information to third parties: • Identifiers (disclosed to [partners powering add-on content and third-party advertising partners]) • Internet and other network activity information (disclosed to [partners powering add-on content and third-party advertising partners]) • Commercial activity (disclosed to [partners powering add-on content and third-party advertising partners]) • Geolocation data (disclosed to [partners powering add-on content and third-party advertising partners]) • Inferences (disclosed to [partners powering add-on content and third-party advertising partners]) We may also disclose the following categories of personal information for a business purpose: • Identifiers (disclosed [within our corporate umbrella and to payment processors, customer service providers, security and quality assurance vendors, and data analytics providers]) • Internet and other network activity information (disclosed [within our corporate umbrella and to customer service providers, security and quality assurance vendors, and data analytics providers]) • Commercial activity (disclosed [within our corporate umbrella and to payment processors, customer service providers, security and quality assurance vendors, and data analytics providers]) • Geolocation data (disclosed [within our corporate umbrella and to customer service providers, security and quality assurance vendors, and data analytics providers]) • Inferences (disclosed [within our corporate umbrella and to payment processors, customer service providers, security and quality assurance vendors, and data analytics providers]) • Audio Information (disclosed [within our corporate umbrella and to customer service providers, security and quality assurance vendors, and data analytics providers]) For more detail about our disclosures of personal information, please refer to the “How LGE Shares Your Personal Information” section above. Please note that we may also share any or all of the categories of personal information described above for legal reasons or in connection with a sale or merger (as described in the “How LGE Shares Your Personal Information” section above). 8. How long will LGE keep my personal information? We will take reasonable steps to make sure that we keep your personal information for no longer than is necessary for us to provide you with Smart Media Product Services or for the purpose for which it was collected, or as required by applicable law. We apply criteria to determine the appropriate retention period for different categories of personal information you provide us with. For example, we will keep information necessary to protect us from possible legal claims, such as information relating to a contract, for the lifetime of the contract and up to ten years after. After this period, it will be deleted, or in some cases, anonymized. Where we have collected the personal information based on your consent and we have no other basis to continue with the processing of that information, we will delete your personal information if you subsequently withdraw your consent. 9. Security We use commercially reasonable physical, technical, and organizational security measures designed to safeguard the confidentiality and security of your personal information. We make reasonable efforts to protect your information from disclosure, access or alteration of the information we hold as below. • To ensure the security of our products, our internal security team uses the Security Development Lifecycle (SDL) to review our products from development through deployment and maintenance. • We operate a program to collect vulnerabilities discovered after product launch. This program receives reports on all vulnerabilities related to LG products through the public website (https://lgsecurity.lge.com), and posts related policies such as protection for those who report vulnerabilities and product update support periods. • We prevent the disclosure and misuse of personal information through privilege management, audits, and internal employee training. Data access permissions are managed by server administrators, and data personnel are required to complete security training. Nevertheless, due to the design of the Internet, ever-changing technology, and other factors outside of our control, no data security measures can guarantee security. 10. Children and LGE Smart Media Products LGE recognizes that parents, guardians, or other adults may purchase the Smart Media Products for family use. When users of all ages interact with LG Smart Media Services, certain persistent identifiers may be automatically collected. For any Smart Media Services directed to children under 16, personal information would only be collected and processed to improve the Services and for internal business operations. LGE may not be able to know whether information was collected from a child under 16 and treats this information as if it were provided by an adult. If LGE learns that it has collected information of a child under 16, LGE will use commercially reasonable efforts to delete such information as soon as possible and take any other measures required by applicable law. 11. Consenting for others Smart Media Products are household devices. If you know that this device will be used by more than one person, you represent that you have obtained consent from all others who will use this Smart Media Product to this Privacy Policy and are providing consent on their behalf. 12. Additional information for features and add-on services For additional information regarding features and related add-on services, please refer to the specific Additional User Agreements that relate to such features and services, which you can find in the “User Agreements” page in the Settings menu. 13. Changes to LGE's Privacy Policy This Privacy Policy may be updated from time to time, with changes effective as of the date indicated on the updated policy. If we make a material change to our Privacy Policy, we will update you via your Smart Media Product or other means. You may be required to acknowledge or agree to the revised Privacy Policy in order to continue using certain Smart Media Product Services. 14. Contacting LGE about this Privacy Policy If you have any questions or comments about this Privacy Policy or LGE’s processing of your personal information, please contact https://privacy.us.lg.com/policies, usprivacy@lge.com, tv.privacy@lge.com or 800-243-0000. Last updated: [February 2024]

LG Smart Media Product Privacy Policy (February 2024)

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