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PROBLEMS COVERED
1. Samsung Ads launch in Canada (FAQs)
2. Updated statement as of 2020
PROBLEM 1:
Samsung Ads launch in Canada
SOLUTION
-AGENT ONLY-
- Samsung Ads places advertisers ads on Samsung Smart TVs. For example, they may appear on the App Store, or Universal Guide (OO Ads). They may also appear on connected devices such as phones, web, and CTV devices based on TV viewing data (Cross Device ads).
- Per SECA legal and external council, we need to notify users of changes to the IBA (Interest Based Advertisements) language following the privacy update to the IBA for Canada. We will show "Samsung Privacy Update" on our Smart TVs.
2018 and 2019 TVs: Global Notification on TV
2016 and 2017 TVs: First Screen Tile Ad Placement, 1 - 2 times per day
- If a customer calls about Samsung Ads on their TV or an update to the privacy policy on their TV, then please use the FAQs below to answer their questions. If the customer is unsatisfied with the FAQ responses, then ask the customer to send their inquiry to the privacy inbox: privacy.officer@samsung.com.
--- FAQs ---
Samsung Interest-Based Advertisements Service - Privacy Policy Update
Policy Update Date: September 2, 2019
DRAFT Q/A: Aug 26, 2019
Q: When does the policy update go into effect in Canada?
- The updated policy is in effect as of September 2, 2019.
Q: Do I need to accept it? It looks like I am automatically opted in without my express consent.
- Samsung provides you with the right to make choices in connection with the personal information we obtain about you. You can opt out of receiving interest-based ads from the IBA Service on your Samsung Smart TV at any time through your Smart TV settings menu. Please note, however, that opting out of the IBA Service does not prevent the delivery of generic advertisements to your Smart TV.
- If the customer asks for assistance in opting out, instruct them to go to Menu, select Support, and then select Terms and Policy. If they opt out of the IBA Service, the IBA Service will no longer deliver interest-based ads on their Samsung Smart TV.
Q: I am getting a ton of ads on my Samsung TV all of sudden; I do not remember opting in to anything. Why is this happening?
- We have recently introduced advertising support to several software functions, which may explain why you are seeing these ads. You can opt out of receiving interest-based ads from the IBA Service on your Samsung Smart TV at any time through the settings menu. Please note, however, that opting out of the IBA Service does not prevent the delivery of generic advertisements to your Smart TV.
- The Smart Hub Terms and Conditions (that were accepted when the Samsung Smart TV was first activated) indicate that as a condition of use, services may be supported by advertisements.
Q: What is Samsung Interest-Based Advertisement Service? How does it benefit me?
- With your consent, we analyze and use data received over time to provide you with useful and interactive advertisements about products and services offered by Samsung and third parties (such as Samsung advertising partners). Samsung system learns about what interests you and is better able to recommend content and advertisements that are useful and relevant to you.
- For more details, we encourage you to review our Privacy Notice and the Samsung Privacy Policy.
Q: Is this all going directly through Samsung Canada?
- The core technology of the IBA Service is maintained by Samsung Ads, a business comprising wholly owned subsidiaries of Samsung Electronics Corporation. Samsung Electronics Corporation is the parent company of Samsung Electronics Canada.
Q: Who is AdGear?
- AdGear is a wholly owned subsidiary of Samsung Electronics Canada.
Q: How does the IBA service work?
- The IBA Service provides advertisements based on your interests by collecting and analyzing information related to your use of your Samsung Smart TV, including information gathered from the Viewing Information Services option if you have enabled it. We may share this information with third parties (such as Samsung advertising partners) for the purpose of delivering advertisements based on your interests. For more details on how this works, we encourage you to review our Privacy Notice and the Samsung Privacy Policy.
Q: Where will I see the IBA service ads you are talking about?
- Depending on the privacy settings you have chosen, IBA Service advertisements can be displayed on your Samsung Smart TV, across various Samsung and third-party platforms, and other advertising-capable devices associated with your Samsung Smart TV, such as a Galaxy phone.
Q: How do my non-Samsung devices get associated with my Samsung Smart TV?
- Associated Devices are those detected as being associated with your Samsung Smart TV. The IBA Service has concluded that you may be using such Associated Devices.
- For more details, we encourage you to review our Privacy Notice and the Samsung Privacy Policy.
- If the customer asks for assistance in opting out, instruct them to go to Menu, select Support, and then select Terms and Policy. If they opt out of the IBA Service, the IBA Service will no longer deliver interest-based ads on their Samsung Smart TV.
Q: Could I receive ads on other devices as well?
- IBA Service advertisements are displayed on your Samsung Smart TV, across various Samsung and third-party platforms, and other advertising-capable devices associated with your Samsung Smart TV (collectively, "Associated Devices"), including websites, streaming video platforms, mobile apps, Galaxy phones, tablets, and other advertising-capable devices.
- We offer you certain choices in connection with the personal information we obtain about you, which may vary depending on the type of device you have and wireless carrier you use. Please visit the setting menu on your Samsung device or service should you wish to change any of your privacy settings.
- Each device will have its own settings menu. If you would like us to assist you, please let us know what device in particular you are using, and we can walk you through the steps.
Q: Will other individuals see these advertisements? My family seems to be getting random ads that seem like they should be for me.
- Although we use a variety of techniques to assist us in displaying interest-based ads on your Samsung Smart TV and Associated Devices, these advertisements may also be displayed to other individuals who use your Samsung Smart TV or Associated Devices.
- However, we offer you certain choices in connection with the personal information we obtain about you, which may vary depending on the type of device you have and wireless carrier you use. Please visit the setting menu on your Samsung device or contact your service provider for specific information on opting out of interest-based ads.
- Each device will have its own settings menu. If you would like us to assist you, please let us know what device in particular you are using, and we can walk you through the steps.
Q: What if I do not want to see any ads through this service? Can I opt out?
- If the customer asks for assistance in opting out, instruct them to go to Menu, select Support, and then select Terms and Policy. If they opt out of the IBA Service, the IBA Service will no longer deliver interest-based ads on their Samsung Smart TV.
- If you opt out of the IBA Service, the IBA Service will no longer deliver interest-based ads on your Samsung Smart TV.
- The Smart Hub Terms and Conditions (that were accepted when the Samsung Smart TV was first activated) indicate that, as a condition of use, services may be supported by advertisements. For this reason, opting out of the IBA Service may not prevent the delivery of generic advertisements to your Smart TV.
Q: I would like to opt out of seeing these ads across all my Samsung devices, not just my Samsung TV; how can I do so?
- We offer you certain choices in connection with the personal information we obtain about you, which may vary depending on the type of device you have and wireless carrier you use. Please visit the setting menu on your Samsung device or contact your service provider for specific information on opting out of interest-based ads.
Q: Are users able to access all of the same functions without agreeing to the privacy policy?
- We offer you certain choices with respect to the personal information we obtain about you. Depending on the choices you have made, it may limit certain functionality and services offered in connection with your device. For example, if you opt out of IBA Service, the products and services offered to you may not be as relevant to your personal interests.
Q: You mention third-party platforms; who are you sharing my information with?
- We do not share personal information collected about you through the IBA Service except as described in the Privacy Notice and the Samsung Privacy Policy.
- As explained in the Privacy Notice, we may share your personal information with our wholly owned subsidiaries and affiliates, which uses your information to provide you with ads that are customised to your interests across your devices.
- We may also share your personal information with trusted third-party service providers who perform services for us. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf and to comply with legal requirements.
Q: Are Samsung Smart TVs analyzing what consumers are watching? If so, is Samsung doing this or a third party?
- For consumers that have enabled viewing information services, Samsung collects information such as TV viewing history based on general interest categories and uses this information to offer content and services that are more relevant to the consumer.
- Samsung provides you with the right to make choices in connection with the personal information we obtain about you. Please visit the settings menu of your Smart TV should you wish to change any of the choices available to you, including if you do not wish to receive personalized recommendations or certain enhanced features on your Smart TV. If you disable such personalized recommendations or additional features, then the information and content displayed on your Smart TV may not be as relevant to you.
Q: Where are you storing my data? How long are you keeping it?
- In order to participate in or use any service, customers must consent to the collection, transfer, storage, and processing of their information outside of their country of residence, such as South Korea and the United States.
- Subject to the requirements of applicable law personal information is retained only for so long as reasonably necessary as detailed in the applicable Privacy Notice of Privacy Policy.
Q: How are you protecting my personal information?
- We maintain administrative, technical, and physical safeguards designed to protect the personal information we obtain through the IBA Service.
Q: Does this mean I am giving Samsung the right to spy on me through my TV?
- Samsung TVs do not "spy" on consumers. Samsung takes customer privacy very seriously, and we design our products with privacy and security in mind. We allow consumers to make choices about the personal information that we collect from them.
Q: I am not comfortable with this, and I would like to make a complaint about the privacy notice. Who do I contact?
PROBLEM 2:
Updated as of April 9, 2020
SOLUTION
Reactive Statement:
- Samsung takes user privacy very seriously, and Samsung Smart TVs are designed with privacy in mind. We make every effort to handle data with the utmost care. Before collecting information from users, we provide them with notice about the information we collect and use and, where appropriate, ask for their consent. We employ industry-standard security safeguards and practices to protect information.
- Per the Samsung website: https://www.samsung.com/us/account/privacy-policy/#1.
- Samsung Ads obtains consent before using household viewership information. Samsung Ads uses and analyzes de-identified household viewership information to deliver a better user experience, including personalization and recommendation of content. Samsung Ads publishes updates to the privacy policy as needed.
[Part of Terms and Conditions]
- The Services or a part thereof may display advertisements and promotions and may be supported by advertising revenue. In accordance with applicable law, such advertisements and promotions may be targeted to you based on information you may make available through the Services and through queries made by third parties in connection with your use of the Services.
[Part of Privacy Policy]
- Please note that your privacy choice with respect to the IBA Service will not affect whether or not you receive or are served with other types of ads and marketing that are not specifically based on TV viewing history or Samsung Smart TV usage information. Those other types of ads and marketing will be based on other data such as generalized location and other estimated or inferred information. They might be less relevant because they are not based on your interests.
- Samsung Ads Tile was activated in Canada in September 2019, but it may have not been visible to users until recently because there were not any ads (Samsung Ads does not show up when there is no ad to show).
- Although we can inform users that Samsung notified users in advance through Terms and Conditions and Privacy Policy, it could sound like a defensive corporate response to users. They could feel that they already paid all costs to use the TV and its smart services, and do not need to "pay" additional costs by seeing ads from Samsung.
- In such case, please explain that the ads are a minimum profit generator to ensure that Samsung can support our ever-growing smart services, as we add more features and contents even after the product is purchased through constant software updates.
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